IR 05000346/1998010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-346/98-10

ML20237C138
Person / Time
Site:	Davis Besse
Issue date:	08/14/1998
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jeffery Wood CENTERIOR ENERGY
References
50-346-98-10, NUDOCS 9808200247
Download: ML20237C138 (2)

Text

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August 14, 1998 L Mr. John Vice President - Nuclear Davis-Besse Nuclear Power Station l Centerior Service Company

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5501 North State Route 2 Oak Harbor, OH 43449 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-348/98010(DRS))

Dear Mr. Wood:

This will acknowledge receipt of your letter dated July 27,1998, in response to our letter dated June 27,1998, transmitting a Notice of Violation associated with the failure to conduct audits of the Process Control Program and the implementation of procedures for processing and packaging radioactive wastes, at least once per 24 months. We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely, l

Original /s/ S. A. Reynolds for  !

John A. Grobe, Director  ;

Division of Reactor Safety  !

Docket No.:. 50-346 I

License No.: NPF-3 Enclosure: Lir dtd 6/23/98 from First Energy to USNRC r See Attached Distribution (Yl DOCUMENT NAME: G:DRS\DAV98010.TY i

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To receive a copy of this document, Indicate in the boa: *C" a Copy wetreul attachment / enclosure T e Copy eth attachment / enclosure *N" = No copy OFFICE Rlli l[ Rll! 6 Rill ,

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9808200247 980614 PDR 0 ADOCK 05000346 PDR.

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, cc w/o encl: J. Stetz, Senior Vice :

President - Nuclear l J. Lash, Plant Manager l J. Freels, Manager i Regulatory Affairs

! . M. O'Reilly, FirstEnergy l

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cc w/ encl: State Liaison Officer, State l of Ohio

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R. Owen, Ohio Department ,

of Health ]

C. Glazer, State of Ohio i

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Public Utilities Commission l l

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Distribution-Project Mgr., NRR w/ encl J. Caldwell, Rlll w/enci C. Pederson, Rill w/enci ,

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' Dans-Besse Nuclear Power Stahon 5501 North State Route 2 (

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?. .lohn Vice President - Nuclear Fax:419-321 8337 l

j Docket Number 50-346 License Number NPF-3 Serial Number 1-1169

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July 27, 1998 l

United States Nuclear Regulatory Commission Document Control Desk 4

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. Washington, D.C. 20555 *

i. Subject: Response to Inspection Report 50-346/98010; Reply to Notice of Violation Ladies and Gentlemen:

l Toledo Edison has received Inspection Report (IR) 50-346/98010 (Log Number 1-3977) and the enclosed Notice of Violation issued on June 27,1998. The violation involved the failure to audit the Process Control Program and radioactive wt.ste processing activities at the required interval.

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Toledo Edison's response for the Davis-Besse Nuclear Power Station, Unit (1) (DBNPS) to the Notice of Violation is presented in Attachment 1.

l Should you have any questions or require additional information, please contact Mr. James L.

Frects, Manager - Regulatory Affairs, at (419) 321-8466.

Very truly yours, CA.K/laj cc: !A. B. Beach, Regional Administrator, NRC Region 111 S. J. Campbell, DB-1 Senior Resident Inspector A. G. Hansen, NRC/NRR Project Manager Utility Radiological Safety Board l

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- Docket Number 50-346 -

License Number NPF-3

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Serial Number 1-1169 Attachment 1 Page1 Reply to a Notice of Violation (50-346/98010)

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Restatement of Alleged Violation

"During an NRC inspection conducted from June 8 through June 11,1998, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure

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for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 6.5.2.8 requires that audits of facility activities be performed under the cognizance of the Company Nuclear Review Board and encompass, in part, the Process Control Program (PCP) and implementation of procedures for processing and packaging radioactive j wastes, at least once per 24 months. 4 "

Contrary to the above, as of June 11,1998, the licensee failed to conduct audits of the PCP and L

implementation procedures for processing and packaging radioactive waste at least once per 24 months. Specifically, as of the date of inspection, no audits of the PCP and the implementation of procedures for processing radioactive wastes were conducted during the preceding 24 month period.

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This is a Severity Level IV violation (Supplement IV)."

Reason for the Violation

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At the time of the inspection, June 11,1998, audit documentation for the PCP and the implementation of processing radioactive waste was inadequate for the proceeding 24-month period. Further review of audit information indicated that although certain aspects of this

, program have been assessed by the Quality Assessment (QA) organization, clear and concise l

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documentation to support completion of this Technical Specification requirement was unavailable.

