ML20071N750

Responds to NRC 820816 Ltr Re Violations Noted in IE Insp Rept 50-346/82-03.Corrective Actions:Qa Program Will Be Updated to Include Review of Regulatory Requirements & Commitments

ML20071N750
Person / Time
Site:	Davis Besse
Issue date:	09/07/1982
From:	Crouse R TOLEDO EDISON CO.
To:	Norelius C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20071N742	List: ML20071N750
References
1-291, NUDOCS 8210080288
Download: ML20071N750 (2)

Text

'

e TOLEDO Docket No. 50-346

%m EDISON License No. NPF-3 RCHARo P. CROUSE Serial No. 1-291 y;;7"**

44191259-5221 September 7, 1"82 Mr. C. E. Norelius, Director Division of Engineering and Technical Programs U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Norelius:

Toledo Edison acknowledges receipt of your August 16, 1982 letter (Log No. 1-668). This letter requested a revised response to Violation No. 5 as identified in the Appendix to your letter dated April 1,1982, as well as our schedule for upgrading our Quality Assurance Program to include review and/or audit of plant safety related activities utilizing all applicable regulatory requirements and commitments. Our revised response to Violation No. 5 follows.

Violation: 10CFR50, Appendix B, Criterion XVIII, requires that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program.

Toledo Edison Company Nuclear Quality Assurance Procedure QAP 2180, " Audits," states in part, "A comprehensive system of planned periodic audits to verify compliance with QA program requirements and to determine QA program effcctiveness shall be conducted.... The goals of the audit system are...

to provide an objecti'.a assessment of compliance with established requirements."

Toledo Edison Company Nuclear Quality Assurance Manual, Volume 1, Section 1.2.8, defines Audit Activity as " Documented QA/QC activities to determine, through investigation, the adequacy of, and adherence to... licensing requirements."

Contrary to the above, the quality assurance audits of the fire protection program performed in June 19-26, 1979 (Audit No. 598),

April 21 - May 30, 1980 (Audit No. 666) and March 23-25, 1981 (Audit No. 744), only reviewed the adequacy of implementation of the existing plant procedures. Assessments were not made 8210000288 821004 i

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THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 SEP. 1 3 ht23

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Serial No. 1-291 September 7, 1982 Page 2 concerning the adequacy of those procedures utilizing the fire protection licensing requirements as inspection guidance.

This narrow scope for the quality assurance audits permitted deficiencies in fire protection procedures to go undetected.

Response: Contrary to the evaluation made above, Toledo Edison considers its present procedure review and audit program in compliance with the quality assurance program commitments made in Chapter 17.2 of the Davis-Besse Unit #1 FSAR. However, Toledo Edison will upgrade its quality assurance program to include the review of regulatory requirements and commitments into the audit program.

Regulatory requirements are interpreted as those plans which receive NRC approval (e.g., Emergency Plan, Security Plan, Fire Hazard Analysis Report, Inservice Inspection Program, etc.) as well as those NRC Regulatory Guide and ANSI Standards committed to in Chapter 17.0 of the Updated Safety Analysis Report.

Toledo Edison will revise its quality assurance program to include the requirement for auditing. regulatory requirements prior to January 1, 1983.

Very truly yours,

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RPC/CTD je d/1 cc: DB-1 NRC Resident Inspector

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