ML17334A952

Submits Formal Tech Spec Upgrade Program Based on Listed Activities,Including Meetings W/Nrc,Performance of 10CFR50.59 Type Review of Interpretation & Safety Significance & Generation of Draft Vocabulary List

ML17334A952
Person / Time
Site:	Cook
Issue date:	04/10/1986
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AEP:NRC:0983, AEP:NRC:983, NUDOCS 8604150296
Download: ML17334A952 (5)

Text

(;)",~', ggQBSSXOQ NBR; a~*~

AUTH. NAI'1E AI EXICHi N. P.

REC IP. NAI'lE DENTON> H. R.

SUBJECT:

860415Q25'~;

50-316 Donald C.

AUTHOR

m ssouLATosv xsvoswTxov ovsvszsunow"svsTsit Cook DOC. DATE:

AFFILIATION

'F86/04/10, Nuclear Power Planti Unit 2. Indiana Indiana 5 Nichigan Electric RECIPIENT AFFILIATION Co.

>os>

NO7'PRIZED:,NO '

8<

DOCj(ET~"+:,:

-~. weal~

0500031h OFFice of Nuc l ear Reactor Reg ul at i oni Direc tor (p ost 851125 Submits formal Tech Spec upgrade program based on listed cII activitiesi including meetings w/NRC. performance of 10CFR50. 59 type review of interpretation Rc safetg signiFicance 8c generation of draft vocabulary list.

DISTRIBUTION CODE: A001D COPIES RECEIUED: LTR l ENCL 0 SIZE:

TITLE: OR Submittal: Qeneral Distribution NOTES RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAI'IE LTTR ENCL ID CODE/NANE LTTR EHCL PNR-A ADTS PWR-A EB PNR-A EICSB PWR-A FOB PNR-A PD4 PD 01 NIQQINQTON> D PNR-A PSB PWR-A RSB INTERNAL: ADN/LFHB ELD/HDS3 NRR/ TSCB NRR/ORAS E 04 RQN3 EXTERNAL: 24X EQbQ BRUSKE> S I PDR 03 NRC PDR 02 NSIC 05 TOTAL NVi'1BER OF COPIES REQUIRED: LTTR 25 ENCL

4 4

4 J'

VCCFLtl'>ftt'I ~)IP'8: 9904)1;!Ol BDC Pwl.E: 'B)t'IGtl D)MOP 'l 4N))P

<<>> hLl 4

)tL'('4'l4'Al'4>>A"'8< C!<! ltt'I )ON Mr~J ll I ..Ill)0( :ti l ['ll" < V) 3'l>,"'.)

I4 > ..- 'A '4 ilk lNDlANA 8 N(CHlGAN ELECTRlC CONPANY P.O. BOX 16631 COLUMBUS, OHIO 43216 Apri1 10, 1986 AEP:NRC:0983 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. $ 0-315 and 50-316 License Nos. DPR-58 and DPR-74 TECHNICAL SPECIFICATION UPGRADE PROGRAM Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

Pursuant to discussions with your staff, we are submitting to you our formal Technical Specification (T/S) Upgrade Program. We have adopted this program because of the following:

1. There has recently been an increased emphasis on the T/Ss as a stand-alone document in enforcement-related activities.

2. The D. C. Cook Nuclear Plant was licensed with the early version of the Standard T/Ss. We therefore have been unable to obtain full benefit from later and more concise versions of this document.

3. A large administrative burden (both for our staff and for the Commission) has been created by T/S interpretations and a succession of emergency T/S changes necessary to allow "literal compliance."

The Cook Plant T/S Upgrade Program is based on the following activities:

1. Regularly scheduled meetings with your staff to discuss required T/S changes. At these meetings we will discuss the difficulties we are having in matching the literal words of a specific T/S with plant equipment and operability requirements. We have had two of these meetings since November 1985, and we find them a valuable tool in processing our various T/S submittals.

2. Performance of T/S interpretations by the following method:

8604150296 8604i0 Pb>

PDR ADOCK 05000315 PDR

I 0 t C

k ~ 43 r> ~

t

Mr. Harold R. Denton AEP:NRC:0983 a) Perform a 10 CFR 50.59 type review of the T/S interpretation to ascertain that it does not have any safety significance and meets the intent of the T/S.

b) Obtain concurrence by the Plant Nuclear Safety Review Committee (PNSRC) of a T/S interpretation and safety review.

c) Advise the NRC Resident Inspector of the T/S interpretation.

d) Maintain administrative records of the T/S interpretations and safety reviews.

e) Apply for a formal T/S change associated with a specific T/S interpretation. as soon as conveniently possible.

3. Generate a draft vocabulary list that would allow further clarification of the T/Ss and licensing documentation upon which they exist. We anticipate submitting a draft vocabulary list for your comments by July 1, 1986.

The T/S interpretation method will be implemented upon your approval.

This T/S interpretation method will be restricted to those areas in which literal compliance would cause deviations from the intent of the T/S. We will not interpret T/Ss so as to deviate from the plant licensing bases.

In addition to the above, it should be noted that we are a member of the Westinghouse Owners Group (WOG) effort to clarify and simplify the T/Ss. We will continue our WOG-related activities along with the activities discussed in this letter.

This document has been prepared following Corporate procedures which incorporate a reasonable set of controls to insure its accuracy and completeness prior to signature by the undersigned.

Very truly yours, M. P. 'A exich)~>~~g Vice President 4 cc: John E. Dolan W. G. Smith, Jr. - Bridgman R. C. Callen G. Bruchmann G. Charnoff NRC Resident Inspector - Bridgman