ML17324A920

Summary of 860430 Meeting W/Util Re Basis for Providing Acceptable Tech Specs on Mgt Issues.Proposed Corrective Actions & Trending Programs Also Discussed.Viewgraphs, Agenda & List of Attendees Encl

ML17324A920
Person / Time
Site:	Cook
Issue date:	05/13/1986
From:	Wigginton D Office of Nuclear Reactor Regulation
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8605220506
Download: ML17324A920 (57)

Text

E, I

gf Docket Nos.:

50-315 and 50-316 1 ~ NAY I

1986 LICENSEE:

FACILITY:

SUBJECT:

Indiana and Michigan Electric Company Donald C.

Cook Nuclear Plant, Unit Nos.

1 and 2

SUMMARY

OF MEETING HELD ON APRIL 30, 1986 WITH INDIANA AND MICHIGAN ELECTRIC COMPANY TO DISCUSS BASIS FOR ACCEPTABLE PROVISIONS OF TECHNICAL SPECIFICATIONS ON MANAGEMENT ISSUES The staff met with the licensee on April 30, 1986, in the third of a series of meetings to discuss and resolve outstanding problems with the Technical Specifications.

The list of meeting attendees is enclosed as Enclosure 1.

The licensee made the presentation from the veiwgraphs enclosed as Enclosure 2.

There were no specific decisions made at the meeting:

the licensee will formalize their submittals and include the necessary documentation to justify any proposed changes.

The licensee also took the opportunity at the meeting to discuss portions of their proposed corrective actions program and trending program that may affect or require changes to the Technical Specifications.

These programs will be formally presentated to the Region at a meeting scheduled for May 8, 1986.

The licensee presented their Technical Specification Upgrade Program activities and status for the benefit of NRC personnel that recently acquired responsibilities on D.

C. Cook.

The licensee's near term program consists of ongoing meeting (such as this one) to discuss proposed Technical Specification

changes, an interpretation method to lessen the burden of the licensee, Region III and NRR, an interpretation document to cross reference Technical Speci-fications by system and references to the FSAR, continued work with the WOG and ANS 58.4 Working Group, the fire protection plan concept much like Perry, and a first cut at a set of definitions of terms acceptable for future Technical Specification changes.

The licensee will submit a draft set of definitions by July 1st to the NRC and was advised to work closely with North Anna.

It is understood that North Anna will serve as the WOG lead plant for short term activities for the Technical Specification Improvement Project.

LS/

David L. Wigginton, Project Manager PWR Project Directorate P4 Division of PWR Licensing-A

Enclosures:

As stated cc:

See next page PWREt /DPWR-A PWR84/DPWR-A DWigginton/mac Q BJYoungblood 05/(g/86 06/ g /86 8605220506 8605i3 PDR ADOCK 05000325 P

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Mr. John Dolan Indiana and Michigan Electric Company Donald C.

Cook Nuclear Plant CC:

Mr. M. P. Alexich Vice President Nuclear Operations American Electric Power Service Corporation 1 Riverside Plaza

Columbus, Ohio 43215 Attorney General Department of Attorney General 525 West Ottawa Street Lansing, Michigan 48913 Townshi p Supervi sor Lake Township Hall Post Office Box 818 Bridgman, Michigan 49106 W.

G. Smith, Jr., Plant Manager Donald C.

Cook Nuclear Plant Post Office Box 458 Bridgman, Michigan 49106 U.S. Nuclear Regulatory Commission Resident Inspectors Office 7700 Red Arrow Highway Stevensville, Michigan 49127 Gerald Charnoff, Esquire Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.

Washington, DC 20036 Mayor, City of Bridgeman Post Office Box 366 Bridgman, Michigan 49106 Special Assistant to the Governor Room 1 - State Capitol Lansing, Michigan 48909 Nuclear Facilities and Environmental Monitoring Section Office Division of Radiological Health Department of Public Health 3500 N. Logan Street Post Office Box 30035 Lansing, Michigan 48909 The Honorable John E. Grotberg United States House of Representatives Washington, DC 20515 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen El lyn, Illinois 60137 J. Feinstein American Electric Power Service Corporation 1 Riverside Plaza

Columbus, Ohio 43216

ENCLOSURE. 1 THIRD TECHNICAL SPECIFICATION UPGRADE MEETING April 10, 1986 D.

C.

Cook Site NAME D. Wigginton V. Benaroya L. Crocker S. Isreal B. Burgess A. Walker B. Jorgensen J. Feinstein P. Barrett F. White D. Powell R.

F. Kroeger M. P. Alexich P. Infanger A. Blind B. Svensson ORGANIZATION NRR-PWRg4 NRR-FOB NRR-FOB NRR-FOB REGION III REGION III RI, D.

C.

COOK AEPSC AEPSC AEPSC AEPSC AEPSC AEPSC AEPSC D.

C.

COOK D.

C.

COOK

NRC D.

C.

COOK MEETING APRIL 30 i 1986 AGENDA 1.

TECHNICAL SPECIFICATION UPGRADE PROGRAM/FIRE PROTECTION 2.

-- TECHNICAL SPECIFICATION ORGANIZATION CHART ASSISTANT PLANT MANAGERS RADIATION PROTECTION SUPERVISORS 3.

CORRECTIVE ACTION PLAN 4 ~

CONSOLIDATED TRENDS PROGRAM 5.

PNSRC CHANGES REGULATORY HISTORY TECHNICAL SPECIFICATION CHANGES TECHNICAL SPECIFICATION CLARIFICATIONS AUDIT PROGRAM 7 ~

LER QUALITY

NANT MANAOE1 AINNHICTRATlVE MNNTENANCE CUtfRVICOR SUPRINNIENOENT STATS SlASS PROQ SUPV.

OPERATIONS SOL TRANllNO COOROINAlOR CONST OPERAT INOfNO NL OtfhATINO f.NONOEfh OL NUCLEAR fNOINEfh SUtfhVlSCN fNOINEf1 CONTROL AINI ~

MJMENTAT fNGINEER PLANT

~

CHEM AL SUPERVISOR tfATN

~

MOIA~

~

T.~.

fOENO:

~ SfNOR OtfRATOR LICENSE OL

~ OPERATOR LOCLNSE

~ ~ KEY SUPRRVISCMV tERSCMWfI UNIT SUtfRVISOR OL

~EhfORMANCE tE1fOIhMANCE RISTItNKNT fNGINEfh fNOINEE1 fOlktMENT OtfRATOR TfCIRRCIAM AUXILIARY fO'r~~H~

OtERATOR

GOALS 1.

