ML020170372

Quality Assurance Program Description Reduction in Commitment

ML020170372
Person / Time
Site:	Cook
Issue date:	01/11/2002
From:	Greenlee S Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:2540, NUREG-0800
Download: ML020170372 (12)

Text

Indiana Michigan Power Company 500 Circle Drive Buchanan, MI 49107 1373 INDIANA MICHIGAN POWER AEP:NRC:2540 January 11, 2002 10 CFR 50.54(a)(4)

Docket Nos.: 50-315 50-316 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop O-P1-17 Washington, DC 20555-0001 Donald C. Cook Nuclear Plant Units 1 and 2 QUALITY ASSURANCE PROGRAM DESCRIPTION REDUCTION IN COMMITMENT Company (I&M), the Pursuant to 10 CFR 50.54(a)(4), Indiana Michigan Power 1 and 2, requests Licensee for Donald C. Cook Nuclear Plant (CNP) Units Assurance Program approval of a reduction in commitment to the CNP Quality The proposed change would revise Description (QAPD), Revision 16.

Training Center File Exception/Interpretation l1 d to allow continued use of the change to the Rooms for the storage of quality assurance records. The proposed Alternative 17.1.17.4, exception/interpretation meets the requirements of Section Plan for the Reviews of Safety Analysis 3, to NUREG-0800, "Standard Review Reports for Nuclear Power Plants," dated July 1981.

background Attachment 1 describes I&M's current commitment, including 2 change. Attachment information, and a detailed discussion of the requested the proposed changes.

provides the QAPD pages marked up to show changes incorporated.

Attachment 3 provides the QAPD pages with the proposed consider this reduction in In accordance with 10 CFR 50.54(a)(4)(iv), I&M will NRC within 60 days of commitment accepted unless notified otherwise by the the date of this letter.

Q~ocD

U. S. Nuclear Regulatory Commission AEP:NRC:2540 Page 2 This letter contains no new commitments. Should you have any questions, please contact Mr. Gordon P. Arent, Manager of Regulatory Affairs, at (616) 697-5553.

Sincerely, S. A. Greenlee Director, Nuclear Technical Services

/dmb Attachments c: K. D. Curry J. E. Dyer MDEQ - DW & RPD NRC Resident Inspector R. Whale

ATTACHMENT 1 TO AEP:NRC:2540 CURRENT COMMITMENT, BACKGROUND INFORMATION, AND DETAILED DISCUSSION OF THE REQUESTED CHANGE to AEP:NRC:2540 Page 1 CURRENT COMMITMENT As required by Exception/Interpretation l1 d in the Donald C. Cook Nuclear Plant (CNP) Quality Assurance Program Description (QAPD), CNP has committed to storing records in storage facilities that meet the requirements of Section 17.1.17.4, Alternative 3, to NUREG-0800, "Standard Review Plan for the Reviews of Safety Analysis Reports for Nuclear Power Plants,"

dated July 1981. NUREG-0800 requires records to be stored in a two-hour fire-rated resistant file room with the following provisions:

1. Early warning fire detection and automatic fire suppression should be provided, with electronic supervision at a constantly attended central station.

2. Records should be stored in fully enclosed metal cabinets. Records should not be permitted on open steel shelving. No storage of records should be permitted on the floor of the facility.

Adequate access and aisle ways should be maintained at all times throughout the facility.

3. Work not directly associated with records storage or retrieval should be prohibited within the records storage facility. Examples of such prohibited activities include but are not limited to: records reproduction, film developing, and fabrication of microfiche cards.

4. Smoking and eating/drinking should be prohibited throughout the records storage facility.

5. Ventilation, temperature, and humidity control equipment should be protected inside with standard fire-door dampers where they penetrate fire barriers bounding the storage facility.

BACKGROUND In 1995, CNP identified that the file rooms in the Training Center were being used to store quality assurance records and did not comply with Section 17.1.17.4, Alternative 3, to NUREG 0800, "Standard Review Plan for the Reviews of Safety Analysis Reports for Nuclear Power Plants," dated July 1981, as required by the QAPD. Ten items of concern were identified. As a result, an engineering review of the Training Center File Rooms to NUREG-0800 requirements was performed. The engineering review identified ten recommendations to resolve the items of concern. Five of the engineering recommendations involved physical corrections to the file rooms, the remaining five recommendations would require a change to the QAPD for reduction in commitment. Subsequently, the physical changes to the Training Center File Rooms were completed, thereby resolving five of the ten concerns.

