ML20236R144

SER Related to Quality Assurance Program Description Changes for Davis-Besse Nuclear Power Station,Unit 1

ML20236R144
Person / Time
Site:	Davis Besse
Issue date:	07/15/1998
From:	Bugg M NRC (Affiliation Not Assigned)
To:
Shared Package
ML20236R136	List: ML20236R134 ML20236R144
References
NUDOCS 9807210264
Download: ML20236R144 (3)

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SAFETY EVALUATION BY THE OFFICr 0F

s. NUCLEAR REACTOR REGULATION RELATED TO OVALITY ASSURANCE PROGRAM DESCRIPTION CHANGES TOLEDO EDIS0N COMPANY CENTER 10R SERVICE COMPANY MQ THE CLEVELAND ELECTRIC ILLUMINATING COMPANY DAVIS-BESSE NUCLEAR POWER STATION. UNIT NO. 1 DOCKET NO. 50-346 1.0 .[ INTRODUCTION In a letter dated February 16, 1998, Toledo Edison Company, Centerior Service Company, and The Cleveland Electric Illuminating Company (the licensees),

submitted a request for changes to the Davis-Besse Nuclear Power Station, Unit No.1, Updated Safety Analysis Report (USAR) Chapter 17.2, " Quality Assurance During the Operations Phase," (part of the Davis-Besse Quality Assurance Program or QAP) and Davis-Besse commitments previously made to the NRC in response to an NRC Notice of Violation (NOV). By letter dated May 11, 1998, in accordance with Nuclear Energy Institute guidance, the licensees formally notified the NRC Office of Enforcement of the proposed change of the commitment to the NOV.

The changes concern the processing and administration of the nonconformance/

corrective action program such as the Potential Condition Adverse to Quality (PCAQ) Program. The licensees state that "these changes are designed to establish greater product ownership and accountability in line management for ensuring proper corrective action administration and implementation, and allow the Nuclear Assurance [ Quality Assurance] Department to continue to focus on the independent evaluation of corrective action documents and the effectiveness of the corrective action process through the 10 CFR.50 Appendix B audit process,"

2.0 EVALUATION The PCAQ Report (PCAQR) process currently requires the performance of an independent close-out review of PCAQRs, including those generated for review of NRC Information Notices (ins), by the Nuclear Assurance Department. In i addition, the Davis-Besse 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. Finally, the PCAQR process, as l

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required'by the USAR Quality Assurance Program, currently requires an independent verification by the Nuclear Assurance Department of the restoration actions and corrective actions.

The corrective action process commitment will be modified stating'that responsible management (instead of the Nuclear Assurance Department) will review the Condition Report (including NRC ins) to deterafae the adequacy of the corrective actions. Sections 17.2.1.4, 17.2.15.2,.17.2.16.1, and 17.2.16.2 of the USAR will. be modified to describe the managensent (instead of the Nuclear Assurance Department) review and concurrence requirements for documenting, scheduling, and completing a Condition Report, including significant conditions adverse to quality.

2.1 Section 17.2.1~.4. Pace 17.2-5 The licensees propose to modify the fourth sentence in the Manager - Nuclear Safety and Inspection description by removing the phrase " review of all corrective actions documents for close-out," to read: "The Manager - Nuclear Safety & Inspection'is also responsible for review and approval or concurrence with select site procedures, receipt inspections, vendor surveillance and review of vendor supplied documentation, and Nuclear Safety & Inspection Staff training."

2.2 Sc-tion 17.2.15.2. Paae 17.2-43 The licensees propose to restructure the third paragraph by moving the first sentence to follow the second sentence in the paragraph, and modify the second I sentence by replacing " Nuclear Assurance" with " responsible management." The '

proposed third paragraph would read: "When the nonconformance has been resolved, responsible management personnel signify their concurrence on the corrective action document. The acceptability of repaired or reworked items is determine.1 by verifying through inspection or testing that the level of  ;

. quality obtained for the item is the same as, or at least equivalent to the '

original quality requirements."

2.3 Section 17.2.16.1. Pace 17.2-44 The licensees propose to modify the first sentence in the fourth paragraph by replacing " Nuclear Assurance Department's" with " responsible management's" to read: "Correctin action documents contain provisions for identifying the root cause of the condition adverse to quality, the recommended corrective 1 action, and the corrective action taken to prevent recurrence, in addition to j the responsible management's documentea concurrence'of the adequacy of the 1 corrective action." The licensees also propose to eliminate the second sentence in tha fourth paragraph: "The Nuclear Assurance Depa~tment also has the; final review of all corrective action documents for close sut."

. td.4 Section 17.2.16.2. Pace 17.2-(1 I

The licensees propose to modify the second sentence in the first paragraph by i

, replacing " Nuclear Assurance Department performs 'a follow-up review or. audit to verify the adequacy of the corrective action" with." corrective action taken j

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I shall be documented and reported to appropriate level of management" to read:

"When the corrective action to a significant condition adversa to quality has been completed, the corrective action taken shall be documented and reported to appropriate levels of management."

2.5 Discussion l The proposal will delete the Nuclear Safety & Inspection Manager's responsibility of reviewing All corrective action documents for close-out.

1 The manager of Nuclear Safety & Inspection reports to the Director of Nuclear Assurance (Davis-Besse's QA Organization). The licensees are proposing that {

responsible management review all corrective action documents for close-out.

Also, the Nuclear Asserance organization will no longer perform a follow-up review or audit for all significant conditions adverse to quality. However, {

the corrective action taken will be documented and reported to the appropriate

~

levels of management. That is, the Nuclear Assurance organization will have no continuous review duties to close out corrective actions.

Article 11.16, Section 17.1 and 17.2, Revision 1 of the Standard Review Plan (NUREG-0800) describes the attributes of an acceptable corrective actinn process. Davis-Besse proposes that Nuclear Assurance monitor the effectiveness of the nonconformance/ corrective action program and the effectiveness of the corrective actions, as it performs audits (required by Technical Specification 6.5.2.8.c) of the "results of actions taken to correct deficiencies occurring in unit equipment, structures, systems or method of operation that affect nuclear safety."

The staff finds the deletion of direct Nuclear Assurar.ce Department involvement in processing PCAQRs acceptable provided that the Nuclear Assurance organization continues the audit of the corrective action program every six months and this audit scope includes an audit of the implementation, disposit-ion, and close-out of corrective actions. The licensees did not request any new exceptions of current commitments to NRC regulatory guides which conditionally endorse industry standards.

3.0 CONCLUSION

The proposed QAP changes described above constitute a reduction in commitment from the previously approved QAP. These changes meet the acceptance criteria in Article 11.16, Section 17.2, Revision 1 of the Standard Review Plan (NUREG-0800). Therefore, the propcsed revision to Davis-Besse's QAP, dated February 16, 1998, part of which was reiterated in the licensees' letter dated May 11, 1998, continues to comply with the quality assurance criteria of Appendix B to 10 CFR Part 50 and is acceptable.

Principal Contributor: M. Bugg Date: July 15, 1998