PROVIDE SUPERVISORS MORE TIME TO SPEND IN THE PLANT 2 ~

3 ~

MAKE THE PNSRC MORE EFFECTIVE AND EFFICIENT REDUCE ADMINISTRATIVE BURDEN ON PNSRC CONCENTRATE ON ISSUES WITH SAFETY SIGNIFICANCE P

ESTABLISH AN EFFECTIVE AND EFFICIENT CORRECTIVE ACTION PLAN DOCUMENT ONLY REAL PROBLEMS RESOLVE PROBLEMS AT LOWER MANAGEMENT LEVELS

- ASSURE REPORTABZLITY OBLIGATIONS ARE MET TRACK CORRECTIVE ACTIONS TO ASSURE TIMELINESS TREND PREVENTIVE ACTIONS TO ASSURE.EFFECTIVENESS ONLY REVIEW SIGNIFICANT PROBLEMS AT THE UPPER MANAGEMENT (PNSRC/NSDRC)

LEVELS

CORRECTIVE ACTION PLAN PURPOSE

SUMMARY

OF PROCEDURE

~

PROPOSED CORRECTIVE ACTION PLAN OBJECTIVES-RETAIN THE OPENNESS AND ACCESSIBILITY OF THE PRESENT SYSTEM UNIFY THE CORRECTIVE ACTION SYSTEMS BETWEEN COOK AND COLUMBUS CONSOLIDATE ALL CORRECTIVE ACTION ONTO A

COMMON FORM STREAMLINE THE PROCESSING AND REVIEW CYCLES ENCOURAGE MEANINGFUL INVESTIGATIONS AND ASSURE EFFECTIVE CORRECTIVE ACTIONS IN A TIMELY MANNER INTEGRATE TRENDING PROCEDURE 1,

PROBLEM IDENTIFICATION 2.:

PROBLEM ASSESSMENT GROUP (PAG)

REVIEW MEMBERSHIP:

PLANT CORPORATE ASSISTANT P.M.

OPERATIONS NUCLEAR SAFETY 6 LICENSING QUALITY CONTROL QUALITY ASSURANCE OPERATIONS ENGINEERING DAILY PHONE LINK BETWEEN AEPSC AND COOKP AS NEEDED DETERMINES REPORTABILITY FRONT-END FILTER ACCESS TO TREND DATA TO SPOT RECURRING CONDITIONS 3,

INVESTIGATION DETERMINE ROOT CAUSE PROPOSE AND IMPLEMENT CORRECTIVE/PREVENTIVE ACTION 4,

REVIEW AND CLOSEOUT BY ORIGINATOR FOR QA/NSDRC AUDITS AND QC SURVEILLANCES BY COGNIZANT SUPERVISOR FOR ALL OTHERS 5,

SAFETY REVIEW BY PNSRC FOR CONDITION REPORTS (SIGNIFICANT PROBLEMS) 6, NSDRC REVIEW (OFF-LINE)

SIGNIFICANT TO AFFECT (1)

THE RESULTS OF IMPLEMENTED PROCEDURES'2)

PLANT OPERATIONS AND/OR (5)

PLANT EQUIPMENT TO THE EXTENT THAT A VIOLATION RESULTED, PNSRC REVIEW 1.

ALL NRC REPORTABLE EVENTS 2 I 3

~

VIOLATIONS OF TECHNICAL SPECIFICATIONS.

CODES.

REGULATIONSi

ORDERS, OR LICENSE REQUIREMENTS.

A.

ALL SIGNIFICANT VIOLATIONS OF THE FIRE PROTECTION PROGRAM.

B.

ALL SIGNIFICANT VIOLATIONS OF THE RADIATION PROTECTION PROGRAM.

C.

ALL SIGNIFICANT VIOLATIONS OF THE RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM.

D.

ALL SIGNIFICANT VIOLATIONS OF REFUELING PROCEDURES.

E.

ALL RECOGNIZED INDICATIONS OF A SIGNIFICANT UNANTICIPATED DEEZCIENCY ZN SOME ASPECT OF DESIGN OR OPERATION OF SAFETY RELATED STRUCTURES'YSTEMS~

OR COMPONENTS'IGNIFICANT VIOLATIONS OF THE SECURITY PLAN, 4,

SIGNIFICANT VIOLATIONS OF THE EMERGENCY PLAN, SIGNIFICANT VIOLATIONS OF THE PROCESS CONTROL

PROGRAM, 6,

SIGNIFICANT VIOLATIONS OF THE OFF-SITE DOSE CALCULATION MANUAL, 7 I UNPLANNED AND/OR UNMONITORED RELEASES OF RADIOACTIVE MATERIAL TO THE ENVIRONS THAT EXCEED TECHNICAL SPECIFICATION CRITERIA, SIGNIFICANT VIOLATIONS OF THE QA PROGRAM FOR EFFLUENT AND ENVIRON-MENTAL MONITORING OR SIGNIFICANT VIOLATIONS OF APPENDIX B TECHNICAL SPECIFICATIONS, 9,

SIGNIFICANT OPERATING ABNORMALITIES OR DEVIATIONS FROM NORMAL AND EXPECTED PERFORMANCE OF PLANT EQUIPMENT THAT AFFECT NUCLEAR SAFETY, 10, DEFICIENCIES IN ESTABLISHED TRAINING PROGRAMS SUCH THAT A SIGNIFICANT PROBLEM COULD OR DID OCCUR, SIGNIFICANT DEVIATIONS FROM SAFETY-RELATED DESIGN DOCUMENTS (E G

DRAWINGS),

12, NRC SEVERITY LEVEL I i I I i I I I i AND IV INSPECTION FINDINGS,

0

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CONSOLIDATED TRENDS PROGRAM PURPOSE SCOPE PLAN FOR DEVELOPMENT BENEFITS

CONSOLIDATED TRENDS PROGRAM PURPOSE TO PROVIDE PROMPT FEEDBACK TO MANAGEMENT WHEN ACTIVITIES INDICATE A DECLINE IN EXPECTED PERFORMANCE

TRENDS SCOPE 1.

PERSONNEL PROTECTION 2.

NUCLEAR SAFETY 3.

QUALITY MANAGEMENT 4.

REGULATORY COMPLIANCE 5.

PLANT EFFICIENCY 6.

EQUIPMENT EFFICIENCY 7.

