IR 05000373/1993023

Insp Repts 50-373/93-23 & 50-374/93-23 on 930827-1015. Violations Noted.Major Areas Inspected:Lers,Review of Plant Operations,Maintenance & Plant Support Activities

ML20059K669
Person / Time
Site:	LaSalle
Issue date:	10/29/1993
From:	Hague R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20059K642	List: IR 05000373/1993023 ML20059K638 ML20059K651
References
50-373-93-23, 50-374-93-23, NUDOCS 9311160139
Download: ML20059K669 (14)

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'U.S. NUCLEAR REGULATORY COMMISSION REGION III ,

Report N /93023(DRP); 50-374/93023(DRP) ,

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Docket.No ; 50-374 License Nos. NPF-ll; NPF-18 ;

Licensee: Commonwealth Edison Company Executive Towers West Ill t 1400 Opus Place Suite 300 ,

Downers Grove, IL 60515  :

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Facility Name: LaSalle County Station, Units 1 and 2 Inspection At: LaSalle Site, Marseilles, Illinois Inspection Conducted: August 27 through October 15, 1993 Inspectors: D. Hills  !

C.PhillIps  ;

J. Roman, Illinois Department of Nuclear Safety

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Approved By: . /d/#7[f5 '

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THaue, Chief .Dat [

Reactb rojects Section 1C j i

Inspection Summarv i

Inspection from Auaust 27 throuah October 15. 1993 (Reports No. 50-373/93023'- l IDRP): 50-374/93023(DRP)).

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Areas Inspected: A routine, unannounced safety inspection was conducted by ,

the resident inspectors and an Illinois Department of Nuclear Safety 1 inspector. The inspection included followup on previously identified items  !

and licensee event reports; review of plant operations, maintenance, and plant . ,

support activities; and completion of Temporary Instruction 2500/028, t

" Employee Concerns Program". ,

Results: One violation was identified regarding a failure to tape hoses at a ,

contaminated area boundar This was indicative of an inability to address ,

overall radiological nousekeeping and radworker practices concerns in a timely manne Plant Operations Despite previous related problems, licensee management failed to. instill a l good understanding as-to constant air monitor.(CAM) purpose and ensure  ;

effective CAM usage. Shutdown risk initiatives have-been described in 'l formal procedure _(as opposed to a previous guidelino document) and were being followe l

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Maintenanc The inspectors observed numerous maintenance and. surveillance activities with .;

no problems note Enoineerina Licensee actions to address problems maintaining drywell oxygen concentration - l

. limits. continued with considerable engineering involvement in this issu l

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.i Radiological housekeeping-and radworkers' practices continued to be problem ~

The licensee failed to make effective-and timely progress following similar q NRC concerns raised most recently in August 199 Toward the end of the l inspection period, the licensee enhanced actions to address this area. A -J large percentage of open. items in the licensee's' housekeeping and material- j condition program were over two years old. The licensee also began a special'-  !

review of these items for further actio !

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i EETAILS'  !

1._ Persons Contacted ..

W. Murphy, Site Vice President l J. Schmeltz, Station Manage f J. Gieseker, Site Engineering and Construction Manager-C. Sargent, Support Services Director  !

M. Reed, Technical Services Superintendent' >

J. Lockwood, Regulatory Assurance Supervisor j

• M. Santic, Maintenance Superintendent  :

• R. Crawford, Work Planning Assistant Superintendent I

• L. Oshier, Radiation Protection Supervisor  !

• T. Shaffer, Executive Assistant for Site Vice President

• John Bell, Maintenance Staff Supervisor j

• J. Arnould, Regulatory Assurance

• M. Cray, Master Instrument Mechanic

• E. McVey, NRC Coordinator *

• D. Carlson, Regulatory Assurance ,

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• Denotes those attending the exit interview conducted on October _15, j 199 :

The inspectors also talked with and interviewed several other licensee

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employees during the course of the inspectio i

~ Licensee Action on Previously Identified Items (92701 and 92702)-

(Closed) Violation (50-374/93013-02(DRP)): A fuel bundle was .

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mispositioned in the fuel pool. A more recent event similar to this'one- 1 is discussed in inspection report 50-374/93028(DRP). That report i includes an evaluation of licensee corrective action effectivenes [

Further actions will be tracked through items in'that report and, i therefore, this-item is close l (Closed) Unresolved Item;(50-373/930ll-02(DRP)): Verify procedures prescribe closure of the' feedwater motor operated gate valve for long 3

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term leakage control. Closure of-the feedwater header stop valves =are - '

prescribed in LaSalle General Procedure 2-1, " Normal Unit- Shutdown."

