NRC-88-0237, Requests NRC Approve Deletion of Commitment to Complete 100% Audit Coverage of Tech Spec Line Items within 5 Yrs,Per Insp Rept 50-341/86-11

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Requests NRC Approve Deletion of Commitment to Complete 100% Audit Coverage of Tech Spec Line Items within 5 Yrs,Per Insp Rept 50-341/86-11
ML20205J320
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 10/18/1988
From: Sylvia B
DETROIT EDISON CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-88-0237, CON-NRC-88-237 NUDOCS 8810310365
Download: ML20205J320 (2)


Text

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8. Aalph Sylvia Senior %ce Pres. dent Detrol,t' _ _ .. ,, , ,,,

Edison ~=v-Octcher 18, 1988-NRC-88-0237 U. S. Nuclear Regulatory Ccunission Attn Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
2) NRC Inspection Report No. 50-341/86011, dated June 13, 1986.
3) NHC Inspection Report No. 50-341/87028, dated October 16, 1987.

Subject:

Deletion of 100% Audit Coverage of Technical Soecifications Items Open item No. 4 of the NRC Inspection Report 50-341/86011 (Reference

2) stated that Fermi 2 does not have a doctroented policy for the time frame in which to co @lete 100% audit coverage of the n'echnical Specification line iterns. Subsequently, applicable procedures were revised to establish a five year time frame to co @ lete such audits and the open item was closed in the NRC Inspection Report 50-341/87028 (Reference 3).

A recent review has indicated that 100% audit coverage of the Technical Specification line items is not necessary as auditing is a randm selection process that 6oes not require 100% coverage, there is no regulatory requirement that all the Technical Specification line items be audited over a fixed period of time, and technical adequacy and accuracy of the Technical Specification line items is assured by i glementing several criteria fr m the Technical Specifications Improvement Program (TSIP) which is in paresa to provide 100% review of the Technical Specification line item. Thece criteria include:  !

o verification that Technical Specifications requirements are included in Technical Specifications surveillance procedures,  ;

including the specific values noted in the Technical Specifications, o Review of procedures for W hnical adequacy. ,

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8810310065 Retole  !

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ADOCK 05000341 PDC

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. - October 18, 1988 NRC-88-0237 Page 2 o Establishment of measures to assure that the need for situational surveillances are identified.

'Ihe consnitment to audit 100% of all the Technical Specification line items dces not fulfill the intent of good QA practices and is redundant to our efforts for the Technical Specification Inprovement Program. Rather than strict adherence to a prescriptive schedule, OA should have the flexibility to focus audits where there is a need. It is very inportant to assess the adequacy of performance of a sanpling of new surveillance procedures as they are generatei by the Technical Specifications Inprovement Program without being overly concerned with a five year schedule for 100% audit coverage of the Technical Specification line items.

Based upo.1 the successful empletion of the Technical Specifications Inprovemrnt Program audit efforts should focus on the following, rather Enan 100% coverage of the Technical Specification line items:

o technical adequacy and accuracy of new and revised surveillance procedures.

o Observation of performance of selected surveillances, review of results, frequency and situational requirements.

An audit program which includes these items will result in tA2 clear Quality Assurance properly assessing performance of Technical Specification inplementation, while devoting more effort to the areas which need attention.

Therefore, Detroit Edison is requesting that the NBC approve deletion of the cmmitment to complete 100% audit coverage of the Technical Specification line items within five years.

If you have any questions, please contact Mr. Girija Shukla at (313) 586-4270.

Sincerely, htJy' cci Mr. A. B. Davis Mr. R. C. Knop Mr. W. G. Rogers Mr. J. Stang USNRC Region III

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