OTHERS

(~

TRENDS PLAN FOR DEVELOPMENT:

22 TRENDS l.

IDENTIFY CURRENT TREND ACTIVITIES COMPLETE 2 ~

ADDRESS HOW CURRANT TRENDS ARE DEVELOPED COMPLETE WHO IS RESPONSIBLE SOURCE OF DATA EXISTING COMPUTER ASSISTANCE EXISTING ADMZNISTRATZVE ASSISTANCE HOW TRENDS ARE BEING USED 3.

IDENTIFY NEW TRENDS

/

CONSIDER NRC AND INPO TRENDS COMPLETE 4

ESTABLISH PRIORITIES FOR INDIVIDUALTREND DEVELOPMENT CONFIRM WITH NRC ON APRIL 30, 1986 5 ~

IDENTIFY INDIVIDUAL TREND FORMATS MAY 15 g 1986 f

6.

IDENTIFY BEST COMPUTER OPTIONS TREND FORMAT DEPENDENT*

TRENDS 7 ~

DEVELOP CORRECTIVE ACTION PLAN - COMPUTER DEPENDENT*

PROCEDURE FOR DOCUMENTING AND CORRECTING ADVERSE TRENDS

+ IMPLEMENTATION DATE - AUGUST 1, 1986 ESTABLISH METHOD FOR TRACKING CORRECTIVE ACTION STATUS AND CLOSEOUT 8.

PREPARE PROCEDURES TO ASSURE UNIFORM TRENDS COMPUTER DEPENDENT*

STANDARDIZED FORMAT FOR REPORTING DATA

+ WHAT INFORMATION IS TO BE PROVIDED FOR EACH TREND TREND RESPONSIBILITIES

+

WHO REPORTS AND HOW OFTEN 9.

DEVELOP TRENDS USER'S GUIDE - AUGUST 1, 1986 DEFINE PURPOSE OF TRENDS DEFINE WHAT THE DATA REPRESENTS DEFINE ADVERSE OR DECLINING TRENDS 10.

ACTIVATE TREND PROGRAMS

• TARGET DATES TO BE SUPPLIED AFTER TREND FORMATS ARE CONFIRMED

TRENDS BENEFITS:

CONTROLLED SOURCE INFORMATION DIRECT INTERFACE WITH CORRECTIVE ACTIONS PLAN TO TRACK ADVERSE CONDITIONS PROVIDES EXPEDIENT FEEDBACK TO MANAGEMENT ON:

+ INDICATORS ADVERSE TO SAFETY

+ INDICATORS ADVERSE TO REGULATORY COMPLIANCE

+ EFFECTIVENESS OF THE QUALITY ASSURANCE PROGRAM

+ TIMELINESS OF CORRECTIVE ACTIONS

+ PLANT PERFORMANCE

+ EQUIPMENT PERFORMANCE

DEVELOPMENT PRIORITY EXISTING/NEW TREND 10 12 13 14 15 16 17 18 19 20 21 22 CONDITION REPORTS NUMBER CONDITION REPORTS CAUSE CONDITION REPORTS DOMINANT/FREQUENT LERs -

NUMBER LERs CAUSE LERs - DOMINANT/FREQUENT FIRE WATCH VIOLATIONS NPRDS COMPONENT FAILURES TECH.

SPEC.

EQUIPMENT -

NUMBER INOPERABLE TECH.

SPEC.

EQUIPMENT INOPERABLE IDENTITY TECH.

SPEC.

INSTRUMENTS -

NUMBER INOPERABLE TECH.

SPEC.

INSTRUMENTS INOPERABLE IDENTITY LCO ACTION STATEMENT ENTERED -

NUMBER LCO ACTION STATEMENT ENTERED - IDENTITY REACTOR TRIPS >158 POWER REACTOR TRIPS C15%

POWER REACTOR TRIPS - CAUSE ESF ACTUATIONS -

NUMBER ESF ACTUATIONS -

CAUSE SAFETY SYSTEM UNAVAILABILITY-NUMBER SAFETY SYSTEM UNAVAILABILITY-CAUSE SAFETY SYSTEM UNAVAILABILITY-IDENTITY NEW NEW NEW NEW NEW NEW NEW EX NEW NEW NEW NEW NEW NEW NEW NEW NEW NEW NEW NEW NEW NEW 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 DESIGN CHANGES (RFCs)

OPEN DESIGN CHANGES (PMs)

OPEN IMPROPER CONTROL ALARMS - NUMBER IMPROPER CONTROL ALARMS - IDENTITY FORCED OUTAGES SOLID WASTE GENERATION RADIATION EXPOSURES RADIOACTIVE RELEASES GASEOUS RADIOACTIVE RELEASES

- LIQUID RADIOACTIVE RELEASES

- PARTICULATE UNPLANNED RELEASES

- NUMBER INDUSTRIAL SAFETY - LOST TIME RATE INDUSTRIAL SAFETY - MEDICAL ATTENTION IST VALVE RESPONSE TIMES NRC SANCTION POINTS

- INSPECTIONS NRC SANCTION POINTS

- LERs CAPACITY FACTOR EQUIVALENT AVAILABILITYFACTOR NEW NEW EX EX EX EX EX EX EX EX EX NEW NEW EX NEW NEW EX NEW

CONSOLIDATED TRENDS PROGRAM 0

ADMINISTRATION CONTROLS OF TREND DATA

~

TREND ANALYSIS METHODS

~

TREND REPORTS

ADMINISTRATIVECONTROLS OF TREND DATA

~

INPUTS FROM PROBLEM REPORTING SYSTEM

~

CAUSE DETERMINATION METHODS (KEPNER-TREGOE

)

~

INSTRUCTIONS FOR PROBLEM DATA COMPUTER ENTRY

TREND ANALYSIS METHODS 0

ITEM POPULATION CHANGES OVER TIME

~

AUTOMATIC LIMITATION FLAGGING (PRESET LIMITS)

~

"CAUSE EFFECT" DOMINANT PROBLEM INTERRELATIONSHIPS 0

STATIST I CAL MOST PROBABLE OCCURRENCES (PARETO ANALYSIS)

LEAST PROBABLE OCCURRENCES (EXTREME VALUE THEORY) 0 KEPNER-TREGOE POTENTIAL PROBLEM ANALYSIS

~

CORRECTIVE ACTION EFFECTIVENESS REPORT INEFFECTIVE CORRECTIVE ACTION TRENDS INTO PROBLEM REPORTING SYSTEM

REPORTING T END N

ORN TION

~

INTERNAL NSDRC PNSRC STA QA NUCLEAR OPERATIONS EXTERNAL NRC INPO STATE 8 LOCAL

PNSRC REGULATORY HISTORY 1.

