ML20134Q090
| ML20134Q090 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 02/17/1997 |
| From: | Fitzpatrick E AMERICAN ELECTRIC POWER CO., INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1238A1, NUDOCS 9702260242 | |
| Download: ML20134Q090 (1) | |
Text
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indlana Ochigan Power Company 500 Circle Drive a
Buchanan MI491071395 f
=
INDIANA MICNIGAN POWER February 17, 1997 AEP:NRC:1238A1 10 CFR 2.201 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 NRC INSPECTION REPORTS NO. 50-315 - 316/96004 (DRP)
REPLY TO NOTICE OF VIOIATION SUPPLEMENTAL INFORMATION Our June 28, 1996, letter AEP:NRC:1238A provided our response to a letter from W.
J.
Kropp dated May 16, 1996, that forwarded two violations to Indiana Michigan Power Company. The first of the two violations was associated with changing the intent of two plant procedures without the required safety reviews being performed. As requested in the violation, our response was to delineate the steps taken to ensure that no operational direction would be provided to operators, outside of the operating procedures, when utilizing plant manager instruction (PMI) -4090,
" criteria for conducting Infrequently Performed Tests or Evolutions. "
Subsequently, during the exit meeting for inspection report 50-315/316-96014, the senior resident inspector requested that we provide additional information regarding more generic actions we have taken to ensure changes to the intent of a procedure not be implemented without prior performance of a safety evaluation.
During the investigation into the subject violation, we determined the existing plant guidance on procedure intent was vague.
Based on this, procedure PMI-2010,
" Instructions, Procedures, and Associated Indexes Policy," was revised to clearly define " change of intent."
The " change of intent" definition added to the procedure was based on industry input and describes conditions under which the intent of a procedure is changed.
The definition i
provides a clear foundation to segregate procedure revisions into
)
intent and non-intent changes, thereby providing assurance that i
safety reviews are performed when required.
Sincerely, E.
E. Fi atric 250145 Vice President l
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cc:
A. A.
Blind
~ l A. B. Beach MDEQ - DW & RPD NRC Resident Inspector J. R.
Padgett I
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