IR 05000010/1974008
| ML19340A667 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/22/1974 |
| From: | Dance H, Johnson P, Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19340A664 | List: |
| References | |
| 50-010-74-08, 50-10-74-8, 50-237-74-05, 50-237-74-5, 50-249-74-08, NUDOCS 8009020604 | |
| Download: ML19340A667 (30) | |
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l U. S. ATOMIC ENERGY COMMISSION
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DIRECTORAIE OF REGULATORY OPERATIONS i
REGION III
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1 RO Inspection Report No. 050-010/74-08
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RO Inspection Report No. 050-237/74-05
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RO Inspection Report No. 050-249/74-08
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i Licensee:
Commonwealth Edison Company P. O. Box 767 s;hicago, Illinois 60690
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Dresden Nuclear Power Station Licenses No. DiPR-2, DPR-19 Units 1, 2 and 3 and DPR-25 Category:. C
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Type of Licensee:
GE, BWR, 200 and 800 Mwe (Net)
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Type of Inspection:
Special
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Dates of Inspection: June 10 - 14, 25 - 26, 1974
Dates of Previous Inspection: May 6 - 8, 10 and 15, 1974 (Materials)
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j Principal Inspector:
R. C. Knop ly fC Yw lkn-b 22-7/-
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Accompanying Inspectors:
P.
H.- Johnson
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j H'. C. Dance
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Other Accompanying Personnel:
J. Costello
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Reviewed By:
G. Fiore111 N 21-79
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Chief, Operations Branch (Date)
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SUMMARY OF FINDINGS
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Enforcement Action A.
The following violations are considered to be of Category II severity:
1.
Technical Spe ification 6.6.B.1 states in part that " Notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
. followed by a written
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. report within 10 days.
. in the event of the abnormal
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occurrences as de' fined in Section :
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Contrary to the above,three events of abnormal occurrances were not identified and reported to the AEC as required.
These were:
a.
Failure of a Unit #3 Main Steam Drain Valve (MO-3-220-2) to operate on May 22, 1974.
b.
Failure of a Unit #1 Valve (MO-CS-31) in the post accident system to open on May 13, 1974.
c.
Failure of a LPCI cross-connect valve (MO-1501-32A)
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in Unit #3 to close on May 4, 1974.
(Paragraph 1.a.Section I)
2.
Technical Specification 6.1.G.2 states in part that the onsite review function shall " Investigate reported instances of abnormal occurrences.... and recommend actions to prevent recurrences".
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Contrary to the above,three abnormal occurrences wer,e not reviewed by the onsite review function. These were:'
a.
Torus - drywell vacuum breaker event documented in DVR 2-74-25.
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Main Steam isolation valve leakage went documented in DVR 3-74-18.
c.
Level indicating switch failure event documented in DVR 3-74-21.
(Paragraph i..Section I)
3.
Technical Specification 6.2.E states that all procedures
identified in Specification 6.2.A and any changes to those procedures shall be reviewed and approved by the Operating Engineer and the Technical Staff Supervisor in areas of
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eperation, fuel handling, or instrument maintenance, and by Maintenance Engineer and the Technical Staff Supervisor in the
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areas of plant maintenance and plant inspection.
In addition, the procedures, and changes thereto, must have authorization by the Station Superintendent before being implemented.
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Contrary to th'e above, the following procedures had not been
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properly approved:
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a.
Preoperational and Startup Test Procedure for the-main steam automatic relief valve modification.
b.
Test for check of the diesel generator holder i
modification.
(Piragraph 9.c.Section I)
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4.
Technical Specification 6.2.F st5tes that temporary changes to
'ir-trument maintenance procedures which do not change the in ent of the original procedure may be made with the con-currence of specified personnel.
Such changes shall be docu-mented and subsequently reviewed, approved and authorized by station management.
Contrary to the abovg Temporary Procedure Change Request for the following were not approved and authorized as required.
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a.
Main Steam automatic relief valve modification test procedure.
(Paragraph 9.b.Section I)
b.
Feedwater Check Hydrostatic test.
(Paragraph 3a Section I)
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c.
Preoperational and Operational Procedure for iacore sipping.
(Paragraph 3b Section I)
d.
SRM rod block calibration check.
(Paragraph 3c Section I)
e.
Reactor pressure 600 psig bypass.
(Paragraph 7c Section I)
5.
10 CFR Part 50, Appendix B, criteria V and/or Technical Specification 6.2 states that detailed written procedures including applicable check off lists.
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pared, approved, and adhered to.
Contrary to the above,
a.
The modification approval sheet was not completed to indicate status of testing and authorization of operation, for the automatic relief valve modifi-cation and the feedwater check valves, during modification as required by Quality Procedure 3-51.
(Paragraph 9.a section I)
i b.
Deviations involving events which are not classified as incidents are not receiving review and docu-
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mentation of the corrective action as required by Quality Procedure 15-52.
(Paragraph ld Section I)
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Detailed * check lists were not being used for onsite
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c.
audit performed for the 1st quarter 1974 asirequired
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by Quality Procedure 18-51.
(Paragraph 6.a.Section I)
d.
Control rods determined to be non-conforming vare not documented in a Discrepancy Report (DR) aa required by Quality Procedure 10-54.
(Paragraph 15 Section I)
e.
Written procedures were not prepared, implemented or documen'ted for post maintenance tests as required by Quality Procedure 3-51 Revision 1.
(Paragraph 8 Section I)
f.
Quality documentation involving use of the 2 part tag and other requirements were not provided for the
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Main Steam isolation valve repair (Paragraph 8 5-etion I) and automatic relief valve (Paragraph 9 Section I) as required by Quality Procedure 8-51.
g.
Portable test equipment calibration records, use of hold tags, calibration schedules are not being accomplished as required by Quality procedure 12-51.
(Paragraph 12.b Section I)
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6.
Technical Specification 4.6.C.2 states that during startups and at steaming rates below 100,000 pounds per hours, a sample of reactor coolant shall be taken every four hours and analyzed for conductivity and chloride content.
Contrary to the above, during Unit 3 startup on June 5 with
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steaming rate below 100,000 pounds per hour, such a.pample was not taken between 0835 and 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br />.
(Paragraph 7 Section I)
7.
Technical Specification 6.1.G.l.a states that the responsibilities of the personnel performing the Offsite Review and Investigation Function include the investigation of violations of Technical Specifications, including review of recommendations to prevent a reccurrence.
It also requires that reviews, audits, and recommendations shall be documented with copies to the Superintendent of Production Division "A" and the Station Superintendent.
Contrary to the above, no evidence was provided by the licensee to demonstrate that violations of Technical Specifications, identified by the AEC, are reviewed by the offsite review group.
(Paragraph 5 Section.II)
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Licensee Action on Previously Identified Enforcement Items: Not inspected.
