IR 05000010/1973004
| ML19338E374 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Zion  |
| Issue date: | 11/16/1973 |
| From: | Pomeroy D, Reinmuth G, Lester Tripp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19338E372 | List: |
| References | |
| 50-010-73-04, 50-10-73-4, 50-237-73-04, 50-237-73-4, 50-249-73-05, 50-295-73-36, 50-304-73-18, NUDOCS 8009250558 | |
| Download: ML19338E374 (16) | |
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U. S. ATOMIC ENERGY COMMISSION
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DIRECTORATE OR REGULATORY OPERATIONS
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REGION III
s Report of Special Inspection
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RO Inspection Report No. 050-010/73-04 R0_ Inspection Report No. 050-237/73-04 RO Inspection Report No. 050-249/73-05 RO Inspection Report No. 050-295/73-36 RO Inspection Report No. 050-304/73-18
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Licensee:
Commonwealth Edison Company.
Post Office Box 767 Chicago, Illinois 60690 Dresden Station Unit 1 License No. DPR-2 Category: C Dresden Station Unit 2 License No. DPR-19 Category: C Dresden Station Unit 3 License No. DPR-25 Category: C Zion Station Unit 1 License No. DPR-39 Category: B Zion Station Unit 2 License No. CPPR-60 Category: B
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t Type of Inspection:
Special (Nuclear Fuel Procurement QA Program)
i Dates of Inspection:
September 25 - 27, 1973 D. L. Pomeroy h. * fY
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Principal Inspector:
(Date)
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Accompanying Inspector:
L. E. Tripp O'/b '7 I (Date)
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Other Accompanying Personnel: None
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Reviewed By:
G. W. Reinmuth, Chief
Technical Assistance Branch (Date)
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A.
Background
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The Directorate of Regulatory Operations conducted a special inspection of the quality assurance (Q/A) system employed by Commonwealth Edison
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-Company (CE) in the procurement of nuclear fuel.
The' primary objective
of this inspection was to obtain information which would permit an appraisal of the implementation and effectiveness of the Q/A controls employed by CE in the procurement of nuclear fuel to assure compliance I
with the 18 Q/A criteria for Nuclear Power Plants (Appendix B, 10 CFR Part 50). The inspection findings are based on review of pertinent
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documents such as the CE Q/A Manual, Q/A procedures, supplier evaluation reports,. purchase orders and reports of inspections of fuel fabricators as supplemented by interviews with CE personnel.
i B.
Enforcement Actions
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The following items of noncompliance were identified during the inspection.
1.
10 CFR 50, Appendix B, Criterion V states in part: " Activities affecting I
quality shall be prescribed by documented.
. procedures,
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appropriate to the circumstances and shall be accomplished in accordance with these.
, procedures,
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Contrary to the above:
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a.
A procedure (Q.P. No. 10-2) has been prepared for use in inspection at the fuel contractor. However, the procedure does not include requirements to i) provide for the assignments-of qualified
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inspectors; 11) prepare documented results of the inspections; iii) provide for management review of inspection results; iv)
reinspect deficient areas; and v) prepare inspection plans or check-lists for each inspection or inspection-type.
(See Details, Section 3)
b.
Procedure Q.P. No. 10-2 requires that during the pre-manufacturing phase a schedule of audits will be established. However, a schedule of audits of fuel contractors has not been prepared.
(See Details, Section 8.1)
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c.
Procedure Q.P. No. 10-2 requires that the Quality Assurance
i Administrator verify completion of corrective action (taken by the fuel manufacturer on areas found deficient by the Nuclear Fuel Ir.spector). However, no systematic method has been developed for following up on deficiencies and thereby allow the Quality Assurance Administrator to verify completion of corrective actions.
(See Details, Section 8.4).
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2.
10 CFR 50, Appendix B, Criterion VII states in part: " Measures shall be established to assure that purchased material,
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conform to the procurement documents. These measures shall include evidence of quality furnished by the contractor, inspection at the contractor source, and examination of products upon delivery.
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The effectiveness of the control of quality by contractors shall be assessed by the applicant or designee at intervals consistent with the importance, complexity, and quantity of the product or services.'
