ML20081F897

Forwards Response to IE Performance Appraisal Insp Repts 50-237/83-16 & 50-249/83-15 on 830509-0603 Re Onsite & Offsite Review & Investigative Functions & Plant Operations. Findings Re Operator Awareness Disputed

ML20081F897
Person / Time
Site:	Dresden
Issue date:	10/27/1983
From:	Reed C COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
7380N, NUDOCS 8311040028
Download: ML20081F897 (13)

Text

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f' 's Commonwealth Edison

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) one First Nationit Plaza, Chicago, litinois

(

} Address Reply to: Post Office Box 767 N

/. Chicago, Illinois 60690 '

October 27, 1983 Mr'. James G. Keppler, Regional Administrator Region III U.S. Nuclear Regulatory Commission 799. Roosevelt' Road Glen ~Ellyn, IL 60137 j

Subject:

Oresden Station Units 2 and 3 Response to Performance Appraisal Inspection Nos. 50-237/83-16 and 50-249/83-15 NRC Docket Nos. 50-237 and 50-249 References (a):

J. M. Taylor letter to Cordell Reed dated July 25, 1983.

Dear Mr. Keppler:

-This letter is in response to the Performance Appraisal Inspection conducted by Mr. D. G. Hinckley and members of the Operating Reactor Programs Branch, Office of Inspection and Enforcement, on May 9 through 20 and May 21 through June 3, 1983, of activities authorized by

-NRC Operating Licenses DPR-19 and DPR-25 for the Dresden Nuclear Station.

Our response addresses, as requested, the observations made in two categories:

On-Site and Of f-Site Review and Investigative Functions cnd Plant Operations.

Commonwealth Edison takes exception to certain observations made in the report specifically with respect to operator awareness.

However, we find that other observations identified specific weaknesser and we have completed or will be implementing the corrective cctions detailed herein.

To.the best of my knowledge and belief the statements contained herein and in the attachment are true and correct.

In some respects these statements are not based on my personal knowledge but upon informa-tion furnished by other Commonwealth Edison employees.

Such information has been reviewed in accordance with Company practice and I believe it to

-be reliable.

If you have any further questions regarding this matter, please direct them to this office.

Very truly yours, b

N(kj 8311040028 831027 PDR ADDCK 05000237-G PDR Cordell Reed Vice-Fresident 1m I

f gdi cc:

.J.

M. Taylor, I&E NRC Resident Inspector - Dresden QQg Attachment

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ON-SITE AND OFF-SITE REVIEW AND INVESTIGATIVE ~ FUNCTIONS Each of the' Performance Appraisal Inspection Team's observations Lare-responded to as follows:

- -Observation lA Although th's Performance Appraisal Team (PAT) indicated a

. concern with:the individual versus collective.on-site review process, we believe.that. a proper combination of the two has existed.

However, we dc recognize that the collective ~ review process has not been well documented

. 'at Dresden.

It-is our11ntent to revise Dresden Administrative Procedure (DAP) 10-1 (On-Site Review and, Investigative. Functions) to more clearly require and describe the method of documenting the collective review process.

In. addition, senior, station management will convene approximately quarterly, but not less.than twice a year to discuss the safety 1 significance ~ of trends. in topics such as Deviation or Licensee 1 Event Reports,_Q.A. Audits, Radiation Occurrence Report trending, Nonconformance or Discrepancy Records, and NRC correspondence which has been issued within that period.

These changes are scheduled to be implemented by' March 1, 1984.. The results of these meetings will be forwarded for additional examination by Of f-Site Review.

As for the Off-Site Review' function these reviews are not con-ducted in.an isolated series fashion without interaction and discussion between the. assigned: reviewers.

The Senior Participant and the Other

-Participant are in the same. organizational unitsand are located in close proximity to each other in the same office area.

Interdisciplinary

. discussions'by these participants and with other selected participants and information sources are essential to a thorough review and are

. practiced..For same reviews'.these group' discussions include the entire 7 corporate office ~ staff of the Office of Nuclear Safety.

