ML20093H592
| ML20093H592 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/03/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20093H583 | List: |
| References | |
| 1-468, NUDOCS 8410160320 | |
| Download: ML20093H592 (3) | |
Text
i Docket No. 50-346 TOLEDO Ei[)lEiClrJ License No. NPF-3 Rompo P. Cnoust Serial No. 1-468 uneassai October 3, 1984 Mr. C. E. Norelius, Director Division of Reactor Projects United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Norelius:
Toledo Edison acknowledges receipt of your September 7, 1984 letter (Log No. 1-1025), requesting an amended response to Item 3 in our August 17, 1984 letter (Serial No. 1-459), which was in response to Inspection Report No. 50-346/84-09 (DRS) (Log No. 1-992). Toledo Edison herein offers the amended response to this item:
3.
Violation:
10 CFR 50, Appendix B, Criterion XVII, as implemented by the Toledo Edison Operating QA Program and the FSAR Section 17.2, require that the applicant shall provide record storage consistent with applicable regulatory requirements. The Toledo Edison QA Program commits to ANSI N45.2.9-1974 and Regulatory Guide 1.88, Revision 2, October, 1976, with an exception specifying a two hour fire protection rating for record storage facilities.
Contrary to the above, records of audits, auditor and QC inspector qualification / certification and calibrations were not provided the required protec-tion.
This is a Severity Level V violation (Supplement I).
Response
ANSI N45.29-1974 contains the following definition of Quality Assurance Records.
" Quality Assurance Records - Those records which furnish documentary evidence of the quality of items and of activities affecting quality.
For the purpose of this standard a document is considered a Quality Assurance Record when the document has been completed."
8410160320 841011 PDR ADOCK 05000346 g
PDR THE TOLEDO EDIGON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43G52 DCT B E04
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Docket N:2. 50-346 Licerse'No. NPF-3' 4
Serial No.1-468 i
October 3,1984 Page 2 i
n TheTolbdoEdisonNuclea'rQualityAssuranceManualand Chapter 17.2 of the Updated Safety Analysis Report further defines a completed Quality Assurance Record as follows:.
" Quality Assurance Records - A document is considered completed when all applicaole information has been recorded and the record has been reviewed and approved
- by the applicable individuals."
Furthermore, the scope of ANSI N45.2.9-19741 ctates:
"It (this standard) is not intended to cover the
. preparation of the records, nor to include working
' documents not yet designated as Quality Assurance Records."
a.
The audit records stored in the Davis-Besse Administration Building (DBAB) are working records in which there are open audit findings.
These documents are periodically updated to reflect actions taken to resolve the audit findings.
Therefore, Toledo Edison considers these audit documents as working documents and subsequently not within the scope of the ANSI N45.2.9.
b.
Auditor qualification / certification records stored in the DBAB and Quality Control Inspector records stored in the Quality Control trailer will be transferred to a storage facility which meets the requirements of ANSI N45.2.9.
This will be accomplished prior to October 12, 1984.
c.
Records for the test and measuring equipment utilized by Quality Control have been transferred
.to the Instrument & Control (I&C) Shop for storage with the remainder of the Station I&C test and measuring equipment: calibration records. In the I&C Shop, these records ~are stored in one hour fire rated cabinets and are maintained in indivi-3, dual folders for each piece of equipment under the
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calibration program. These folders provide an equipment history file for each piece of equipment and'are periodically updated as calibration occurs.
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bocket.No.50-346 i ::
License No. NPF-3 Serial No. 1-468-October.3. 1984 Page 3 To clarify our position on the storage of cali- -
bration records, Toledo Edison will submit for your approval a change in our Nuclear Quality Assurance program to permit the storage of these.-
records in one hour fire rated cabinets. This
. submittal will be made -prior to November 1,1984.
Very truly yours, f f h ;==
RPC:SGW:nif cc: DB-1 NRC Resident Inspector
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