Also, Criterion IV requires that contractors provide a quality assurance program consistent with the Appendix B criteria.
Contrary to the above, inspections of fuel contractors were incomplete
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in that these inspections were not conducted against each of the Appendix B Criteria. For example:
a.
Criterion I-Organization.
Inspections of fuel contractors do not include a determination that the fuel contractors' organization provides that: 1) the authority and duties of persons performing quality assurance function are clearly established and delineated in writing; and 11) such persons have sufficient authority, organizational freedom and independence to identify quality problems;
to initiate, recommend, or provide solutichs; and to verify
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implementation of solutions.
(See Details, Section 8.2)
b.
Criterion III-Design Control. Although the responsibility for fuel design contractor, pnd design review is delegated to the nucelar fuel y
the inspections did not determine the establishment or effectiveness of the design control measures applied by the fuel contractor.
(See Details, Section 8.2)
c.
Criterion IV and VII-Control of Procurement Documents and Purchased Material.
Inspections of fuel contractors did not include a determination that the fuel contractor is assuring that adequate requirements are included in his procurement documents. These inspections did not include a determination that material purchased by the fuel contractor conforms to the procurement documents.
(See Details, Sc tion 8.2)
d.
Criterion IX-Control of Special Processes.
Inspections of fuel contractors did not include a determination that the special processes used in the manufacturer of nuclear fuel are cccomplished by qualified personnel using qualified procedures.
(See Detaiis, Section S.2)
e.
Criterion XVI-Corrective Action.
Inspections of fuel contractors did not include a finding that 1) the fuel cot tractor determines the causes of conditions adverse to quality; ii) takes corrective action to preclude repetition; iii) documents causes and corrective actions;
and iv) reports these to appropriate levels of his management.
(See Details, Section 8.2)
1/ " Responses to AEC Inquiry Concerning Commc 3 wealth Edison's Quality Assurance Program for Nuclear Fuel," dated March 22, 1973, submitted to Licensing on May 16, 1973, Docket No. 50-I..
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3.
10 CFR 50, Appendix B, Criterion XVI states in part: " Measures shall be established to assure that conditions adverse to quality, such as deficiencies, deviations, defective material, and non-conformances are promptly identified and corrected. The identifi-cation of che significant condition adverse to quality, the cause of the condition, and the corrective action taken shall be documented and reported to appropriate levels of management."
Contrary to the above, a) identification of significant conditions adverse to quality from the fuel inspector's inspections were not
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reported to appropriate levels of management and b) corrective actions
were not documented and reported to appropriate levels of management.
(See Details, Section 8.2)
i 4.
10 CFR 50, Appendix B, Criterion XVIII states:
"A comprehensive
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system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program. The audits shall be performed in accordance with the written procedures or checklists by appropriately trained personnel not having direct responsibilities
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in the areas being audited. Audit results shall be documented and reviewed by management having responsibility in the area audited.
Follow-up action, including reaudit of deficient areas, shall be taken where indicated."
Contrary to the above, no internal audits had been performed to verify compliance with, nor determine the effectiveness of the quality assurance program for the purchase of nuclear fuel.
(See Details, Section 4)
C.
Significant Findings
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1.
A review of the records of CE inspections conducted at three fuel
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fabricators indicated that some 40 insp2ctions had been made,slasting 2-3 days each. The inspection reports indicated that substantive deficiencies with the fabricators Q/A program were often found, however, i
follow-up actions were found to be inconsistent.
(See Details, Section 8)
2.
CE is reorganizing their Q/A functions and has recently established
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a " Manager of Q/A" position reporting to an Executive Vice President.
(See Details, Section 2)
3.
A review of nuclear fuel purchasing documents indicated that Q/A requirements were being included.
(See Details, Section 6)
4.
CE has utilized outside laboratories for independent analyses of production fuel quality.
(See Details, Section 9)
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5.
CE fuel failure experience is being analyzed and there is feed-back from this experience into the fuel QA program.
(See Details, Section 10)
D.
