ML17326B102
| ML17326B102 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 01/20/1984 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML17326B101 | List: |
| References | |
| AEP:NRC:0858, AEP:NRC:858, CAL, NUDOCS 8402060373 | |
| Download: ML17326B102 (51) | |
Text
INDIANA8 MICHIGAN ELECTRIC COMPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 January 20, l984 AEP:NRC:0858 Donald C.
Cook Nuclear Plant Docket Nos.
50-315 and 50-316 License Nos.
DPR-58 and DPR-74 NRC Confirmatory Action Letter of November 17, 1983 Mr. James G. Keppler U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Keppler:
This letter and its attachment responds to your Confirmatory Action Letter dated November 17, 1983.
The actions contained in our response will be incorporated into our Regulatory Performance Improvement Program (RPIP) and tracked under the management system being established to ensure satisfactory completion of our RPIP.
Although the NSDRC Subcommittee Chairmen and various key members of the NSDRC have reviewed the information contained in this letter individually, the NSDRC has not yet reviewed the entire contents of this letter while meeting in concert.
The NSDRC will review this letter at its next scheduled meeting.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completion prior to signatur e by the undersigned.
Very truly yours, 1
M.
. Ale ch Vice Pre ident MPA/th cc:
John E. Dolan H. G. Smith, Jr. - Bridgman R. C. Callen G. Charnoff E.
R. Swanson, NRC Resident Inspector - Bridgman 8402060373 840202 PDR ADOCK 050003l5 8
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UCTIO The following is a description of the changes that will be made in AEPSC committee activities and programs to be implemented in response to the November 17, 1983 Confirmatory Action Letter.
The AEPSC Nuclear Safety Design Review Committee (NSDRC) and NSDRC Subcommittee charters and procedures have been or are currently being revised to ensure that all commitments and requirements will be met.
The revised charters and/or procedures will set forth in part:
-the responsibilities of each committee
-the committee membership
-how the committee will conduct their business
-that committee meeting minutes will be generated and that minority opinions will be documented in these minutes.
-that committee meeting minutes and reports will be distributed to all NSDRC members and alternates.
-the review and approval process for committee minutes and reports.
-committees membership training
-maintenance and management of committee records.
e The schedule for charter and procedure revision is as follows:
NSDRC Charter Revision 0 approved 1/10/84>>
NSDRC Procedures - approved 1/10/84 Subcommittee Charters - approved '1/10/84 Subcommittee Pr ocedures - 3/31/84 All historical reviews described herein, will be conducted utilizing the described upgr aded or new procedures.
<<NSDRC Charter has been incorporated into the NSDRC Procedures Manual.
Revision 8 of the old charter is now designated as Revision 0.
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"Plans and schedule for comprehensive, indepth audits of the conformance of facility operations to the Technical Specifications and applicable license conditions, The plans will include provisions for auditing each Technical Specification topic within each audit year and for auditing each Technical Specification line item within a specified period of time."
Effective January 1,
1984, the AEPSC QA Department, at the direction of the AEPSC Nuclear Safety and Design Review Committe (NSDRC), will initiate a program to audit faoility conformance to Technioal Specifications.
This program will be oomprised of two parts; (1) verification that Technical Specification surveillance requirements and license conditions are being met and (2) verification that Limiting Conditions for operation (LCO) are being met and that the Action Statement is complied with.
Appendix A1 hereto provides a
description of this program and a schedule for implementation.
For the surveillance verification portion, the program will audit each section of the Technical Specifications for each unit twice per year on a sampling basis.
Each audit will focus on a different surveillance requirement and its associated procedure(s).
The verification of compliance with LCOs will be accomplished by review of daily control room logs with the auditor noting any action statement entries.
Depending upon the number of aotion statement entries all or, a significant sample, will be audited for Action Statement compliance.
The NSDRC Audit Subcommittee will review and the NSDRC will approve the audit plans for this program.
The Subcommittee will
. review the resulting audit reports and will report those items deemed to have significant importance to plant safety to the full NSDRC.
The subcommittee will utilize this program for its audits focusing on areas that appear to have problems as determined by this program".
The AEPSC QA Department will develop a plan to ensure that applicable license conditions are audited either as part of the NSDRC or AEPSC QA audit programs.
A complete review of the Cook Plant licenses has been initiated by AEPSC QA to; (1) confirm the applicable license conditions, (2) determine whether these conditions are currently being audited and by whom, and (3) generate revisions to audit schedules to accommodate those conditions not currently being audited.
This effort will be completed by April 15, 1984 and the results communicated to the NRC by May 1, 1984 as an update to our R.P.I.P.
"Plans and schedule for auditing compliance with each aspect of all 18 criterion of Appendix B to 10CFR Part 50 at least every 24 months including both corporate and plant activities."
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asuum The Plant and AEPSC QA programs are audited on a 24 month cycle by the AEPSC QA Department.
The audit reports resulting from these audits are reviewed by the NSDRC Subcommittee on Audits and significant findings are reported to the full NSDRC.
The overall audit schedules for AEPSC QA Department audits will be reviewed and approved by the NSDRC.
Appendix A2 hereto are the 1984-85 audit schedules for the AEPSC QA Department.
Review of audit results provides the initial determination of (a) adequate
- scope, (b) adequate audit process, and (c) program effectiveness from which the NSDRC can identify those areas requiring audit, reaudit or other forms of followup action.