' Observation'1B

-Though we believe that the intent of the Technical Specifications

. has been accomplished by both the Operating Engineer and procedure DTP-8,

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me agree that: improvement of this review could be made.

The above mentioned procedure:willibe revised to strengthen the review of facility operations to: detect potential safety hazards'.

Ob'ervation'lCI s

'With1 reference to the uselof "line organization" personnel in

.0f f-Site Reviews, it is not intended.that these persons perform Has

" participants"..~When used they are' considered "information sources" to

- provide factual'information required to supplement or elaborate on the reports or data available for.the1 review.

As such, they should'not be

' identified as " participants" making evaluations and judgment decisions on lthe: review overall topic itself.

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.- Of f-Site Review disagrees that the examples mentioned here transferred the technical portion of its review responsibilities to the line organization.

Specialists and consultants are available to either On-Site or Of f-Site Review.

Providing recommendations to Of f-Site Review does not place these consultants in the line organization as long as they remain independent of the Station Superintendent.

It would be redundant and not cost effective if Of f-Site Review had to bring in a second, independent' consultant as a participant.

Of f-Site Review assures that an independent review is performed by using and listing as participants only individuals independent of the Station Superintendent.

No further inde-pendence from the Nuclear Division organization is required by the Technical Specifications.

There is no deliberate effort to exclude people who have been previously involved (with some aspects of the subject being reviewed).

Their input is examined for completeness and accuracy and they are treated only as information sources not participants.

Observation 10 It has been the practice at Dresden Station to allow review participants to be suggested by the originator subject to the approval of the Station Superintendent.

DAP 10-1 presently indicates that the Technical Staff Supervisor may assist in the initial selection process.

In practice at Dresden Station, the Technical Staff Supervisor has been selected to review and approve virtually every on-site review that has been issued.

Therefore, we feel that the review of the participants by the Technical Staff Supervisor and the Station Superintendent insures that selection is based on expertise, tra'ining and experience and that people

-cre not excluded because they may have strong opinions, etc.

Observation IE This observation is difficult to understand in light of Observa-tions 1C and 3.

When specialists are used as part of a review, this is done so that their particular expertise can be utilized in that review.

It is our belief that a combination of personnel who have the necessary technical expertise should be used along with personnel who have an under-standing of potential safety hazards and unreviewed safety questions.

Please note the Technical Specifications require only a minimum of two individuals to perform any review in addition to the review performed by the Station Superintendent or Supervisor of Of f-Site Review, as applicable.

Observation 2 Dresden Station believes that the observation made in Item 2 will be addressed in our review and revision of DAP 10-1 as indicated in the response to Observation 1A.

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'The Off-Site Review and Investigative Function Administrative

" Procedures do not specify'" series" reviews.

The administrative ~ procedure

for this function states, "the findings.and recommendations are developed by_the. Senior Participant in~ consultation with any_other review

. participants".- The Supervisor of the Of f-Site Review " reviews and

. approves _the. review participants'and.the report".

Also, committees may be

formed and meetings held to facilitate discussion end' resolution of review

-items".

The' OffdSite Review and Investigative Function, by Technical

Specification 6.1.G.10, provides for " review and report findings and recom-mandations regarding all items ; referred by the..... Manager of Quality LAssurance". JQA audit. reports are routed lto the Senior and alternate

-Participants'for.their examination and identification of safety related

' items.~

Of f-Site Review-performs reviews.of items as required by the.

plant Technical Specifications.

As such, none of the corrective action systems listed:here' require review.

However Quality Assurance audit findings are received-and-read by-the Senior, Participant.

Radiation, Occurrence. Reports'are-reviewed within the station and by the Nuclear Stations Division.

Nonconformance Reports and Discrepancy Records are reviewed'in-accordancefwith-the Quality Assurance Procedures.

In all cases, Of f-Site Review considers the process in -place as entirely satisfactory.