Management Interview At the conclusion of the inspection Messrs. Pomeroy and Tripp met with the following CE personnel:
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Name Title J. H..Ellis Section Engineer - M&S Engr.-CECO W. M. Kiefer Director, Nuclear Fuel Services R. J. Squires QA Coordinator (Production)
- W. J. Shewski Manager of QA G. F. Marcus Fuel' Agent E. J. Hemzy QA Administrator (Engrg. & Constr.)
L. W. Duchek Nuclear Fuel Inspector
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The meeting was opened with comments from Mr. Pomeroy regarding the purpose of the inspection and its relationship to the direct inspections by Regulatory Operations at fuel fabricator facilities.
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It was explained that the presentation of findings would include,'in addition to deficiencies identified, the personal observations and conclusion made by the inspectors for whatever benefit the licensee might derive. The introductory remarks were concluded with an explanation of the method by which the inspection findings would be documented and the subsequent release of these documents to the Public Document Room.
Following these comments, the detailed results of the inspection were discussed, as described in Paragraph B and C above. Comments by the licensee are outlined below:
1)
Internal Audits The licensee questioned the inspectors regarding the need to conduct audits of their fuel Q/A program. Were they to " audit" the " auditor"?
The inspectors replied that the type of_ program that CE had outlined in their Quality Procedures No. 18-1, General Office Audit of Total Quality Assurance Program, was what they had in mind.
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The inspectors also stated that the implementation of this type of procedure to the fuel Q/A program would appear necessary to meet the requirements of the CE Q/A policy manual which states in part (Q.R.18.0 Internal Audits): " Audits will be performed by CE Co.
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to verify the adequacy and effectiveness of~ quality programs under their cognizance. These audits are to be conducted to assist the
organization being audited and assure that required corrective action or improvements are accomplished."
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2) Qualification of Fuel Contractors The inspectors discussed the commitments made in the CE submittal to Regulatory Licensing on their fuel Q/A program regarding the evaluation of contractors. ' The inspectors stated that these commitments did not appear to have been implemented. CE personnel stated that a procedure had been prepared to implement this commitment, that it would
. be used in the future and that it was now being used as an aid in their contractor inspection program.
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3) Contractor Inspections
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The inspectors stated that based on the experience of RO inspectors with inspections of this type, many of the CE fuel QA inspections
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should have been conducted by a team (2 or 3) of inspectors rather than by one person due to the complexity of typical nuclear fuel fabrication operations. This would permit the utilization of inspection personnel with different (but complimentary) backgrounds and technical expertise and would avoid the situation ia which one
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inspector confronts several vendor personnel by himself. CE responded that they believed "can days" of inspection time was a better criteria for gaging the' scope of an inspection program.
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DETAILS
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Persons Contacted J. A. Abel, Nuclear Licensing J. Dolter, Nuclear Fuel Services L. W. Duchek, Nuclear Fuel Inspector E. J. Hemzy, QA Administrator (Engineering and Construction)
W. M. Kiefer, Director, Nuclear Fuel Services G. F. Marcus, Fuel Agent, Purchasing W. Shewski, Manager of Quality Assurance RJ J. Squires, QA Coordinator (Production)
A. Veras, Nuclear Fuel Service:
2.
Fuel QA Organization Tha Commonwealth Edison Company (CE) responsibility for nuclear fuel quality acsurance is as follows:
President - Overall responsibility for CE Nuclear fuel quality assurance program.
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Manager of Quality Assurance - Responsible for development, implementation, and execution of nuclear fuel quality assurance program.
Mr. Shewski has just recently been appointed to this position as a part of the reorganization currently in progress at CE.
Until his appointment, these responsibilities were shared by the V.
P., Engineering and Construction and the Manager of Production.
Fuel Agent - Responsible for coordinating design control and procurement document control as well as controlling the distribution of documents.
Nuclear Fuel Inspector - Responsible for evaluation of contractor's fuel QA program; surveys of the fuel contractor for implementation of special process procedures, assurance that procedures are established and executed, assurance that test controls are established and executed, assurance that procedures and records for calibration of test equipment are established and executed, assurance that instructions for handling, preservation, storage,and shipping are established, and disposition of non-conforming items including identification and correction; determination that the contractor's QA program includes procedures for identification of items and traceability of documentation; and for audits of the fuel j
contractor's procedures.
