ML20154R035

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-213/98-03 Issued on 980821.Ack That Program Improvements for Violations That Occurred During Sys Decontamination,Still in Progress

ML20154R035
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	10/14/1998
From:	Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Mellor R CONNECTICUT YANKEE ATOMIC POWER CO.
References
50-213-98-03, 50-213-98-3, NUDOCS 9810260149
Download: ML20154R035 (3)

See also: IR 05000213/1998003

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October 14,1998

' Docket No. 50-213 License No. DPR-81

' R. A. Mellor

Vice President, Operations and Decommissioning

Connecticut Yankee Atomic Power Company

l 362 Injun Hollow Road

L East Hampton, CT 06424-3099

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SUBJECT: INSPECTION NO. 50-213/98-003

Dear Mr. Mellor:

L This letter refers to your September 21,1998 correspondence,' in response to our August 21,

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1998 letter.

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l Thank you for informing us of the corrective and preventive actions documented in your letter.

We acknowledge that your program improvements for these violations and other events that

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occurred during the reactor system decontamination are still in progress. These actions will be

L examined during a future inspection of your licensed program. In addition, we are evaluating

l your response to other similar events that were subsequent to the events cited in the Notice of

l Violation. Our review will include your plans for implementation of corrective actions for events

that had common root causes.

Your cooperation with us is appreciated.

Sincerely,

Originalsignedby RonaldR. Bellamy

Ronald R. Bellamy, Chief  !/

Decommissioning and Laboratory Branch

j Division of Nuclear Materials Safety //

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R. Mellor 2

Connecticut Yankee Atomic Power Company

cc:

D. Davis, President and Chief Executive Officer

T. Bennet, Vice President and Chief Financial Officer

D. Amerine, Vice President, Human Services

K. Heider, Decommissioning Director

G. Bouchard, Unit Director

J. Haseltine, Engineering Director

G. van Noordennen, Licensing Manager

J. Ritsher, CYAPCO Counsel

R. Bassilakis, Citizens Awareness Network

J. Block, Attorney for CAN

J. Brooks, CT Attorney General Office

- K. Ainsworth, Town of Haddam

State of Connecticut SLO

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Connecticut Yankee Atomic Power Company

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Distribution:

Region I Docket Room (with concurrences)

PUBLIC

Nuclear Safety Information Center (NSIC)

NRC Resident inspector

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J. Wiggins, DRS

J. White, DRS

J. Nick, DNMS

R. Bellamy, DNMS

Distribution (VIA E-MAIL):

K. Kennedy, OEDO

S. Weiss, NRR, DRPM, PDND

T. Fredrichs, PM, NRR

M. Callahan, OCA

W. Travers, SPO

R. Correia, NRR

F. Talbot, NRR

D. Screnci, PAO, ORA

DOCDESK

Inspection Program Branch, NRR (IPAS)

DOCUMENT NAME: G:\DNMS\DOCWORK\lNSPLTR\LDPR61.A

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To receive e copy of INe docuenent, inacete in the boa: "C' = Copy w/o ottsch/enel 'E' = Copy w/ ettsch/enci *N' No copy

OFFICE DNMS/Rt lN DNMS/RI l T:: DNMS/RI l l

NAME- BRaymond/ tmh JNick @ RBellamy P

DATE 10/14/98 10/1998 10/f798 10/ 198

OFFICIAL RECORD COPY

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CONNECTICUT YANKEE ATOMIC POWER COMPANY

HADDAM NECK PLANT

362 INJUN HOLLOW ROAD e EAST HAMPTON, CT 06424-3099

September 21,1998

Docket No. 50-213

_GY-9E-151

He: 10 CFR 2.201

U.S. Nuclear Regulatory Commission

Attention: Document Control Desk

Washington, D.C. 20555

Haddam Neck Plant

Reply to a Notice of Violation (NOV)

NRC Intearated Insoection Report No. 50-213/98-03

The purpose of this letter is for Connecticut Yankee Atomic Power Company

(CYAPCO) to reply to the notice of violations contained in NRC Inspection Report

98-03W. The violations involved the failure to classify an event in accordance with the

emergency actions levels following an inadvertent release of radioactive liquid; the

failure to control the plant configuration during valve manipulations or tagging activities,

resulting in plant events; the failure to properly calibrate the stack flow instruments used

in the stack effluent pathway; and, the failure to provide complete information in support

of a license amendment application.

