05000315/LER-1982-016, Forwards LER 82-016/03X-2 Re 810719 Suction Strainer Pinhole Leak.Revised LER Rescinds Commitment to Submit Rept Whenever Action Statement Entered Other than for Preventive Maint or Testing,Per Insp Repts 50-315/85-07 & 50-316/

Forwards LER 82-016/03X-2 Re 810719 Suction Strainer Pinhole Leak.Revised LER Rescinds Commitment to Submit Rept Whenever Action Statement Entered Other than for Preventive Maint or Testing,Per Insp Repts 50-315/85-07 & 50-316/85-07

ML18095A008
Person / Time
Site:	Cook
Issue date:	07/30/1985
From:	Will Smith INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML17321A834	List:
References
AEP:NRC:0935B, AEP:NRC:935B, NUDOCS 8508200033
Download: ML18095A008 (3)

LER-1982-016, Forwards LER 82-016/03X-2 Re 810719 Suction Strainer Pinhole Leak.Revised LER Rescinds Commitment to Submit Rept Whenever Action Statement Entered Other than for Preventive Maint or Testing,Per Insp Repts 50-315/85-07 & 50-316/85-07

Event date:
Report date:
3151982016R00 - NRC Website

text

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( ";,)~VD/AAA.,6, boa/aA/I; FiFCraIC CONPAgr DONALDC. COOK Y\\3CLEAR PLAYT P.O. Box 45S. Bridgrnan, %michigan 'Bl06 (616) 46i-590i July 30, 1985 MP'RC 0935'onald C.

Cook Nuclear Plant, Unx.t hos.

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Docket, Number 05000315 and 05000316 License Numbers DPR-58 and DPR-74 LER 50-315/82"016 Hr. J.

G. Keppler U.S. Nuclear Regulatory Commission Office of Inspectioa aad Enforcement.

Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear. Hr. Keppler:

Attached is a revised LER which rescinds, with support.iag rationale, our commitment to initiate a Condition Report anytime we enter an Action Statement "For any reason other than for preventive maintenance or surveillance testing."

Because of the event identified in I.E. Report 50-315/78-27; 50-316/

78-31, we began the practice of initiating a Condition Report when a

piece of Technical Specification equipment was out of service for what-ever reason.

We formalized this process in LER 3)6/S2-016 (attached) where an LER again was not initiated.

At that time, the reporting reouirements of HUREG-0)6) and Technical Specification 6.9.1.12 and 6.9.1.13 specified that an LER be submitted.

Subsequently,

)0 CFR 50.73 revised the reporting criteria, specifically not requiring an LER on Technical Specification equipment outages so long as the Technical Specification Action Statement(s) were met.

The Condition Report is our method of ensuring all events adverse to quality are reported to upper management for resolution aad reportability.

Since January,

)9S4, we have continued this practice of init.iating a Condition Report whenever a piece of Technical Specificatioa equipment

. is removed from service regardless of the reason.

En 1984 alone, over 700 Condit.ion Reports of this type were generated.

In light of the new reporting requirements, these are viewed as unnecessary and as adding more paperwork to aa already overburdened system.

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Cond tron Repor; burden Condition Reports is wo vhich category fall t.ho snspectxor.

kepor. 3'15/3)6-85/00, anc b~

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strugg xnp tc manag a szgns=i.cantlv increas c

One vav t.o improve our t.xmely closeout o:"

eliminate t.hose vhich are unnecessarv int.c se Condition Reports committed to in LER 315/8"-016.

he--are proposing to effect this change in order to eliminate the generation of unnecessary Condit.ion Reports together with the time iavolved in in-vestigat.ing and revieving the reports.

Me feel that by eliminating this category of unnecessary Condition Reports, ve vill be able to place the appropriat.e level of management review on legitimate safety related and adverse to quality issues.

The proposed effective date for this rescission of the commitment is August 31, 19S5.

The intervening time is to allov for you or members of your st.aff to reviev the matter and express any question you have on the proposed action.

Q. G. Smith, 3r.

Plant Nanager DFK/ss cc:

3. E. Dolan Yi. P. Alexich

ÃRC Region III Resident.

Inspectors at D.

C.

Cook Y.. Evar s

B. Mm.

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