ML20202J508
| ML20202J508 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/16/1998 |
| From: | Jeffery Wood CENTERIOR ENERGY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20202J513 | List: |
| References | |
| 2509, NUDOCS 9802230165 | |
| Download: ML20202J508 (5) | |
Text
_
E=-
LE=
DansDesse Nucioar Poker Staton yy
$501 North State Route 2 m
Oak Ha+or Orvo 43449 97%
JohnK.Apod 419 249 2300 VcePrescant Nucwar far 419-3218337 Docket Number 50 346 License Number NPF 3 Serial Number 2509 February 16. 1998 United States Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 0001
Subject:
Request for Changes in Quality Assurance Program Nonconformance Processing (10 CFR 50.54 (a)(3)) and Changes in Commitment Regarding the Review ofInformation Notices Ladies and Gentlemen:
Thic letter provides proposed reduction in-commitment char ges to the Davis-Besse Nuclear Power Station (DBNPS), Unit i Updated Safety Analysis Report (USAR) Chapter 17.2," Quality Assurance During the Operating Phase,"(Quality Assurance Program) and DBNPS commitments previously made to the NRC in response to an NRC Notice of \\*iolation. Purmant to 10 CFR 50.54 (a)(3), Toledo Edison (TE) hereby submits its plans regarding changes in the proceasing and administration of the nonconformance/ corrective action program (i.e., the Potential Condition Adverse to Quality (PCAQ)
Program) at the DBNPS, Unit 1.
QMtv Assurance Proctam Commitments:
The changes discussed in detail in the attached 10 CFR 50.54 (a) cview have been identified as reductions to the commitments currcntly contained in the DBNPS USAR Chapter 17.2. Although these changes have been identified as reductions in commitment, the Quality Assurance (QA) Progrr.m continues to satisfy the criteria of 10 CFR 50, Appendix B as the changes alter self imposed "non regulatory" required commitments.
Manacement Commitment:
In addition to changes to the QA Program as described in the USAR, a DBNPS management commitment to the NRC regarding a portion of the corrective action process was also identified as being affected and requiring NRC approval prior to implementation in accordance w;th the Nuclear Energy institute (NEl) guidance provided in the document " Guidance for Managing NRC Commitments". This
- commitment was made to the NRC in response to the Notice of Violation contained in inspection Report (IR) Number 96-008, dated October 22,1996 (TE Log Number 1 3753).
i hi)O
[
~
9002230165 900216 ADOCKOS0003j6
{ll l lll (.llll PDR e
4 Docket Number 50 346 License Number NPF 3 Serial Number 2509 Page 2
' Toledo' Edison's response dated Nov mber 21,1996 (TE letter Serial Number 1 1111) to IR Number e
96 008 cor aitted to modify the NRC Information Notice (IN) review process to utilize the DBNPS corrective action program. The DBNPS corrective action program, as described in procedure NO NA 00702," Potential Condition Adverse to Quality (PCAQ) Reporting",is the administrative system for identification and resolution of potential problems. As committed in TE letter Serial Number 1 1111. NRC ins are captured as PCAQ Reports (PCAQR) and the PCAQ process ensures NRC ins receive: a prompt operability and reportability review, timely resolution in accordance with the PCAQ process required timeline, a significance review, a multi discipline review (if determined appropriate based on significance), and an independent close-out review. This commitment was made to strengther.
weaknesses at the DBNPS in the review of industry experience contained in NRC ins to ensure a complete technical review is perfonned and appropriate actions taken. The portion of this management commitment being affected by this change k the independent review of the PCAQR, including NRC ins, at close out.
Present Corrective Action Process:
This section and the following section of this letter describe the present and proposed corrective action processes at the DBNPS. The descriptions are provided as information only to facilitate the NRC stafrs understanding of these processes in relationship to the proposed changes in commitments.
As committed, the PCAQ process presently provides: prompt operability and reportability reviews, a structured timeline for resolution, a prompt significance review, a multi discipline review of the potential problem (if determined appropriate based on signi0cance), and an independent review of the PCAQR at closc-out.