REVIEW OF CONDITION REPORTS 2.

PERFORMANCE OF TRENDS 3.

REVIEW OF NONSAFETY RELATED PROCEDURES 4.

REVIEW OF SAFETY-RELATED PROCEDURES 5.

REVIEW OF AUDIT REPORTS, INSPECTION REPORTS, BULLETINSi CIRCULARS, AND NSDRC MEETING MINUTES 6.

REVIEW OF TRAINING FOR LICENSED PERSONNEL

EVIEW OF CONDITION REPORTS PMI-1040 4.9.5.1 "The Subcommittee on Operations performs reviews of.

~.

the closeout of Condition Reports...A summary report of Condition Report closeout will also be presented to the PNSRC."

5.,5.1.1 "The PNSRC shall review for closeout all plant Condition Reports..."

AEPNRC - Letters No letters identified which establishes a commitment as to what is to be documented on a Condition Report (C/R).

FSAR -

Pro ram 1.7 '5.2.1

"...The Job Order System and/or the Condition Report system are used at D.

C.

Cook Nuclear Plant to identify nonconforming items and initiate corrective action..."

1.7.16.2.2 "Condition Reports provide the mechanism for plant personnel to not y management of conditions adverse to quality...

Further, Condition Reports are used to identify those actions necessary to prevent recurrence of the reported condition.

Condition reports are also used to report violations to codes, regulations and the Technical Specifications.

Condition Reports are reviewed by the PNSRC for evaluation of actions taken to correct the deficiency and prevent recurrence."

ANSI N18 7-1976 4.1 "...Programs for reviews...shall be established by the owner organization to...verify that reportable

events, which require reporting to NRC in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, are promptly investigated and corrected..."

4.3.4 "The following subjects shall be reviewed by the independent review body...

(4) Violations, deviations and reportable

events, which require reporting to the NRC..

such as:

(a) Violations of license requirements or internal procedures or instructions ~havin safet si nificance (b) Significant operating abnormalities or deviations from normal or expected performance of plant safety-related structures,

systems, or components...

Review of events covered under this subsection shall include the results of any investigation made and the recommendations resulting from such investigations to prevent or reduce the probability of recurrence of the event..."

1

4.4 "...The onsite o eratin or anization should screen subjects of potential concern to independent reviewers an per orm pre mznary nvestigations see 4.

.4 Technical S ecifications 6.5.1.6 "The PNSRC shall be responsible for:...

e. Investigation of all violations of the Technical Specifications inc udxng t e preparation and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Chairman of the NSDRC.

f. Review of all REPORTABLE EVENTS" 6.5,.1.7 "The PNSRC shall...

b. Render determinations in writing with regard to whether or not each item considered under 6.5.1

~ 6(a) through (e) above constitutes an unreviewed safety question..."

TRENDING PMI-1040 5.5.1.3.1 "The PNSRC shall periodically review facility operating records for the purpose of detecting trends that may not be readily apparent on a az y asks and might possibly be adverse to safety..."

5.5.1.3.2 "Each PNSRC member shall be responsible for reviewing the

[trend] report..."

AEP'NRC:0752 ATTACHMENT Page 2, paragraph (4)

The PMI [1040] will be revised to reflect the requirement to review 'designated operating records."

IR 8 -17 Page 4, paragraph (e)

"There were no requirements to review the following:

...Facx ty operat ons and records to detect trends that would not be apparent to the day-to-day observer..

~ "

ANSI N18 7-1976 4.1

'~Pro raus for reviews and for audits of activities affecting plant safety during the operational phase shall be established by the owner organization to:...

0 (4)

Detect Trends which may not be apparent to a day-to-day observer.

These programs for reviews and audits shall be, themselves, be periodically reviewed for effectiveness by management of the owner organization..."

Technical S ecifications No requirement specified for PNSRC to perform trends or review trends.

0 SAFETY RELATED PROCEDURES AND DESIGN CHANGES pMT-loao 4.9.3.6 "...Review 'and approval of non-safety related procedures shall be documented and signed y t e Subcommittee Chairman as non-safety related.

The Subcommittee shall determine if further review is required."

5. 2. 3 (f) "... The PNSRC shall perform a review of all Plant Modifications to ensure that the proposal is not safety-related or safety-interfaced and that an unreviewed safety question does not exist..."

AEP'NRC:0752 Page 2, paragraph (6)

"...Procedures for performing these evaluations

[10 CFR 50.59]

will be prepared to assure an adequate and consistent app(roach."

IR 82-17 Page 5, paragraph (1.4)

"...[Plant] Instructions for the

[PNSRC Review] checklist stated that no unreviewed safety question determination was required if the proposal was not safety related.

This is contrary to 10 CFR 50.59 which requires that any change to the facility, as described in FSAR, be evaluated for an unreviewed safety question."

Page 6, paragraph (1.5) m...plant Modifications (pMs) were passed through the subcommittee review process with no consideration for 10 CFR 50.59 application.

PMs were segregated from o'ther design changes as not safety related an t ere ore not requiring a 10 CFR 50.59 review.

nce again, t zs is contrar to 10 CFR 50.59, which makes no distinction as to whether or not a change is safety related."

ANSI N18 7-1976 review body:

(1)

Written safety evaluations of changes in the facility as described in t e Sa ety nalysis Report, changes in procedures as described in the Safety Analysis Report and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval...

(2)

Pro osed changes in procedures, proposed changes in the facility, or proposed tests or experiments, any of which involves a change in the technical specifications or an unreviewed safety question..."

Technical S ecifications 6.5.1.6 "The PNSRC shall be responsible for:

and changes

thereto,

2) any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety.

h.

Review of all ro osed tests and experiments that affect nuclear safety.

C.

~.

d.

Review of all ro osed changes or modifications to plant systems or equipment t at affect nuclear safet 10 CFR 0 59

"(a) (l) The holder of a license authorizing operation of a production or utilization facility may (i) make changes in the facility as described in the safety analysis report, (ii) make changes in the procedures as described in the safety analysis report...unless the proposed change involves a change in the technical specification...or an unreviewed safety question...

(b) The licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section, to the extent that such changes constitute changes in the facility as described in the safety analysis report or.constitute changes in procedures as described in the safety analysis report..