Attachment 1 to this letter restates the cited violations and provides the required

CYAPCO responses. As requested by the NRC's letter of August 21,1998, CYAPCO

has included in the responses to violations B and C, a discussion on our actions taken

to address the underlying causes of the plant configuration control and human  ;

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performance issues, and our plans and schedule to provide an independent verification

that the plant procedures for demonstrating compliance with technical specification

surveillance requirements are acceptable.

Attachment 2 presents CYAPCO's commitments made within this letter. Other

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statements within this letter are provided for information only.

(1) Mark C. Roberts letter to R. A. Mellor, "NRC Integrated Inspection Report

50-213/98-03," dated August 21,1998.

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If there are any questions regarding this submitta'!, please contact

Mr. G. P. van Noordennen at (860) 267-3938.

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Very truly yours,

CONNECTICUT YANKEE ATOMIC POWER COMPANY

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Russe Mellor 7

Vice Presi ent - Operations and Decommissioning

Attachments

cc: H. J. Miller, Region l Administrator

T. L. Fredrichs, Project Manager, Haddam Neck Plant

W. J. Raymond, Senior Resident inspector, Haddam Neck Plant

E. Wilds, Director, CT DEP Monitoring and Radiation Division

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Docket Number 50-213

CY-98-151

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Attachment 1

Haddam Neck Plant

Reply to Notice of Violations  !

NRC Insoection Reoort No. 50-213/98-03

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September 1998

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CY-98-151/ Attachment 1/Page 1

Restatement of Violation

During an NRC inspection conducted on April 14 - August 13,1998, violations of NRC

requirements were identified. In accordance with the " General Statement of Policy and

Procedure for NRC Enforcement Actions,"(Enforcement Policy), NUREG-1600, the

violations are listed below.

A. 10 CFR 50.54(q) states, in part, a licensee shall follow and maintain in effect

emergency plans which meet the standards in 10 CFR 50.47(b) and the

requirements in Appendix E of this part.

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The Licensee's Emergency Plan, Section 6, Emergency Plan Implementing

Procedures (EPIP) 1.5-1, Revision 31, Emergency Assessment Using EAL

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Tables, under Section 6.2 and EAL OU1, Unplanned Release, requires, in part,

the declaration of an Unusual Event, for liquid discharges in which total activity

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exceeds 1000 microcuries.

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Contrary to the above, following the unplanned release of about 800 gallons of

water containing approximately 2200 microcuries of radioactivity from the "A"

waste test tank on June 20,1998, the licensee failed to declare an Unusual

Event. j

This is a Severity Level IV violation (Supplement IV).

B. Technical Specification 6.8.1 requires that written procedures and/or

administrative policies be established, implemented and maintained covering the

activities as recommended in Appendix A of Regulatory Guide 1.33. Regulatory

Guide 1.33 requires that procedures be established governing plant operations

and work controls.

1. Procedure NOP 2.14-15B, Revision 4, requires that valve WD-V-133A be

closed during the discharge of the "B" Waste test tank (WTT).

Contrary to the above, on June 20,1998, valve WD-V-133A was open

during the discharge from the "B" WTT, resulting in the inadvertent

release of 800 gallons of water from the "A" WTT.

2. Work Control Manual (WCM) 2.4-1, Equipment Tagging, Revision 9,

requires in Step 1.6.1 that components be aligned and tagged in

accordance with the tagging sheet. Procedure NOP 2.0-8, independent

Verification, Revision 0, requires in Step 6.1 that the independent verifier

verify that the tagged component is in the correct position.