This item is close a

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(Closed) Violation (50-373/92027-03(DRP)): Several procedures' were inadequate. Revision of the subject procedures and other actions such- ;

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as additional training addressed the specific items. 'In addition,--the'

licensee continued actions to better track and encourage procedure' s revision requests. Continued progress on procedure revision backlog ,

will continue to be evaluated during routine inspections. This item is ;

close No violations or deviations were identified in this area; 3 1

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L Licensee Event Reports Followuo'(92700)

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The following licensee event reports were reviewed to ensure _that . _ 'l reportability requirements were met, and that corrective actions, both !

immediate and to prevent recurrence, were accomplished or planned in 1 accordance with the -technical 'specifica?. ions-(Closed) LER 374/92016-01 ' Reactor Scram'on' Loss.of Air Due toLan

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inadequate Out Of Service Revie ,

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(Closed) LER 373/93014-00 Lack of Automatic Trip of the' Mech'anical _

Vacuum Pump on Main Steam Line High Radiation Due to an Inadequate Pre- ;

License Change Review- 1 (Closed) LER 374/93006-00 Diesel Generator Cooling Water Pump' Breaker

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l Failure Due to Unknown Reasons In addition, recent problem identification forms (PIFs) were reviewed in 1 order to monitor conditions related to plant or personnel performance and to detect potential development of trend No violations or deviations were identified in this are .

4. Plant Operations (60710. 40500, and 71707)

The inspectors' reviewed the facility for.conformance with_ the license ,

and regulatory requirement On a sampling basis the inspectors observed control' room _

i activities for proper control room staffing; coordination'of plant .,

activities; adherence to procedures'or technical specifications; I operator cognizance of plant- parameters and alarms; electrical! l power configuration; and the frequency of plant and control ro~om :

visits by station managers. Various logs and surveillance-. records j were reviewed for accuracy and completenes i On September 24, 1993, the inspectors noted the " trip 2" light

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illuminated on one of the constant. air monitors (CAM)Lon the refuel floo (The " trip 1" light bulb was burnt out.) No work i was in progress on the floor at the time- and licensee management-

, was informe The licensee indicated that the trip setpoint l needed to be raised and that a work request had' already been

initiated. The following day while observing movement of fuel from the new fuel storage vault to the Unit 2 spent fuel pool, the ,

inspectors noted the " trip.1" and " trip 2" lights were still ..

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illuminated on the same CAM and the " trip 1" light was illuminated on the other CAM.- Failure to correct the setpoint of the CAMS prior to performing work in the refuel floor, effectively negated 1 the visual alarm function. (No audible alarm was- provided in the . I CAM's design.) The inspectors considered this poor utilization of - !

the CAMS. The inspectors had previously noted problems with. poor

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material condition _ of plant CAMS and failures to. perform._ CAM surveillances in inspection report 50-373/93007(DRP);' ,.

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50-374/93007(DRP)), including issuance of a notice of violatio !

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Furthermore, a refuel floor contamination' event on September 7, 1993 involved aL failure to properly place and utilize the' CAM l-Despite these previous problems, licensee management failed to -I-instill a good understanding as to CAM purpose and ensure  :

. effective CAM usag _. ;

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' Walkdowns of select engineered safety features (ESF) were ._ .,

performed. The ESFs were reviewed for' proper valve.and electrical l alignments. Components were inspected for leakage, lubrication; abnormal corrosion, ventilation and cooling water supply *

availability. Tagouts and jumper records were reviewed fo .i accuracy where appropriate,  ;

i The inspectors verified that refueling activities were being l conducted and controlled as required by technical specifications-  !

and approved procedure This was done on a sampling basis  ;

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through direct observation of activities and equipment,_ tours-o the facility, interviews and discussions with licensee personnel, .

and independent verification of-safety system status and-limiting l conditions for operation (LCO) action requirements. Specific  ;

problems noted are described in inspection report 50-374/93028(DRP)). Shutdown risk initiatives-were similar to-  :

those in the last refuel outage and documented in corresponding ~  !

reports. The shutdown risk program had been described in a: forma ;

procedure versus the guideline document utilized previousl ]

a No violations or deviations were identified in this are j

! Maintenance (61726 and 62703) ,

. . i Station maintenance ' activities affecting the safety-related.an .i '

important to safety systems and components listed below were observed o reviewed to ascertain that they were conducted in accordance with approved procedures, regulatory guides and industry codes or 3tandards, and did not conflict with technical specification The following maintenance activities were observed and reviewed:

I WR L20745 Perform 0 diesel generator inspection WR L24692 Replace the motor on the IB reactor protection system (RPS)

motor generator (MG) set l WR L23914 Adjust the 0 diesel generator-cooling water pump oiler WR L22122 Replace the Unit I average power range monitor (APRM) bypass switch l ' Surveillance testing required by technical specifications, the safety analysis report, maintenance activities, or modification activities were observed or reviewed. Areas of consideration 'while performing observations were procedure adherence, calibration of test equipment, 5 '!

