ML19310A062
| ML19310A062 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 04/23/1980 |
| From: | Moody D Maine Yankee |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19310A061 | List: |
| References | |
| WMY-80-70, NUDOCS 8006060030 | |
| Download: ML19310A062 (1) | |
Text
C m
k-4 mal #E'2=i FA##EE.W29F9"EcFmF.W! e run s,,x, n0,0,nT.,,
- g. W':h ENGINEERING OFFICE WESTBoRO, MASSACHUSETTS 01581 617-366-9011
- w.. 2 NIM B.4.1.1 WMY 80-70 April 23, 1980 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prassia, PA 19406 Attention:
Mr. Boyce H. Grier, Director
References:
(a)
License No. DPR-36 (Docket No. 50-309)
(b)
IE Inspection Report No. 50-309/80-04 Deac Sir:
Subject:
Response to IE Inspection Report 50-309/80-04 In response to Reference (b), the following information is hereby submitted:
Apparert Item of Non-Compliance A.
1.
Technical Specification 5.8.1 states, in part, that Written procedures shall be established, implemented, and meintained covering... a.
The applicable procadures indicated in Appendix
- A" of Regulatory Guide 1 33, November, 1972.
Regulatory Guide 1 33, Appendix A, paragraph A.2 requires procedures delineating the responsibilities and authorities for safe operation and s hu t-down.
Contrary to the above, the licensee implemented a major staff reorganization without issuing a procedure defining the authorities and responsibilities of the new positions created or those for which title changes were made.
2.
Technical Specification 5.2.2 states, in part, that "The Facility Organization shall be shown on Figure 5.2-2...
Contrary to the above, the actual onsite organization is not in accordance with Table 5.2-2 or the proposed change (PC-66-2) to the table which the licensee implemented on December 12, 1979 in that the Assistant Plant Manager is still onsite performing his duties and a Technical Assistant to the Plant Manager is onsite and not reflected in either the proposed change or the approved organization in Technical Specifications.
8 o o e o e oc>.sr ;
c
t Unit 2d Stat:0 Nuclcir Rrguletory Commission Paga 2 April 23, 1980 Kesponse A.
1.
Appendix A to Reg. Guide 1.33 contains a paragraph designated
" Authorities and Responsibilities for Safe Operation and Shutdown" as an area that is typically covered by procedure.
With regard to this section, Maine Yankee Procedure 1-150-1,
" Responsibilities and Authorities of Operating Personnel" has been in effect since 1975. The staff reorganization implemented in December of 1979 did not affect any of the positions discussed in this procedure and therefore no procedure change was necessary.
A.
2.
The former Assistant Plant Manager remained on site from December of 1979 through March of 1980, to assist in the refueling shutdown coordination and to effect an orderly transfer to the new staff organization structure. The transfer was completed on April 1, 1980. The plant does not consider this orderly transition to be in any way detrimental to plant safety. However, future changes to the plant organizational staff will be preceeded by the transition phase prior to the official implementation of changes in title and responsibili'ies.
The Technical' Assistant to the Plant Manager position, creaced in December of 1979, has no direct in-line authority or responsibility in areas affecting plant safety.
The plant does not consider it necessary to reflect those ancillary, and often temporary, positions in the formal Tech. Spec. orgainization chart.
Historical.ly, the Tech. Spec organization chart has only shown those positions which have a direct relationship to plant safety. To <!o otherwise would unnecessarily restrict the organizational flexibility necessary to respond to changing requirements.
A case in point is the proposed change mentioned in this Notice of Violation (PC-66).
This proposed change was originally submitted in July of 1978, for the purpose of updating plant staff titles and the plant organization chart.
This change has yet to be acted upon by the commission.
Based on the above, Maine Yankee feels no violation of Technical Specifications has occurred and requests that the above items,be withdrawn as an Item of Non-Compliance.
Apparent Item of Non-Compliance B.
Technical Specification 5.8.1.a states, in part, the "Writtan procedures shall be established, implemented, and maintained covering... a. The applicable procedures indicated in Appendix "A" of Regulatory Guide 1 33, November 1972." Regulatory Guide 1 33, Arizeadix A, paragraph J requires, in part, " Chemical and radiochemical procedures should be written to prescribe...
instructions maintaining water quality within prescribed limits, and the limitations on concentrations of agent that may cause corrosive attack..."
United States Nuclear Regulatory Commission Page 3 April 23, 1980 Contrary to the above, the licensee performed cleanup operations of the reactor coolant system, with a contractor's assistance, without the use of a procedure.
Response
Due to the simplicity of connecting a vendor's portable demineralizer to a standard plant system's vent and drain connections, a procedure was not generated to describe the actions necessary to effect cleanup of the reactor coolant system chemical impurities. However, to ensure in the future that procedures are prepared in accordance with Regulatory Guide 1.33, Appendix A, Maine Yankee has modified Procedure No. 0-02-I, Material, Equipment and Service Purchased. This revised procedure will now require an evaluation to be performed upon the purchase of equipment or services to determine whether additional procedures are required to utilize the equip-ment or service being purchased.
This procedure has been revised and is presently going through the review and approval process.
Implementation of this' revision is expected by June 1, 1980.
We trust this information is satisfactory.
Should any additional information be required, please feel free to contact us.
Very truly yours, MAINE YANKEE ATOMIC POWER COMPANY A
D. E. Moody Manager of Operations DEM/am
,,