~ These records shall include a written safety evaluation which provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question..."

VIEW OF SAFETY RELATED PROCEDURES PMI-1040 4.9 '.2 "The Subcommittee on Procedures shall also normally perform the required review of all changes to 'safety-related'rocedures..."

TECHNICAL SPECIFICATIONS 6.5.1.6 "The PNSRC shall be responsible for:

a.

Review of 1) all procedures required by Specification 6.8 and changes

thereto,

2) any other proposed procedures or changes thereto as determined by the Plant Manager to affect nuclear safety..."

10CFR50.59 Does no s ecif what or anization, department, or individuals are required to review safet related procedures and changes thereto.

OTHER UTILITIES'ECHNICALSPECIFICATIONS Trojan,'an Onofre 2 and 3, Catawba, and McGuire.

NRC has'pparently issued technical specifications which allow the respective departments to perform the 10CFR50.59 review of safety procedures and changes thereto.

[See the attached December 4,

1985 Federal Register, Vol. 10, No.

233j

AUDITS I SPECTIO S

AND INFORMATION PMT-10a0 4.9.6.1 "The subcommittee on Audits performs reviews of audit reports by the Quality Assurance Department and the NSDRC as well as NRC Inspection Reports as described in Section 5.5.1.2.

Any responses to these documents will also be reviewed by the Subcommittee..."

5.5.1.2. 1 "The PNSRC shall review all written reports of audits performed by the AEPSC Quality Assurance Department and the AEPSC Nuclear Safety Design Review Committee (NSDRC).

The Committee shall also review NRC Inspection Reports as well as NSDRC meeting minutes..."

AEP'NRC'0752 ATTACHMENT Pape 1 and 2, paragraph (4)

"Phial-1040 will be modified to reflect the requirements for review of Quality Assurance (QA) and Nuclear Safety and Design Review Committee (NSDRC) audit reports as well as NRC Inspection Reports (which contain citations for Technical Specification violations) and the licensee's responses thereto.

The PNSRC will also review NSDRC meeting minutes, NSDRC reports..."

IR 82-17 Page 4, paragraph (e)

"There were no re uirements to review the following:

o NSDRC meeting minutes, reports, and correspondence.

o QA and NSDRC audit reports.

o RC nspectzon

reports, ulletins, licensee responses to these, NRC cxrcu ars..."

ANSI N18 7-1976 4.1 "...These pro rams for reviews and audits shall, themselves, be periodically reviewed for effec by management of the owner organization.

The programs provided for reviews and for audits may take different forms.

For example, the owner organization may assign these functions to separate established organizational units independent of the onsite operating organization, or may appoint a standing committee comprised of individuals from within or outside the owner organization to perform reviews and to exercise overview of audits...

This standard does not s ecif an or anizational structure for meetin the review and audit functions but in lieu thereof delineates essential elements of satisfactorily comprehensive programs for review, and for audit in the manner best suited to the owner organization involved."

7

Tech ica S eci ications No re uirements are specified for PNSRC to review any audit reports (QA or NSDRC), NRC ins ection re orts, NSDRC meetin

minutes, or NSDRC reports.

PNSRC is res onsible for investigation of all Technical Specification violations which may be documented in NSDRC or QA audit reports, or NRC inspection reports.

TRAINING OF LICENSED PERSONNEL PMI-1040 5.5.1.4.1 "The PNSRC will periodically review the ~trainin /retraining program status for both licensed and nonlicensed personnel..."

5.5.1.4.2 "A summary report of overall training status shall be provided...

The report...shall include...information as to departmental skills training..."

AEP:NRC:0752 ATTACHMENT Pages 1 and 2, paragraph (4)

"...The PNSRC will also review...reports on training programs for licensed and non-licensed personnel.."

IR 82-17 Page 4, paragraph (e)

"There were no re uirements to review the following:

...~Trainin and re-training programs for licensed and non-licensed facility staff members..."

NSI N18 7-1976 No re uirements or recommendations specified for PNSRC to review any training programs.

TECHNICAL SPECIFICATIONS No requirement specified for review of training.

10CFR50 A

endix B

Criterion II

"...The [Quality Assurance]

program shall provide for indoctrination and training of personnel...The applicant shall regularly review the status and adequacy of the quality assurance program..."

PLANT NUCLEAR SAFETY REVIEW CONNITEE ~PNSRC CHANGES IN RESPONSIBILITIES AND PRACTICES

- REVIEW ONLY SIGNIFICANT PROBLEMS -- FSAR/QA CHANGE PURPOSE OF PNSRC REVIEW DEFINED

- NO REVIEW OF AUDIT REPORTS OR NRC INSPECTION REPORTS (ONLY SIGNIFICANT PROBLEMS) -- NO TECH.

SPEC.

CHANGES NEEDED ft REVIEW ONLY THE TRENDS REPORT PNSRC NOT RESPONSIBLE FOR REVIEWING RECORDS TO DETECT TRENDS -- NO TECH.

SPEC.

CHANGES REVIEW OF TRAINING ADEQUACY FOR LICENSED PERSONNEL COULD BE DONE BY THE TRENDS PROGRAM AND QA -- NO TECH.

SPEC.

CHANGES

- REVIEW ONLY CHANGES TO PLANT MANAGEMENT INSTRUCTIONS (PMIs)

TECH.

SPEC.

CHANGE ALL OTHER PROCEDURES ARE REVIEWED BY THE RESPECTIVE DEPARTMENTS

- REVIEW SAFETY EVALUATIONS,OF CHANGES TO DESIGNS AND EXPERIMENTS

-- TECH.

SPEC.

CHANGE REVIEW ALL CHANGES, WHICH MAY INVOLVE AN UNREVIEWED SAFETY QUESTION.

NO REVIEW WOULD BE REQUIRED OF NSDRC MINUTES OR REPORTS (ONLY SIGNIFICANT PROBLEMS) -- NO TECH.

SPEC.

CHANGES NEEDED

ADNIVIS.RATIVE CONTROLS

,AL ERNATES 6.5.1.3 All alternate members shall be appc'nted in writing by the PNSRC Chairmar. to sez've cn a tempozary basis;

however, no moze than two alternates shall par"ic pate as vot'ng members n

PNSRC activities at any one time.

NEETINVG FRE UENCY 6.5.1.4 The PNSRC sha

meet at least once per calendar month and as convered by the*PNSBC Cl:ai.rman or h' designated alternate.