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identification- of testIdeficiencies, 'and personnel qualificatio'n. . Areas-

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of consideration while reviewing surveillance records were. completeness, .

proper authorization and review signatures, test results properly .l dispositioned, and independent verification documented. The following i activities were observed or reviewed-  !

LaSalle Technical Surveillance (LTS)-1100-13, " Control Rod Drive Stall' :i'

Flow Measurement" LaSalle Operating Surveillance (LOS)-RD-SR3, " Control Rod Operation in i Plant Conditions 3 or 4"

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j LaSalle Mechanical Surveillance (LMS)-DG-01, " Main'. Emergency Diesel Generator Unit Surveillance"

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No violations or deviations were identified in this are . Enaineerina i

The inspectors continued to evaluate licensee progress in addressing '

problems with maintaining drywell oxygen concentration within' technical specification limits. A limiting condition for operation (LCO)'was j entered approximately five times in 1993 for this condition. A .. l surveillance to determine oxygen concentration was performed on a weekly -

basis and actions taken based on the results. The licensee had . i previously lowered the concentration threshold that prescribed actions -

to lower the oxygen concentration but this did not resolve the proble The licensee believed inaccurate hydrogen / oxygen monitors were largely  ;

at faul The licensee was upgrading several components including the '

reagent gas flow meters during the current Unit- 2 refuel outage and planned the same for the next Unit I refuel outage to provide more -

precise calibration. The system engineer was also evaluatin ..

installation of a continuous monitor to provide earlier warning that  ;

limits were being approached. A final decision had not yet been made .

whether to proceed with this change. The inspectors will evaluate the  !

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effectiveness of these actions in future ~ inspections.-

i 7. Plant Support (71707. 40500) l On a routine basis the inspectors toured accessible areas of the 1 facility to assess worker adherence to radiation controls and the site  !

security plan, housekeeping or cleanliness, and control of field ,

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activities in progres Radiological housekeeping continued to be poo Inspectors y touring the reactor and turbine buildings identified concerns -l similar to those described in inspection report 50-373/93019(DRP);

50-374/93019(DRP). Examples of these conditions from a  !

September 21, 1993 tour included discarded anti-contamination clothing inside and outside several contaminated. area boundaries, water on the floor around the Unit I heater drain pumps, and drip ,

rags, saturated with oil, left around diesel generator equipmen ]

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-I Finally, four carts on wheels were found in an unsecured  ;

condition, one near reactor vessel level instrumentation (close' to *

the northside Unit 1 control rod drive hydraulic control units). -

This would be a concern- for potential damage to important  :

equipment upon a. seismic event and contrary to LaSalle. Pol. icy : !

Guide Number 6 Station quality verification (SQV)-had noted ~'

similar deficiencies in August 1993 with . regard to removed breakers, portable air coolers, and a handwheel cart (LaSalle: . ;

County Station August 1993 Field Monitoring Program Report). 'SQV !

recently identified additional examples, indicating licensee ,

corrective actions were ineffective, and had escalated the j corrective action record (CAR) level to obtain greater management ~ ;

awareness and response. The inspectors will continue to evaluate ,

licensee actions as to wheeled cart control and SQV effectiveness in forcing effective resolution of this issu +

The licensee failed to make progress regarding radiological-housekeeping improvements following NRC concerns raised in August i

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1993 and documented in the above report. Historically, plant radiological housekeeping concerns have been-raised periodically, !

followed by some temporary improvemen However, the licensee-has <

been unable to effect a permanent solution. To address this~and a related recurring issues, the licensee designated a corrective

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actions manager (CAM) near the end of the inspection'for-the !

remainder of the refuel outage to overview radiation work practices, plant housekeeping, system and area material condition,. .

and procedural complianc The CAM oversaw dedicated observation teams to identify unacceptable plant. conditions and a dedicated- :

team to correct these conditions. . Increased emphasis was also '

placed on increasing plant management time in the plant which !

previously was minimal in many cases. - The inspectors will  :

continue to evaluate expected short term' effectiveness of these (

actions. The licensee was also evaluating long term actions t I preclude the repeated occurrences'noted in the pas j On September 21, 1993, while performing an inspection in the t reactor building, hoses.and an electrical cord which breached -

contaminated area boundaries on the 786 foot elevation of the !