Those areas which appear to require most attention will be the sub)cot of the NSDRC 24 month audits.
Criteria examined by the NSDRC audits may vary and may not necessarily include all 18 Appendix B criteria on each audit.
- However, each of the 18 criter ia will have been reviewed for (a) (b) and (c) above by virtue of the AEPSC QA audit.program.
The evaluation of adequacy/effectiveness is a primary purpose of audit review by the
- NSDRC, and is considered prudent to take the results of the QA audits on Plant and Service Corporation activities into account when assessing both plant and corporate QA programs.
Furthermore, these QA audits are an ongoing activity as is the NSDRC review process.
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"Procedures for assuring that audit reports are issued within 30 days of audit completion, that audit reports include an evaluation regarding the effectiveness of the Quality Assurance Program elements
- audited, and that Corrective Action Requests are returned to the issuer with adequate
- response, as defined in ANSI N45.2. 12-1974, within 30 days of the issuance of the Corrective Action Requests."
All 1984 and subsequent NSDRC audits will be developed and administered by the AEPSC QA Department (QA) under the cognizance of the NSDRC and its Subcommittee on Audits.
The conduct of these audits will be governed by the revised Subcommittee procedures and existing QA and AEPSC General Procedures.
These require the completion nd issuance of audit reports within 30 days, the issuance of Corrective Action Requests (CAR) within 14 days of the post audit conference and the response to CARs within 30 days of issuance.
ln addition, the CAR response due date and the disposition due date of any commitments made in response to a CAR will be entered into and tracked by the computerized commitment list in accordance with existing procedures.
Furthermore, the Subcommittee Secretary is required to follow-up on the timeliness of each audit and to report regularly to the Subcommittee on the overall progress of the NSDRC audit program.
NSDRC audits will be conducted in accordance with QA procedures which require an evaluation regarding the effectiveness of the QA program elements audited in the broader aspect of safe plant operation, of which QA is an integral part.
The Subcommittee will ensure continued compliance regarding the "Effectiveness Statement".
NSDRC Audits of Facility Conformance to Technical Specification and License Condition Program and Schedule
DONALD C.
COOK NUCLEAR PLANT QUALITY ASSURANCE DEPARTMENT TITLE:
VERIFICATION OF COMPLXANCE TO TECHNICAL SPECIFICATXON RE-QUIREMENTS AND LIMXTING CONDITIONS FOR OPERATION (LCO's) 1.0 OBJECTIVE To provide, verification that surveillance requirements for Technical Specifications comply with Specifications 1.0 through 6.0.
2.0 BACKGROUND
2.1 2.2 2.3 2.4 Unit One Technical Specifications.
Unit Two Technical Specifications.
PMI-4030, Surveillance Testing.
QAP-19, Supplement No. 3.
3.0 DETAILS TECHNICAL SPECIFICATIONS 3.02 4.02 and 4.03 3.1.1 3.1.2 Technical Specification Surveillances will be verified with respect to compliance to frequency, test parameters and acceptance criteria.
A detailed review of the Unit One and Unit Two Technical Specifications has determined there is a
total number of 1,476 Technical Specification Surveillances.
A schedule (Attachment No.
1) has been developed to verify, in detail, a representative sample of the total number of Unit One and Unit Two Technical Specification Surveillances.
(1,476)
The schedule has been developed such that one sur-veillance is verified each week.
The Technical Specifica-tion Surveillance will be alternated by unit to allow for each verification in both Units One and Two.
The represen-tative sample size based on a two year cycle (104 weeks) was calculated as follows:
Surveillance Scheduled for Verification 104 0.0705
=7.05%
Total Number of Surveillances 1,476 3.1.3 The Compliance Verification Form, Attachment No. 2, will be used to document the verification process for Technical Spec-ification Surveillance.
This Compliance Verification Form will be filled out for each surveillance verified based on the schedule provided in Attachment No. 1.
3.1.4 The Compliance Verification Form provides identification of the surveillance based on Technical Specification Paragraph Number, Unit associated, frequency, and responsible depart-ment.
The form requires the review of the implementing pro-cedure for Technical Specification Paragraph, frequency, test parameters and acceptance criteria.
All of the above ele-ments are justified through additional comments if it is de-termined that, the adequacy within the procedure is "unaccept-able.
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3.1.5 The verification will examine the last four completed tests based on completion dates, condition reports (if applicable) and test results.
The time in days between the test com-pletion dates is determined and addressed against the limit of 25% extension time which is permitted by Technical Spec-ification 4.0.2.
This Technical Specification Surveillance compliance verif-ication process will involve each of the following depart-ments proportionally:
1.
Technical (Engineering/C&Z) 2.
Technical (Chemical/R.P.)
3.
Operations 4.
Maintenance 5.
Quality Control 3.1.7 This process will verify that adequate Technical Specifica-tion Surveillance compliance has been achieved in approved procedures and by Plant action for the representative sample of surveillances.
Following the in%.tial two year cycle, the next two year cycle will generate another schedule to verify Technical Specification Surveillances for'ach department still based on the sample size of 7.05% of the total and will verify different surveillances than those checked in the pre-vious two year cycle.
A master list will be kept. up to date of the 1476 Technical Specification Surveillances that have been schedule for verification.
3.2.1 An in depth review of the Daily Control Room Logs for both Unit One and Two will be conducted.
The auditor will docu-ment every log entry that indicates that entry was made into a "Technica3; Specification Action Statement" as set forth under a specific "Limiting Condition for Operation".