~UORUM 6.5.1.5 A quorum of the PNSRC shal'onsist of the Chairman or his designated alternate and sufficient members, includina alternates, to constitute a ma3ority.

RESPONSIP XLITIE 6.5.1.6 The PNSRC shall be responsible for:

Review of 1) all procedures required bv Specification 6.8 and chanaes

theretc,

2) ary other proposed procedures or changes thereto as determined by tl..e Plant Nanacer to affect nuclear safety.

b.

Review cf a]1 prooosed tests and expeziments that affect rucleaz safety.

Co Review of all proposed changes to Append'x "A" Technical Specificat'ons.

d.

Review o all proposed changes or mocificaticrs to plant systems o

eauioment that affect ruclear safety.

O.C.

COOK - UNIT 2

6-6 Amendment No.

73

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PNSRC PROPOSED TECHNZCAL SPECZFZCATZON CHANGES 6.5.1.6 The PNSRC shall be responsible for:

a

~

b.

c ~

d 0 Review of all Plant Management Znstructions (PMZs);

Review of safety evaluations for (1) plant site procedures, (2) change to plant site procedures, equipment, systems or facilities, and (3)2tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question; Review'f proposed procedures and changes to procedures, equipment, systems or facilities which involve an unreviewed safety question as defined in 10 CFR 50.59 or involves a change in Technical Specifications; Review'f proposed test or experiments which involve an unreviewed safety question as defined in 10 CFR 50.59 or requires a change in Technical Specifications; (1)

The PNSRC review shall confirm that the appropriate nuclear safety concerns appear to have been considered; that controls will be maintained to assure nuclear safety; and that no unreviewed safety questions have been identified.

(2)

Safety evaluations under the provisions of 10 CFR 50.59 shall be performed for changes that could actually impact(l) the configuration or operation of those parts of the plant that could have nuclear safety significance or (2) the results of implemented procedures that. have nuclear safety significance.

(3)

PNSRC shall perform these reviews if other safety evaluations identify any unreviewed safety questions, that are not resolved.

l f

g )

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6.5.3 TECHNICAL REVIEW.AND CONTROL ACTIVITIES 6.5.3

~ 1 Activities which affect nuclear safety shall be conducted as follows:

a ~

b.

Procedures required by Specification 6.8 and other procedures which affect plant nuclear safety, and changes thereto, shall be prepared, reviewed and approved.

Each such procedure or procedure change shall be reviewed by a qualified individual/group other than the individual/group which prepared the procedure or procedure

change, but who may be from the same organization as the individual/group which prepared the procedure or procedure change.

Procedures other than Administrative Procedures shall be approved by the appropriate Department Head as designated in writing by the Manager, D.

C.

Cook Plant.

The Manager, D.

C.

Cook Plant, shall approve Administrative Procedures, Security Plan implementing procedures and Radiological Emergency

Response

Plan implementing procedures.

Temporary changes to procedures which do not change the intent of the approved procedures shall be approved for implementation by two members of the plant staff, at least one of whom holds a Senior Operator license, and documented.

The temporary changes shall be approved by the original approval authority within 14 days of implementation.

For changes to procedures which may involve a change in intent of the approved procedures, the person authorized above to approve the procedure shall approve the change prior to implementation; Proposed changes or modifications to plant nuclear safety-related structures, systems and components shall be reviewed as designated by the Manager, D.

C.

Cook Plant.

Each such modification shall be reviewed by a qualified individual/group other than the individual/group which designed the modification, but who may be from the same organization as the individual/group which designed the modifications.

Proposed modifications to plant nuclear safety-related structures, systems and components shall be approved prior to implementation by the Manager, D.

C.

Cook Plant;

6.5.3 TECHNICAL REVIEW AND CONTROL ACTIVITIES (Continued)

C ~

Proposed tests and experiments which affect plant nuclear safety and are not addressed in the Final Safety Analysis Report or Technical Specifications shall be prepared,

reviewed, and approved.

Each such test or experiment shall be reviewed by a qualified individual/group other than the individual/group which prepared, the proposed test or experiment.

Proposed tests and experiments shall be approved before implementation by the Manager, D.

C.

Cook Plant; d.

Individuals responsible for reviews performed in accordance with Specification 6.5.3.1a.,

6.5.3.lb.,

and 6.5.3.1c.,

shall be members of the plant management staff previously designated by the Manager, D.

C, Cook Plant.

Each such review shall include a determination of whether or not additional, cross-disciplinary review is necessary.

If deemed necessary, such review shall be performed by qualified personnel of the appropriate discipline; e.

Each review shall include a determination of whether or not an unreviewed safety question is involved.

Pursuant to Section 50.59, 10 CFR, NRC approval of items involving unreviewed safety questions shall be obtained prior to the Manager, D.

C.

Cook Plant, approval for implementation; and The Plant Security Plan and Radiological Emergency

Response

Plan, and implementing procedures, shall be reviewed at least once per 12 months.

Recommended changes to the implementing procedures shall be approved by the Manager, D.

C.

Cook Plant.

Recommended changes to the Plans shall be reviewed pursuant to the requirements of Specifications 6.5.1.6 and 6.5.2.8 and approved by the Manager, D.

C. Cook Plant.

NRC approval shall be obtained as appropriate.

6.8 PROCEDURES AND PROGRAMS 6.8

~ 1 Written procedures shall be established, implemented, and maintained covering the activities referenced below:

6.8.2 a.

The applicable procedures recommended in Appendix A of Regulatory Guide 1.33,

November, 1972.

b.

Security Plan implementation.

Emergency Plan implementation.

d.

PROCESS CONTROL PROGRAM implementation.

e.

OFFSITE DOSE CALCULATION MANUAL implementation.

f.

Quality Assurance Program for effluent and environmental monitoring using the guidance in Regulatory Guide 1.21, Rev.

1, June 1974 and Regulatory Guide 4.1, Rev. 1,'pril 1975.

Each procedure and administrative policy of Specification 6.8.1 above, and changes theretoi including temporary changes, shall be reviewed prior to implementation as set forth in Specification 6.5 above.

>>g) ~ qf(o<<getty<<

p>>ufo)5/ 5 6.7 S~==

Y L?.".:, YICL'ZION 6.7.1 The followfng actions shall b

t:ken fn.hc even a Safety Lf.-,.ft fs violated:

a ~

C ~

The facflfty shall be placed fn at least HOT STANDBY within one hour ~

The Safety Limit violation shall be repor tcd to the Ccmfssfon and to the Chairman of thc NSGRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A Safety Limit Vfolatfon Report shall be prepared.

