ML17328A759

Requests Concurrence for Delay in Submittal of Adverse Findings to Allow Time for Investigation

ML17328A759
Person / Time
Site:	Cook
Issue date:	10/30/1990
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 9011060202
Download: ML17328A759 (4)

Text

ACCELERATED ISTRIBUTION DEMON RATION SYSTEM c~

REGULATORY XNFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9011060202 DOC.DATE: 90/10/30 NOTARIZED: NO DOCKET 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.

Indiana Michigan Power Co. (formerly Indiana

& Michigan Ele RECIP.NAME RECIPIENT AFFILIATION DAVIS,A.B.

Region 3 (Post 820201)

I

SUBJECT:

Requests concurrence for delay in submittal of adverse findings to allow time for investigation.

DISTR1BUTION CODE:

AOOID COPIES RECEIVED:LTR Q ENCL

~ SIZE:

TITLE: OR Submittal:

General Distribution NOTES D

RECIPIENT XD CODE/NAME PD3-1 LA COLBURN,T.

INTERNAL: NRR/DET/ECMB 9H NRR/DST 8E2 NRR/DST/SICB 7E NUDOCS-ABSTRACT OGC/HDS1 RES/DSXR/EIB EXTERNAL: NRC PDR COPIES LTTR ENCL RECIPXENT ID CODE/NAME PD3-1 PD NRR/DOEA/OTSBll NRR/DST/SELB 8D NRR/DST/SRXB 8E OC G FILE Ol NSIC COPIES LTTR ENCL 1

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NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM Pl-37 (EXT. 20079) TO ELIMINATEYOUR NAMEFROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

C TOTAL NUMBER OF COPIES REQUIRED:

LTTR 17 ENCL A

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Indiana Michig~

power Compa'~

P.O. Box 16631 Coiumbus, OH 43216 ml AEP:NRC:0847T Donald C. Cook Nuclear Plant Unit Nos. I and 2

Docket Nos.

50-315 and 50-316 License Nos.

DPR-58 and DPR-74 INTERPRETATION OF ANSI'45.2.12 1977 COMPLETION OF CORRECTIVE ACTION WITHIN 30 DAYS U.S. Nuclear Regulatory Commission, Region III 799 Roosevelt Road Glen Ellyn, IL 60137 Attention Mr. A. B. Davis October 30, 1990

Dear Mr. Davis:

Based on a discussion on October 17, 1990 with Mr. M. Phillips of your staff, Cook Nuclear Plant's interpretation of ANSI N45.2.12 1977 paragraph 4.5.1 is acceptable.

Specifically, paragraph 4.5.1, which addresses audited organizations, requires that responses to adverse findings "... clearly state the corrective action taken or planned to prevent recurrence.

In the event that corrective action cannot be completed within thirty days, the audited organization's response shall include a scheduled date for corrective action."

Our interpretation of paragraph 4.5.I for Cook Nuclear Plant concludes that certain circumstances warrant more than 30 days to completely investigate the cause and/or total impact of an adverse finding.

For those circumstances, an initial 30 day response would be provided which addresses a schedule for known corrective actions, the reason why additional investigation time is needed, and a schedule for completion of the investigation (which may result in additional scheduled corrective actions).

Once the investigation is completed, an updated response, which delineates all corrective/preventive actions (and the respective schedules, ifnecessary) would be provided.

90ii060202 90i030 PDR ADOCK 050003i5 PDC

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Mr. A. B. Davis AEP:NRC:0847T Though not a frequent occurrence, there are occassions in which certain adverse findings necessi tate extensive investigations to ensure that the full impact and scope of'he adverse findings are identified.

For these occassions, we have concluded that a complete and thorough investigation is more important than premature and incomplete corrective actions.

Though paragraph 4.5.l does not expli citly address the investigation portion of adverse findings, we believe that the above interpretation is consistent with the intent of paragraph 4.5.l in ensuring timely and complete corrective actions.

Your staff's written concurrence of the subject interpretation would be appreciated.

This document has been prepared following Corporate procedures that incorporate

-a reasonable set of controls to ensure its accuracy and completeness prior to signature by the undersigned.

Si ncerel y, M. P. Alexich Vice President MPA/nlh cc:

D. H. Williams, Jr.

T.

G. Colburn - NRC, Washington, DC NRC Resident Inspector Bri dgman