This documentation will be in a controlled Q. A. Log book with the following data for each entry:
1.
Unit affected 2.
Time of event.
3.
Date of event.
4.
Identification of the Technical Specification number and the specific action statement that was entered.
5.
Operational Mode Unit was in 3.2.2 The word "action" as defined by Technical Specifications, shall be those additional requirements specified as coro-llary statements to each principle specification which are part of the specifications.
The criteria for action state-ment compliance to the specifications is stated in Technical Specification 3.0.2.
D. C. Cook Nuclear Plant, Quality Assurance Dept.
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Once per quarter a representative sample based on the total number of events documented within the Q. A. Log book will be determined utilizing QAP-19, Supplement No.
3 for sample size.
3.2.4 The representative sample of events for the quarter will be verified for adequate compliance to the action statement requirement(s) for the applicable power operational mode in which the event occurred.
This review process will be doc-umented on Attachment No. 4, "Power Operation Under an Ac-tion Statement Requirement".
4.0 TECHNICAL SPECIFICATIONS 1.0, 2.0, 5.0, and 6.0 4.1 4.2 T/S 1.0 "Definitions" there are no auditable attributes in this section.
T/S 2.0 Will be covered by QA's review of procedures and the biennal departmental procedure reviews.
4.3 T/S 4.01 through 4.04 will be factored into the audit pro-grams described herein.
T/S 4.05 is audited under the current QA audit program.
4,4 4.5 T/S 5.0 Auditable attributes will be audited under the QA audit program.
T/A 6.0 With the exception of 6.5.2, all auditable attri-butes will be audited under the QA audit program.
Audits of 6.5.2 will be conducted under the cognizance of the NSDRC.
5.0 REPORTING/MANAGEMENT REVIEW 5.1 The completed verification forms will be signed by the aud-itor(s) performing the task(s) and approved by the AEPSC Q. A. Supervisor.
The AEPSC Q. A. Supervisor maintains the responsibility for assigning and assessing all corrective action pertaining to these reviews and the processing of completed review forms.
The completed forms will be sent to the Plant Manager for information or action, as approp-riate.
Copies of the"completed forms will be provided to The AEPSC Q. A. Manager, Chairman of Nuclear Safety and Design Review Subcommittee on Audits, Appropriate Assistant Plant Manager and Appropriate Plant Department Supervisor(s).
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24, 1984 1
TEAR:
1984 Septerrrrrer 3, 1984 10, 1984 17, 1984 OE)ARIREIIT Operation.
Perfonnance Operations C 4 1
SOIIIIEILLAIKE 4.5.1a2 4.6.1,3b 4.6.1.5.la and 4.1.2.3.1 4,6,4.2bl
~SR RO.
October 1,
1984 8,
1984 15, 1984 22) 1984 29, 1984 Hoverrrrer 5,
1984 12, 1984
!9, 1984 26, 1984 Oecember 3,
1984
!0, 1984
!7, 1984 24, 1984 31, 1984 1
2 1
2 Chemical Haintenanr.
Nuc)ear Operations Performance Operations C & I OperatiorIs Nuclear'nvironm ntal q.C.
Haintenance C & I Operations (T)4.3-9, (1)538 (Ch. CK.)
4.7.9.1.2cl 4.1.1,1,!d 4,5.4.1a 4.7.9.4bl 4.6.l.la2 (T)4.3-1, (1)022 (Ch. Fun.)
4.6.5.3.1a 4,1.1,4a (T)3.12-1, (1)WB 4.3.4.1.2d 4.7.9.2b2 (T)4.3-3, (l)klA (Ch, Fun. )
4.7, 1,3.2 and 4.1.2.5d KN:
!985 January 7, 1985 34, 3985 21, 3985 28, 1985 UHlT HO.
DEPARTHrHT Performance Operation; c a r
'/P SURVEILLANCE 4.5.2.el 4.8,2.3.1 (T)4.3-8, (r)i 1C Ch, Fun.)
T)4.3-9, (r)a2A Ch. Cal. )
SIR IN.
Febrra.ry 4,
1985 2
33, 3985 1
38,
!985 2
25, 1985 Operations Performance Haintenar.ce Nuclear 4.7.1,2a4 4.7.3.lb2 4.6.5 'a (T)4'-3, (r)EzH (3) (Ch. Cal.)
Harch 4,!985 11, !985 18, 1985 25, 3985 Operations Perforrlsarca Operai,ions Chemical-4.7.9.3a and 4,9.8 4.6.2.2d (T)4.3-1, (r)i32 (Ch. C'k,)
4.4.7
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hTTAN%N N4 i YM:
1985 October 7,
1985 14, 1985 21, 1985 28, 1985 IllllTN.
2 0EPNSEHT Performance Chemical Operations Chl SNVBL!AKE 4.8,1.}.2'.11.2.5 and 4.}.2.lan T)4.34 (1)$5 Ch, Ck.)
T)4.3-}O. (})iS Ch. CI(.)
November 4, 1985 1
11, 1985 2
}8) 19S5 1
25, l9S5 2
December 2, 1985 1
9, 1985 2
16, 1985 1
23, 1985 2
Nuclear Operations Naintenance Q.C.