Thc rcport shall be rcvfewed by the PNSRC.

This repor t shall describe (1} applfcablc cfrcumstances preceding the vfolatfon, (2) effects of the violation upon facility components, systens or

'tructures, and {3) corrective action taken to prevent recurrence.

The Safety Limit Yfolatfon Rcport shall bc suhmfttcd to thc Coaanfssfon, the Chafrman of the NSNC and the Yfce President; Nuclear Engfneerfng wfth$n 14 davs of the violation.

\\

6.8 PROCES"RES 5.8.1 Mrftten procedures shall be established, implemented and main-tained covering the ac.ivfties referenced below:

The applfcabble procedures rcccmmendcd fn Appendfx "A" cf Regula-.ory G id 1.33,

November, 1972.

b.

Refu lirg opcratfcns.

c.

Surveillance an" tcs. ac.',vitics of safety related equipment.

C.

Securf.y Plan fmplemcnwticn.

e

~

-~e. g ncy Plan fmplemen ation.

f.

Fir! Pr otcc.ion Program frplcmentatfon.

g.

P."-.CC:-SS C":lTRCL PRQG?~ f imple...entaticn.

h.

OFFSETS

COSc, CALCJLATIGN NNOAL implementation.

gualfty Assurance Procram for ef,luent and environmental mcnit"r'..",9 us rg :h auidan."e in Regulatory Guide 1.21, R v, June

'i97-'.

nd R gulat-ry Guide 4.1, Rev.

1, April 1975.

3 h pr cc>urc and a~ nistrativc policy of 6.8,1 above

~ and t'<<erato, s'.".al]

>e rcv awe" by the PNSRC an" apcroved by t.".e Plan Manager prior to i;..p1eacntaticn an" reviewed periodically as sat

"rth in aCmlnistratfv<<oroccdur <<s.

C.

C.

CCQK - UN:7 1

6-13

~I<<

~ <> ~~<<n b ilv o 72

ADMZNISTRATZVE CONTROLS e.

Investigation of all violations of the Technical Spec'cations including the preoaration and forwarding of reports covering evaluation and recommendations to prevent recurrence to the Chairman of the NSDRC.

f.

Review of all REPORTABLE EVENTS.

g.

Review of facility operations to detect potential nuclear safety hazards.

h.

Performance of special reviews, invest'gations of analyses and reports thereon as requested by tne Chairman o

the NSDRC.

i.

Feview of the Plant Security Plan and implementing procedures

- and shall submit recommended changes to the Chairman of the NSDRC.

j.

Review of the Emergency Plan and implementing procedures and shall submit recommended changes to the Chairman of the NSDRC.

k. 'evie~ of every unplanned cnsite zelease of radioactive mater'al to the environs including the p eparation and forwarding of recorts covering evaluation and recommen-dations to prevent recurrence to tne NSDRC.

Review cf changes to

.he PRCCESS CONTROL PROGRAM, OFFSZTE DOSE CALCUL~~':CN MANUAL, and radwaste treatment system.

AUTHOR TY 6.5.1.7 The PNSRC shall:

'a ~

Pecommend to the Plant Manager wr'tten approval or disapproval of 'ems considered under 6. 5. 1.6(a) throuch (d) above.

b.

Render determinations in writing with regard to whe"her or not each item considered under 6.,5. 1.6(a) thrcugh (e) above constitutes an unreviewed safety question.

c Provide written notification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NSDRC of disagreemen between the PNSRC and the Plant Manager;

hcwever, the Plant Manacer shall have responsibility for resolution of such d'sagreements pursuant to 6.1.1 above.

D. C.

COOK " UNIT 2 6-7 Amendment No-73

PNSRC PROPOSED TECHNICAL SPECIFICATION CLARIFICATIONS 6.5.1.6 The PNSRC shall be responsible for:

e.

k.

"Investigation of all violations of Technical Specifications" does not include review of NRC inspection reports or QA/NSDRC audit reports.

Investigation does include violations of technical specifications identified in NRC inspections or NSDRC/QA audits.

"Review of the Plant Security Plan and implementing procedures... "

"Review of the Emergency Plan and implementing procedures..."

"Review of every unplanned onsite release of radioactive material to the environs including the preparation...of reports..."

"Review of changes to the PROCESS CONTROL

PROGRAM, OFFSITE DOSE CALCULATION MANUAL, and radwaste treatment system."

(4)

These reviews may be accomplished by a cognizant individual (non PNSRC member) who summarizes the review and findings to the PNSRC.

~

)

NUCLEAR SAFETY DESIGN REVIEW COMMITTEE ~NSDRC CHANGES IN RESPONSIBILITIES AND PRACTICES REVIEW SAFETY EVALUATIONS OF CHANGES TO ADMINISTRATIVE PROCEDURES ONLY REVIEW ONLY THOSE CHANGES TO PROCEDURES F

DESIGNS F

AND EXPERIMENTS WHICH NS&L OR PNSRC CONCLUDE THAT AN UNREVIEWED SAFETY QUESTION MAY EXIST (e.g.

TECHNICAL SPECIFICATION CHANGES)

- NSDRC WOULD NOT ROUTINELY PARTICIPATE DIRECTLY IN AUDITS (ONLY WHEN QA AUDIT FINDINGS OR THE TRENDS PROGRAM INDICATE SUCH PARTICIPATION ZS WARRANTED) -- TECH.

SPEC.

CLARIFICATION ELIMINATE REDUNDANT AUDITS REDUCE ADMINISTRATIVE BURDEN ON PLANT NSDRC WOULD NOT ROUTINELY REVIEW QA AUDITS (ONLY WHEN ADVERSE FINDINGS OR TRENDS PROGRAM INDICATE THAT CHANGE IN AUDIT SCOPE MAY BE NEEDED TO ASSURE EFFECTIVENESS OF THE QA PROGRAM OR THE AUDIT ITSELF.

I r

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ADMINISTRATIVECONTROLS QUORUM 6.5.2.6 A quorum, the minimum number of regular members and alternates required to hold a NSDRC meeting, shall be eight (8) members, of whom no more than two (2) shall be Designated or Temporary Alternates.

The Chairman or Acting Chairman"" shall be present for all NSDRC meetings.

If the number o: members present's greater than a quorum, then the majority participating and voting at the meeting shall not have line responsibility for operation of the facility.

