ML17328A758
| ML17328A758 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 10/30/1990 |
| From: | Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CAL, NUDOCS 9011060198 | |
| Download: ML17328A758 (8) | |
Text
ACCELERATED STRIBUTION DEMON RATION SYSTEM
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'I REGULATORY XNFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9011060198 DOC.DATE: 90/10/30 NOTARIZED: NO DOCKET. 4 FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Unit 1, Indiana 05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana 05000316 AUTH.NAME AUTHOR AFFILIATION ALEXICH,M.P.
(formerly Indiana
& Michigan Ele RECXP.NAME RECXPIENT AFFXLIATION MURLEY,T.E.
Document Control Branch (Document Control Desk)
I
SUBJECT:
Withdraws commitment in response to 850830 CAL re QA audits of Tech Spec surveillances
& LCO.
DISTRIBUTION CODE:
A001D COPIES RECEIVED:LTR ENCL SIZE:
TXTLE: OR Submittal:
General Distribution NOTES:
D RECXPIENT ID CODE/NAME PD3-1 LA COLBURN,T.
XNTERNAL: NRR/DET/ECMB 9H NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS 1 RES/DS IR/EIB EXTERNAL NRC PDR COPIES LTTR ENCL 1
1 2
2 1
1 1
1 1
1 1
1 1
0 1
1 RECIPIENT ID CODE/NAME PD3-1 PD NRR/DOEA/OTS B1 1 NRR/DST/SELB 8D NRR/DST/SRXB 8E OC/LFMB 01 NSIC COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
0 1
1 D
D S
C R
D S-NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE! CONTACI'HE DOCUMENT CONTROL DESK, ROOM P 1-37 (EXT. 20079) TO ELIMINATEYOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 17 ENCL 15 D
D
0 h
Indiana Michiiir~
Power Compar~
P.O. Box 16631 Columbus, OH 43216 AEP:NRC:0858D Donald C.
Cook Nuclear Plant Unit Nos. l and 2 Docket Nos. 50-3l5 and 50-3l6 License Nos.
DPR-58 and DPR-74 h'ithdrawal of Commitments Related to Quality Assurance Audits of Technical Specification Surveillances and Limiting Conditions for Operation U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C.
20555 Attention Dr. T. E. Murley October 30, 1990
Dear Dr. Murley:
This letter constitutes a wi thdrawal of commitmpnts identified in response to the Confirmatory Action Letter dhted November l7, l983 (AEP:NRC:0858) and the verbal commitment of Mr. M. P. Alexich, AEPSC, to Mr. C. E. Norelius in response to the Confirmatory Action Letter dated August 30, l985.
In response to the CAL dated November l7, l983, we submitted letter AEP:NRC:0858 dated January 29, l984 which details actions to be undertaken as part of the Regulatory Performance Improvement Program (RPIP).
AEP:NRC:0858 states that '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" and that "once per quarter a representative sample based on the total number of (LCO) events documented within the g.A. logbook... will be verified for adequate compliance to the action statement requirement(s) for the applicable power operational mode in which the event occurred."
Our documented understanding of a verbal commitment to the CAL dated August 30, l985 states that "...you (licensee] will expand, by October 3l, l985, your corporate g.A. audit program for surveillance testing as specified in your January 20, l984 letter (AEP:NRC:0858) to two surveillances per week on an ongoing basis."
90i10601.98 90i030 P
Dr. T. E. Murley AEP:NRC:0858D The above commitments are hereby withdrawn because of the sustained significant improvement related to Technical Specification surveillances and ICO compliance; and the significant QA manpower expenditure associated with these gA actions.
Attachment l to this letter describes the compliance history associated with the subject commitments and indicates the significant improvement made.
The elimination of the subject commitments will permit the 0A audit activities to be more responsive to real time performance-based initiatives and to have the flexibilityto respond to more significant plant performance indicators.
Thus, the audit activities would be providing more meaningful feedback on the effectiveness of the gA controls which are more deserving of management attention.
This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.
Si neer el y, M.. AI xich Vice President HPA/nlh Attachmen t cc w/attach:
D. H. Williams, Zr.
A. A. Blind - Bridgman R.
C. Callen G. Charnoff A. B. Davis Region III NRC Resi dent Inspector Bridgman NFEH Section Chief
ATTACHMENT 1 TO AEP:NRC:0858D COMPLIANCE HISTORY
Attachment No. 1 Page 1 of 2 MPLTAN EHI T RY T
hnical cifi i n rveillance Verific, i n Since the verbal commitment to the August 30, 1985 CAL, the Quality Assurance Department has reviewed 517 Technical Specification surveillance rcquiremcnts (as of June 30, 1990). Of the 517 requirements reviewed, 94 deficiencies were identified, Of the 94 identified deficiencies, two were determined to be reportable and these resulted in the generation and submittal of LER 315/85-072 and LER 315/85-072-01.
(Refer to Figure 1.)
Both LER's documented noncompliance with required surveillance intervals relative to seismic monitoring instrumentation.
Upon calibration, the as-found status of the subject instrumentation was determined to be within Technical Specification criteria and the surveillance intervals were subsequently revised.
These items are considered to be corrected and it is concluded that the health and safety of the public were not affected.
Further, the vast majority of the remaining 92 deficiencies are the direct result of conservative programmatic controls designed to assure Technical SpeciTication action statements are adequately addressed in procedures and to assure adequate tracking of surveillance intervals.
None are considered to have created a significant safety concern.
120 Technical Specification Status 100 --
108 106 104 104 80 ---'2 6o --.
40 ---
26 20-0 1986 1986 0
20 1987 1988 1989 10 1990 Total Minor Doltctoncloa Slgnlllcant Oollcloncloa Figure 1 Except for the conditions rcportcd via the two LER's, no safety signiTicant deficiencies have been identilicd.
'c Attachment No. 1 Page 2 of 2 L
m lin Vrifi in Compliance to LCO action statements, as verified by Quality Assurance Department audits, has been found to be highly effective. Audits for the 1985 through 1990 timeframe have reviewed 585 action statements (as ofJune 30, 1990). Of the 585 action statements reviewed, 27 deficiencies were identified.
Of the 27 identified deficiencies, one was determined to be reportable and resulted in the generation and submittal ofLER 316/86-02. (Refer to Figure 2.) This LER documented four instances of noncompliance with required surveillance intervals relative to estimation of condenser evacuation system flowat a frequency of once every four hours.
Since the maximum time the surveillance interval was exceeded was approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 18 minutes, and all flow rates recorded were within the expected range, it is concluded that the health and safety of the public were not affected.
Further, the remaining 26 deficiencies are the result of conservative programmatic controls designed to assure LCO compliance and are not considered to be of a significant nature.
LCO Status 160 140 120 --
100---
80 80 -
60 100 128 70 40 20.
2 0
4 o
3 0
3 0
10 0
1986 1986 1987 1988 1989 1990 Total Mtnot Oat tcfanctoo Stcntttcont Dottctanctao Figure 2
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