CAI Operations C 4 I Operations 4.1.1.4.2b 4.8.1.1.2a4 (T)4.3-V, (1)a}3 (Ch. Cal,)
4,4.1O.1 (T)4.3-4, ( l)OAK (Ch. Fun.)
T)4.3-10, (l)f}
Ch. CR,)
i)4,3-S, (})e4 Ch. Cal.)
T)4.3-}Os (1)f4 (Ch.
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ATTN'T}IU i 20, }985 27, 1985 June 3, 1985 10, }9&5 }7) 1985 '4, 1985 Ju}y 1, 1985 8, 1985 15, 1985 22, 1985 29, }9&5 August 5, 1985 }2, 1985 2 1 }9, 1985 2 26, }9&5 September 2, 1985 2', }9&5 1 16, 1985 2 23, 1985 } 3O, 1985 2 YERR: 1888 UIIIY IN. Apri} 1, 1985 2 &, 1985 1 158 1985 2 22, 1985 29, 1985 Nay 68 1985 13, 1985 Perforeanz Operation: Ch 1 Perfortrance Haintenance Cl } Operations R/p Performance Q.C. CC} Operations Performance Ch} Operations Naintenance Performance Knvironrrrenta} Ch} Operaticns Perforrrence Operations Ch} Oper'ations Performance Maintenance Operations SURVEILIRRCE 4.5,292 T)4 3 }8 (l)1}4 Ch. 0(.) T)4.3-10, (})i9 (Ch. Cal.) 4.6.5.4c 4.7,7.1c 4.4.11.la (T)4 3-28 (l)8}K (Ch. Ci(.) 4.7.7.1.2a2 4.6.1.6 4.4.5.1 (T)4.3-1, (l)44 (Ch. Fun.) (T)4.3-2, (l)8383 (Ch. CR ) 4.6.2.1d (T)4.3-2, (l)Qc Ch, Fun.) T)4.3-6, (1)f4 Ch. Ci.) 4.8.2.3.2a2 and 4.9.6 1 4.6.5.1b2
- 4. }1.1.2 T)4.3-2, (l)838}
Ch, Fun.) (T)4.3-5, (1)I38 (Ch.'Ci.3 4.7.5.1cl (T)4.3-7, (})8}0 (Ch. CI(,) (T)4,3-2, (})a&A (Ch. Fun.) (T)4.3-6, (})k2 (Ch. CI(.) 4,7.6.1dl 4.8.2,5.2cl (T)4.3-8, ( 1)148 (Ch, C1(.) S/R IN.
ATTACHHENT NO, 1 TECHNICAL SPECIFICATION COHPLIANCE SURVEILLANCE SCHEDULE YEAR: 1994 January 2, 1984 9, 1984 16, 1984 23, 1984 30, 1984 February 6, 1984 13, 1984 20, l984 27) 1984 Harch 5, 1984
- 12) 1984 19, 1984 26, 1984 April 2,
1984 9, 1984 16, 1984 23, 1984 30% 1984 Hay 7 ) 1984 ia, 1984 21, 1984 28, 1984 June 4, 1984 il, 1984 18, 1984 25, l984 July 2, 1984 9, 1984 16, 1984 23, I984 30, k984 August 6, 198< 13, 1984 20, 1984 27, 1984 2 ~ 1 OE)ARTNENT Cherrrica1 Nuclear Operations Performance Operations C61 Operations R/P Nuclear Haintenance Perforrmnce Operations C 6 I Operations Performance Environmenta) Operations Performance Operations Haintenance C 6 I Operations Performance R/P Q.C. C,6 I Operations Performance C6I Haintenance Nuclear Environmenfal Performance Operations C 6 I SORVEILLANEE 4.1.2.8al 4.2.3.2b 4.1.1.l.lb 4,7.9,2c 4.1.1.3a 4.3.3.8.1 4.1.1.5b (T)4.3-3, (I)SIA (Ch, Cal.) 4.1.1.1.2 4.4.9.1.2 (T)4.3-7, (I)ei4 (Ch. Ck.) 4.1.3,1.1 (T)4'3-1, (l)aI3 (Ch. Cal.) and 4.4.9.3.1A 4.2.5 and 4.8.2,2 4.5.ld 4.11.2.4 4.2.l.lal 4,7,9.3bl 4.4.4.2 4.5.2.d2 ~ ~ T)4.3-9, (I}k3a Ch, Fun.) 4.3.4.1.2b 4,2.5.2 4.12.2 4.7.10a 4,4.11.1b 4.5.2bl and 4.4.9.3.1C (T)4.3-2, ( I}lib (Ch. Cal. } 4.4'. lc 4,6.4,2b2 4.2,3,1b 4.11.3,lb 4.4.11.3 4.4.11.2 4.5.2cl ~SR IIO. '"r t
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Q,A. Surveillance No.: "" Safe., of ~ I l ATTACHMENT NO. 2 AEPSC Q,A. DEPARTMENT TECHNICAL SPECIF IGATION Com liance Verification Form [7 Unit One Tech. Spec. Paragraph No.: Required Frequency: Test Parameters: Unit Two'mendment No.: Acceptance Criteria: Responsible Department: Implementing Procedure No.: Rev. No.: Review the procedure and verify that the following elements are adequately addressed: Tech. Spec. Paragraph: Frequency: Test Parameters: Acceptance Criteria: Acceptable Acceptable Acceptable Acceptable Q Unacceptabl e Unacceptab1 e Unacceptable Unacceptable Justify all elements which were rated as unacceptable: Q Attached Page Review the last four (4) completed tests and provide the following information (list test dates from most current to oldest): Test Com letion Date Test Results Condition Re ort 2. 3. 4. Acceptable Acceptable Acceptable Acceptable Unacceptable Unacceptable Q Unacceptable Unacceptable C/R ¹: C/R ¹: C/R ¹: C/R ¹: Enter the Condition Report number which was generated for each unacceptable test. If any Condition Report was not classified as a reportable occurence, justify below:
...,.,g;-~4. Surveillance No.~ page'f ATTACHMENT NO. 2 Utilizing the required test frequency and the four (4) test completion dates previously
- obtained, complete the following:
Requ(red Test Frequency ((n days) x 25K ~ days. D(fference $ n Time (days) tn Excess of the Test Frequency: Between Test No., 1 and No. 2: days. Between Test No. 2 and No. 3: days. Between Test No. 3 and No. 4: days. Add the Total Time (days) Between Test: days. Compare each of the above figures to the number identified in the box. If any figure exceeds the number identified in the box, determine if the responsible department has previously written a Condition Report. If one has not been written, generate one. Condition Report Required If required: Condition Report Number: Not Required General Coments: Performed By: Approved By: Date: Date:
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ATTACHMENT NO. 4 POWER OPERATION UNDER AN ACTION STATEMENT REQUIREMENT UNIT NUMBER: EVENT TIME: EVENT DATE: OPERATIONAL HOOE AT TIME OF EVENT: TECHNICAL SPECIFICATiON NO.: ACTION STATEMENT ENTERED: PLANT ACTION TAKEN: ADDITIONAL PAGES Q DATE AND TIME FULL COMPLIANCE WITH ACTION STATEMENT WAS ACHIEVED: CONDITION REPORT/LER NUMBER(S) ASSOCIATED WITH EVENT: C/R: LER: HRS REVIEWERS COMMENTS: REVIEWED BY: APPROVED BY: EPSC Q.A. SUPERVISOR ADDITIONAL PAGES Q DATE: DATE:
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AEPSC QA Department Audit Schedules 1984-85
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~ y <picA< E'a.Bc' AMERICAN ELECTRIC POWER SERVICE CORPORATION ~ Q gD ER 5Y5<5 oATE: December 21, 1983 QA-12-83-C01756 AEPSC QA INTERNAL AUDIT PROGRAM SCHEDULE 1984/85 FROM: TO: M.F. Scaramellino W~i~/i/~~ Attached is the AEPSC Quality Assurance Master Internal Audit Schedule for 1984/85. The schedule is designed to perform the audit required by Criterion 18 of
- 10CFR50, Appendix B.
Each applicable Criterion of 10CFR50, Appendix B will be audited at least once over the two year audit cycle. It is to be understood that some audits will be cancelled during the imple-mentation of this audit schedule as the Criterion scheduled for audit may not be applicable to the Auditee. ~ Cancellation of a scheduled audit will be based upon a review by the AEPSC QA Department which verifies that the Criterion is, in fact, not applicable to the Auditee. Please contact me should you have any questions regarding this audit schedule. M.F. Scaramellino Internal Audit Coordinator INTRA-SYSTEM
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III I P Attachment No. 1 C01756 12/21/83 Page 2 of 2 AEPSC UALITY ASSURANCE MASTER INTERNAL AUDIT SCHEDULE 1984/85 (AEPSC CORPORATE OFFICES) AEPSC Division/Section Criteria 1 & 2 1984 Criteria 3&8 Criteria 4&7 Criteria 5,6, 17 1985 Criteria 9-15 Criteria 16 & 18 Design Division -Architectural/Structural -Electrical Plant 'Mechanical -Control. Services April July'ct. April July Oct. Mechanical Engineering Div. -Steam Gen. -HVAC/Fire Protection -Chemical -Heaters & Pumps -Instrument & Control -Piping & Valves -Turbine -Metallurgy -R & D/Analytical May Aug. Nov. May Aug. Nov. Electrical Engineering Div. -Electrical Gen. Nuclear Engineering Div. -NM & FM -NS & L -Nuclear Operations -Rad. Support June Sept. Dec. June Sept. Dec. Civil Engineering Div. -Structural Engineering -Civil Engineering Lab. Materials Handling Div. Puxchasing Division -AEPSC -I & MECo. PSC+ect'
- Manager, Audits
& Procurements c,~~ ~~ g> z/ gg AEPSC Manager o Quality Assurance ) AE SC - NSDRC
~g ~ p <gal % gg< lQERlciM RLEcTR1c PN'tR QRYicE'cORPoRATION AEQ +%a e~s~~+ Oecember 23, )983 -jlaacT~ )985>'85 Audit Schedule T.p. BeHman
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i /*z)pg 8ased upon the number of Plant Nanaoer fas5~c'talons present)y unde~ revision and those scheduled for tev sioa %ring l984, frequent changes wH1 be necessary to the audit schedv)e. It is requested that 5 be given the flexSi~~ty to rf.uisf. the audit schedUle as needed so that se can be ", espms~ce to these PNf changes. Any changes that 1 make e)u)d result ~n a revised schedule Sich cou)d be traosmitted e you saith my justif-:cation.ar the change. Please advise if this fs an acceptable. ay~aa;-b. cc: File
~ e' a e P 1984/85 AUDIT SCHEDULE Re1riewed BY: Approved By : NSDRC: +Ps Dats z Oat< MONTH AUOIT SUBJECT AUOITOR AUOIT NO. January February March Apri 1 May June July August September October November Oecember PMI-4060 PMI-2271 PMI-2260 PMI-3120 PMI-4050 PMI-5040 PMI-7080 PMI-5060 PMI-2010 PMI-2270 PMI-6030 PMI -5031 PMI-4030 PMI-5020 Canonic NRC Commitments PM I -2110 PMI-2220 L.K. Comstock PMI-7030 PMI-2140 PMI-'1030 PMI-2130 PMI-5080 PMI-3010/7040 PMI-2070 PMI-2100 Power S stems, Inc. PMI-2290 PMI -2080, NRC Commitments PMI-2272 PMI-5050 Pace 1 of 2
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1935 MONTH January February March April May June July August September October AUDIT SUBJECT PMI-6040 PHI-2090 PHI'-1010 Da co PHI-2030 PMI-7070 PHI -1040 PMI-2160 PMI-2210 PMI-4030 PMI-2060 PMI-5075 NRC Commitments PMI-3130 PMI-6020 Manta'MI-2040 PMI-4020 PMI-2275 PHI-5090 PMI-3150 PMI-5070 PMI-6010 PMI-4040 PMI-5100 PMI-5045 PMI-2310 I.C.M.S. PMI-5030 AUDITOR Reviewed By: Approved By: NSDRC: AUDIT NO. ~Z Dat f>0 t November NRC Commitments December Page 2 of 2