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In this review, particular emphasis was placed on Q.P. 10-2 since this procedure was the most applicable to the fuel QA program. This procedure has no requirements for assignment of qualified inspectors to the fuel surveillance program. Although the general areas to be inspected during the fabrication surveillance program are outlined, this procedure cannot be used as an inspection plan or checklist.
In the procedure, there are no requirements to prepare inspection reports or documented results of inspections, for managemane review of inspection results, for reinspection in area found deficient, or to conduct the inspections in accordance with written proceduras or checklists for each inspection or inspection type.
4.
Audits The CE QA policy manual, in Section 18.0 on Internal Audits, states in part that, " Audits will be performed by CE Co to verify the
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adequacy and effectiveness of quality programs under their cognizance.
These audits are to be conducted to assist the organization being audited and assure that corrective action or improvements are accomplished."
Organizationally, these audits appear to be the responsibility of the Mechanical and Structural Engineering Department and the Station Electrical Engineering Departmant. The RO inspectors asked CE representa-
-c tives if any internal audit of their fuel QA program had ever been done to s
determine its effectiveness and were told that no internal audits had evet been performed of the fuel QA function.
5.
Qualification of Fuel Contractors The CE submittal to Licensing dated March 22, 1973, states in part that, " Qualified contractors are selected on the basis of evaluated or demonstrated capability to provide a product, process, or service.
An overall review of the contractor's quality assurance program is performed as necessary. Where valid records.sf contractor capability and quality performance are not available to Commonwealth Edison Company, a survey of the contractor's facilities, capabilities, and quality assurance systems has been made by Commonwealth Edison Company or its designated representatives.
Such surveys include, as applicable, a review of facilities, organization, quality assurance experience, existing controls, knowledge of special processes, and an understanding of, and a willingness to meet, contract or purchase order requirements."
Since 1970, Jersey Nuclear (now Exxon Nuclear) has been considered as an approved potential supplier of reload fuel. The inspectors reviewed the qualification procedure for Jersey Nuclear. According-to Mr. Marcus, Jersey Nuclear made one or more technical presentations to CE representa-tives, Mr. Veras made a visit to their fabrication facilities, and a detailed written proposal to another utility which included a description of Jersey Nuclear qualifications was made available for CE teview. CE conducted a search of their records and was unable to find any documentation to indicate that an evaluation of Jersey Nuclear was made or that demonstrated capability had been evaluated.
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The CE Quality Assurance Manual now has a procedure (Q.P. 4-2) for i
evaluation of contractor's quality assurance program and another procedure now in preparation has requirements for evaluation of the vendor's quality program prior to award of contract.
Such procedures, if implemented, would appear to be an adequate method to assure that only qualified suppliers were considered for nuclear fuel orders,
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6.
Procurement Document Control The methods for assuring that procurement documents contain the necessary l
QA requirements were covered by the inspectors. The method for getting these requirements into contracts is an informal approach and no written procedure has been prepared. The fuel agent consults with the QA staff to get their input as to what was required to handle QA/QC audits,-inspections, surveillance, etc.
Portions of fuel contracts from the late 1950's thru 1972 were examined with one of the most recent examined in' detail.
This recent contract requires the fuel supplier to establish a proccam
such that CE c n satisfy applicable USAEC requirements as to fue1 quality.
It requires the fuel vendor to submit his quality assurance prcgram in writing to CE for review and comment prior to fuel manufacture.
It also applies to the fabricator's subvendors. Finally, it requi~es the fabricator
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to make applicable records, procedures and data availab1; to CE for
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inspection and it establishes the right of access of CE representatives
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to vendor and subvendors ahops for necessary inspections.
7.