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reactor building were found not taped at the contaminated area-

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boundary. This same type condition ~was noted previously and was ,

the subject of a previous violation (50-373/93019-02(DRP)). While-observing the condition, a licensee Quality Control (QC) inspector: .

entered the area outside the contaminated area._. The QC inspecto !

was unaware of.the recent violation or the need to tape hoses and- i electrical cords at the contaminated area boundary. Despite l passage of a month since identification' of the previous violation, j the licensee had not effectively dealt with the ' problem. Th .. i Jailure to tape hoses and the electrical cord at the boundary of 'a !

contaminated area as required by radiation control procedures is ~!

another violation (50-373/93023-01(DRP)) of technical l specification 6.2.B which requires adherence to radiation' control !

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c, . The inspectors reviewed items identified in the licensee's housekeeping and material condition. progra Approximately 9700 items were closed-since its inception in October 1990 with about ;

630 items still open. A large portion (about 30 percent). of' L remaining.open items existed prior to 1992. The' corrective: 1 actions. manager began reviewing these items r. ear the end of the !

inspection. The licensee also acquired additional resources t .

repair insulation, a substantial percentage of the older item !

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One violation and no deviations were identified in this' are j Temporary Instruction 2500/028. " Employee Concerns Proaram" The inspectors verified the licensee had implemented an employee $

concerns program to provide an alternate path from normal line management to raise safety concerns. The specific characteristics o this program and an evaluation of its effectiveness is described on the -

attached form. This temporary instruction is considered close i

.I No violations or deviations were identified in this are l 1 Report Review (90713) 1 i

During the inspection, the inspector reviewed selected licensee reports _)

and determined that the information was technically adequate, and that- l it satisfied the reporting requirements of the license, technical i specifications, and 10 CFR as appropriat )

No violations or deviations were identified in this are ,

l 10. Exit Interview J The inspectors met with licensee representatives (denoted in Paragraph ~

1) during the inspection period and at the conclusion of the. inspection period on October 15, 1993. The' inspectors summarized the scope an results of the inspection and discussed the likely content of this

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inspection report. The licensee acknowledged the information and did- 'l not indicate that any of the information disclosed during the inspection could be considered proprietary in natur l

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i Attachment EMPLOYEE CONCERNS PROGRAMS l

.i PLANT NAME: LaSalle Licensee: CECO DOCKET #:L50-373:374 ,

Dresden CECO 50-237:249-Ouad Cities CEC 0 _50-254:265 ,

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Byron CECO 50-454:455 Braidwood CECO 50-456/457 ,

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_C_EJO 50-295/304 ;

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NOTE: Please underline yes or no if applicable and add comments in the space provide t PROGRAM: I

, Does the licensee have an employee concerns program?  !

e (.Y_es or No/ Comments) l The licensee conducts a Quality First (QF) program to identify and :I address employee concerns. Other programs such as thc vision :

through quality (VQ) search for opportunity (SFO) exist.. The VQ/ -

SF0 program is more oriented toward identifying and developing- !

improvement initiatives versus a formal program for raising !

specific safety issues. Therefore, the completion of this form' .i will deal only with the QF progra ;

1 Has NRC inspected the program? Report #

The NRC had not recently inspected this progra )

i SCOPE: (Circle all that apply) j Is it for:

} Technical? (Yes. No/ Comments)

! Administrative? (Yes. No/ Comments) Personnel issues? (Yes. No/ Comments) q The concerns are categorized as security, quality, and management - I but may, in fact, involve any of the abov ;

' Does it cover safety as well as non-safety issues?

(Yes or No/ Comments) , Is it designed for:  ; Nuclear safety? (Yes. No/ Comments)

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i Personal safety? (Yes. No/ Comments) l I Personnel issues - including union grievances?

(Yes or h / Comments) .;

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Although it.can involve personnel issues,.it does not deal ,

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with union grievance !

' Does the program apply to all. licensee employees? }

(Yes or No/ Comments) ,

l Contractors?

(Yes or No/ Comments) {

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This program is not necessarily stressed to contract employees' the' '

licensee believes are not in a position to identify Quality First !

issues such as parking lot paver j .

Does the licensee require its contractors and their subs to have a~ :!

- similar program?  !

(Yes or M/ Comments)  ;

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Ceco administers the entire progra .;

Does the licensee conduct an exit interview upon terminating l employees asking if they have any safety concerns?,  ;

(Yes or No/ Comments)  ;

t Upon termination, employees are given concern. disclosure ,

statements to- complete. Exit interviews are given. The .

percentage of ~ terminating employees receiving them has been !!

drastically reduced due to a reduction in program' manpower'.since 'l the beginning of the yea j C. INDEPENDENCE: .I

- What is the title of the person in charge?