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"Plans, schedule and pr ocedures for reviews of the NSDRC audit program. The reviews will be for status and adequacy of the audit program and the initial reviews will include the past audit program to determine appropriate remedial actions>>. The charter for the Subcommittee on Audits has been extensively revised to define expanded responsibilities and contains the following significant features: -NSDRC Audits of facility and committee activities to be performed by the AEPSC QA Division under the cognizance of the NSDRC. -Audit teams will be comprised of a fully qualified Lead Aud1tor and usually include a regular or alternative member of the NSDRC as Audit Team Leader. -The requirements for independent reviews of NSDRC Audit Reports, the QA Program and QA Audit Reports. The procedures for the Subcommittee on Aud1ts have been completely rewritten to strengthen the NSDRC audit program and to formalize the Subcommittee's expanded review functions and to institute reporting of audit findings and results of independent reviews to the NSDRC. Significant.features of the new procedures are as follows: -Definition of the interface and delineation of the responsibilities for the conduct of NSDRC Audits between the AEPSC QA Department and the Subcommittee. -Detailed methods for the review and analysis of each NSDRC audit report for scope and depth of audits,, and for the rev1ew of NSDRC audit reports for trends detrimental to quality and implications of findings to establ1sh the status and adequacy of the NSDRC Audit Program. -Detailed instructions for the independent review each six months, of the QA,audit program and of QA audit reports for significant findings 1n order to ensure adequacy and status of the QA Audit Program. Described below are some of the new review functions and the dates when instituted: -Since January 1982, audit team leaders have been suppl1ed, for their review, with past audits covering their assigned audit subjects. In many instances, the1r audit plans covered items of apparent weaknesses in previous audits. -Since January
- 1983, NSDRC audit reports have been rev1ewed by the members of the NSDRC.
-Since June
- 1982, AEPSC QA audit reports have been reviewed by the Subcommittee for trends and the effectiveness of the QA program.
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~ I The Subcommi as now identified all NSDRC reports for the last three (3) audit cycles which have not been sub)ected to all'of the above descr ibed reviews. As a remedial action, the Audit Subcommittee will conduct reviews for status and adequacy of these reports. These remedial reviews, carried out in accordance with detailed review methods contained in the new Subcommittee Procedures, will be completed by June 30, 1984. The reason for limiting the remedial review to the past three (3) audit cycles is that any deficiencies would have reoccurred dur ing this period and would have been identified during subsequent audits on the same sub)cot during the three (3) cycles.
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B.2 "Plans, schedule and approved procedures to assure NSDRC review of safety evaluations for (a) changes to procedures, equipment, or systems and (b) tests or experiments completed under the provisions of 10 CFR 50.59 to verify that such actions did not constitute an unreviewed safety question. The plans and schedule will include a historical review of previously completed safety evaluations to assure conditions do not exist which constitute an unreviewed safety question." a e Between January 1, 1984 and March 1,
- 1984, the PNSRC will identify those plant procedures deemed to be safety related based upon cr iteria provided by the NSDRC.
Commencing March 1, 1984 the NSDRC Subcommittee on Proposed Changes will review the Plant Nuclear Safety Review Committee's (PNSRC) Safety Review for changes to Cook Plant procedures deemed to have significant importance to plant nuclear safety, including those identified in the interim period. Commencing January 1,
- 1984, the PNSRC Safety Reviews for changes to Abnormal and Emergency Operating procedures will be reviewed by the subcommittee.
To date, there have been no safety reviews made for changes to AEPSC General Procedures. The AEPSC Nuclear Safety and Licensing Section (NS&L) will determine, by March 1, 1984 which General procedures are deemed important to plant nuclear safety and commence performing safety reviews on all subsequent changes to these procedures.. The Subcommittee will review NS&L's safety reviews on a routine basis. The PNSRC will select a statistically representative random sample from each plant department, of changes that have been made to plant procedures deemed to have significant importance to plant nuclear safety, and will submit the procedure/changes along with the associated safety reviews to the Subcommittee by March 30, 1984. The Subcommittee will review these safety reviews under the new Subcommittee procedures by December 31,
- 1984, and report to the NSDRC.