CE Review of Fuel Design and Fabrication Changes The CE March 22, 1973, submittal states that, "in areas of special
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concern the contractor requests review and comment before modification started." As a result of PWR fuel experience, changes were made to the
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Zion 1 and Zion 2 initial cores after fabrication had ctarted. To observe the CE implementation of the above commitment, the RO inspectors asked to review the CE actions relative to these changes.
l CE representatives followed applicable PWR experience closely including direct contacts with the station staff. Af ter review and discussions wit a Westinghouse of their recommendations, it was agreed on October. 25, 1972, to use the original Zion 2 fuel (Regions 2 and 3) in Zion 1 after.
increasing the fuel density and the internal pressurization pressure. The original Region 3 fuel of Zion Unit 1 was refabricated (the contained uranium was reconverted to UF and subsequently reconverted to UO ) to be used
7 in Region 3 of Zion Unit 2.
The original Region 2 fuel of Unit 1 was repres-surrized at a higher pressure for utilization in Region 2 of Unit 2.
The CE documentation of the above modifications indicated that CE personnel had reviewed other utility experience with Westinghouse fuel, reviewed the proposed modifications, commented as appropriate, and
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concurred with the actual modifications.
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8.
' Inspections of Fuel Vendors The CE fuel fabricator inspection program is described below.
8.1 General The CE Nuclear Fuel Inspector (NFI),was hired upon graduation from college approximately three years ago.
According to Mr. Henzy, he conducts surveillance inspections, not audits.
In his early inspections,
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he was accompanied by Mr. Squires and/or by representatives of a CE consultant, NATCO. NATCO als o assisted CE in the fuel QA program by making'an evaluation of tha Westinghouse fuel QA program during late 1971 - early 1972.
Since the initial inspections, the Nuclear Fuel Inspector has been conducting vendor inspections by himself.
The NFI writes a report describing these inspections to the QA Administrator. The NFI attempts to get' deficiencies noted.in his inspections corrected at the time of the inspection, at the exit meeting at the vendor, or thru the participation of appropriate CE management.
The NFI has no pre-planned schedule for inspections. His inspection
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trips to the vendor are based on when CE fuel is to be manufactured.
According to,the NFI, he regularly talks by phone to the fabricator's representatives to deterrine when CE fuel will be in manufacture'and schedules his trips accordingly. This is not in agreement with Q.P.
No. 10-2 which requires that a schedule of audits will be established-during the pre-manufacturing phase.
Inspections are.not conducted in accordance with written procedures. The NFI may submit a list of items or areas to be looked at to the QA Administrator for his concurrence prior to visiting the vendor. From the RO inspectors conservations with the NFI, it was apparent that inspections are not conducted on a planned or systematic basis and little use is made of written procedures of checklists.
8.2 Reports of Inspections The.CE surveillance trips to Westinghouse, GUNFC and General Electric are summarized in Table'1. 'Most of the reports covering these
. inspections were reviewed ~1n this inspection.
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TABLE I'
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NUCLEAR FUEL FABRICATION INSPECTIONS Ii '.
l Year Company No. of-Inspections and Location No. of Days of Inspections 1971
- G. E.
Wilmington (5)
1 GUNFC Hematite (1)
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New Haven (1)
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Columbia-(2)
Pittsburgh (1)
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i 1972 GE (0)
t CUNFC Hematite (3)
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New' Haven (2)
l Elmsford (1)
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Cheswick (4)
Monroeville (1)
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Columbia-(7)
1 1973 GE Wilmington (2)
GUNFC New Haven (1)
EJmsford (1)
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- W Columbia (4)
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The NFI's reports showed a lack of organization and cover the details of these surveillance inspections in a rambling manner.
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Significant findings were not highlighted or summarized in these
reports. Outstanding or unresolved items were not listed or highlighted for management attention and followup in subsequent
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inspection for resolution.
Except for the NFI's memory, there was no method for maintaining a current list of problems identified during the inspection and no procedure for assuring closecut or resolution of outstanding items.
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Correspondence to and from the vendors was reviewed which indicated that some problems were being resolved in this manner. 'In this correspondence, there was no evidence that these letters were being cross checked with the items and issues raised in the inspection reports so that all problems could be resolved.
The NFI's reports were reviewed to determine if they established t
that the fuel fabricator contractor's quality assurance program meets the requirements of the 18 Criteria of 10 CFR Appendix B.