Several factors contributed to the failure to assess and report on the PCP. Merging of audit

activities together in the Radiation Protection area over the past several years has resulted in the

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current audit schedule not clearly identifying the PCP as an audit activity. The audit that was intended to capture this requirement is currently identified as the " Radiation Protection, Radiological Environmental Monitoring Program (REMP), Offsite Dose Calculation Manual (ODCM), and Meteorological Monitoring" audit, or commonly known as the Radiation

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Protection (RP) audit.

Procedure NG-NA-00710," Audit and Surveillance," does state that the audit schedule shall, at a

. minimum, be commensurate with the frequencies defined in the Technical Specifications, Updated Safety Analysis Report (USAR), Nuclear Quality Assurance Manual (NQAM), and ASME (American Society of Mechanical Engineers) Quality Assurance Manual (AQAM).

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Docket Number 50-346 License Number NPF-3

. Serial Number 1-1169 Attachment 1 l Page 2 l

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! However, as noted above, the merging of activities under the RP audit resulted in the audit I

j schedule not clearly associating the required frequency with these activities, including PCP.

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Also contributing to this situation was that numerous Eleventh Refueling Outage (11RFO)

l. outage planning and work activities were in progress while the RP audit was being planned and

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conducted. These outage related activities resulted in the RP audit focus shifting onto Radiation Protection 11RFO related work activities and the PCP and radioactive waste processing activities l were overlooked. Staffing changes within the Quality Assessment organization and Radiation

Protection audit team changes made to address emergent 11RFO outage conditions were also l

contributing factors in this oversight. Therefore, the Radiation Protection audit conducted during 11RFO did not include the PCP and radioactive waste processing. ,

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Corrective Stcos Taken and Results Achieved l Immediate corrective actions taken included the conduct of a special PCP and radioactive waste processing activities audit. This audit included a line-by-line verification of the PCP program to ensure implementing procedures for processing and packaging of radioactive waste are adequate.

This action was initiated on June 17,1998, and a post audit exit meeting was conducted with site

management on July 8,1998, to discuss the results of this audit. One audit observation and no findings were initiated as a result of this audit. The PCP audit report was issued on July '21,1998.

l To ensure no additional Technical Specification audit frequency issues exist, Quality Assessment i

reviewed the 1997 and 1998 audit schedule and compared it with all additional Technical

! Specification 6.5.2.8 requirements. A cross-reference table was utilized to ensure all these l frequency requirements were properly scheduled. Audit reports were then reviewed to ensure i these individual Technical Specification requirements were being satisfied. No additional Technical Specification compliance issues were identified during this review.

l l Corrective Steps That Will Betaken to Avoid Further Violations l To ensure future compliance with these requirements is maintained the following long- term corrective actions will be implemented. Quality Assessment will develop a matrix that will cross-l reference the audit schedule with all known audit frequency requirements contained in Technical l Specifications, Code of Federal Regulations (Title 10), Regulatory Guide's, NQAM, AQAM, l USAR and Toledo Edison Regulatory Management System commitments. This activity, originally done several years ago, will now be captured as part of an approved audit schedule.

This will ensure that a clear understanding of all audit frequency requirements is available for

{ audit team members and audit supervisors. This will also allow easy transfer of these audit requirements during any future staffing and personnel changes and allow auditors to easily verify these requirements during the audit preparation process. Additional enhancements will be made to the current audit schedule to separate activities such as PCP, ODCM, Radioactive Waste, and REMP into one audit separate from the RP audit. This would allow more focus on these r

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Docket Number 50-346 '

License Number NPF-3

. Serial Number 1-1169 Attachment 1 Page 3 requirements in a non-outage environment and allow the Radiation Protection audit to focus on emergent activities relating to Radiation Protection. This should also alleviate any future concern with outage activities distracting the QA audit team from satisfying these specific requirements.

The Quality Assessment staff will be trained on these proposed schedule changes and the

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expectations to clearly document these requirements in audit reports. A copy of this Notice of l

Violation, and its response, will also be captured in Quality Assessment working files that are referenced during the audit preparation process.

Date When Full Comoliance Will Be Achieved -

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- Full compliance with Technical Specification 6.5.2.8 was achieved on July 21,1998, when the audit of the PCP and radioactive waste processing activities was complete and the report issued.

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