Quality First Administrator (QFA) ] Who do they report to?

Director of Station Quality Verification q

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Yes-Reports through offsite quality verification organization - Does the ECP use third party consultants?  ;

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No'-However, quality verification personnel have'been utilized to' l do interviews. The_QFA determines the appropriate group to do.the !

. investigatio j How is a concern about a manager or'vice' president followed.up? ;

'I This would be decided on a case by case basi L

'I RESOURCES:

! What is the size of staff devoted to this program?

l Since the beginning of the year, staff has been cut to one  !

individual for all six CECO plant !

. What are ECP staff qualifications (technical training,  !

interviewing training, investigator training, other)?- :l No specific qualifications exist for the QFA, who has been f involved in the program a number of years. Guidelines for  :

interviewers are~ available but there are no specific ,

qualification j

REFERRALS: '[

i Who has followup on concerns (ECP staff, line management, other)? j

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The QFA may do the followup himself or. assign it to another group including line managemen j t CONFIDENTIALITY:

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4 Are the reports confidential?

(Yes or No/ Comments) -i i Who is the identity of the alleger made known to (senior  !

management, ECP staff, line management, other)? j

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Information on the alleger identity remains with QFA.- l

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' Anonymous? (Yes/No Comments) Report by phone? (Yes,No/ Comments) .j-l A toll free number is availabl ;

.' FEEDBACK: Is feedback given to the alleger upon completion of the followup?- j (les or No - If so, how?) .'

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b Feedback'is given by mail or telephon i 2. . Does program reward good ideas? l

No- l

Who, or at what level, makes the final decision of resolution?  !

This is determined by QFA in conjunction with line managemen I r Are the resolutions of anonymous concerns disseminated? -!

No t Are resolutions of valid concerns publicized (newsletter, bulletin -

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board, all hands meeting, other)? {

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, EFFECTIVENESS:

' How does the licensee measure the effectiveness of the program?

Not measured  ;

i Are concerns: j Trended? (Yes or No/ Comments) ,

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There are too few official ~" Records of Concern" (ROC) to warrant trending. The QFA does informally look for common

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concerns on items which do not warrant official ROC l

! Used? (Yes or No/ Comments) [

Corrective actions are addressed in the progra U In the last three years how many concerns were raised?

Closed? What percentage were substantiated? ,

The QAF screens comments and identifies those to be handled as  ;

official Records of Concern" (ROC). l The following data is for ROCS from 1990 through August 1993. No- .l formal ROCS have been initiated thus far in 199 :

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1. Raised and Closed-  % Substantiated i LaSalle 2' 100  !

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Byron 9 22 Br_aidwood 6 33 i Quad Cities 3 33  :

Dresden 4 25- 1 Z. ion 1 0 . )

l Comments received during or after a refuel outage that the QAF :i determines do not warrant an official ROC are compiled and l transmitted to plant management for information. This occurs-- .!

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several months after the outag j 1 How are followup techniques used to measure effectiveness (r;andom i survey, interviews, other)?

No followup techniques utilized except perhaps for contractors they see multiple times at different CECO site > How frequently are internal audits of the ECP conducted and by whom?

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'There are no audits of this area. The onsite quality verification superintendent is responsible for reviewing information ' copies of quality- ROCS to determine if additional QA- reviews are. warrante ADMINISTRATIVE / TRAINING: Is ECP prescribed by a procedure? (Yes or No/ Comments)

Nuclear Operations Directive (N0D)-0A.12,. " Quality First Program Directive" How are employees, as well as contractors, made aware of this program (training, newsletter, bulletin board, other)?-

The program is briefly described -in Nuclear General Employee-Training (NGET) It may also be mentioned in occasional safety meetings or departmental tailgate ADDITIONAL COMMENTS: (Including characteristics which make the program especially effective or ineffective.)

In viewing the number of official " Records of Concerns (ROC)," that are I

formally tracked, investigated, and resolved, the effectiveness of the'

program is questionable. No ROCS have been generated thus far for 199 This may be partially related to the staff reduction and availability of i personnel to conduct exit interviews. -Due-to the lack of resources, ~

some concerns which would have been handled as ' official ROCS in previous years are now being handled. more informall l.

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t E The person completing this- form please: provide the following information to .

the Regional Office Al. legations- Coordinator. and fax it'to Richard Rosano at . i!

301-504-343 i

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NAME: TITLE: PHONE #:

David E. Hills / Senior Resident inspector /815-357-8611

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DATE COMPLETED: 9-6-93  ;!

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