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U. S. Nucl=r Regulatory Commissian

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CY-98-151/ Attachment 1/Page 2

Contrary to the above: (a) The tagging sheet for Clearance 980200

required that valves SI-928 and SI-929 be red tagged and independently ,

verified closed. On July 14,1998, valves SI-928 and SI-929 were found l

open, and, (b) The tagging sheet for Clearance 980229 required that l

valve PW-V-108A be red tagged and independently verified closed. On l

July 7,1998, PW-V-108A was found open. The mispositioning of I

PW-V-108A resulted in the inadvertent spray of workers and equipment in

the Spent Fuel Building on July 7,1998. I

3. Procedure NOP 2.7-1 requires that valve LD-V-238 be full open to place l

the reactor coolant system (RCS) letdown post filter in service. I

Contrary to the above, on July 27,1998, LD-V-238 was found less than I

full open, which caused a partial flow blockage in the letdown line ahd

contributed to the pressure transient and vibrations during the RCS

decontamination.

This is a Severity Level IV violation (Supplement IV).

C. Technical Specifications 3/4.3.3.8 requires that the stack flow monitor be

calibrated and operable. Technical Specification Section 1.4 defines the

Channel Calibration, which states, in part, "The Channel calibration shall

encompass the entire channel including the sensors and alarm,..."

Contrary to the above, on June 5,1998, the NRC determined that, since about l

1974, a sensor (pitot tube) of the main stack flow rate monitor (FT-1101) was not  ;

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included for the channel calibration. The stack flow instrument was historically

inoperable (LER 98-05).

This is a Severity Level IV violation (Supplement IV).

D. 10 CFR 50.9(a) requires that the information provided by a licensee to the

Commission be complete and accurate in all material respects.

Contrary to the above, on July 20,1998, the licensee identified an error made in I

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an application to amend License DPR-61. The application made by letter

CY-97-006 dated May 30,1997, stated that following a loss of normal power,

limited makeup water to the fuel pool could be provided by gravity feed from a

tank. The tank had insufficient inventory to provide gravity feed of makeup water

to the fuel pool at the time of the May 30,1997 application, or any time

thereafter, and was abandoned on October 9,1997.

This is a Severity Level IV violation (Supplement IV).

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Reason For The Violation (Violation A)

On Saturday June 20,1998, CYAPCO personnel reviewed the discharge from the "A"

WTT for reportability. A review of the Emergency Action Level (EAL) tables indicated

that the event was reportable as an Unusual Event if the Effluent Monitors are in Alarm ,

or if there is an unplanned, unmonitored or uncontrolled offsite release and DELTA- l

TWO posture code limits as determined from Emergency Plan Implementing l

Procedures (EPIP) were exceeded. CYAPCO personnel then reviewed EPIP 1.5-1,

" Emergency Assessment Using EAL Tables" and EPIP 1.5-1 A, "Non-Emergency Event

Assessment." Both tanks had been sampled and analyzed prior to the discharge in

accordance with our National Pollutant Discharge Elimination System (NPDES) permit.

All parameters for both tanks were within NPDES permitted limits and the Haddam  ;

Neck Plant Radiological Effluent Monitoring and Offsite Dose Calculation Manual l

(REMODCM). CYAPCO personnel determined that the release was not unplanned

since CYAPCO had already issued internal permits to discharge both tanks. Based on

this reasoning, CYAPCO initially concluded that this event was not reportable to the

NRC as an Unusual Event.