Unusual Occurrences. Not applicable.
Other Significant Findings A.
Current Findings 1.
The licensee stated that the following positions have been added to the Dresdca site.
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G. Diederich has been assigned to a new position of admin-istrative assistant reporting to the Superintendent.
J. Jurecki and J. Tambling have been assigned to new positions of Staff assistant engineers reporting to the Maintenance Engineer.
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R. Ragan has been assigned in a new Fourth Operating Eng-ineer's position responsible for Special Projects.
(Cur-i rently - Radwaste Management)
2.
The licensee has revised approximately 57 administrat've i
procedures during the past six months.
Some of these pro-
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cedures covering such items as routing of work requests are still being implemented.
B.
Unresolved Matters 1.
The onsite review process documentation requires clarification
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to fully support:
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The assignment of personnel to the review function by the a.
superintendent.
b.
The documentation to verify that personnel assigned to
the incident have reviewed and concurred in the invest-
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igation findings and recommendations as stated in the 10 day report.
(Paragraph 1 Section I)
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Revision to the onsite receipt inspection procedure is needed to provide quality control tracking of material received by personnel other than the storekeeper.
(Paragraph 8 & 15 Section I)
3.
The effectiveness of the site Quality Assurance Engineer's monitoring quality activities is not supported by documented
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evidence.
(Paragraph 11 Section I)
4.
The Administrative Procedures Manual require revision to (a)
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revise sections that are outdated e.g., references to NRB and SRB committees.
(b) Provide a coordinating mechanism between administrative procedures.
(Paragraph 4 Section I)
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Status of Previously Reported Unresolved Items:
Not applicable.
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Management Interview On June 14, 1974, the inspectors met at the site with F. Palmer, Super-intendent of Production, Division A; B. Stephenson, Plant Superintendent; and other members of the corporate and plant staff. Matters discussed included the detailed results of the inspection.
Pertinent comments are noted in the body of the report.
On July 26, 1973, Messrs. Dance and Knop of RO:III met at the site with Messrs. F. Palmer, Superintendent of Production, Division A; A. Roberts, Assistant Plant Superintendent; G. Redmond, Assistant Superintendent, Nuclear and Fossil Systems; and other members of the corporate and plant staff.
Items discussed included the violations listed in Paragraph A of the Enforcement Action and the unresolved matters listed in Paragraph B of Other-Significant Findings.
On July 30, 1974, Messrs. Keppler, Fiorelli and Knop of the RO:III office met with senior corporate representatives of Commonwealth Edison Company to again discuss the results of the inspection. Messrs. W.
Beneke, Executive Vice President and B. Lee, Jr., Vice President repre-sented Commonwealth Edison Company at this meeting.
The recent plant performance leading up to this management inspection
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was discussed. The findings of the inspection in terms of violations and unresolved matters were identified.and discussed.
In addition, observations and conclusions made by the inspector involving managemenc controls were also discussed.
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The licensee acknowledged the statements and indicated that the appro-priate comments would be factored into their review of the proposed corrective action. RO:III's positica regarding recommendation for a full term license for Unit 2 was also presented to CE management.
This positionis documented in the formal communication to the licensee.
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REPORT DETAILS
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Persons Contacted Dresden Site
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B. Stephenson, Station Superintendent A. Roberts, Assistant Superintendent G. Diederich, Administra*1ve Assistant D. Scott, Operating Engineer Unit #3 E. Budzechowski, Operating Engineer Unit #1 N. Jackiv, Quality Assurance Engineer R. Meadows, QC-Engineering Assi'stant W. Hildy, Instrument Engineer R. Thomas, Instrument Foreman E. Johnson, QC-Engineering Assistant E. Maintel, Maintenance Engineer R. Cozzi, QC-Engineering Assistant W. Knop, Maintenance-Engineering Assistant R. Jeffers, Maintenance-Engineering Assistant J. Skoryi, Records-Engineering Assistant M. Wright, QC-Engineering Assistant G. Abrell, Operating Engineer, Unit #2
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R. Ragan, ' Operation Engineering, Radwaste Company Offices B. Lee, Vice President (Construction Licensing and Environmental)
F. Palmer, Superintendent of Production, Division A W. Shewski, Manager of Quality Assurance N. Kershaw, Superintendent of Nuclear & Fossil System G. Redmond, Assistant Superintendant, Nuclear & Fossil Systems R. Squires, QA Administrator, Production B. Roysden, QA Administrator, Production N. Duke, Quad Cities Project Engineer, Production F. Morris, Dresden Project Engineer, Production
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J. Abel, Nuclear Licensing Administrative (BWR's)
N. Wandke, Administrative Engineer, Production, Division A
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R. Lemke, Engineer, Production, Division A C. Reed, BWR Section Engineer, M&S D. Galle, Dresden & Quad Cities Project Engineer, M&S A. Spyksma, Engineer, M&S W. Rosenmeir, Engineer Associate M&S
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f Section I
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Inspection at The Dresden Station 1.
Licensee Review of Operating Problems Including Abnormal Occurrences Review and investigation of operating problems are governed primarily by Quality Procedure (Q.P.) 15-52 of the Commonwealth Edison Quality Assurance Manual and Section 6.1 of the Technical Specifi-cations.
As discussed in.the Q.P., certain operating problems falling within the definition of a deviation are made the subject of a Deviation Report (DVR).
The DVR provides for review of the event by supervisory and station management, the Onsite Review Function, and corporate groups.
To provide a current evaluation of the effectiveness of the licensee's problem review procedures, the inspector reviewed all reactor operating logs and DVR's subsequent to May 1, 1974, against the requirements of the Technical Specifications, Q.P.'s, and other licensee procedures. The findings of the review were as follows:
a.
Three equipment deviations were noted during the review of Operators log that had not been documented as an incident on a Deviation Report as required by QP 15-52.
In addition these
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deviations were not reported to the AEC as abnormal occurrences as required by Technical Specification 6.6.B.l.
(Violation)
These deviations were (1) Failure of a Unit #3 Main Steam line drain valve (MO-3-220-2) to operate properly on Iby 22, 1974.
(2) Failure of a Unit #1-Motor Operated Valve (MO-CS-31) in i
the past accident system to open on May 13, 1974, and (3)
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Failure of a LPCI Cross-connect Valve (M0-1501-32A) in Unit #3 to
't close on May 4, 1974.
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b.
Discussions with licensee representatives indicated that DVR's are passed promptly, usually by hand, to the Operating Engineer (OE) for the unit. The OE reviews the DVR, initiates necessary corrective action, and determines whether AEC notification is required.
Q.P. 15-52 states that the DVR then goes to the Station Superintendent for review and approval (on Part 3 of the DVR), and subsequently to the Onsite Incident Review and Investigation Function.