In 1999 it was noted that the previously identified changes to the QAPD had not been made.

Subsequently, the previously performed engineering evaluation was re-verified.

to AEP:NRC:2540 Page 2 An evaluation in February 2000 confirmed that the original evaluation was still valid. The evaluation noted that the original QAPD change request did not materialize because records management was to provide a dual storage approach by scanning records in the Training Center file rooms. Since that decision was made, the project slated to scan the records was cancelled and the records remained in the Training Center File Rooms.

DETAILED DISCUSSION OF CHANGES The proposed change would revise Exception/Interpretation 11 d to allow continued use of the Training Center File Rooms for the storage of quality assurance records. The proposed change to the exception/interpretation meets the requirements of Section 17.1.17.4, Alternative 3, to NUREG-0800, "Standard Review Plan for the Reviews of Safety Analysis Reports for Nuclear Power Plants," dated July 1981. The changes to the exception includes:

1. The floor slab is on grade; therefore, the two-hour fire rating is not applicable.

2. The present design of the ceiling assembly has a minimum of three inches of concrete on metal pan. This design provides approximately between 45 to 90 minutes of fire resistance.

The level of risk associated with a fire penetrating through the ceiling is minimal since the walls are sealed to the ceiling and fire barrier seals were installed. A fire above the rooms would tend to bum both upward and outward from its origin, reducing the impact of a fire burning down through the ceiling of concern. The rooms and surrounding areas are also protected by automatic wet pipe sprinkler systems, which would control or extinguish a fire until arrival of the fire brigade.

3. The presence of the light switch within the wall has a minimal impact on the overall fire rating. The noncombustible nature of the block will also prevent the spread of fire should a short or fire develop at the switch.

4. The pipe penetrations through the fire rated walls were sealed. The fire protection and service water pipes located in the facilities overhead do not have any affect on the fire rating; however, the potential hazard is if a pipe is ruptured, records could suffer water damage.

5. The PVC pipe penetrations were sealed. The level of risk associated with a fire penetrating through the sealed PVC piping is minimal. A fire above the rooms would tend to burn both upward and outward from its origin, reducing the impact of a fire burning down through the ceiling of concern. The rooms and surrounding areas are also protected by automatic wet pipe sprinkler systems, which would control or extinguish a fire until arrival of the fire brigade.

to AEP:NRC:2540 Page 3 The continued use of Training Center File Rooms for storage of quality assurance records is based on the risk-informed information below:

1. The fire protection system consists of a two-stage activation system.

2. The fire protection system is electronically monitored at a 24-hour security station that ensures prompt response in the event of a fire.

3. The file room walls are interior to the building and are not subject to weather and other adverse conditions.

4. The additional provisions in NUREG-0800 are stated as recommendations (i.e.,

"should's").

5. Access to these rooms is controlled and only activities pertaining to the file rooms are performed therein.

ATTACHMENT 2 TO AEP:NRC:2540 QAPD PAGES MARKED TO SHOW PROPOSED CHANGE Page 48 Page 48a

Quality Assurance Program Description 1lb. Sec. 5.4, Item 2 Requirement "Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel file cabinets are preferred."

Exception/Interpretation Records are suitably stored in steel file cabinets, or on shelving in containers. Methods other than binders, folders, or envelopes (for example, dividers) may be used to organize the records for storage.

I lc. Sec. 6.2 Requirement "A list shall be maintained designating those personnel who shall have access to the files."

Exception/Interpretation Rules are established governing access to and control of files as provided for in ANSI N45.2.9, Section 5.3, Item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or microforms may exist for general use.

SlId. Sec. 5.6 Requirement When a single records storage facility is maintained, at least the following features should be considered in its construction: etc.

Exception/Interpretation The Cook Nuclear Plant Master File Room and Training Center File Rooms comply with the requirements of NUREG-0800 (7/81), Section 17.1.17.4, option 3 \ith the following exceptions for the Training Center File Poomis:

1. The floor slab is on grade; therefore, the two-hour fire rating is not applicable.

2. The present design of the ceiling assemrbly has a mninimium of three inches of concrete on mnetal pan. This design provides approximately between 45 to 90 minutes of fire resistance. The level of risk associated with a fire penetrating through the ceiling is minimral since the walls are sealed to the ceiling and fire barrier seals were installed.