The AEPSC Nuclear Safety and Licensing Section will perform a safety review on existing General Procedures deemed important to plant nuclear safety by September 1,
- 1984, and will report their findings to the NSDRC.
b. Changes to either Requests (PMs) since the of the NSDRC in there have been were classified equipment or systems have been made under for Changes (RFCs) or Plant Modifications initial licensing of Unit 1 and the inception 1975. From 1975 through November 30, 1983 a total of 1492 RFC's approved, of which 597 as safety related or safety interface and
there have been 85 PMs routed to AEPSC since the inception of the Plant Modification portion of the AEPSC Design Change Program. The Subcommittee on Proposed Changes has reviewed 515 safety related or safety interface RFCs and 4 PMs as of November 30, 1983. Currently copies of all approved
- RFCs, and PMs that have been submitted to AEPSC, are being routed to the Subcommittee for review.
The Subcommittee on Proposed Changes will select and review a statistical, random sample of 80 existing safety related/safety interface RFCs and 13 PMs. This review will be completed by December 31,
- 1984, and findings reported to the NSDRC.
C ~ Annual plant operating reports and PNSRC meeting minutes will be examined under the direction of the Subcommittee on Proposed
- Changes, to identify any non-routine tests or experiments that have been performed on systems deemed as safety-related.
Such tests and experiments will be reviewed to" assure that no unreviewed safety questions existed as defined in 10CFR50.59. The Subcommittee will complete their review of any such tests or experiments by December 31, 1984. The PNSRC procedures will be revised by February 15, 1984 to require that the safety reviews for all proposed, non-routine tests or experiments on systems deemed as safety-related, be submitted to the NSDRC Subcommittee on Proposed Changes for prior review and subsequent NSDRC approval. d. adeem"Q. The revision to the Subcommittee on Proposed Changes Charter and Procedures will ensure that the requir ed reviews are conducted by delineation of the methods by which the Subcommittee will review the safety evaluation for changes to procedures, equipment, or systems and tests or experiments completed under the provision of 10CFR50.59. In the case of the above outlined "historical" reviews, the samples will be deemed representative of past
- PNSRC, NSAL, Subcommittee activities. It will be further deemed that past practices and activities were effective in precluding the generation of an unreviewed safety question provided the historical reviews do not identify any significant safety concerns.
~ 't i ~ B3. "Plans, schedule and procedures for NSDRC review of violations of codes, regulations,
- orders, Technical Specifications, license requirements, or internal procedures or.
instructions having nuclear safety significance. The plans and schedule will include a historioal review to assure that conditions adverse to quality do not exist." aO The Subcommittee on Corporate and Plant Occurences, has
- been, and currently is reviewing Licensee Event Reports for adequacy of corrective action.
Commencing April 1,
- 1984, the NSDRC Subcommittee on Corporate and Plant Occurrences will expand it's review to include evaluating all violations of
" codes, regulations,
- orders, Technical Specifications, license requirements or internal procedures or instructions.
Such violations are documented in Licensee Event Report, Cook Plant Condition Reports, AEPSC Noncompliance
- Reports, NRC Inspection Reports, and 10CFR21 Data Packages.
These reviews and evaluation will determine whether significant safety problems exist or are developing and whether the corrective actions taken were adequate. B.4 To ensure that conditions adverse to safety have not gone undetected, a histor ical review of Condition Reports, ,Noncompliance
- Reports, IE Inspection Reports and 10CFR21 data packages will be performed utilizing the new Subcommittee procedures.',
To date there have been'pproximately 5146 Condition Reports, 62 Noncompliance
- Reports, 280 IE Inspection Reports and 44 10CFR21 Data Packages generated.
A statistical, random sample of 591 Condition Reports and 32 NRC Inspection reports will be reviewed. All of the AEPSC Noncompliance Reports and 10CFR21 Data packages will be reviewed. There reviews will be completed by April 1,
- 1985, and findings repor ted to the NSDRC.
"Plans, schedule and procedures for NSDRC review of the minutes of PNSRC meetings. The plans and schedule will include a historical review to assure conditions adverse to quality do not exist." I Starting with the minutes of Plant Nuclear Safety Review Committee (PNSRC)
- November, 1983 meeting number 1450, the Subcommittee on Corporate and Plant Occurrences will review the minutes of each PNSRC meeting to ensure that conditions adverse to safety were adequately controlled.
1't A histovical review of PNSRC meeting minutes will be performed on a statistical random sample. of 125 meeting minutes prior to meeting number 1450. This review will be completed by December 31,
- 1984, and findings reported to the NSDRC.
C'a.e t
The procedures for the Subcommittee on Corporate and Plant Occurrences are being developed to ensure that all requirements are fully implemented and that Subcommittee members are trained in the procedural requirements so as to be able to perform adequately the required reviews and evaluations. The procedures will include criteria and checklists to ensure uniformi,ty of reviews as well as a means for documentation of review findings. The procedures for the historical reviews will include criteria specifying corrective actions to be taken should significant safety or quality concerns be found to exist. The statistical random samples will be deemed as representative of the effectiveness of past practices and activities in precluding the generation of significant safety or quality concerns provided the historical reviews do not identify any such concer'ns.