Following investigation and preparation of the incident report (10-day report), if required, the DVR and the report are returned to the Station Superintendent for
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approval ton Part 4 of the DVR).
For most DVR's classed as
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incidents, the signature of the Station Superintendent on Parts 3 and 4 of the DVR were affixed on the same date,
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nominally almost ten days after the occurrence.
This indicated that he had not documented formally the review of the DVR as required
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before its assignment to the Onsite Review Function for
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investigation nor was it clear which personnel participated in the review.
c.
The incidents (Abnormal Occurrences) documented on DVRs 2-74-25 (Torus - drywell vacuum breakers), 3-74-18 (Main steam isolation valve leakage) and 3-74-21 (Level indicating switch failure) were not reviewed by the onsite review functicn as required by QP 15-52 and by Paragraph 6.1.G.2 of Technical Specification (Violation).
For most iriidents an onsite review is documented shortly
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after the e ent, but in other cases a review of the completed investigation and the letter submitted to the'AEC was not
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indicated.
d.
For deviations involving events which are not classified as incidents, QP 15-52 requires review and documentation of the corrective action by the technical staff supervisor.
A review of the DVRs indicate that this step is not being accomplished e.g. DVR 2-74-35 regarding control rod insertion times and DVR 3-74-22 concerning HPCl low pressure isolation switches.
(Violation)
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e.
The review of reactor operating logs disclosed variances from the log keeping requirements of Administrative Procedure 30-173, as follows:
(1) alarms were not being entered in the log
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at the beginning of shift by all operators, and (2) the fail-ure of valve 2-220-2 to operate on May 22 and excessive leakage of MSIV 3-202-1B on May 15 were not entered in the
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log.
A review of the system used for following outstanding action items (as a result of recommendations) showed it to be functioning effectively.
Approximately 8 followup actions.from recent incidents were checked, and all were found to be in the system.
Because of their recent nature none had yet been carried to completion. A licensee repre-sentative stated that a backlog of older action items still remained.
to be completed. To avoid dilution of management followup, the action item system is currently being used only for items of sign-ificance, such as AEC commitments, and not for routine station matters which can be handled by work request or a comparable method.
2.
Technical Review Capabilities The numbers and experience levels of persons assigned to the
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technical staff were reviewed and discussed with a licensee repre-sentative. At the time of the inspection approximately sixteen
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members of the technical staff held engineering degrees, including-9-
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the Technical Staff ' Supervisor. One of these is assigned as
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Instrument Engineer', one is Lead Engineer for the onsite Quality Control Group,-and two are assigned to the Rad / Chem Group.
Each of the three units is assigned a Lead Engineer, a Nuclear Engineer, and a Thermal Engineer. A Lead Nuclear Engineer coordinates the
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efforts of the unit Nuclear Engineers, and a Projects Engineer carries out'special tasks as assigned by station management (e.g.,
testing of offgas system modification). The several Engineering
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Assistants.(non-degree) which are assigned to the technical staff have various responsibilities such as surveillance test scheduling, computer progra= ming, review and coordination of plant modifications, and administration of the records retention program.
l The three engineers assigned to each unit bear most of the burden for technical review of unit operation, investigation of operating j
problems, and the conduct of non-routine testing.
The inspector j
expressed concern that the three engineers could provide coverage
of these activities to the depth necessary, particularly during an i
outage, especially in view of the relatively short period some have
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been assigned to the technical staff.
For example, the three engineers assigned to Unit l' have a total of 19 months experience j
at the Dresden Station and represent slightly over six years of combined engineering experience.
The three Nuclear Engineers
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of approximately one year and have been on Station 4, 19, and 4 months respectively. The Lead Nuclear Engineer, who has been at tLa Dresden Station for five years, assists dnd guides the unit nuclear engineers when necessary, but the depth et inuclear eng-ineering support in the event of his absence or during periods of unusual activity is marginal.
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T The capability of the two remaining engineersoto follow ptoblems, tests, and operation of each unit was also deemed marginal.
Other.
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comments regarding inadequate following of unit activities by technical personnel were given in previous RO Inspection Reports, i
such as 050-249/74-05 (related to Unit 3 Integrated Containment Leak Test) and 050-010/74-06 (concerning activities resulting in
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the loss of J-hook in the Unit 1 reactor vessel.)
With formation of a staff for~the LaSalle County Station to be considered in the near future, the possibility exists that transfer of some of the staff from Dresden could affect the depth and experience of onsite technical review capability.
3.
Review of Operating Procedures The licensee's systems for review, approval, and distribution of
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operating procedures were examined and discussed with licensee
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representatives. A procedure review form is used which provices
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for initiation of a new or revised procedure by anyone cognizant of the need, preparation and typing of the procedure, and control of procedure distribution. The form requires onsite ' review of the draft and again after final typing.
A safety evaluation is performed on each procedure and included with the procedure review package.
Distribution is controlled by the Quality Control Group.
Six recent procedure revisions were verified to have been filed as required in the Operating Engineer's and Control Room Manual of operation procedures.
Ir relation to operating procedures there was noted a lack of a routine periodic review of procedures to ensure that they are maintained current.
This is a requirement of ANSI 18.7 - 1972, although the licensee has made no commitment to fully implement ANSI 18.7 at the Dresden Station until 1975.
The inspectors asked
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that such a periodic review progran be considered, noting that it would become a requirement at s'ome future time.
The station uses Operating Orders (in some places referred to as Station Orders) to publish some instructions of temporary nature.
These are normally approved by the Onsite Review Function, although
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one was noted not to have been approved by the Technical Staff Supervisor as required by Administrative procedure 30-159. The
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approval of two Senior Licensed Operators had been obtained as required by the Technical Specifications.
The licensee's system for review, approval, and distribution of temporary procedures was examined and. discussed with licensee representatives.
Three temporary procedures in the Temporary Procedures Manual were reviewed with the following results:
a.
Temporary Procedure o. 3200 "Feedwater Check Hydro" was not subsequently approved by the Station Superintendent.
b.
Temporary Procedure No. 37-9-6 (Revision 3) "Preoperational and Operational procedure for Incore Sipping" was not subsequently
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approved by the Station Superintendent.
c.
Temporary Procedure No. 33-700-1 "SRM Rod Block Calibration Check" did not specify a termination date as required by Q.P.
5-51, did not contain a Senior Reactor Operator's signature as required by Technical Specification 6.2.F, and was not subsequently
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signed by the Station Superintendent.
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v In each of the above procedures Technical Specification 6.2.F requires subsequent approval by the Station Superintendent.
(Violation)
i The. Document Control mechanism has not been effective in establishing accountabiltcy of temporary procedures or to assure that they are
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subsequently routed for approval.
The issuance of temporary procedures i
was being actively discouraged by station supervisory personnel.
