ML17334B310

Requests Change to QA Program as Described in Updated FSAR to Allow Exception to Biennial Review of Plant Procedures. Justification Provided

ML17334B310
Person / Time
Site:	Cook
Issue date:	05/09/1989
From:	Alexich M INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
AEP:NRC:0847P, AEP:NRC:847P, NUDOCS 8905230120
Download: ML17334B310 (15)

Text

gc CEMRATED D1STKBUTION DEMONSTRA,T10.i SYSTEM REGULA'1Y INPORMATION DISTRIBUTIO+YSTEM (RIDE) 5't ACCESSION NBR':8905230120 DOC.DATE: 89/05/09 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 MURLEY,T.E.

Document Control Branch (Document Control Desk)

SUBJECT:

Requests change to QA program as described in updated FSAR to allow exception to biennial review of plant procedures.

DISTRIBUTION CODE:

Q004D COPIES RECEIVED:LTR I

ENCL I

SIZE:

TITLE: QA Topical Report, Amendment, or Correspondence (Docket/Utility NOTES:

Speci D

RECIPIENT ID CODE/NAME PD3-1 LA INTERNAL: IRM/DCB (AMDTS)

NUDO

STRACT rILE 01 EXTERNAL: LPDR COPIES LTTR ENCL 1

1 1

1 1

1 2

2 1

1 RECIPIENT ID CODE/NAME STANGIJ NRR/DLPQ/QAB 10 OC/LFMB RGN3 FILE NRC PDR COPIES LTTR ENCL 1

1 2

2 1

1 1

1 1

h NOIR 'IO ALL RIDS" RECIPIENIS:

PLEASE HELP US IO REDUCE HASTEl CXNIACZ 'IHE DOCUMENT CORBEL DESK ROC'l-37 (EXT. 20079)

%0 EZaIMZNAXS ACR MQKE HtN DIPIKGSOTXCH LTSTS PDR DOCUMEKCS VXJ DQH'T NEED!

r P S

h D

D S

TOTAL NUMBER OF COPIES REQUIRED; LTTR 12 ENCL '2

1 I

I a

P

Indiana iIIiichigan Power Company P.O. Box 16631 Coiumbus, OH 43216 Donald C.

Cook Nuclear Plant Units 1 and 2

Docket Nos.

50-315 and 50-316 License Nos.

DPR-58 and DPR-74 REQUEST FOR CHANGE IN QUALITY ASSURANCE PROGRAM 10 CFR 50.54 AND UPDATE FSAR BIENNIAL REVIEWS OF COOK NUCLEAR PLANT PROCEDURES AEP:NRC:0847P U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555 Attn:

T.

E. Murley May 9, 1989

Dear Dr. Murley:

This letter constitutes a request for change to the Quality Assurance Program as described in the Donald CD Cook Nuclear Plant Updated (July 1988) Final Safety Analysis Report (UFSAR),

Section 1.7, Appendix A, Item 5.

Currently the UFSAR, by reference to ANSI N18.7, and the plant implementing procedure PMI-2010, Revision 15, require biennial review of procedures.

We hereby request an exception to the biennial review of plant procedures based on the justification enclosed in Attachment 1.

Attachment 2 contains the proposed change to the FSAR.

We believe this change does not involve a reduction in commitment.

We will assume that this proposed change is acceptable 60 days from the date of this letter, unless informed otherwise, as provided by 10 CFR 50.54(a)(3)(iv).

PMI-2010 will be revised immediately following approval and the change will be incorporated into the UFSAR by our normal UFSAR submittal.

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.

Sincerely, M. P. Alexxch Vice President ldp Attachments

(

8905230120 890509 PDR ADOCK 05000315 P

PNU

Dr. T.

E. Murley AEP:NRC:0847P cc:

D. H. Williams, Jr.

W.

G. Smith, Jr.

- Bridgman R.

C. Callen G. Charnoff A. B. Davis NRC Resident Inspector

- Bridgman G.

Bruchmann

ATTACHMENT I TO AEP:NRC:0847P JUSTIFICATION OF PROPOSED CHANGES

Attachment 1 to AEP:NRC:0847P Page 1

JUSTIFICATION FOR CHANGE It is our belief that a dynamic process is necessary to maintain procedures in an accurate and useful condition.

The static biennial review process specified by ANSI N18.7 is not responsive enough to meet our needs.

Over the past years, we have effected programmatic controls to ensure that potential procedural impact is assessed and revisions occur upon receipt of changes in source documents.

Examples of these programmatic controls include the design change process, vendor manuals, Technical Specifications amendments, problem report and audit report preventive actions, and Corporate Engineering Specifications.

Although no system is infallible, our proposed alternative to the biennial review process is considered to be more timely and equally effective.

Further, since substantive changes to plant procedures are now being made on an as-needed

basis, the additional biennial review is redundant, has proven to be unnecessary and is a significant drain on plant resources without a commensurate improvement in plant safety.

~

n ATTACHMENT 2 TO AEP:NRC:0847P SUGGESTED FSAR WORDING

Attachment 2 to AEP:NRC:0847P Page 1

SUGGESTED FSAR WORDING N18.7, Section 5.2.15 Page 1.7.B-106 Re uirement "Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."

Exce tion Inter retation 1&M has programmatic control requirements in place that make the biennial review process redundant from a regulatory perspective.

These programmatic controls were effected in an effort to ensure that plant instructions and procedures are reviewed for possible revision when pertinent source material is revised, therefore maintaining the procedures current.

We believe that this approach better addresses the intent of the biennial review process and is more acceptable from both a technical and a practical perspective than a static two-year review process.

AC CELERATM 53hI MBU IJ UA DEMO.%STRA,TlO."i SY> TER ACC"SSION NBR FACIL:50-315 50-316 AUTH. NAME ALEXICH,M.P.

