B17571, Requests NRC Review & Approval to Discontinue Use of Previous Regulatory Commitment Re Implementation of TS 6.5.3.7.a of TS for Mnps,Units 1,2 & 3.Discontinuation Will Allow Util to Enhance TS Audit Process
| ML20199D932 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 01/13/1999 |
| From: | Bowling M NORTHEAST NUCLEAR ENERGY CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| B17571, NUDOCS 9901200255 | |
| Download: ML20199D932 (2) | |
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Fas (860) 444-4277 n,e sonh.an viina. syn JAN I 31999 Docket Nos. 50-245 50-336 50-423 B17571 i
i U.S. Nuclear Regulatory Commission Attention: Document Control Desk L Washington, DC 20555 Millstone Nuclear Power Station, Unit Nos.1,2, and 3 Reauest for Discontinuation of Reoulatory Commitment i
References:
(1) NU letter B13018 from E. J. Mroczka to USNRC, " Proposed l
Revision to Technical Specification Administrative Controls-Safety Limit Violation, Audits," dated January 12,1989 t
e (2) J. F. Stolz letter to E. J. Mroczka, " Issuance of Amendments (TAC l
Nos. 71877, 71878, 71879 and 71880)," dated April 25,1989 l
l (3) NEl Guideline for Managing NRC Commitments, Revision 2, l
dated January,1996.
j The purpose of this letter is to request NRC review and approval to discontinue use of a; previous regulatory commitment associated 'with implementation of ~ Technical i
' Specification 6.5.3.7.a of the Unit Technical Specifications for Millstone Unit Nos.1,2, and 3.
This commitment relates to audits of conformance of unit operations to j
provisions contained within _ the Technical Specifications and applicable license conditions. In Reference (1), Northeast Nuclear Energy Company (NNECO) committed to the following:
l "All sections of the Technical Specifications and the License are audited each year; however, all items in each section need not be audited annually. Over a five-year period, the audits will address each item in the sections, subsections, j
and tables." '
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' NNECO would like to discontinue this commitment. The reason for our request is to i
enable NNECO to enhance the Technical Specifications audit process by focusing on l
i areas of concern and activities _with the greatest impact on safety and reliability. Rather than an art >itrary and general approach to performing audits, the new approach will I
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B17571 E ge2 utilize a performance-based method for conducting audits of the Technical Specifications.
This approach remains consistent with the latest version of the Northeast Utilities Quality Assurance Program Topical Report, which states thm audits are scheduled on the basis of " status and safety importance of the activities being performed."
The commitment for audits to address each item in the sections, subsections, and tables of the Technical Specifications over a 5 year cycle was specifically stated as oad of the basis of approval in the NRC Staff's Safety Evaluation Report in Reference (2) in support of license amendments for the Millstone Units. As such, the annual audit i
frequency and the five-year audit cycle for all items contained in the Technical Specifications, documented in the NRC SER, constitutes a regulatory commitment that requires NRC review and approval to discontinue in accordance with Reference (3).
NNECO respectfully requests NRC review and approval of the regulatory commitment discontinuation discussed above. As discussed in telephone conversation on January 13,1999, between Mario Robles (NNECO) and James Anderson (NRC), a response is requested by February 28,1999, so NNECO can move forward with the planning and performance of Technical Specification audits in 1999.
If there are any questions on the information provided in this letter, please contact Mr.
David A. Smith at (860) 437-5840.
Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY Martin L. Bowling, Jr.
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Recovery Officer - Technical Services cc:
H. J. Miller, Region i Administrator L. L. Wheeler, NRC Project Manager, Millstone Unit No.1 D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2 S. Dembek, NRC Project Manager, Millstone Unit No. 2 A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3 J. W. Andersen, NRC Project Manager, Millstone Unit No. 3 E. V. Imbro, Director, Millstone ICAVP inspections