Under the present process, a PCAQR is initiated identifying the potential problem (including NRC ins).
The PCAQR is then reviewed for completeness by a cognizant supervisor and is submitted to the Control Room Operations Shift Supervisor for prompt review. This review includes determination ofimmediate reportability in accordance with 10 CFR 50.72. Additionally, the poten*.ial problem is assessed for impact on the Operating License Technical Specifications and the operability of applicable plant equipment. Responsibility for the PCAQR is then assigned to a specific DBNPS organization.
The assigned responsibie DBNPS organization determines the apparent cause(s), evaluates equipment operability, determines 10 CFR 21 reportability, proposes restoration action (s), and identifies responsible organizations for completion of the corrective action (s), including due dates. If appropriate, based on the signi0cance of the issue, the issue is reviewed by an oversight PCAQ Review Board and the actions tracked to completion. The PCAQ Review Board may also request corrective actions, if not already i
provided.
if appropriate, based on the signi0cance of the issue, the assigned organization then determines the root
- cause, proposes the preventive action (s), identifies tasks to be performed and determines due dates.
Depending upon the significance, the PCAQR may receive further PCAQ Review Board review.
An irdependent close-out review of PCAQRs (including NRC ins)is performed by the DBNPS Nuclear Assurance Department's Nuclear Safety and Inspection Section. Also, for signincant conditions adverse to quality, an independent verification of the remedial actions and the corrective action (s) to prevent
Docket Number 50 346 License Number NPF 3 Serial Number 2509 Page 3
' recurre*nce is performed by the DBNPS Nuclear Assurance Department's Nuclear ' afety and Inspection Section or the Quality Assessment Section.
Proposed Corrective Action Process:
The USAR Quality Assurance Program commitments described in the attached 10 CFR 50.54 (a) evaluation and the TE management commitment would be modified under the proposed change for processing PCAQRs. The proposed process would still require prompt operability and reportability reviews, a structured timeline for resolution, a prompt signincance review, multi discipline review of the problem (if determined appropriate based on signincance), and a review of the corrective action (s) for adequacy. The assigned responsible department will review and investigate documented conditions adverse to quality (nonconformances) to determine, schedule and complete appropriate corrective action (s) in a timely manner. Ilowever, rather than the Nuclear Assurance personnel performing an independent close-out review of the corrective actions for adequacy (as is currently done), management of the responsible department will perform a review of the proposed corrective actions for adequacy, in the proposed DBNPS corrective action process, the Condition Report (formerly PCAQR)is initiated identifying the potential problem (including NRC ins). The Condition Report will be reviewed by 1 cognizant supervisor for completeness and immediate determination of whether this potential problem could impact plant operations. If the supervisor determines that the potential problem could potentially l
impact plant operations, the Condition Report will be reviewed by the Control Room Operations Shill Supervisor or Shill hianager to determine operability and reportability to the NRC in accordance with 10 CFR 50.72. Additionally, the potential problem will be assessed for impact on the Operating License Techn kal Specifications and the operability of applicable plant equipment.
A hianagement Review Committee, comprised of key station managers, will evaluate the Condition Report to: determine if the potential problem is a condition adverse to quality categorize the condition for significance, require multi-discipline review of the problem if warranted based on signi0cance, assign a responsible organization for restoration action, and determine if corrective action to prevent recurrence is required. Additionally, the hianagement Review Committee will independently evaluate the potential problem's impact on plant operations, if the hianagement Review Committee determines the potential problem could impact plant operations, the Conditim Report will be reviewed by Operations for equipment operability and reportability to the NRC.
The assigned responsible organization will determine the apparent cause(s) of the problem, evaluate equipment operability, determine 10 CFR 21 reportability, propose restoration action (s), and identify responsible organizations for completion of the corrective action (s), including due dates. When the proposed action (s) and schedule for completion have been agreed to (i.e., resolved), responsible management will signify their concurrence on the Condition Report. The Condition Report may then be I
closed and the actions will be tracked to completion. If appropriate, based on the roblem's significance, l
the Condition Report will then be reviewed by an independent supervisor / manager peer group.