RE'IIEW 6.5.2.

?

The NSDRC is zesponsible for assuring that independent"* reviews oz the following are performed:

a ~

The safety evaluations for 1) changes to procedures, equipment or systems and

2) tests or experiments completed under the provision of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question.

b.

Propcsed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in 10 CFR 50,59, C ~

Propcsed tests or experiments which involve an unrev'ewed safety cuest'cn as de ined in 10 CFR 50.59.

d.

Proposed charges to Technical Specifications or this Operating License.

e.

Violations of ccdes, regulations,

orders, Technical Specificat'ors, license requirements, or of internal procedures or instzuctions having nuclear safety significance.

F Significant operating abnormalities cr deviations b~ normal and expected per ormance of p'ant equipment that affect boucle'ar safety.

g.

A'1 REPORTABLE EVENTS.

h.

All recognized indicat'ons of an unanticipated deficiency in some aspect of design or operation of safety related structures,

systems, and components.

i.

Reports and meeting minutes o

the PNSRC.

• Regular NSDRC members are expected to attend the meeting whenever

possible, and alternates may attend as voting members only on an irregular basis.

1'f both a regular member and his alternate attend a meeting, only the regulaz member may participate as a voting member, and the alternate is considered a guest.

• • Independent reviews may be performed by groups which zeport dizectly to the NSDRC and which must have NSDRC membership participation.

D. C.

COOK - UNIT 2 6-10 Amendment No.

73

~

I ~

NSDRC PROPOSED TECHNICAL SPECIFICATION CHANGES 6.5.2.7 The NSDRC is responsible for assuring that independent reviews of the following are performed:

a.

The safety evaluations for changes to Plant

4

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~

~

~

~ ~

D.

C.

COOK TECHNICAL SPECIFICATIONS UPGRADE PROGRAM

- AEP PROGRAM INTERFACE WITH WOG INTERFACE WITH ANS FIRE PROTECTION PROGRAM

i i I'1 KX

~ ~

AEP I.

DICTIONARY VOCABULARY LIST COVERING TECHNICAL SPECIFICATIONS

- MAY BE EXPANDED TO INCLUDE PROCEDURES AND REGULATIONS WILL BE REVIEWED BY NSSS VENDOR FOR GENERIC APPLICABILITY DRAFT PLANNED TO BE SENT TO THE NRC BY JULY l, l986

II.

INTERPRETATION PROCESS PERFORM A 10 CFR 50.59-TYPE REVIEW OF THE TECHNICAL SPECIFICATION INTERPRETATION OBTAIN CONCURRENCE ON INTERPRETATION FROM PLANT NUCLEAR SAFETY REVIEW COMMITTEE

- ADVISE THE NRC RESIDENT INSPECTOR OF THE INTERPRETATION MAINTAINADMINISTRATIVERECORDS OF THE INTERPRETATION APPLY FOR A TECHNICAL SPECIFICATION CHANGE TO CLARIFY THE ISSUE AS SOON AS CONVENIENTLY POSSIBLE

III. INTERPRETATION DOCUMENT STILL IN CONCEPTUAL/DRAFTING STAGE WILL BE A CROSS-REFERENCE OF TECHNICAL SPECIFICATIONS, ORGANIZED BY SYSTEMS WILL INCLUDE REFERENCES TO THE FSAR FOR EACH TECHNICAL SPECIFICATION

I

)

I)

" I

~

~

~

WESTINGHOUSE OWNERS GROUP (WOG)

ACTIVE ON TECHNICAL SPECIFICATIONS SUBCOMMITTEE PARTICIPATED IN THE APPLICATION OF THE AIF SEPARATION CRITERIA TO THE STANDARD TECHNICAL SPECIFICATIONS AND WOLF CREEK'S TECHNICAL SPECIFICATIONS

- UNDER CONSIDERATION TO BE THE LEAD PLANT ZN THE WOG TECHNICAL SPECIFICATIONS UPGRADE PROGRAM

- AEP REPRESENTS THE WOG ON THE ANS STANDARD 58.4 WORKING GROUP

ANS 58.4 WORKING GROUP I-REVISING ANS STANDARD 58.4, CRITERIA FOR TECHNICAL SPECIFICATIONS FOR NUCLEAR POWER STATIONS UPDATING STANDARD TO INCLUDE THE AIF SEPARATION CRITERIA ADDING A WRITERS GUIDE TO THE STANDARD

NRC REGULARLY SCHEDULED MEETINGS WITH NRC STAFF TO DISCUSS PROPOSED TECHNICAL SPECIFICATION CHANGES NOVEMBER 1985 - WRONG TRAIN/WRONG UNIT DECEMBER 1985 RADIATION MONITORING

- JANUARY 1986 VENTILATION AND A VARIETY OF TOPICS APRIL 1986 - ADMINISTRATIVETECHNICAL SPECIFICATIONS DISCUSS TECHNICAL SPECIFICATION INTERPRETATIONS AND DECIDE IF CHANGES TO THE SPECIFICATIONS ARE NEEDED

- WEEKLY TELEPHONE CONFERENCES BETWEEN NRR, REGION III AND AEP

FIRE PROTECTION PROGRAM FIRE WATCH TECHNICAL SPECIFICATION INTERPRETATION WILL BE SUBMITTED SHORTLY

- APPENDIX R RELATED ACTIONS

- ALTERNATE SAFE SHUTDOWN TECHNICAL SPECIFICATIONS AND PROCEDURES COMPREHENSIVE FIRE PROTECTION DOCUMENT IS BEING DEVELOPED TO PROVIDE THE CAPABILITY OF PERFORMING OUR OWN INTERPRETATIONS OTHER APPENDIX R ISSUES WILL BE ACCOMPLISHED ADMINISTRATIVELY

- ULTIMATE GOAL IS REMOVAL OF FIRE PROTECTION TECHNICAL SPECIFICATIONS

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4 4

p

MEETING

SUMMARY

DISTRIBUTION

'1 3,MAY 1986 c

Docket F~i]e NRC PDR L PDR NSIC PRC System PWR84 Reading File Project Manager D.

Wi inton M. Duncan

Attorney, OELD J. Partlow E. Jordan B. Grimes ACRS (10)

NRC Partici ants 1 gglnton V. Benaroya L. Crocker S. Isreal B. Burgess A. Walker B. Jorgensen OTHERS bcc:

Licensee 8 Service List

E g S ';

4y),'g V

1 4

P E

C