ML20076M347

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Responds to NRC Re Violations Noted in IE Insp Repts 50-315/83-07 & 50-316/83-08.Corrective Actions: Procedures & Instructions Amended to Include Description of Master Plant File Vault & Records Policy Statement
ML20076M347
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 07/01/1983
From: Will Smith
INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20076M346 List:
References
AEP:NRC:0825, AEP:NRC:825, NUDOCS 8307200273
Download: ML20076M347 (2)


Text

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6 INDIANA & MICHIGAN ELECTRIC COMPANY

vsten, DONALD C. COOK NUCLEAR PLANT l

P.O. Box 458, Bridgman, Michigan 49106 (616) 465-5901 July 1, 1983 AEP:NRC:0825 Donald C. Cook Nuclear Plant Unit Nos. 1 and 2 Docket Nos. 50-315 and 50-316 License Nos. DPR-58 and DPR-74 IE Inspection Reports 50-315/83-07 And 50-316/83-08 Mr. James G. Keppler, Regional Administrator U.S. Nuclear Regulatory Commission Office Of Inspection and Enforcement Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

This letter responds to Mr. J. F. Streeter's letter of June 1, 1983, which forwarded to us the subject Inspection Reports.

The Notice of Violation attached to Mr. Streeter's letter identified one Item of Violation requiring a written response. A re-statement of the Item and our response to it follows.

ITEM 6

10 CFR 50, Appendix B, Criterion XVII states, in part.... the applicant shall establish' requirements concerning record retention such as duration, location, and assigned responsibility". The licensee committed to comply with Regulatory Guide 1.88-October 1976 and ANSI 45.2.9-1974 in the licensee's approved Operational Quality Assurance Program specified in Section 1.7 of the FSAR.

Subdivision 5.3 of ANSI 45.2.9-1974 and the Custodial Section of the licensee's procedure PMI-2040 require that storage procedures shall include a description of the storage facility and a method for filing supplemental information to Quality Assurance Records.

Regulatory Guide 1.88-October 1976 states, in part, "Two methods for protection of quality assurance records from the hazards of fire are described in Subdivision 5.6 of ANSI N45.2.9-1974. NFPA No. 232-1975, " Standard for Protection of Records",

also contains provisions for records protection equipment and records handling techniques that provide protection from the hazards of fire. This standard within its scope of coverage, is considered by the NRC staff to provide an acceptable alternative to the fire protection revisions listed in Subdivision 5.6 of ANSI N45.2.9-1974." The minimum fire resistance rating for design of a records vault described in NFPA No. 232-1975, Chapter 2, Sections 2022 and 2252 is two hours.

0307200273 830714 PDR ADOCK 05000315 jyL gg G

PDR

Mr. J. G. Keppler

-2 AEP:NRC:0825 Contrary to the above:

a: The licensee's storage procedures did not contain a description of the storage facility and a method for filing supplemental information to Quality Assurance Records.

b.

The door on the Master Plant File Vault is only a one and one-half hour fire resistant rated door and the penetration through which a conduit passes through the vault wall for fire detection equipment was not sealed.

This is a Severity Level V violation (Supplement I).

RESPONSE TO (a)

Procedure 12-0AP-2040.MPF.004, " Storage of Quality Assurance Records" (in draf t form at the time of inspection) has been amended to include a description of the Master Plant File Vault.

Plant Manager Instruction PMI-2130, " Plant Records Preparation and Retention" is being amended to include a policy statement with regard to supplemental records.

In addition, Procedure 12-0AP-2040.MPF.004, " Storage of Quality Assurance Records" has been amended to include administrative controls for the filing of record supplements.

Procedure 12-0AP-2040.MPF.004 was issued on June 30, 1983.

Instruction PMI-2130 will be amended as described above and issued by September 1, 1983.

RESPONSE TO (b)

RFC-12-1924 has been initiated which will replace the existing door with a three hour rated Class"A" fire door. The schedule for the delivery and installation of this door is unknown at this time.

The conduit penetration through the vault wall has been sealed.

In order to insure that you received this response on a timely basis our normal corporate procedures,with proper approval,have been bypassed. We plan, however, to submit this letter through our normal review procedures and will inform you of any error or inaccuracy that we may find during the review procedures.

Very truly yours, t

V0)f s W.

. Smit Plant Manager cc:

J. E. Dolan - Columbus M. P. Alexich R. W. Jurgensen R.~ S. Hunter - New York l

R. C. Callen G. Charnoff l

NRC Resident Inspector at Cook Plant - Bridgman

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