On Monday, June 22,1998, senior management conducted a further investigation of

the event. Because a portion of the "A" WTT was inadvertently discharged

simultaneously with the discharge from the "B" WTT, which is not the normal practice,

senior management concluded that the event was not planned to occur in that fashion

and, thus, was an " unplanned" release. This determination was made even though the

water in the "A" WTT met all NPDES and REMODCM discharge criteria and was ready

for discharge. This event was reportable as an " Unusual Event" per the EAL tables

since the discharge was unplanned and the total radioactivity released (excluding ,

Tritium and dissolved gases) exceeded 1000 microcuries. It should be noted that the I

internal permit limits for releases for these two tanks were 36,000 microcuries and

13,000 microcuries for the "A" WTT and "B" WTT, respectively. The discharge from the

"A" WFT was calculated to be 2,250 microcuries, which exceeded the " Unusual Event"

activity limits, but was within routine discharge parameters for radioactivity.

The root cause of this event was unclear and potentially conflicting guidance in

governing procedures and supporting documents, in particular the word " unplanned"

and the definition of Unusual Event. In addition, there was evidence of a lack of

questioning attitude by management personnel contacted on Saturday by the personnel I

working on shift.

Corrective Steps That Have Been Taken and the Results Achieved (Violation A)

The following actio s have been taken as a result of the above violation:

The root cause team has determined that the Shift Manager's initial reportability

decision was not correct. CYAPCO is sharing the lessons learned from this event with

the other Shift Managers and Director of Site Emergency Operations (DSEOs). In

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addition, the on call DSEO is available, via pager, to the Shift Managers to provide

!- assistance, if requested, in making their reporting decisions. The on call DSEOs have

been given a controlled copy of EPIP 1.5-1 and 1.5-1 A to assist them if they are

contacted by the shift manager concerning event reportability. Note, that when

CYAPCO implements the Defueled Emsrgency Plan, this support will continue to be

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available to the Shift Managers and will be provided by the Emergency Director (s).

Corrective Steps That Will Be Taken To Avoid Further Violations (Violation A)

The following actions will be taken as a result of the above violation to prevent

recurrence:

Reporting procedures will be reviewed and revised, as appropriate, to ensure clear l

guidance is provided. These improvements will be completed by December 15,1998 l

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(CY-98-121-04).

Date When Full Compliance Will Be Achieved (Violation A)

j CYAPCO is currently in full compliance with 10 CFR 50.47(b) and the requirements in

Appendix E of this part. I

Reason For The Violation (Violation B)

Violation B discusses the need for CYAPCO to develop procedures that govem plant i

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operations and work controls. The NRC cited in this violation three examples whereby

required steps in various procedures were not complied with. CYAPCO has performed

root cause analyses for each of the cited examples which resulted in identifying causes  ;

and implementing extensive corrective actions. CYAPCO has found that for two of the  !

three issues the strong underlying theme was personnel error.

In the first example cited by the NRC, the "A" WTT pump discharge isolation to the

Aerated Drain Tank (ADT) header and river should have been closed, but was found to

be partially open. The cause of this event was personnel error in that people working in

the area of this valve were unaware of plant conditions and the significance of

evolutions in progress. One of these individuals accidentally bumped valve

WD-V-133A, which caused the valve to open slightly. This bumping allowed water from

the "A" WTT to be inadvertently released. Contributing to this event was the failure of

the shift to notice the change in the evolutions in progress,

in the second example cited by the NRC, CYAPCO failed to isolate valves on the safety

injection line (SI-V-928 and SI-V-929) and on the primary water makeup line to the

spent fuel pool (PW-V-108B). PW-V-108B needed to be isolated to provide system

isolation to support installation of an approved modification. Two personnel errors were

identified during these examples. The first personnel error was the failure of the initial

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CY-98-151/ Attachment 1/Page 5

operator to properly position the valve (s). The second personnel error was the failure of

the second operator to adequately independently verify the position of the valve (s).