Observation 3 Subsequent to the_ performance ~of the PAT Inspection, a seminar cas : held with all members of the Technical Staff to discuss the referenced

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' materials available and provide a better understanding of 10 CFR 50.59.

InLaddition, a memo has been sent to all'on-site _ review. participants' to

'edd additional' reference material to their booma and also to remind them of.:what'.is available in-the reference book.

Finally, a_ training session at which 10 CFR 50.59 will be

. discussed.will'be given-by' February 1984 to the On-Site Review partici-

-pants..- LThis training. session will also include a discussion of an unreviewed safetyzquestion.and the use of the FSAR.

. ;To Limprove the Off-Site l Review Program -and to be responsive to

)the' indicated concerns the statement from 10 CFR 50.59 defining what constitutes.an unreviewed safety question will be incorporated into the

.0ff-Site. Review Program Manual.

Also, ~ 0ff-Site Review will prepare a document.providing guidance

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.to' reviewers,< consultants and other specialists in the understanding of 10

_CFRl50.59 and its applicationoto the identification of unreviewed safety (questions.

., Observation 4 Off-Site Review believes that proper controls are already in -

place to assure that all items requiring review are being submitted..This requirement is audited annually by Quality Assurance and no findings or discrepancies have been reported.

Further verification is provided by.

station visits by the Senior Participant and through discussion with plant personnel.

Procedure changes are transmitted to Off-site and require return of the transmittal letter to verify receipt.

Procedure manuals in the

~ 0ffice of Nuclear. Safety are audited for completeness by Quality Assurance and the signed, returned. transmittals are audited at the station.

These controls assure completeness in this area of the example.

The completeness of safety related modification submittals will be checked further by requesting Quality Assurance to increase.their sample size in the next audit.

If any findings are made, corrective cction will be taken at that time.

Of f-Site Review will examine the findings of the proposed meetings committed to in Observation lA to assure that appropriate referrals to Of f-Site Review have been made.

An independent Safety Engineering Group has been established at LaSalle Station and similar groups are planned.for all stations.

The close interface between the group and the station will insure that all appropriate issues are referred to Off-Site Review.

This will provide an edditional overview to assure completeness of reviews.

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. PLANT OPERATIONS

.Th's Performance AppraisalLInspection Team's observations in the area; of-plant operations were reviewed. :Dresden Station Management takes

exception to some of'the conclusions identified.

Lacking more specific informationRon certain observations, it appears that the management

! controls provided or the actual operating activity observed at Dresden Station were misunderstood or overlooked.

This may have resulted from the

lack of adequate discussions with the individual making the observations.

g However, other~ findings in this area were applicable and a corrective Ecction plan. implemented.

.A response _to each observed weakness is as follows:

Observation-2

,This observation identified three concerns:

l.

Poor. definition of the Shift Engineer and Shift Control Room

-Engineer. interface during abnormal conditions.

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Lack of-procedures covering the transfer of control room responsibilityjduring transient' conditions.

3.

LLack ofitransient-condition team training on the simulator.

DAP 7-1 addresses-the roles of both the Shift Engineer (S.E.) and the major Shift _ Control Room Engineer'(SCRE) under accident conditions.

The major function of the-SCRE during accident conditions is to evaluate

-events in: progress;an~d advise the S.E. on the proper-actions to be taken.

Much of.the guidancefprovided in this'~ area comes from.the Dresden General

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? Abnormal. Procedures (DGAs)', specifically, DGA 19, which is a step-by-step procedure'used to ensure adequate core cooling.

Further, theiact of transfer of hesponsibility is not complex,

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andc each control room position._has'a defined role during a-transient.

We

-do not believe-thatta procedure covering this transfer'of responsibility is-necessary.

It~would be, by definition, simplistic and; redundant since Jcach individual's role.is1 clearly defined during the transient-and everyone is_in4close communicationLduring the. transition period and throughout the transient itself.-_ This' process was successfully demonstrated during a December 1982 GSEP event-in which both operating units (2 and 3) at Dresden

' Keere brought ~to a cold shutdown condition.