In several areas, it was found that the NFI had not established that the fuel
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contractors' programs were in compliance with these criteria.
In general the surveillance inspections were QC, not QA inspections.
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Specific examples where the UFI had failed to establish contractor compliance included the following:
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The NFI's reports did not include evidence of critical evaluation or inspection of the vendor's QA organizatien.
j Design, design review, and design control responsibilities
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are assigned to the vendor. However, CE had the responsibility for auditing these areas to insure that they are being properly accomplished. No audits of design, design
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review, and design control activities at G.E.,
GUNFC or Westinghouse have been performed.
Inspections at the fuel contractors did not cover in sufficient detail procurement documents and incoming or receiving QC inspections.
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Inspections at the fuel contractors did not establish that special manufacturing processes and procedures are qualified or that persons performing activities affecting quality 2re properly trained and qualified.
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The NFI's verification of the fuel vendor's initiation of corrective actions is only accomplished to the point of
I verifying that deficiencies in CE fuel are corrected or repaired and not to assure that deficiencies will not be repeated.
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In reviewing the NFI's inspection reports, the RO inspectors found indications that the NFI had encountered problems in obtaining access to necessary records, procedures, and data to assess the effectiveness of the vendot's fuel QA program. However, by the time of this inspection, most of the access problems had'been resolved satisfactorily.
Another item of interest found in the NFI's reports was the fact that four Dresden I Batch 9 fuel assemblies were fabricated in Japan using AEC en*iched UF material by Sumitomo Electric Industries, Ltd. (SEI),
a licensee of GUNFC. These assemblies were fabricated in accordance with GUNFC drawings and specifications and under GUNFC's supervision.
SEI was not required to have a quality system manua? for fuel fabrication. The QA manager at GUNFC identified, carough discussions with SEI, that adequate plans for inspection, etc. existed. These
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discussions were documented in an internal CUNFC memo PM-667 dated July 10, 1972.
8.3 NATCO Assistance CE together with Consolidated Edison and Vepco, hired an outside consultant (NATCO) to assist them in the fuel QA area with respect to the Zion 1 and 2 fuel manufacture by Westinghouse. Phase 1 of this effort was initiated on August 16, 1971, and covered a five-month period. Phase 1 was comprised of an overall detailed review, analysis, and evaluation for the participating utilities of specifications for purchased and Westinghouse-manufactured materials, the operations and processes, and the associated quality assurance and quality control programs used by Westinghouse to fabricate nuclear fuel assemblies.
Phase 2 consisted of audit-inspections of Westinghouse operations during the fabrication of the Zion fuel for CE.
During this inspection, the RO inspectors reviewed some of the reports submitted by NATCO. These reports raised what would appear to be several valid concerns about Westinghouse QA/QC programs and procedures.
However, many of these concerns were not resolved by CE, and were never pursued.
In their last report of May 18, 1972, NATCO states that, "NATCO and Commonwealth Edison representatives requested that Westinghouse formally reply to the utility on each of the statements and suggestions listed in Section 2.0 cf this report. --- NATCO suggests
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i that Commonwealth Edison follow up with Westinghouse on each issue and consider. meeting with Westinghouse representatives at a higher-management level to obtain their concurrence on some of the requests which.the utility deems critical to the quality assurance program." Howeve:
most of the unresolved items listed in this-report were never resolved i
or closed-out and no meeting of the type suggested by NATCO was ever-held between CE and Westinghouse. The NFI did go through the issues raised by NATCO item-by-item and write down (in long. hand) his thoughts and opinions which included some items'which he consideied satisfactorily resolved but there was no evidence that his comments were ever formally transmitted to management.
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8.4 Management Participatioq,
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Management participation in the surveillance inspection program appeared
to be minimal. CE management did not participate directly in inspec-tions and had little participation in followup actions to resolve
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problems identified in the NFI's rep' orts.
For example, at the i
conclusion of the NATCO assistance program, a meeting.was held in
Monroeville, Pa., on May 1-2, 1972, to discuss all remaining unresolved
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concerns of NATCO and the -CE NFI regarding the Westinghouse fuel QA program. There was no management participation by CE in this meeting (caly the NFI~ represented CE).