REC IP, NAME M4R

'k I

~ w

~

DOCKET 050003' 05000316 1-"-e RZGU'AyR'-

NROR.'-4-':ON DES RiS'-::OgS'-Si:N (R:DS)

8905230120 DOC.DATE: 89/05/09 NOTAR Z"D; NO Donald C.

Cook Nuc'ear Power Plant, Unit ', indiana Donald C.

Cook Vuc'ear Powe Plant, Unit 2, Indiana AUTHOR AFFILIATION Indiana Michigan Powe Co. (formerly ndiana

& Michigan RECIP EN A"FILIATION Oocume.".t Cont ol Branch (Docu~i:e"..t Cont o'esk)

SUBDAE

"; Re~" eats 0 a'low change to QA o ogre..i as escr 'eQ uDda" ed "SAR evcept'on "o 'oie.".nia'evi= '

oianc procedures, DIS 2:3i::ON CODE:

Q004D COPI:-S REC" i:-D:~:R I

ENCL I

Si QA =ooical Re@or~,

~we.".d.-:.-.-.t, or Correspond-nce (Dock NO':-S:

e c / v r, '

-', '1 SDe'ECIPIENT ID CODE/.'VWZ PD3-'A INTERNAL: IRM/DCB (AMDTS)

NUDO

TRACT G

LE 01 EXTERNAL: LPDR COPIES LTTR ENCL 1

1 1

1 1

2 2

1 1

RECIP 'NT

D CODE/NAME STANG,J NRR/DLPQ/QAB 10 OC/Lr MB RGN3 r ILE NRC PDR COPI-S LTTR ENCL 1

1 2

2 1

1 1

1 1

1 NOXK 'lo ALL 'RIDS" R!KZPIZNIS:

PURSE HELP US KO REKXKE HASTE!

CKM(RCZ 'IHE DXXlMEÃl CXKVRL DESK, IZBTS XQR DOCXlMEHXS RXJ DCSERT NEZDf TOTAL NUMBER QF COPIES REQUIRED:

LTTR 12 ENCL 12

Indiana 1Vlichigan Power Company P.O. 8ox >6631 Commbus. OH ~32]6 INDIANA NICHIGAN POWER Donald C.

Cook Nuclear Plant Units 1 and 2

bocket Nos.

50-315 and 50-316 License Nos.

DPR-58 and DPR-74 REQUEST FOR CHANGE IN QUALITY ASSURANCE PROGRAH 10 CFR 50.54 AND UPDATE FSAR BIENNIAL REVIEWS OF COOK NUCLEAR PLANT PROCEDURES AEP:NRC:0847P U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington, D.C.

20555 Attn:

T.

E. Hurley May 9, 1989

Dear Dr. Murley:

This letter constitutes a request for change to the Quality Assurance Program as described in the Donald C.

Cook Nuclear Plant Updated (July 1988) Final Safety Analysis Report (UFSAR),

Section 1.7, Appendix A, Item 5.

Currently the UFSAR, by reference to ANSI N18.7, and the plant implementing procedure PMI-2010, Revision 15, require biennial review of procedures.

We hereby request an exception to the biennial review of plant procedures based on the justification enclosed in Attachment l.

Attachment 2 contains the proposed change to the FSAR.

We believe this change does not involve a reduction in commitment.

We will assume that this proposed change is acceptable 60 days from the date of this letter, unless informed otherwise, as provided by 10 CFR 50.54(a)(3)(iv).

PMI-2010 will be revised immediately following approval and the change will be incorporated into the UFSAR by our normal UFSAR submittal.

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.

Sincerely, M. P. Ale ich Vice President ldp Attachments 8905230120 890509 PDR ADQCK 05000315 P

PNU

Dr. T.

E. Murley AEP:NRC:0847P cc.

D. H. Williams, Jr.

W.

G. Smith, Jr.

- Bridgman R.

C. Callen G. Charnoff A. B. Davis NRC Resident Inspector

- Bridgman G.

Bruchmann

ATTACHMENT I TO AEP:NRC:OS47P JUSTIFICATION OF PROPOSED CHANGES

Attachment 1 to AEP:NRC:0847P Page l JUSTIFICATION FOR CHANGE It is our belief that a dynamic process is necessary to maintain procedures in an accurate and useful condition.

The static biennial review process specified by ANSI N18.7 is not responsive enough to meet our needs.

Over the past years, we have effected programmatic controls to ensure that potential procedural impact is assessed and revisions occur upon receipt of changes in source documents.

Examples of these programmatic controls include the design change process, vendor manuals, Technical Specifications amendments, problem report and audit report preventive actions, and Corporate Engineering Specifications.

Although no system is infallible, our proposed alternative to the biennial review process is considered to be more timely and equally effective.

Further, since substantive changes to plant procedures are now being made on an as-needed

basis, the additional biennial review is redundant, has proven to be unnecessary and is a significant drain on plant resources without a commensurate improvement in plant safety.

ATTACHMENT 2 TO AEP:NRC:0847P SUGGESTED FSAR WORDlNG

Attachment 2 to AEP:NRC:0847P Page 1

SUGGESTED FSAR WORDING N18.7, Section 5.2.15 Page 1.7.B-106 "Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less frequently than every two years to determine if changes are necessary or desirable."

Exce tion Inter retation I&M has programmatic control requirements in place that make the biennial review process redundant from a regulatory perspective.

These programmatic controls were effected in an effort to ensure that plant instructions and procedures are reviewed for possible revision when pertinent source material is revised, therefore maintaining the procedures current.

We believe that this approach better addresses the intent of the biennial review process and is more acceptable from both a technical and a practical perspective than a static two-year review process.