The inspectors noted that while permanent procedure revisions should be issued where possible, the availablility to operating personnel of temporary charges was considered important to foster an attitude of compliance with procedures.
4.
Review of Administrative Procedures The licensee's system for review and approval of Administrative procedure was examined and discussed with the licen~see represent-atives.
The station has three systems of administrative procedures.
They are:
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The company Quality procedures (QP) manual approved by the
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Superintendent of Nuclear and Fossil Systems.
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Chapter 30 of the Station's procedures manual approved by the onsite review group and the Station Superintendenr.
c.
Station Quality Control procedures utilizing similar number to the Company QP manual. These procedures are approved by the onsite review group and the Station Superintendent.
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No problem was noted with the review and approval of these procedures.
The following observations were-made by the inspector:
a.
In many cases personnel were using procedures in two or more
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of the above procedure categories in performance of their work.
In some cases these procedures agreed with each other
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almost word for word and in others there were significant differences in scope and content. When questioned some of the quality control personnel were not aware which procedure
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system predominated.
b.
Many of the procedures contained outdated information, such as.
references to SRB and NRB committees which no longer are in existence.
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review / audit Participants".
Five of the auditor's qualifications
were-selected at random and compared to the Technical Specification requirement (ANSI N18.1 - 1971).
No decrepancies were noted.
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' Documentation was also reviewed verifying that the auditors were selected and approved by the Station Superintendent and the onsite
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review group as required by the Technical Specifications.
When questioned as to the training given to the auditors, the licensee responded that none had been accomplished to date.
Scope of Audit The inspector reviewed the general audit plan schedule specified in procedure 30-155.
No deficiencies relative to the scope required by Technical Specifications were noted. Audits ars being' performed i
on a quarterly basis such that all documents on the audit plan are i
completed each calendar year.
Some of the documents such as operating logs are audited each quarter.
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Performance of Audit The results of the first Quarter were reviewed against the. require-
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ments of QP 18-51 and administrative procedure 30-155.
The inspector l
reviewed documentation verifying that the auditors had been selected in accordance with-the selection of onsite Review / Audit Partici-
j pants procedure.
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Ten of tha areas performed during the first Quarter Audit were reviewed in detail. The following items were noted in the majority
of the audits review by the inspector.
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Detailed checklists were not provided for the audits as
j required in step 4d of QP 18-51.
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Auditors were not providing any specifics on what documents j
they reviewed or what sample size they were auditing.
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c.
Auditors are providing only general information on what deficiencies were found.
(e.g., did not state which of the
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audited work requests were not approved properly etc.)
d.
Auditors do not enlarge sample size when deficiencies are
found in each item of the samples audited to determine if the
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deficiencies noted are exceptions or prevalent, l
e.
Auditors were not conducting debriefings with the audited
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department as required by step 4f of QP-18-51.
As a result a
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significant number of the deficiencies were later determined
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not to-be deficiencies.
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Deficiencies found during audits that are not included in
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action items do not get resolved in the record, e.g. there is no record that out-of-date procedures found during the first Quarter Audits were updated to close out the deficiency.
Corrective Action for Deficiencies i
Three of the completed audits with listed deficiencies were reviewed
to determined status of correction action.
It was determined that action items had been initiated for each audit.
A review of the action item log indicated that two of the action items had been completed and that the procedure to implement the corrective action for the third item had been completed in draft form and was in final typing.
7.
Surveillance
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Regularly scheduled surveillance tests required for the station have been entered on a computer.
The surveillance engineer with the aid of computer printouts informs work groups of due dates.
d Completed dates are returned to the surveillance engineer. He also scans completed surveillance procedures for operations.
Deficien-cies of the operations Daily Log are noted on a summary sheet and
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circulated to management. The following were noted:
a.
Responsibilities of the surveillance engineer and his means of handling deviations are not in writing.
For example, if a specific test was not performed within its required test interval, the surveillanc'e engineers enters "not done" on the computer record and verbally informs the responsible super-
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visor. Review to correct cause for not completing the sur-veillance is not incorporated in the system nor has a mechanism been established to bring the violation before the onsite review group as required by Technical Specifications 6.1.G.2.
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b.
Nonroutine type tests required following extended outages or during special plant conditions were spot checked and found not to be included on the scheduled tests.
For example-1.
During Unit 3 startup on June 5, 1974, the conductivity and chloride analysis required by rechnical Specification 4.6.C.2. each four hours, when steaming less than 100,00 pounds / hour, was not performed between 0835 and 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br />. (Violation)
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2.
HPCI surveillance testing scheduled during unit shutdown was confirmed to have been completed during or prior to
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T Unit 2 startup on March 3 and Unit 3 startup on June 5.
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In both cases the testing was satisfactorily performed but appeared to have been performed primarily due to other work in process and not because of. scheduled surveillance.
Review of Units 2 and 3 operational tests of Core Spray, Low Pressure Coolant Injection, and High Pressure Coolant Injection Systems since February 1974 and Diesel Generator since February 1974 were satis-
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factory.
Review of seven instrument calibrations deter-mined that each had been performed as required.
A temporary procedure change, associated with the reactor pressure 600 psig bypass circuit, dated June 2, 1974, was noted not to be subsequently approved by plant management as required by TS 6.2.F.
(Violation)
8.
Maintenance Program The maintenance control system was comoared with the requirements of 10 CFR Part 50, Appendix B, and the Corporate and Station administrative procedures relative to maintenance control.
Review of Completed Work Request Package
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Fifteen Safety related Work Requests were selected at random from the completed Safety Related Work Request file.
The following deficiencies were noted by the inspector.
(Note this inspection was made against the requirements of QCP 3-51 Revision 1 which was in effect at the time the work requests were processed.)
The procedure requires an operating Engineer to Specify post maintenance testing and quality control requirements.
The review of the WRs indicated that in general that this step was npt properly implemented. None of the work requests reviewed contained specific testing and quality control (QC) requirements.
Generally the work request and attached QC requirements sheet were only checked for general categories such as " Functional Test" for " Leak Test".
Under the QC requirement for work procedures a~ gain, only general categories were checked such as " craft capability." " Vendor Manual" e.g., actual vendor manual and section not referenced.
In only two of the 15 cases were specific maintenance work pro-cedures referenced.
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One of the quality control requirements listed by the Operating Engineer was a step requiring the Shift Engineer to " list pre-cautions taken to provide for reactor Safety during repair." A review of the work request quality control requirement document-
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ation showed that this step was not properly implemented.
In each WR package this step was signed off as required, however, in only
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one of the packages were the required actual precautions listed for
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maintaining reactor safety during the repair.
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Another quality control requirement of the procedure is a step requiring documentation of the completion of the test requirements.
A review of the work requests indicated that in 12,of the 15 WRs
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there was no specific documentation of the test performed to verify operability of the equipment.