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C. 1 ~ "Design control procedures implementing the design verification requirements specified in ANSI N45.2.11-1974. The procedures will be part of the normal design control practice implemented by each engineering group performing design activities associated with the D. C. Cook Nuclear Plant." AEPSC is revising its Corporate level procedure (general Procedure No. 25 Rev.
- 1) to more fully implement the design verification requirements on ANSI N.45.2.11-1974.
These requirements are set forth in our top tier General Procedure No. 3.0. In oertain cases, it will be necessary to supplement General Procedure No. 25 with lower tier organizational specific procedures. The following is our schedule for implementation of the ANSI N.45.2.11-1974 Design Verification requirements. 25. This preliminary revision is to be used to perform design verification in the interim period until the formal procedure revision is issued. e - Hold meeting to review comments and finalize revision to General Procedure No. 25. - Issue revision to General Procedure No. 25. M - Issue all organizational specific new procedures or procedure revisions. 2 ~ "Plans and schedule for review of all past design activities performed in con)unction with the D. C. Cook Nuclear Plant for which required design verification was not per formed and documented." a 0 Although, according to the established QA programs for AEPSC and Cook Plant, the design verification requirements of ANSI N.45.2. 11-1974 apply only to those design activities defined as safety-related, we have decided to expand our design verification review program to also include design changes classified as safety interface because of the possible safety implicati'ons. AEPSC will select a random, statistical sample of 50 safety-related/safety interface engineering design change RFCs (Request for Change) from the approximately 400 such changes approved since 1977. Even though these changes were implemented using the design verification methods in place at the time in General Procedure No. 25, and in the various organizational specific procedures or accepted practices, a special team will be established to oversee the review of this random sample of RFCs under the design verification criterion as set forth in AEPSC General Procedure No. 3.0 and as implemented by the above discussed revision to General Procedure No. 25.
Ci>( J F
The purpose of this review is to process these RFCs through the upgraded design verification requirements to determine if there are any significant deficiences or deviations. Any significant deficiences or discrepancies will be corrected. Further reviews beyond the selected sample will depend upon the review team findings. The definition of what are significant findings and the criteria or making the decision for further reviews will be set forth in the review team procedures. This review will commence during the week of June 4, 1984 and continue until completed. The review team will submit monthly reports to the NSDRC Subcommittee on Proposed Changes and the Chairman, AEPSC Change Control Board. b. With respect to the design activities associated with the original design of the Cook Plant, AEPSC has initiated an effort to develop a description of the practices that were inplace during that time frame. The objective of this effort is to demonstrate that these practices were at least as effective as a documented design verification, in ensuring that the design was adequate. We will look at some of the original design activities in the electr ical, mechanical and structural area using the updated General Procedure No. 25 design verification requirements to verify that the past design practices were adequate. The description along with a schedule for completion of the aforementioned verification activities will be forwarded to the NRC by May 1, 1984 as an update to our R.P.I.P.
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February 1, 1984 I D TRIBUTION ORB81 Rdg CParrish DOCKET NO(S). 5O-315/316 Nr.. John Dolan, Vice President Indiana anddHichigan Electric Company c/o American Electr ic Po>e'er Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43215
SUBJECT:
DONALD C. COOK NUCLHAR PLANT UNITS 1 AND 2 The following documents concerning our review of the subject facilityare transmitted for your information. Notice of Receipt of Application. Draft/Final Environmental Statement, dated Notice of Availabilityof Draft/Final Environmental Statement, dated Safety Evaluation Report, or Supplement No. , dated Notice of Hearing on Application for Construction Permit. Notice of Consideration of Issuance of Facility Operating License. Application and Safety Analysis Report, Volume Amendment No. to ApplicationISAR dated LJ Construction Permit No. CPPR- , Amendment No. , dated Facility Operating License No. , Amendment No. , dated Order Extending Construction Completion Date, dated 'I K Other(Specify) Monthly Notice coverin eriod throu h Januar 26 1984. Expiration date for hearing requests and comments Februar 27 1984. Division of Licensina, Office of Nuclear Reactol'egulation"
Enclosures:
As stated cc w/enclosures OFF/CEI1 SURNAME) DATEP ORNA.; P.L. CParrish;p ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ NRC FORM 318 {10/80) NRCM 0240 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ OFFICIAL RECORD COPY
Indiana and Michigan Electric Company Donald C. Cook Nuclear Plant, Units 1 and 2 CC: Mr. M. P. Alexich Vice President Nuclear Engineering American Electric Power Service Corporation 1 Riverside Plaza
- Columbus, Ohio 43215 Mr. William R.
Rustem (2) Office of the Governor Room 1 - Capitol Building Lansing, Michigan 48913 Mr. Wade Schuler, Supervisor Lake Township
- Baroda, Michigan 49101 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 Honorable Jim Catania, Mayor City of Bridgman, Michigan 49106 U.S. Environmental Protection Agency Region V Office ATTN: E IS COORDINATOR 230 South Dearborn Street
- Chicago, IL 60604 Maurice S. Reizen, M.D.
Director Department of Public Health Post Office Box 30035 Lansing, Michigan 48109 The Honorable Tom Corcoran United States House of Representatives Washington, DC 20515 James G. Keppler Regional Administrator - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137}}