ML17191A595

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Notice of Violation from Insp on 980212-0305.Violation Noted:Master Records Retention Schedule of Procedure 136,dtd 950915 Failed to Designate Measuring & Test Equipment Calibration Records as Quality Assurance Records
ML17191A595
Person / Time
Site: Dresden  
Issue date: 04/14/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17191A594 List:
References
50-237-98-07, 50-237-98-7, 50-249-98-07, 50-249-98-7, NUDOCS 9804170096
Download: ML17191A595 (2)


Text

NOTICE OF VIOLATION Commonwealth Edison Company Dresden Station, Units 2 and.3 Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 During a Nuclear Regulatory Commission (NRC) inspection conducted on*February 12 through March 5, 1998, one violation of NRC requirements was identified. In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 6.8.A.1 required the implementation of Regulatory Guide 1.33, Revision 2, 1978 "Quality Assurance Program Requirements (Operations)."

Regulatory Guide 1.33 required the implementation of American National Standards Institute (ANSI) N 18. 7-1976/ ANS-3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."

Section 5.2.12 of ANSI N18.7-1976 required that ANSI N45.2.9-1974, "Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants,"

be used for the management of plant records during the operational phase.

Appendix A of ANSI N45.2.9-1974 required that Measuring and Test Equipment (MITE) calibration records be retained as quality assurance (QA) records for at least five years.

Contrary to the above, the licensee identified that previous to December 22, 1997, the Master Records Retention Schedule of General Procedure GP 136, dated September 15, 1995, "Retention of Company Records, " failed to designate measuring and test equipment calibration records as quality assurance records and the procedure allowed the records to be eliminated after three years.

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

Pursuant to the provisions of 10 CFR 2.201, Commonwealth Edison Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, _within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not.received within the time specified in this Notice, an order or a Demand for Information niay be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken.

Where good cause is shown, c6nsideration will be given to extending the response time.

9804170096 6~866~37

~DR ADOCK PDR

Notice of Violation 2

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Beca.use your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information.. If you request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790 (b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 1 O CFR 73.21.

Dated at Lisle, Illinois this/~ay of April 1998