(Violation)
J For Work Request 1392 the testing requirements indicated that
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j visual, leak test and functional test should be performed for the Diesel Generation #2 following replacement of the fu'el oil hose.
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This step was not signed off demonstrating completion of the required post maintenance testing.
i Three of the Work Request (WR) packages reviewed by the inspector did not contain documentation to indicate that safety related components were installed as replacement parts as required by QP 3-
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51.
Prior to the conclusion of the inspection the Quality Control group was able to find documentation relating to two of the three packages.
WR 3736 was used to install new power supplies in the Power Range
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Monitors.
The certification of conformances were found the next day in the instrument Engineer office.
The shipping package had
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bypassed the normal receipt inspection by the storekeeper and was
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sent directly to the instrument Engineer.
WR 4166 was used to install a new motor in the MSIV outboard drain valve. After a review of the Foremen records it was established by the pickup delivery ticket kept in the Foreman's office that a like for like replacement had been accomplished.
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The documentation for WR 4021 package did not contain a tpo-part tag demonstrating receipt inspeccion and any of the required information required by QP 8-51 relating to the material confor-mance e.g., Heat treat data, material certifications for the Main steam disc, Guide and seal ring and steam and pilot valve assembly.
(Violation) This WR was accomplished using a vendor's instruction (which vendor instruction was not specified in the package.)
This work request package did not contain any acceptance criteria for the test procedure to indicate that an acceptable valve leak was obtained or that the required closing time was obtained fol-lowing the completion of the work.
The licensee stated that they were aware of many of these short-comings found by the inspector and as a result, instituted a revised administrative procedure (dated 6-7-74) covering maintenance WR.
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w He further stated that it was their intent to provide emphasis on
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improved maintenance work and testing procedures and have augmented their maintenance staff, to accomplish this requirement, by adding two staff assistant Engineers.
Review of The Revised Station Work Request Routing Procedure The administrative procedure approved 6-7-74 covering centrol of maintenance work requests was compared to the previous revision.
Outside of several procedural handling problems the revised pro-cedure appears to give more definitive guidance on quality require-
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ments.
It was noted that during the inspection the revised WR
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procedure has not yet been fully implemented in that summary sheets and other control devices specified in the procedure were not yet in existance.
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Maintenance Control The following general elements were noted in the maintenance control program to have been absent.
Both the old and revised procedure states that the Operating Engineer is to define what work is safety related in accordance
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with QCP 2-53.1.
In discussions with the Operating Engineers and,
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j Maintenance Engineer it was determined that no such list existed.
Personnel in the past have been either making judgements based on experience or by an unapproved list located in the Quality Control
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trailer. Prior to the conclusion of the inspection it was deter'
mined that this QCP 2-53.1 was in final typing and in the approval review chain.
i The Dresden station does not curren'.ly have an overall preventive maintenance schedule describing the frequency and type of main-
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tenance to be performed as recommended by ANSI N18.7 - 1972, Section 5.1.6.2.
The Licensee stated that some preventative maintenance is being scheduled such as lubrication and surveillance of other equipment such as Diesel, snubbers,etc. The Licensee said that this item would be reviewed in light of their committment*to comply with the ANSI standard in the future.
9.
Review and Approval of Facility Changes in Accordance with AEC Regulations (10 CFR Part 50.59)
Review of six recent safety related facility modifications deter-mined that implementation of station requirements were noted as
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follows:
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a.
The Modification Approval Sheet had not been completed to in-i dicate completion of testing and authorization of operation as required by Design Control for Operations - Plant Modifi-
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cations, QA 3-51 (dated November 27, 1973) and the newly
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revised Station Work Request Routing QCP 3 52.1 (dated June s
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1974) for:
(1) M12-3-74-78, Automatic Relief Valve.
(2) M12-3-74-87, Modify Feedwater Check Valve 0-Ring. (Violation)
b.
Temporary Procedure Change Request prepared for 33-200-XIII on May 22, 1974, to test the relief valve circuitry (M12-3-74-78)
was approved by the Instrument Engineer and Foreman but not by the Senior Operator of the affected unit and subsequently by station management as required by Technical Specification-6.2.E.
(Violation)
Test Procedures had not been approved and authorized by the c.
Station Superintendent as required by Technical Specification 6.2.E for:
(1) The Preoperational and Startup Test Procedure for M12-3-74-78, Automatic Relief Valve; and (2) The Test Procedure for M12-3-74-48, Modify Diesel Generator Fuse Holder.
(Violation)
d.
Since the relief valve installation (M12-3-74-78) was coordin-ated by construction this valve bypassed the normal station receiving inspection including the attachment of the two-part red stock-log specified in QA No. 8-51, Identification and
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Control of Materials, Parts, and Components for Operations -
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Identification, Inventory Control and Disbursal.
(Violation)
f A certificate of conformance was available at the site.
Final valve certification had not been received at the time of phe inspection.
Safety evaluations had been prepared but not approved as e.
required by QP No. 3-51, Design Control for Operations - Plant, Modifications (dated November 27, 1973) for:
(1) M12-2-74'-49,-
Replace Diesel Generator Air Solenoid.
(2) M12-3-74-101, Feedwater Connection Repair (not safety related according to site listing).
f.
Work Request 4224 associated with M12-3-74-96, Modify Breaker for Valve 1201-7, specified " functional" test.
Discussion with site personnel determined that this requirement is not interpreted the same by all individuals.
In this instance the QC Engineer has specified cycling the valve three times.
Examination of changes made to seven station procedures confirmed that each had been evaluated for 10 CFR 50.59 application.
Such a review was not available for Special Maintenance Procedure M14, Feedwater Check Valves, written over a year ago and recently approved by DOSR.
.
Temporary procedure change to Chapter 36, Procedure E, Preventive Maintenance (Units 2 and 3 diesel generators) was noted to have been properly approved on March 14, 1974.
However, discussion with
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site personnel indicated that the use of the temporary procedures
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system is discouraged when revising procedures which are still in the old format.
Recognizing the stations commitment to revise procedures to comply with ANSI 18.7, the inspector stated that the system should not encourage personnel to bypass the approved means of procedure changes.
The licensee stated this was not the intent.
10.
Retraining The following was derived from discuss ion with site training personnel and a' review of records. The licensee has complete training programs for orientation and plant operation.
Emphasis of this review vas on the retraining aspect of licensed personnel.
Continued management support is required as noted by the following:
a.
A two year operator requalification program was submitted to Directorate of Licensing on April 5, 1974, and included topics of retraining. All aspects of the program had not been implemented such as the oral examinations and evaluations by supervision. Training attendance records do not correlate directly to the topics referenced or to an individual's remaining requirements.
Training sessions were stated to be interwoven to cover pertinent areas.
