ML17324A642
| ML17324A642 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/21/1986 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| AEP:NRC:0974, AEP:NRC:974, NUDOCS 8603030180 | |
| Download: ML17324A642 (6) | |
Text
INDIANA8 1MICHIGAN ELECTRIC COINPANY P.O, BOX 16631 COLUMBUS, OHIO 43216 February 21, 1986 AEP:NRC:0974 Donald C.
Cook Nuclear Plant Unit Nos.
1 and 2
Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NRC Report Nos.
50-315/85040(DRS) and 50-31 85040 DRS)
Mr. James G. Keppler U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Keppler:
This letter is in response to Mr. J.
A. Hind's letter dated January 22, 1986, which forwarded the subject Inspection Reports of the routine safety inspection conducted by your staff at the Donald C. Cook Nuclear Plant during the period December 9-12, 1985.
The Notice of Violation attached to Mr. Hind's letter identified one violation of Technical Specification 6.8.la.
In addition, one open item was identified in Section 7.a of the report.
The responses to this violation and the open item are addressed in the attachment to this letter.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.
Very truly yours, M.. Ale ichflA Vice President g,2i<
Attachments cc:
John E. Dolan W. G. Smith, Jr.
Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman
~j i:O~ g.(gA FEB 2 4 1986 8603030180 860221 PDR ADOCK 05000316 8
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Page 1
Attachment AEP:NRC:0974 I.E.
INSPECTION REPORT 50-315/850405 50-316/85040 NRC VIOLATION "Unit 1 and Unit 2 Technical Specification 6.8.1a states that written procedures shall be established, implemented and maintained covering among other things, the applicable procedures recommended in Appendix 'A'f Regulatory Guide 1.33 November, 1972.
"This requirement is implemented in procedure 12 THP 6020 LAB.044,
'Laboratory Quality Assurance,'Revision 6, September 12, 1985), that states in part (Section 12.1):
'A program to assure the reliability of procedural accuracy and individual technician technique will be routinely conducted.
Each relevant procedure will be checked at least quarterly with "unknowns."'Contrary to the above requirements, the licensee has not fully implemented this procedure in that:
1.
The licensee failed to provide 'unknown'amples to check the procedural accuracy in the determination of boron concentrations in reactor systems.
2.
Some technicians have not been checked for performance to assure individual technician technique."
RESPONSE
TO ITEM NO.
1 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Boron unknowns were prepared and analyzed to check procedural accuracy.
This was completed on January 23, 1986. 'he results were reviewed and the procedure was determined to be capable of providing accurate reactor coolant boron samples.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATIONS Boron unknowns are scheduled to be completed on at least a quarterly basis.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on January 23,
- 1986, when the above boron analysis was completed and scheduled to be performed periodically.
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v Attachment AEP:NRC:0974
RESPONSE
TO ITEM NO.
2 CORRECTIVE ACTION TAKEN AND RESULTS ACHIEVED Technicians will be checked for proper performance and technique during the routine supervisors'echnician observation time.
This observation will monitor and specifically address adherence to procedures and technique.
In addition, technicians are further checked during on-the-job training, "unknown" analysis, and the routine analysis of standards.
CORRECTIVE ACTION TO BE TAKEN TO AVOID FURTHER VIOLATION (See above)
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance was achieved on January 1, 1986, when the supervisors were asked to take particular note, during technician observation time, to analysis technicgxes.
NRC OPEN ITEM 50-315/85040-03; 50-316/85040-03 "The inspectors reviewed the QA/QC programs in the chemistry laboratory based on Procedure 12 THP 6020.LAB.044, "Laboratory Quality Control,"
Revision 6, September 12, 1985.
This revision, which improves the descriptions and documentation of the laboratory QA practices, was in response to a 1984 Quality Assurance Department Audit QA-84-20.
This procedure is specific in some areas in its purview, such as control of chemicals and reagents, calibration of instruments, and maintenance of deionized water, but it is fairly general with respect to control of analytical methods.
It does not specify the use of control charts, nor the handling and trending of data.
Control charts are not used and the data are not trended regularly.
However, the laboratory maintains for each instrument a log book that contains information useful for quality control such as calibration, maintenance and analysis data.
The Plant Chemistry Supervisor stated that the plant also plans to initiate the use of control charts for nonradiological analyses and that an implementation date would be forwarded with the response to the report (Open item 50-315/85040-03; 50-316/85040-03)."
RESPONSE
TO NRC OPEN ITEM 50-315/85040-03; 50-316/85040-03 Control charts for trending non-radiological data were implemented on January 21, 1986.
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