ML17334B589

Application for Amends to Licenses DPR-58 & DPR-74,removing TSs Certain Requirements for Administrative Controls,Related to QA Requirements,Per Administrative Ltr 96-05

ML17334B589
Person / Time
Site:	Cook
Issue date:	06/11/1996
From:	Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17333A466	List: ML17333A465 ML17334B589
References
AEP:NRC:80027, AL-96-05, AL-96-5, NUDOCS 9606180596
Download: ML17334B589 (12)

Text

REGULATO INFORMATION DISTRIBUTION 'YSTEM (RIDS)

ACCESSION NBR:9606180596 DOC.DATE: 96/06/11 NOTARIZED: YES DOCKET I FACIL:50-315 Donald C. Cook Nuclear Paw~'Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant,'nit 2, Indiana M 05000316 AUTH. NAME AUTHOR AFFILIATION FITZPATRICK,E. American Electric Power Co., Inc.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

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SUBJECT:

Application for amends to Licenses DPR-58 6 DPR-74,removing TSs certain requirements for administrative controls, related to QA requirements,per Administrative Ltr 96-05.

DISTRIBUTION CODE: A001D COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR Submittal: General Distribution NOTES:

RECIPIENT COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 HICKMAN,J 1 1 INTER F CENSE 01 1 1 NRR/DE/EMCB 1 1 NRR/DRCH/HICB 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC 1 1 NRC PDR 1 1 NOTE TO ALL "RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK, ROOM OWFN SD-5(EXT. 415"2083) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 11

American Electric 1 Riverside Plaza P~

Columbus, OH 43215 2373 614 223 1000 AEP:NRC:80027 June j.l( 1996 Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

Donald C. Cook Nuclear Plant Units 1 and 2 LICENSE AMENDMENT REQUEST FOR THE RELOCATION OF TECHNICAL SPECIFICATION ADMINISTRATIVE CONTROLS RELATED TO QUALITY ASSURANCE This letter and its attachments constitute an application for a license amendment to the technical specificat:ions (T/Ss) for the Donald C. Cook Nuclear Plant units 1 and 2. This proposed amendment would remove from the T/Ss certain requirements for administrative controls, related to quality assurance requirements, in accordance with the guidance of administrative letter (AL) 95-06. Attachment 1 provides a detailed description of the proposed changes, the justification for the changes, and our determination of no significant hazards consideration performed pursuant to 10 CFR 50.92. Attachment 2 contains the existing T/S pages marked to reflect the proposed changes. Attachment 3 contains the revised T/S pages.

We believe the proposed changes will not result in (1) a significant change in the types of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.

These proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Commit:tee .

In order to be effectively implemented, these proposed changes will require changes to the Quality Assurance Program Description (QAPD). Therefore, if this amendment request is approved, we request a 120 day implementation date from the date of issuance.

0 qr,n 9 9606i80596 9606ii WDOCV, 050003i5 P -- PDR,-

U. S. Nuclear Regulatory Commission AEP: NRC: 80027 Page 2 In compliance with the requirements of 10 CFR 50.91(b)(1), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and the Michigan Department of Public Health.

In accordance with the guidance of AL 95-06 the subject administrative controls related to quality assurance requirements that are presently in the T/S will be relocated to the QAPD.

Related changes to the QAPD will be accomplished in accordance with the requirements of 10 CFR 50.54(a).

Sincerely, E. ED Fitz rick Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS~i~DAY OF 1996 N tary Public eh CC: A. A. Blind G. Charnoff H. J. Miller NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett

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U. S. Nuclear Regulatory Commission AEP:NRC:80027 Page 3 bc: M. S. Ackerman - w/attachment S. J. Brewer/C. C. Savitscus - w/attachment J. A. Kobyra/S. H. Steinhart/S. P. Hodge/D. R. Hafer J. B. Shinnock J. S. Wiebe J. B. Hickman, NRC - Washington, D.C. - w/attachment PRONET - w/attachment DC-N-6015.1

ATTACHMENT 1 TO AEP:NRC:80027 DESCRIPTION OF PROPOSED 'CHANGES, THE JUSTIFICATION FOR THE CHANGES, AND DETERMINATION OF NO SIGNIFICANT HAZARDS

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l to AEP:NRC:80027 Page 1 1.0 Sections to be Chan e Unit 1 and 2 T/S index; pages XVI, and XVII Unit 1 and 2 pages 6-4 through 6-13 Unit 1 and 2 page 6-19,6-20, and 6-22 2' Extent of Chan es This license amendment request. proposes removing the requirements for certain administrative controls related to quality assurance from the T/Ss for Cook Nuclear Plant units 1 and 2 This will be done following the guidance of AL

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95-06 index and the T/Ss were repaginated.

