ML20138K963
| ML20138K963 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/16/1985 |
| From: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| NUDOCS 8512190125 | |
| Download: ML20138K963 (2) | |
Text
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'0E0 1 01985 MEMORANDUM FOR: James G. Partlow, Director Division of Inspection Programs Office of Inspection and Enforcement, HQ FROM:
Charles E. Norelius, Director Division of Reactor Projects Region III
SUBJECT:
REGIONAL ASSESSMENT This is to address your memorandum on this subject' of October 16, 1985 which enclosed an inspection report by IE personnel and made several observations relative to the inspection program being implemented _by Region III at D. C. Cook. The following' responses apply to like numbered observations in your memorandum..
1.
We concur with your assessment that the minimum and basic programs for IE Manual Chapter 2515 had been acceptably implementeu in the areas of plant operations anC surveillance.
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2.
We agree' that 'ot}r inspectors' found PMI 4030, " Surveillance Testing,"
Revision-7 sid,the surveillance test schedules satisfactory. We note, however, that Revision 7 to PMI 4030 listed only surveillance requirements and responsible departments. Revision 8 reviewed by the mint-PAT inspection, apparently added the related surveillance procedure to,the matrix which your inspectors found incomplete.
Therefore, we do not agree that our inspectors should have found the same problem in their review of Revision 7.
The current Inspection Procedure 61725 used by the 3
Region.does not require verification that procedures have been prepared for all surveillances, only that the requirement to have such procedures exists in the administrative procedures. We plan to propose revisions to Inspection Procedure 61725 to include a sampling-basis verification that procedures exist for each selected TS-related surveillance requirements.
3.
We understand how you may have concluded that the resident inspectors
.. ss shouM have identified this' problem. The " potential programmatic" nature of this problem was ' recognized bn the IE Team because they (properly) 3 followed-up by reviewing numerous files when an example of this a
deficfancy was observed in the field. We are confident our inipectors would.have responded in like manner had they observed,the same problem.,
y J10 wever, they did not, despite a number of observations of
' work-in-progress in this area. As you note, we have identified problems 7
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with procedure adherence and cherved (and pursued licensee correction for) instiances of " casual" cata-taking in the C&I area which frivolved initially recording data on scrap paper or a previously-used datesheet.
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1 James G. Partlow
-2 DEC 1 61985 The Region is sensitive to this issue and inspection efforts are being focused accordingly.
5.
We discussed the frequency of QA audits of surveillance requirements with the company following the mini-PAT inspection and they agreed to double their prior schedule to the 14.2 year cycle to which they are currently committed.
It is our view that the more important review is the two year review cycle of the adequacy of procedures, including surveillance procedures, conducted by the plant. We also are aware that an outside contractor recently conducted a review of the technical adequacy of the surveillances, and of course, in response to our Confirmatory Action Letter, the company reviewed a suitable sample of surveillance procedures in areas where problems were identified. We would expect that if the company identified any problems during any existing audits, that they would increase the scope of their sample.
In view of these programs, we do not plan to take additional actions to increase the frequency of QA audits.
We also note imposition of more intensive QA requirements would constitute a backfit, and if warranted, we believe IE should handle the matter generically.
6.
On November 27, 1985, the SALP Board rated D. C. Cook Category 3 with a
" Declining" trend in Surveillance. The Operations area was rated Category 2 with no appreciable trend noted. An Enforcement Conference was held in Region III on November 13, 1985, with the Chief Executive Office of American Electric Power Company and members of his staff to discuss our continuing concerns regarding surveillance activities.
We appreciate.your sharing with us the observations of your team regarding the implementation of the IE inspection program at D. C. Cook. We will forward to you under separate cover, the proposed revisions to Inspection Procedure 61725 discussed in Item 2 above.
% hui S!;ned by C. E. Horellus" Charles E. Norelius, Director Division of Reactor Projects cc:
A. B. Davis, Deputy Regional Administrator
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