NRC-90-0091, Requests Relief from Commitment to Perform 100% Audits of Tech Spec Line Items.Tech Spec Improvement Program Has Been Completed Which Provides Extensive Review of Tech Spec Line Items

Requests Relief from Commitment to Perform 100% Audits of Tech Spec Line Items.Tech Spec Improvement Program Has Been Completed Which Provides Extensive Review of Tech Spec Line Items

ML20055D968
Person / Time
Site:	Fermi
Issue date:	07/02/1990
From:	Orser W DETROIT EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-0091, CON-NRC-90-91 NUDOCS 9007100208
Download: ML20055D968 (2)

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3 l j -m l *h y"*N;fy*lm n, l Detroit:  % .

9*i 1 Edison EsnP 34ggp 2 3"as. j U. S. )bclear Regulatory Ccm nission "

Attention: Docunent Control Desk -  :

Washington, D.C. 20555

References:

1). Fermi 2 .

NIC Docket No. 50-341 )

NIC License No.' tFF-43 -

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2) NIC Inspection Report No. .50-341/86011, dated June 13, 1986  :

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3) NIC Inspection Report No.- 50-341/87028,  ;

dated October 16, 1987-

4) Detroit Mison letter NIC-88-0237, i dated October 18,>1988- j

5) NIC letter dated August 24,1989 j 1

Subject:

Deletion of 100% Audit Coverage of '14chnical  ;

Aneification Line Itane 1 1

In April 1986, NIC Inspection.86011, Open ' Item No. 4, statedi that .  !

Fermi- 2 did not' have 'a documented policy for the ' time' frame in\which to couplete 100% audit coverage of. the Technical Specification line items. ~ Subsequently, Detroit Mison developed a program and revised' the applicable procedures to establish a five year' tine frame .in which. '

to couplete such -audits. The five year time frame began with' fuel' loading in March of 1985. l

, In August .L986, Detroit Mison developed a Technical Specification Line Item Matrix which would enable management to assign' and track.the -

Technical ~ Specification line items for audit purposes. Approximately-three man.nonths were spent on this effort..

.The first Technical Specification line item audits began in June . l s 1987. The first five year cycle was conpleted'in March 1990.. During l

' that cycle of audits, tha audit program did not identify any violation:

~o f the Technical Specification' sections 2,- 3 and 4 itens. In 1989

'alone, Detroit Mison spent in excess of 3770 man hours conducting

'1%chnical Specification line item audits. During the five year cycle '

approximately 15,000 man hours were spent with no significant findings.

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c,3' 1U. S. !bclear Regulatory Ccmnission1 i NIC-90-0091. '

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- July 2,L1990-Page 2L '

The commitment to audit 100% of'all'the' Technical Specification line items every five years has required significant Quality Assurance . (@)

resources. Rather than adhere to a strictly prescribed j conpliance-based schedule, m should have the flexibility to focus  !

audits in suspecta5 weak performance, areas or.on;ites significantly i affecting plant' safety and reliability. -j

! Our preference 1is .t'o continue to inplement 'our performance-based .

. mditing techniques.. The performance-based auditing was intrcduced by the' Nic with NURIE/CR-5151 in' June 1988. This audit concept provides

nuch more benefit for' the effort expended' than a purely .

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E conpliance-based' audit which -is characteristic of the Technical

. Specification line item audits.

In October l1988, a request was submitted to the NIC to grant relief ifrom the'100% audit of Technical Specification line' items.- This .

request was' subsequently. denied. . However, since- this request has;been made,. there has been increased emphasis on performance-based .

auditing. .In addition, Detroit Edison's Technical Specification

'Inprovenent' Program has been coupleted which provided. an extensive - J review 'of. the Technical Specification.line items. --

l-Detroit Edison has concluded that the Technical Specification line -

item audits have provided little or no benefits and ~is: contrary to

. performance-based auditing. This lack'of. benefit was discussed with NIC (Division of Beactor Safety) personnel'at the Great Lakes @ i Managers neeting in May'1990. They suggested, that Detroit Edison l

"< resubmit the request to be grante3 relief .from the commitment to:

perform 100% audits of the Technical; Specification ~'line.-items. -j 1

If you ham any questions, please contact Mr. Joseph Pendergast',  !

Coupliance Engineer, at -(313) 586-1682.

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E j Sincerely,  ;

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cc A. B. Dayis-

.R. W. DeFayette- 1

H. Miller M. Phillips ,'

'W. G.-Rogers

'J.~ F. Stang' , l Region III '

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