In the third example cited, letdown valve LD-V-238 was required to be fully open, but

was found to be not fully open. This valve is locally manipulated by an operator via a

reach rod. In this particular situation, the valve was found to have been moved from its

closed position to a partially open position. The operator in question was unaware of

the number of turns required to fully open this valve, and in this particular situation, the

operator turned the handwheelin the open direction until it would no longer move. The

operator believed the valve was fully open. However, due to the materiel condition of

the valve, and the operator being unaware of the number of turns required to open this

j valve, the valve was not fully opened.

As noted in our August 3,1998, meeting with the NRC and in subsequent discussions,

CYAPCO is concerned about the recent configuration control and human performance

problems. CYAPCO is:

. Reinforcing how a proper independent verification of valve position is done;

e Instituting a peer check of critical configuration changes;

• Performing an evaluation and change out, as necessary, of blocking devices to

ensure devices on critical valves or breakers provide the greatest amount of

protection against inadvertent movement;

e Developing a document showing the number of valve turns needed to open or close

critical valves, excluding 90 degree ball valves;

e Assigning dedicated operators or placing physical barriers to preclude inadvertent

valve bumping during certain evolutions.

Our investigations of Violations A and B as well as other events during the reactor

coolant system decontamination have identified improvements necessary in

organizational structure, teamwork, communication and materiel condition. These l

improvements are being combined with the lessons learned from the decontamination 1

by plant departments to establish overall corrective actions. CYAPCO has announced j

the appointment of Mr. Ken Heider as Decommissioning Director. Mr. Heider's first  !

, objective will be to work with plant management to establish an organizational structure

that will meet the future needs and resolve the identified weaknesses in the areas of

organizational structure, communication and teamwork. A review of materiel conditions  !

of equipment and structures needed for the remainder of the decommissioning is being

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undertaken to identify, prioritize and implement the improvements.

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Corrective Steps That Have Been Taken and the Results Achieved (Violation B)

The following actions have been taken as a result of the above violation:

A dedicated Operator or physical barriers are currently used, as appropriate, to

preclude inadvertent valve bumping during liquid discharges.

CYAPCO has revised the procedure on independent verification to clarify expectations

and ensure operators perform tagging and verification functions independently. In

addition, CYAPCO has counseled the individuals involved in the mispositioning of the

safety injection valves and primary water valve. All operators responsible for tagging

and independent verification as well as job supervisors, contact persons or designees

attended work stand down training on valve operations and tagging.

The mispositioning of the primary water valve occurred late in the midnight shift. The

individuals who made the error were on their first day of work after time off. CYAPCO

has reminded managers and supervisors to ensure that people under their control are

not fatigued. Individuals were reminded to advise their supervisors if they are fatigued.

Letdown valve LD-V-238 is locally manipulated by an operator via a reach rod.

CYAPCO has developed a list of purification system valves where reach rods are

utilized and determined the number of valve turns required to open or close these

velves.

Corrective Steps That Will Be Taken To Avoid Further Violations (Violation B)

The following actions will be taken as a result of the above violation:

Operations is evaluating critical configuration changes and systems that should have

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peer checks. Peer checks are reviews that are performed with two individuals. The

peer individual will review the activities performed and ensure they are consistent with

procedures and objectives. We are currently performing peer checks based on the

l Judgment of the Shift Managers. The process of peer checks will be formalized and will

be fully instituted by December 1,1998 (CY-98-151-01).

CYAPCO has installed blocking devices on critical valves to protect against inadvertent

movement. As other valves are identified for future plant evolutions, blocking devices

, will be installed as appropriate. By December 15,1998, an Operations Department

Instruction will be implemented to address the use of blocking devices on critical valves

to protect against inadvertent movement (CY-98-151-02).

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CYAPCO has developed a list of purification system valves where reach rods are

i utilized. This list provides the number of turns needed to turn the valve handwheel from

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full open to full closed. CYAPCO is in the process of developing a document which will

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CY-98-151/ Attachment 1/Page 7

list nuclear island critical system manual valves, excluding 90 degree ball valves, and

the number of valve turns required to open or close these valves. This list will be

completed by December 15,1998 (CY-98-151-03).

l Date When Full Compliance Will Be Achieved (Violation B)

CYAPCO is currently in full compliance.