1Thelthree-day' annual simulator training is conducted in four-man

' classes-that usuallyzconsist of-two (2) SR0s and two (2) R0s.. The people

-ottending each class are not necessarily from_the same operating crew.

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Many times other_ technical and operating personnel are combined with shift SR0s and:R0s to form a' class. -This approach enables an infusion of diverse. backgrounds to ensure a broad understanding of the transients and the. required 1 responses.

We believe this approach of mixing people with diverse backgrounds is superior _to,the team training concept.

O

. Observation 3

.The ANSI Standards (ANSI 18.7-1972) to which Dresden is committed requires a periodic review of station procedures.

In addition, the guld-ance of Regulatory Guide 1.33 was used in the determination of how often Dresden's procedures would_be reviewed.

Based on these two guides and the number of approved procedures, it was concluded that these procedures would not receive a quality review:if reviewed every two years.

However, specific procedures such as Radiation Protection, Emergency Planning and Operating Abnormals are reviewed every two years or less.

Procedures which are used on a routine basis.are reviewed 1through the performance of the job.

If a problem is identified either a' temporary change or procedure inquiry is initiated which may result in a permanent procedure change.

In addition, as part of the modification approved procedures are reviewed for applicability and revised as necessary.

Dresden Station feels that the established procedural review process is adequate.

Observation AA Although the current backlog of Lracedure revisions stands at cpproximately 250, significant progress has been made over the past few years.

The clerical staff has been increased to handle additional proce-dures.

More recently, a quarterly surveillance was initiated in which outstanding procedures on routing for on-site review, procedure inquiries cnd temporary procedure changes which are greater than three (3) months old cre identified.

Those which may have a bearing on safety related cctivities are also noted.

This list of procedures is then distributed to the Assistant Superintendents and Technical Staff Supervisor for disposi-tioning.

Many of the outstanding procedures (50%) are attributed to planned modifications (ie:

Primary Computer Changeover, Special Parameter Display System).

Others are due to the periodic procedure review process required by the ANSI Standards.

An investigation by the Procedure Coordinator and Office Supervi-sor was done in an attempt to streamline the clerical processing of procedures.

Two corrective actions were determined and have since been

' implemented.

Since approximately 30% of the outstanding procedures are minor in nature, the originator is now required to proofread the procedure following. typing.

Previously, a clerical person was charged with this responsibility for all procedures.

The second action was to provide cvertime for the clerical personnel in those areas of the procedure

-process which are identified as bottlenecks.

Observation 48 Modifications and the procedures they affect are discussed and reviewed'by the Modification Group, Procedures Manager and other qualified personnel on a case-by-case basis per Dresden Administrative Procedure (DAP) 5-1.

Shift personnel occasionally find a procedure p

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. requiring revision due to an implemented modification.

Based on our experiences and this observation, DAP 5-1 will be reviewed and changed implemented, if necessary, to strengthen the current process by June 1,

'1984.

We place this corrective action in a lower priority category since the current system is acceptable although possibly in need of refinement.

Observation AC Upon review of the observation, a verifier will be used more in the future as part of the On-Site Review of Operating Procedures in an attempt.to reduce errors.

A review of.the outstanding procedures identi-fled that approximately 60% which encompassed major changes were scheduled to be verified.

The process includes a hands-of f walkdown of the procedure end is usually done by operations personnel.

Observation 5 With the current method of informing the operator that the procedure has a temporary change against it, the operator is forced to have a Shift Supervisor, normally the SCRE, look up the change and verify its validity.

This also gives a Shift Supervisor complete control of temporary changes which would prevent any other person from writing in or adding steps to a temporary change without a Shift Supervisor having know-

- ledge of the desired change.

A temporary change to an approved procedure is a serious' step and needs tight control.

However, this process will be reviewed to assure proper and timely operator action during abnormal plant conditions.

The review is scheduled to be completed by March 31, 1984.

Observaticn 6 All of the observations contained in the subparagraphs of Item 6 (subparagraphs a through i) relate to perceived " weaknesses" observed during shift activities.