3.0 S ecific Chan es Re uested We propose to make the following unit 1 and unit 2 T/S changes:

(a) delete on Index Pages XVI and XVII section 6.5 "Review and Audit" (b) delete on Index Page XVII section 6.10 "Record Retention" (c) delete T/S 6.5 "Review and Audit" from T/S page 6-4 through page 6-12.

(d) delete T/S 6.6.1 b from T/S page 6-12 (e) delete references to PNSRC and NSDRC from T/S 6.7.1 a, 6.7.1 b and 6.7.1 c from T/S page 6-12 (f) delete T/S 6.8.2 from T/S page 6-13 (g) delete T/S 6.10 "Record Retention" from T/S page 6-19 and 6-20 delete references to "Record Retention" from T/S 6 '3.1 a, and 6.14.1 a from T/S page 6-22 delete references to PNSRC from T/S 6.13.1 b, and 6.14.1 b from T/S page 6-22 4.0 Discussio AL 95-06 "Relocation of T/S Administrative Controls Related to Quality Assurance" was written to inform the licensees about recent experiences involving the relocation of T/S administrative controls related to quality assurance. Our license amendment request, using the guidance of AL 95-06, is voluntary, AL 95-06 does not transmit or imply any new or changed requirements or staff positions'.

Following the guidance of AL 95-06 we propose to relocate certain T/S requirements that are administrative controls, related to quality assurance, to the QAPD.

to AEP:NRC:80027 Page 2 In accordance with 10 CFR 50.54(a), changes that do not reduce the commitments will be submitted to the NRC in accordance with the requirements of 10 CFR 50.71.

In accordance with 10 CFR 50.54(a), changes to the QAPD that do reduce the commitments will be submitted to the NRC and receive NRC approval prior to implementation. In order to streamline our QAPD update process, by reducing the time to implement a separate, additional submittal, we envision that after NRC approval of this submittal, and during the 120 day implementation period of this submittal, we will submit a proposed change to the QAPD in accordance with 10 CFR 50.54(a).

Justification These administrative controls do not satisfy the criteria of 10 CFR 50.36 for inclusion, in the T/Ss, as limiting conditions for operation. The relocated requirements will be controlled directly by regulations (Appendix B to 10 CFR Part 50 and 10 CFR 50.54(a) and a related licensee program (the QAPD). Our proposed change is consistent with the above and will follow the guidance of AL 95-06.

5.0 No Si nificant Hazards Determinat o We have evaluated the proposed T/S changes and have determined that the changes should involve no significant hazards consideration based on the criteria established in 10 CFR 50.92(c). Operation of Cook Nuclear Plant in accordance wi.th the proposed amendment

• will not satisfy any of the following criteria:

(a) Involve a si nificant increase in the robabilit or conse uences of an accident reviousl evaluated The proposed 'hange does not involve any physical alteration of plant configurations, changes to setpoints, or operating parameters. This proposed amendment is to relocate the T/S requirements for administrative controls that are related to quality assurance to the QAPD. This is in accordance with the guidance provided in AL 95-06. Also, the relocated requirements and future changes are controlled by 10 CFR 50.54(a) which requires prior NRC approval for changes that reduce the commitments in the program description previously accepted by the NRC. Therefore, there will be no significant increase in 'the probability or consequences of an accident previously evaluated.

to AEP:NRC:80027 Page 3 (b) Create the ossibilit of a new or different kind of accident from an reviousl anal zed The proposed change does not 'nvolve any physical alteration of plant configurations, changes to setpoints, or operating parameters. This proposed amendment is to relocate the T/S requirements for administrative controls that are related to quality assurance to the QAPD. This is in accordance with the guidance provided in AL 95-06. Also, the relocated requirements and future changes are controlled by 10 CFR 50.54(a) which requires prior NRC approval for changes that reduce the commitments in the program description previously accepted by the NRC, Therefore, this proposed change does not create the possibility of a new or different kind of accident from any previously analyzed.

(c) Involve a si nificant educt o i a mar in of safet The proposed change does not involve any physical alteration of plant configurations, changes to setpoints, or operating parameters. This proposed amendment is to relocate the T/S requirements for administrative controls that are related to quality assurance to the QAPD. This is in accordance with the guidance provided in AL 95-06. Also, the relocated requirements and future changes are controlled by 10 CFR 50.54(a), which requires prior NRC approval for changes that reduce the commitments in the program description previously accepted by the NRC. Therefore, this proposed change does not involve a significant reduction in a margin of safety.

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