Reason For The Violation (Violation C)

Flow element FE-1101 is a pitot-venturi located in the ductwork on the Primary Auxiliary

Building (PAB) roof which runs to the plant stack. This flow element is part of an

instrument channel that indicates and records the total flow to the stnk on a panel in

the PAB and is required by the Technical Specifications. The pitot-venturi is part of the

original plant design. It is capable of measuring flows from 0 CFM to 87,108 CFM. The

pitot-venturi amplifies the differential pressure between the static and total pressure that

would be otherwise observed if using a standard pitot-static tube. This characteristic is

desirable in low flow conditions. The amplification factor makes it necessary to use

vendor provided data to determine the velocity from the amplified differential pressure.

A graph is located at the PAB panel which is based on the vendor data and allows

volumetric flow rate to be determined based on the pressure indicated on flow indicator

HlC-1101. The pitot venturi does not average the entire flow through the duct.

Therefore, it is positioned within the duct at a point that is representative of the average

flow through the duct. A review of the surveillance procedure which calibrates this

instrument channel revealed that the procedure does not require pedormance of a l

periodic verification of the calibration curve of the pitot - venturi flow element.

The apparent causes for the inadequacies of total stack flow channel F-1101 are as

follows:

First, the original installation was based on lower flow rates than are present today.

This is a result of the 1974 modification which replaced the PAB/Porge Fans with larger

units. The second cause is that the velocity to differential pressure relationship of the

pitot - venturi has not been periodically re-verified. Finally, CYAPCO personnel had an

inadequate understanding of system design, operational and calibration requirements

for this system.

Corrective Steps That Have Been Taken and the Results Achieved (Violation C)

The immediate corrective action was to declare the F-1101 channel out of service and

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develop a means of estimating flow every four hours as required by the Technical

Specification Table 3.3-10.

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. On May 22,1998, flow data was collected to determine the velocity profile and total flow

at FE-1101 with one and two PAB/ Purge Fan operation. This information has been

4 used to evaluate channel F-1101.

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Since July 10,1998, temporary instruments have been used to measure total stack flow

every four hours. This method of measuring flow will be used until the long term

solution is implemented.

Corrective Steps That Will Be Taken To Avoid Further Violations (Violation C)

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The existing flow element FE-1101 will be recalibrated or replaced so that total stack

flow is accurately displayed on the PAB panel (CY-98-089-02). s

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Historical release data will be reviewed and the impact of using default flow values will

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be assessed. This review will also incorporate any findings that are made regarding

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isokinetic flow and particulate plate - out in the sample lines of the radiation monitoring

_ system. The results of this review will be forwarded in a supplemental LER

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(CY-98-089-01).

The Oversight organization is verifying all portions of License Amendment 125 ~

(i.e.,

conversion to Standard Technical Specification format and definitions) that remain in

effect as amended by License Amendment 193 (i.e., defueled Technical

Specifications). To accomplish this effort, CYAPCO will use the Oversight organization

to verify that for each technical specification surveillance requirement that the existing

procedure (s) adequately perform (s) the activity required by the technical specifications

(CY-98-151-04).

, Date When Full Compliance Will Be Achieved (Violation C)

Corrective actions associated with the above will be completed by January 31,1999.

Reason For The Violation (Violation D)

4 The preparation of the license amendment submittal letter for the defueled technical

specifications contained the statement that " limited make-up water to the fuel pool could

be provided by gravity feed". The limited capability was available by gravity feed only if

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the refueling water storage tank (RWST) was nearly full. Lower water levels in the

spent fuel pool would allow more of the water in the RWST to gravity feed. While this

gravity feed capability was a feasible alternative through a valve alignment, the primary

method of transfer during a loss of normal power was repowering the primary water

pumps and using the normal makeup source or pumping water from the RWST using

the purification pump. Another " backup" source was and stillis river water via a diesel

< engine driven pump in the fire water system.