The NFI writes his inspection reports to the QA Administrator for Engineering and Construction with copies to other departments within
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CE that have an interest in his inspections. The QA Administrator does not comply with the requirements of Q.P. No. 10-2 which require him to verify the completion of corrective actions. There is no documented
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listing to'the QA Administrator of unresolved deficiencies in the fuel vendors' QA/QC programs in the NFI's reports. The QA Administrator's participation in followup on outstanding items with the fuel fabrication vendors appears unorganized and undocumented. Closcout
actions on deficiencies are-generally transmitted verbally or in the text.of the inspection reports to the QA Administrator.
In one case, after the fuel fabrication was nearly completed, the N.I went
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back through the' inspection reports for that vendor and indicated in a written manner on a report-by-report bi ais to the QA Administrator-what had happened with respect to the deficiencies in the vendor's program discussed in thc.e reports, i
CE management has not directed the NFI to develop inspection
plans and schedules, to highlight deficiencies found at the vendors, I
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or write his reports in a more systematic or organized manner, - however, he has been instructed to make his reports more brief and to the point.
Although CE management was responsible for hiring an outside consultant to assist in their fuel.QA program, this censultant's work appeared ineffective due to inadequate CE management participation and followup.
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9.
Independent Analyses of Production Fuel Quality CE has utilized outside assistance in specialized areas. On occasion, they have utilized two outside laboratories for checks on pellet moisture and chemical impurity content. Some weld samples have been taken for metallographic examination. This is not done on a routine basis but rather as a spot check. When one vendor proposed to utilize a special type of cladding material in some test rods in one of their reactors, CE hired an outside consultant to evaluate the proposal before acceptance.
10. Fuel Performance Feedback into the Fuel QA Program CE fuel failure experience was revie~wed to determine how this experience was factored into measures to prevent further or future fuel failures.
The Nuclear Fuel Services department analyzes fuel failure mechanisms and failure experience in detail working jointly with the vendors.
(They are currently attempting to hire a fuel technologist with expertise in fuel design and fabrication.) These fuel failures are discussed informally with the fuel QA people (NFI and QA Administrator) and the Nuclear Fuel Services department receives copies of all of the NFI's reports. The Nuclear Fuel Services department utilizes the NFI to get the necessary-
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r::ords for attempts to correlate fuel failures with specific fuel manufacturing activities. CE has not looked into detailed specifications related to items such as moisture or hydrogenous material content of the fuel. The leave such matters to the vendor but utilize fuel contracts-which provide strong economic incentives to the vendors to produce sound, long life fuel. In several cases CE has required the vendor to replace failed or defective fuel including a complete core replacement for Dresden 2.
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UNITED STATES
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ATOMIC ENERGY COMMISSION
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E DIVISION OF COMPLIANCE REGION lit egg g 799 ROOSEVELT ROAD TELEF". cone GLEN ELLYN, ILLINols 60137 (312) ass.2eso I
A.
RO Inspection Report No.(s)
050-010/73-04, 050-237/73-04, 050-249/73-05, 030-ca/ /3-ao, vau-304/73-18.
November 21, 1973 Transmittal Date
Eistribution:
Distribution:
RO Chie f, FS&EB R0 Chief, FS&EB RO:HQ (5)
RO:HQ (4)
DR Central Files L:D/D for Fuel & Materials Regulatory Standards (3)
DR Central Files Licencing (13)
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B.
RO Inquiry Report No.
i Transmittal Date
Distribution:
Distribution:
R0 Chief, FS&EB R0 Chief, FS&EB RO:HQ (5)
RO:HQ DR Central Files DR Central Files Regulatory Standards (3)
RO Files Licensing (13)
RO Files C.
Incident Notification From:
(Licensee & Docket No. (or License No.)
Transmittal Date
Distribution:
Distribution:
RO Chief, FS&EB RO chief, FS&EB RO:HQ (4)
RO:HQ (4)
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Licensing (4)
L:D/D for Fuel & Materials DR Central Files DR Central Files RO Files RO Files l
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