Training programs are
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still being developed, for example, a general session was planned for QA topics in about a month.
The inspection findings of procedural deficiencies indicates additional emphasis is required in this area.
b.
Requalification examinations have been initiated annually to determine areas where retraining is required. Twenty-two personnel (all but one are supervisory personnel) out of approximately sixty have yet to take the requalification examination which is due by Septemier 1, 1074. These examin-ations provide the basis for addi'.onal specializcd training.
c.
Scheduling of personnnel for training is a continuing problem as noted in the requalification examination, attendance records, and from a recent lecture which was reportedly given about ' thirty times over a three month period to cover all personnel.
Instructor substitutions appear to frequent and require topic revision as noted from several records.
d.
Training staff consists of four personnel (two part-time), two of which hold Senior Reactor Operators licenses and a former instrument foreman.
It is expected that all will become full time plus another training engineer to be added to the staff by July 1, 1974.
From the present 4 classrooms, additional
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space in the training building is expected to be available in the near future.
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Training is supplemented by approximately weekly televised
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tapes which include modifications, operating orders, deviation
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l or incidents. An index of the content for each tape does not exist. Attendance to review tapes is encouraged but not mandatory.
Records are maintained of viewers.
f.
In addition to the above, three days per year is spent at the simulator with GE providing evaluations.
11.
Quality Assurance Engiheer Function The Corporate Quality Assurance Engineer (QAE) function at the site was reviewed to determine the QAE's effectiveness in verifying by audit and surveillance, the station's implementation of Quality Procedures and station procedures.
The responsibilities of the QAE are spelled in a letter from the QA Administrator (Production). Using this letter as a measure the
following observations were made by the inspector.
The QAE is responsible for preparing the offsite audit plan, a.
participating in the audit and preparing the audit report.
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No deficiencies were noted in this area.
b.
The QAE is responsible for Weekly Audits of plant operations
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in accordance with QP 18-51 (Note:
QP 18-51 does not address audits by QAE).
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The following observations were made by the inspector for audits performed in February and March 1974.
(No audits were I
performed in April and May 1974.)
1.
Audit plans and check lists developed by the QAE were not approved by the QA Administrator.
2.
No overall audit plan schedule has been established to
assure that all portions of the QA program are reviewed by the QAE over a period of time.
3.
In discussions with the QAE it was determined that docu-mentation is audited to determine compliance with the Corporate QA Manual but the QAE has not audited to determine compliance to Station Quality Procedures.
4.
When performed, the weekly audit has been limited to a
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review of only one item per week and a small sample is
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selected for that one item.
For example the week of
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February 28, 1974, audit was limited to a review of 3
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work requests.
5.
No significant deficiencies were found during these audits resulting in a corrective action' report during either the February or March 1974 audits.
c.
The QAE is responsible for performing surveillance of (1)
document control for station procedures (2) incorporation of engineering changes into station procedures (3) maintenance inspection and test documentation and (4) completion of corrective action by station.
The QAE did not have documentation to support that he had performed any surveillance of the above mentioned items.
Nor did he document any of the deficiencies found when the person being surveyed agreed to conform to the requirements.
The significant deficiencies not cotcected are documented in the action item record.
d.
The QAE has been responsible for reviewing AEC inspection reports and the station's reply to determine accomplishment of commitments.
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The inspector stated that during the past several months due to the large amount of legwork required for follawup of this function that the audit and surveillance duties were not
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accomplished.
It appeared that this responsibility was more properly that of a QC function r.ather than a QA function.
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12.
Instrument Maintenance a.
Control of Measuring..and Test Equipment for Operations -
Station Instrumentation, Q.P. No. 12-52, dated October 23, 1973, requires calibration of plant equipment as specified by Technical Specifications.
No discrepancies were noted during review of eight required calibrations.
The Instrument Engineer and Foreman are responsible that required tests are properly performed. Dates of completed tests are forwarded to the Surveillance Engineer.
Test of required HPCI instruments was confirmed to have been completed as required prior to the Unit 3 startup of June 5.
b.
Control of Measuring and Test Equipment for Operation - Portable Test and Measurement Equipment, Q.P. No. 12-51, dated October 23, 1973, was determined not to be implemented.
Equipment had been identified and a tentative schedule prepared for about
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90% of the equipment.
However, contrary to QP 12-51, the tentative schedule was not being maintained, file of cal-ibration records was incomplete, QA Hold Tags were not in use, and no notification by the Operational Analysis Department of
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equipment out of accuracy limits had been reported to date.
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Regarding the later, most but not all, plant calibration
records 'aclude the test instrument used.
(Violation)
c.
Control of Instrument Setpoint Changes (Q.C.P 12-52.1) approved May 8, 1974, was determined to have been utilized probably for
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the first time on June 6 (nitrogen storage tank low level).
The mechanism was not in use on May 15, for the MSL High Temperature setpoint changes'.
13.
Jumper Log i
Administrative procedure 30-146, approved November 1, 1973, states for a person not responsible for the original installation verify
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the proper unresolved installation and removal of jumpers. No means exist to verify this requirement is being met.
The Jumper Logs at both the Unit 2 and Unit 3 desks had obsolete procedures posted on the logs which did mot include this requirement. The above procedure also states a daily audit of the jumper log will be performed.
Space is provided on the Daily Surveillance Log to
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document this review.
This item had not been completed on the
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assigned 12-8 shift on June 10, 1974.
Jumper Log reviews were also noted to be frequently but not consistently documented on jumper
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logs. Elimination of long standing jumpers to permanent facility
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changes is not being expedited on a priority basis.
14.
Caution Card
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Control of Caution Cards in the station is discussed in a station procedure.
Examination behind the control room panel disclosed several caution cards in use not covered by the system.
However
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for the most part tags on permanent equipment were logged in the i
system. A caution card log in use for each unit is poorl'y main-tained and difficult to determine the status.
15.
Control Rod Receipt During a tour of the plant the inspector noted that a control rod blade (HY-15) stored in the reactor building was marked " failed
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NDE".
In subsequent discussions with Quality Control it was determined that three control rod blades were on hold status due to defici-encies found during recent inspection. These deficiencies were as follows:
Rod HY-15 did not have an NDT stamp on the rod socket as required and Rods HY-2 and HY-21 had dimensional problems requiring
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rework or return to vendor.
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Through discussions.with Quality Control personnel it was deter-mined that discrepancy reports (nonconforming) had not been issued for the three rods as required by QP 10-54.
The licensee stated that final disposition of the rods had not been determined.
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(Violation)
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Control of Station Records
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The Dresden record center control was re',_9wed to determine com-pliance to the administrative procedures and requirements of
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It was determined that the station record system is in a transition stage in order to put the majority records on either 16mm roll i
film, microfiche, or 35mm aperture cards.