A fire above the roomis would tend to burn both upward and out-ward from- its orig~in, reducing the imipact of a fire burning down through the ceiling of concern. The roomis and surrounding areas are also protected by/ automnatic wet pipe sprinkler syýstemis, Which wouldJ control. or exting-uish a fire until arriv,,al of the fire brigade.

Revision 16 48

Quality Assurance Program Description 3.The presence of the light switch within the wall hais a minimal impact onl the overall fire rating,. The noncombustible nature of the block will also prevent the spread of fire should a short or fire develop at the switch.

4. The pipe penetrations through the fire rated walls were sealed. The fire protection and service water pipes located in the facilities overhead do not have any affect on the fire rating; however, the potential hazard is if a pipe is raLptured, records could suffer water damage.

5. The PVC pipe penetrations were sealed. The level of risk associated with a fire penetrating through the sealed PVC piping Is minimal. A fire above the rooms would tend to hurn both up-ward and outwýard fromn its origin, reducing the impact of afire burning down through the ceiling of concern. The rooms and surrounding areas are also protected by automatic wvet pipe sprinkler systems, wvhich would control or extinguish a fire until arrival of the fire brigade.

Ille. Sec. 5.6 Requirement Section 5.6 requires the record storage facilities to have a four-hour fire rating.

Exception/Interpretation In lieu of this requirement, the minimum two-hour rating as specified in ANSI N45.2.9 1979 is an acceptable alternative.

Revision 16 48a

ATTACHMENT 3 TO AEP:NRC:2540 PROPOSED QAPD REVISED PAGES Page 48 Page 48a

Quality Assurance Program Description 1lb. Sec. 5.4, Item 2 Requirement "Records shall not be stored loosely. They shall be firmly attached in binders or placed in folders or envelopes for storage on shelving in containers. Steel file cabinets are preferred."

Exception/Interpretation Records are suitably stored in steel file cabinets, or on shelving in containers. Methods other than binders, folders, or envelopes (for example, dividers) may be used to organize the records for storage.

1ic. See. 6.2 Requirement "A list shall be maintained designating those personnel who shall have access to the files."

Exception/Interpretation Rules are established governing access to and control of files as provided for in ANSI N45.2.9, Section 5.3, Item 5. These rules do not always include a requirement for a list of personnel who are authorized access. It should be noted that duplicate files and/or microforms may exist for general use.

I ld. Sec. 5.6 Requirement When a single records storage facility is maintained, at least the following features should be considered in its construction: etc.

Exception/Interpretation The Cook Nuclear Plant Master File Room and Training Center File Rooms comply with the requirements of NUREG-0800 (7/81), Section 17.1.17.4, option 3 with the following exceptions for the Training Center File Rooms:

1. The floor slab is on grade; therefore, the two-hour fire rating is not applicable.

2. The present design of the ceiling assembly has a minimum of three inches of concrete B

on metal pan. This design provides approximately between 45 to 90 minutes of fire resistance. The level of risk associated with a fire penetrating through the ceiling is minimal since the walls are sealed to the ceiling and fire barrier seals were installed.

A fire above the rooms would tend to bum both upward and outward from its origin, reducing the impact of a fire burning down through the ceiling of concern. The rooms and surrounding areas are also protected by automatic wet pipe sprinkler systems, which would control or extinguish a fire until arrival of the fire brigade.

Revision 16B 48

Quality Assurance Program Description

3. The presence of the light switch within the wall has a minimal impact on the overall fire rating. The noncombustible nature of the block will also prevent the spread of fire should a short or fire develop at the switch.

4. The pipe penetrations through the fire rated walls were sealed. The fire protection and service water pipes located in the facilities overhead do not have any affect on the B fire rating; however, the potential hazard is if a pipe is ruptured, records could suffer water damage.

5. The PVC pipe penetrations were sealed. The level of risk associated with a fire penetrating through the sealed PVC piping is minimal. A fire above the rooms would tend to burn both upward and outward from its origin, reducing the impact of a fire burning down through the ceiling of concern. The rooms and surrounding areas are also protected by automatic wet pipe sprinkler systems, which would control or extinguish a fire until arrival of the fire brigade.

lie. Sec. 5.6 Requirement Section 5.6 requires the record storage facilities to have a four-hour fire rating.

Exception/Interpretation In lieu of this requirement, the minimum two-hour rating as specified in ANSI N45.2.9 1979 is an acceptable alternative.

Revision 16B 48a