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The cause of the violation was a personnel error on the part of the Individual who

, developed the letter to the NRC. The Individual who developed this letter to the NRC

l Inserted this statement in an attempt to show that multiple fuel pool makeup capabilities l

l were provided to compensate for evaporative losses during an extended loss of offsite  !

l power event. CYAPCO should not have included this statement about gravity feeding i

l from the RWST in our May 30,1997 letter to the NRC. l

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The normal makeup source is the Primary Water Storage Tank using primary water  :

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pumps. Current backup sources include 1) use of a gasoline engine driven pump that

supplies water from the seismic Demineralized Water Storage Tank and 2) river water

via the fire water system using a diesel driven pump.

The plant procedure for processing outgoing correspondence with regulatory agencies j

requires the Licensing Coordinator to work with the Lead Functional Manager to I

develop the correspondence and resolve comments. The Lead Functional Manager is,

by procedure, technically responsible for the accuracy of the letter. In this case, the

additional statement regarding the ability to gravity feed make-up water to the spent fuel

pool was inserted after the Lead Functional Manager had approved the letter. I

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Corrective Steps That Have Been Taken and the Results Achieved (Violation D) l

l CYAPCO submitted a letter to the NRC on July 30,1998W which provided clarifying

information on the spent fuel pool makeup capability at the Haddam Neck Plant. In

addition, the Individual who developed the May 30,1997, letter to the NRC that

contained the incorrect information is no longer working at the Haddam Neck Plant.

The Licensing Manager reviewed this violation with the Licensing Department staff and l

reinforced the requirements to follow the existing process for developing outgoing  ;

correspondence. l

Corrective Steps That Will Be Tak6n To Avoid Further Violations (Violation D)

None

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Date When Full Comphance Will Be Achieved (Violation D)

CYAPCO is currently in full compliance with 10CFR50.9(a).

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(1) CYAPCO letter CY-98-127 to U.S. Nuclear Regulatory Commission, "Information

on Spent Fuel Pool Makeup Capability," dated July 30,1998.

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Docket Number 50-213

CY-98-151

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Attachment 2

Haddam Neck Plant

identification'of Commitments

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September 1998

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U. S. Nuclear Regulatory Commission

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CY-98-151/ Attachment 2/Page 1 4

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The following are the commitments contained within this letter. Other statements

contained within this letter are provided for information only. l

CY-98-121-04 Reporting procedures will be reviewed and revised, as appropriate,

to ensure clear guidance is provided. These improvements will be  :

completed by December 15,1998.

CY-98-151-01 The process of peer checks will be fully implemented by

December 1,1998.

CY-98-151-02 By December 15,1998, an Operations Department Instruction will ,

be developed to address the issue of blocking devices on critical  ;

valves to protect against inadvertent movement. i

CY-98-151-03 CYAPCO is in the process of developing a document which will list

nuclear island critical system manual valves, excluding 90 degree

. ball valves, and the number of valve tums required to open or close

these valves. This list will be completed by December 15,1998.

CY-98-089-02 The existing flow element FE-1101 will be recalibrated or replaced

so that total stack flow is accurately displayed on the PAB panel by

January 31,1999.

CY-98-089-01 Historical release data will be reviewed and the impact of using

default flow values will be assessed. This review will also

incorporate any findings that are made regarding isokinetic flow

and particulate plate - out in the sample lines of the radiation I

monitoring system. The results of this review will be forwarded in a

supplemental LER.

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, CY-98-151-04 The Oversight organization is verifying all portions of License

Amendment 125 that remain in effect as amended by License

Amendment 193. CYAPCO has begun to independently verify that

plant procedures address the surveillance requirements using

Amendment 193 of the Technical Specifications as the basis. This

will be completed by November 30,1998.

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