After filming the film l
record is being compared to the Hard copy to verliv the completeness I
and readability of ^he film.
During this interim filming period alldocumeg)tsarebeingsenttotheRecords,RetentionandRe-trieval (R center for processing instead of the permanent record location specified in QP-17-51.
The licensee stated the record system wculd revert back to control of the office supervisor at the conclusion of the filming.
Both films and records are being maintained at the present time until
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procedures are developed approving the use of the film technique and storage methods.
Two corrective maintenace items and one modification was selected from a 1973 six month report to determine retrieveability.
All records were found eatisfactory and no deficiencies were noted.
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Section II
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Inspection at Corporate Office
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1.
Management Review of Reactor Uperations
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Two general categories of operation were considered by the in-spector in evaluating management review of reactor operations:
a i
Routine review of operation and review of operating problems.
Examination of these areas was restricted to the office of the Superintendent of Production Division "A".
Performance of the Superintendent of Nuclear and Fossil Systems is discussed in a separate paragraph.
The office of the Superintendent of Production Division "A" includes the Superintendent, as Assistant Superintendent, and an engineer (whose responsibilities include coordination of emergency and security plans at the nuclear stations).
The Superintendent, and the other members when possible, participate in a morning meeting
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each working day at which operating conditions, plans, and recent problems are discussed by phone with each station.
Discussions with the Superintendent indicated he was aware of existing con-
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ditions at the Dresden Station. He stated that a monthly summary i
of plant operation is also received.
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Station Superintendent (SS).
The receipt of an enforcement letter N
is normally made the subject of a telephone conversation between
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the Nuclear Licensing Administrator (NLA) and the SS.
The response
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is normally drafted by station personnel and transmitted to the NLA by one week prior to due date.
After review and concurrence by tha NLA, the Vice President (Construction, Licensing, and Environmental),
and the Superintendent of Production Division
"A",
the response is normaEy signed and transmitted by the SS.
A spot check of recent responses to enforcement letter verified they had been transmitted within the allowed 20 days.
As discussed in the onsite po.rtion of this report, a primary action item system is maintained by stacion personnel to follow outstanding actions, such as AEC commitments.
Licensee personnel stated during the corporate portion of the inspection that a double check of AEC commitments was also accomp-lished by the NLA.
Review of his action item followup system, however, did not indicate the status of completion of short-term commitments.
Interested departments attend a meeting at the station once per month to update the status of the Action Item system. The Superintendent of Production Division "A" stated that o
he or a representative of his office normally attends. The Assistant Superintendent of Production was at the Dresden Station during the corporate inspection to participate in the June meeting.
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As explained by licensee personnel, a lettersto the Executive Vice President following this monthly meeting identifies actions which are not preceding as required.
Copies of the letter are also sent to other interested offices.
The NLA maintains a separate listing of AEC comnitments, based upon his review of enforcement letters, licensee reports to the AEC, and other correspondence. His listing is updated, compared with the station listing, and retyped once each month.
Correspondence received between updates is filed until the next update. At the time of the inspection an updated list was soon to be published, and the file was noted to include items of correspondence containing AEC commitments ranging up to six weeks old.
In some cases the status of commituents for which the completion date had already passed had not been posted.
The review and discussions with the NLA showed that the NLA's followup system is expected to ensure that a commitment is not lost from the
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Action Item system, and not to progress the status of station action items which have near-term commitment dates.
Timely com-pletion of such commitments resulting from AEC enforcement actions or abnormal occurrence reports is the responsibility cf the SS.
A separate system used by the NLA principally for the followup of
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actions requested by the Directorate'of Licensing was noted by the inspector tc be informal but apparently effective.
4.
Offsite Audit Committee
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The Commonwealth Edison Company (CECO) provides a common list of qualified auditors for all of its nuclear facilities.
The performance
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The Superintendent of Production Division "A" and the Superin-
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tendent of Nuclear and Fossil Systems are notified by phone when
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deviations occur.
A copy of the Deviatic7 Report (DVR) is also telecopied to the corporate offices, where both receive a copy. A copy of the final DVR is also forwarded to the Superintendent of Production Division "A" when the deviation is an incident (abnormal occurrence or departure from safety limits, as defined in Technical Specifications).
Examination of the Production Division
"A" files for Dresden 2 verified the Superintendent had reviewed all 1974 DVR's when received. The DVR's were filed sequentially, with the final smooth copy (with AEC report attached) replacing the initial notification (telecopy) when received.
Eighteen of the 34 1974
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DVR's for Dresden 2 were present in final form, and all had been signed by the Superintendent to indicate his review.
A repre-sentative also stated that the concurrence of a member of the Superintendent's staff is obtained for each abnormal occurrence or unusual event report before its transmittal to the AEC. As noted during the onsite portion of the inspect!.on, DVR's not classed as incidents were not being routed in fina'. form for review as required by the licensee's Quality Procedure 15 52.
Review of the management followup syscem for corrective ac'tions related to plant operating problems v.emonstrated that company management is relying primarily upon the Station Superintendent for
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the timely fulfillment of commitment s (as discussed further in Paragraph 3).
2.
Offsite Technical Support Assistance with station problems was stated to be available when required from the Superinte. dent of Nuclear and Fossil Systems and
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I the various engineering departments.
The methods for rcybesting offsite assistance did not appear to be formally defined, but consisted of a number of contacts between station personnel, the Superintendent of Production Divisien "A",
the Superintendent of
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Nuclear and Fossil Systems, and the engineering departments (Mechanical & Structural, Station Electrical, and Operational Analysis). The degree of formality and corporate attention given to particular problems appeared to vary depending upon the sign-ificance of each problem and the urgency of its resolution.
Methods for establishing priorities of resources among various stations and projects were not formally defined, although the Superintendent of Production Division "A" was stated to have the authority to procure assistance outside the company when required.
3.
Management Followup of AEC Enforcement Actions This paragraph discusses the followup by management of corrective
.
f actions related to AEC enforcement actions.
Letters informing the licensee of enforcement actions are addressed to the Vice President (Construction, Licensing, and Environmental), with a copy to the
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j ry of the audit functicn wa$ reviewed against the requirement of
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Tcf.nical Specification 6.1.G.1 and the CECO Quality Assurance
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x manual section QP 18-51.
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The first 6 month audit cf the Dresden facility was performed during the week of April 15 thru 19, 1974.
The eight auditors used during this audit were verified to be on-the approved auditors list. Three of the auditors qualifications were compared against the technical Specifications requirements.
No deficiencies were i
noted.
It was aise determined that th'e minimum number cf dis-ciplines required by.tcehnical specification were exceeded.
In discussions with the licensee it was determined that a two year i
audit plan was in rough draft to cover the remaining three audits in the two year plan indicating that areas required by the technical specifications were scheduled for completion.