If required, based on significance, the assigned organization will determine and document the root cause(s), propose corrective action (s) to prevent recurrence, and identify tasks to be performed and
(
determine duc dates. Depending upon the significance, the Condition Report may receive peer group review. When the corrective action (s) to a significant condition adverse to quality has been completed,
Docket Number 30 346 License Number NPF-3 Serial Number 2509 Page 4
' the coricctive action (s) taken will be documented and reported to appropriate levels ofinanagement. The in line review of each signincant condition adverse to quality by the Nuclear Assurance Department will no longer be performed.
These changes to the DBNPS corrective action process provide the following benefits: increase line management's accountability for timely and thorough corrective action, and remove an unnecessary administrative burden from the Control Room Operations Shift Supervisor for review of potential problems that do not impact plant operations. The proposed reliance on responsible management for scheduling and completion of corrective action (s) will permit the Nuclear Assurance Depanment to focus on verifying the cifcctiveness of corrective actions for nonconformances through audits and reviews as presently required by the Techaical Speci0 cation 6.5.8.2," Audits," and the USAR Quality Assurance Program Section 17.2.18," Audits." This approach is supported by recent analysis of the close-out review of PCAQRs (including signincant conditions adverse to quality) indicating the number of unsatisfactory PCAQR corrective action documentation errors has decreased to less than 1%. These rejections involved minor administra' ve errors, not failures of the corrective action process.
Summary:
The information provided above in this submittal to describe the corrective action process is for the purpose of describing the presently existing process and the proposed process, it does not preclude future changes to the corrective action process following normal practices, or to require additional NRC notifications or approvals of such changes other than those currently required. This submittal modifies the following NRC commitments as described below.
Commitments Changed:
- 1) The PCAQR process, as committed in TE letter Serial Number 1 1111, currently requires the
~
performance of an independent closc out review of PCAQRs (including NRC ins ) by the Nuclear Assurance Department. 2)The DBNPS USAR Quality Assurance Program also commits to the performance of a close-out review by the Nuclear Assurance Department's Nuclear Safety and Inspection Section. 3) The PCAQR process, as committed in the USAR Quality Assurance Program, currently requires an independent verification of the restoration action (s) and corrective action (s) to prevent recurrence to be performed,if appropriate based on the safety signincance, by the Nuclear Assurance Department.
Proposed Coimnitments Modifications:
- 1) The corrective action process commitment, as described in TE letter Serial Number 1-1 I 11, will be modified stating that responsible management (instead of the Nuclear Assurance Department) will review the Condition Report (including NRC ins) to determine the adequacy of the corrective action (s).
- 2) The attached marked-up USAR pages of Sections 17.2.1.4,17.2.15.2,17.2.16.1, and 17.2.16.2 describe the management review and concurrence requirements (instead of the Nuclear Assurance Department) for documenting, scheduling, and completing a Condition Report, including significant conditions adverse to quality.
Docket Number 50 346 License Number NPF 3 Serial Number 2509 Page5
' These ' roposed changes in the corrective action process were based on benchmarking the best practices p
of other nuclear power facilities (i.e., Browns Ferry, Cataw ba, Comanche Peak, Duane Arnold, P'lo Verde, Perry, Robinson, and South Tn 4 ') and the aerospace, airline, automotive, and petrochemical industries Toledo Edison requests tha. de NRC approve these proposed changes to the DBNPS Quality Assurance Program within the next 60 days in accordance with 10 CFR 50.54 (a)(3)(iv).
If you have any questions regarding this submittal, please contact Mr. James L. Freels, Manager -
Regulatory Affairs, at (419) 321 8466.
Very truly yours, 7
wA "V
JCS/1.,
Attachments c: A.11. Beach, Regional Administrator, NRC Region til S. J. Campbell, DB 1 NdC Senior Resident inspector A. G. llansen, Dil 1 NRC/NRR Project Manager Utility Radiological Safety Board e
)
=
_ - _ _