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The six month audit performed at Dresden was reviewed to determine that:
1.
Detailed checklists were used.
2.
Auditors and audit plan had been approved by the Superintendent
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of Nuclear and Fossil systems.
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3.
The Audit had been. performed according to the audit i
plan.
4.
Corrective accion for deficiencies found during the audit were either complete'd or scheduled to be completed.
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No problems were noted against these requirements. The area covered by the audit appeared to have been reviewed in depth and thoroughly. The corrective action response to the deficiencies
appeared to be timely and responsive.
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5.
Offsite Review and Investigative Function i
Technical Specification 6.1.G.1 states requirements for the Offsite Review and Investigative Function and Audit Function.
These
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functions are elaborated on, in a procedure "Dresden and Quad
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Cities Offsite Review Program" dated December 1973. The inspector noted the following in his review:
j a.
.Offsite review procedures state review items will be properly
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i submitted in writing.
One review Item 74-8, Increased Activity in-Unit 2 Containment, was performed from a verbal request following an onsite review on March 8,1974.
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b.
Ten reviews other than incident reviews had been performed
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during 1974 for Dresden.
Review concurrences are not required
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to be documented by the review participants nor is the com-
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pleted review necessarily distributed to all participants.
Those selected as review participants were selected from a qualified list.
l c.
A formal system existed for reviewing abnormal eccurrences.
{
d.
The group formally reviews only violations (deficiencies)
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-identified by the audit function.
No evidence existed that i
reviews are made of all such as AEC identified, " Violations of Technical Specifications, including review of recommendations
to prevent a reoccurrence". as required by TS 6.1.G.1.a(4).
>
The licensee stated that in his view these matters weJe addressed to management and therefore had received corporate review.
(Violation)
6.
Ehdifications
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Quality Procedure 3-51, Design Control for Operations - Plant Modifications, dated November 27, 1973 is writion to control modifications.
Review indicated that the control of modifications from an administrative view point is primarily the responsiblity of the station.
For Example:
Station personnel authorize the in-
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stallation of a modification after selected prerequisites have been met.
The Action Item Request System has recently been adapted to serve as a tool to focus management attention on priorities established by the station, a.
Verbal approvals for two modifications (Unit 1 sphere pene-tration, May 7,.1974; and Unit 2/3 torus sightglass, June 13, 1974) were given by MSS Engineering to the station after listening to the safety evaluation read over the telephone.
Supporting information on these modifications had not been received from the station at the time of the inspection.
Engineering requirements ware identified in the approval request and are the only evidence of a design evaluation. A corporate memorandto dated April 18, 1974, was sent to the Station Superinten'ent to empahsize specified notifications required by QP 3-5'. for the Engineering Department, b.
QP 3-51 as written includes steps which are not applicable for
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all modifications. For example step C-13 is only utilized for l_
Category C (major) modifications and the Nuclear Licensing
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Administrator is only involved in modifications requiring AEC approval. Engineering personnel agreed the procedure needed revision.
Strict adherence of all steps in QP 3-51 were not
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completed in a timely manner as evidence from the incompleted packages of modifications in Engineering.
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c.
Monthly meetings between Engineering Construction, and Pro-
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N duction were~ initiated for Dresden in March 1974 to discuss
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i outstanding Action Items Requests (AIR's) and to highlight those that are not on schedule.
This is the only means for the station to assign priority to a modification and have it
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l periodically reviewed. Therefore, to assign 'riority to a p
modification an AIR must be issued.
Status of off-schedule
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items are highlighted in monthly meeting minutes by station i
personnel and circulated to management.
Minutes of the last
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three meetings were reviewed by the inspector.
d.
The Mechanical & Structural Engiceering Department has eight graduate engineers and two engineering associates to follow
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Dresden and Quad Cities project work requirements. Major l
design effort is sub-assigned to the Architect Engineer.
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Modifications received from the station are logged and assigned to one of the engineers. M&S records indicated 12 modifications involving Dresden were open. These dated back
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_to 1972 and does not include items which were part of the contract settlement with General Electric Company. Modifi-
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cations in Engineering are not assigned a priority system
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except as noted in section c.
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7.
Drawing Conti;1
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Prior to December 27, 1973, GE reportedly handled most of the drawing changes.
Presently when station initiates a Drawing Change Request, M&S makes a copy of the request for file and forwards one copy with the print to S&L for revision. Approximately 30 Drawing Change Requests had been issued between July 73 and May 74 accord-i ing to these records.
None had been received back completed from-
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S&L. M&S representative stated that station personnel were in the process af reviewing all previous modifications to assurd that drawings had been updated.
8.
Quality Assurance Organization The Nuclear and Fossil Systems Department is currently charged with the responsibility for all CE operating plant's Quality Assurance
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Programs.
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i The Quality Assurance Administrator serves as a focal point for all I
quality assurance matters for the department.
His assigned respon-siblities include:
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a.
Coordinating, reviewing, updating and approval of. Quality Procedures for the Corporate Quality Assurance Manual.
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b.
Supervises one Quality Assurance Engineer at each reactor i
site.
(See Item 10 Section I)
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c.
Reviews Quality Assurance Reports sent to the department.
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Discussions. relating to the Quality Assurance Engineer were covered in the sith portiog ~Oe management incpection.
No significant deficienci.es'wsrebsotad-in the inspectors review of items a and c.
When questioneo relative to the training being given the QA engineers the licensee stated that informal training sessions were conducted monthly to discuss changes and interpretations of the quality manual and to discuss problem areas. 'The licensee stated that no formal training has been conducted nor are any planned.
9.
Training The corporate office has a 3 man staff to coordina'te training requirements. The training programs for Dresden, Quad Cities, and Zion were noted to be summarized in a writeup dated June 14, 1974 A proposed change to Quad Cities program was sunnarized and was indicated in an internal letter dated June 21, 1974, a's having been recently presented to the Directorate of Licensing.
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10.
Licensee Methods of Finding Problems at Other Reactor Sites
.n discussions with members of the Corporate Office it was deter-
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mined that the licensee utilizes the following as sources of infor-i mation to determine what problems are occurring at other reactors.
I 1.
Clearing House News 2.
Edison Electric Institute m,eeting i
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3.
AEC Reactor Operating Experience Reports
4.
R0 Bulletins and other information received from the AEC regional offices.
The licensea. stated that these information sources are routed thru the office and items pertinent to the various stations are submit-ted to the Station Superintendent for review and action.
In addition personnel from the Corporate Office have monthly meetings to discuss problems being experienced at the Commonwealth Edison sites with the Station Superintendent. Agenda covers QA problems, status of outage works, problems being experienced at the sites, etc.
On a short term basis the Manager of Production contacts each. site each~ day to determine status, plant problems being experienced, etc.
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