This area was nf major concern to both station

'end corporate management since it seemed to portray-unsatisfactory and inattentive operating shift performance.

Based on our perception, such a characterization of shif t performance is not accurate.

Our Quality Assurance Department, subsequent to the PAT visit, conducted af ollow-up audit of the Operating Department to make an f

independent assessment of shif t performance.

Quality Assurance's report

dated June 13, 1983. corroborates our feelings that a characterization of shift performance is satisfactory and attentive, contrary to the observa-tion.

Following are statements extracted from the Evaluation Section of the Q.A. Audit Report:

"Most of the deficiencies were relatively minor; however, the number of deficiencies indicates that strict adherence to the letter of various requirements is not being enforced.

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-.. Operator-attentiveness was considered very gobd.

When entering the Control Room during backshift hours, the operators quickly acknow-ledged my presence.

All operators responded quickly to annuaciator alarms and correction of any problems was prompt, and thoroughly investigated.

The Control Room-Operators acted as'a team, ar.d close supervision by Operating Management was observed.

Overall operation of the plant was considered safe, professional, and thorough.:

During plant rounds the Equipment Operators and Attendant;s fellowed

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all required Radiation Protection Practices.

They were' prompt in reporting any problems to the NSO and Shift Foreman.

Resolution of these problems was aggressively pursued by the Shift Operators."

Additionally, station management conducted a reviey of each of the observations contained in Item 6 for the purpose ofcdetermining possi-ble corrective. actions.

This review was difficult since fen specifics cere contained in the PAT report nor were they obtained during the PAT visit or at the exit meeting..Regardless of this difficulty, our assess-s ment of each of the subparagraphs of Item 6* follows.

Observation 6A A

This observation indicated that NSO's did not acknowledge all

. Control Room annunciator alarms nor did they evaluate the alarm condition.

We could not determine what4 activities and what alarms were in question during the observation period. tone possible explanation for the observa-tion is that Instrument Mechanics are routinely allowed to acknowledge

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clarms that occur as.a result of surveillance in progress.

The surveil-lance procedures contain checks to ensure that alarms annunciate at a

' specific step and can be cleared at a specific step in the procedure.

Shift supervision gives written permission to perform these soecific surveillances.

The Instrument Mechanics understand that they must immediately notify the NSO of any unexpected alarm condition on the panel ot~which they are working.

We feel that these policies are appropriate since they prevent the NSO from being pulled away from other event that may be in progress.

Observation 6B

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y' This observat'&on identified ten (10) alarms during one three-hour period.that were responded to without reference to any procedure.

Again, it could not be determined which alarms were observed.

However, normal ennunciators such as " Control Rod Drive (CRD) High Temperature" and "Drywell Sump 1 Valves Open" occur so frequently that Annunciator Response Procedures are committed to memory.

If the valve manipulations were essociated with pumpin down the containment sumps, these valves are

opened at'least.four (g) times per shift.

Pumping of the sumps by first 4

opening the valves and starting the pumps is in no way a complex

.cperation, nor does it require more manpower than the Unit NSO.

For more complex plant' manipulations, operators are required to use procedures at Dresden Station.

This point will be re-emphasized to operations personnel

-in future'six-week training sessions.

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.. - Observation 6C Dresden: Station is..in compliance with Vice President's Directive

.(VPD) No. 13'and Dresden Administrative Procedures-(DAPs).

It is believed i

that this' observation was based on a limited review of Control Room cctivities.

Normally' Shift Supervision, Operating Engineers, Quality

-Assurance Auditors and NRC Site Inspectors review Control Room activities on a frequent basis.

Since.the implementation of VPD No. 13 and the DAP, d.. fullicompliance has been observaed.

Had his concerns been immediately

'D broughtyto the' attention of. Shift Operating Management, we would have had "an opportunity to clarify them on the spot by questioning the specific NS0s

' involved.-

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_ Station' policy relatingsto reading in'the' Control Room and attentiveness will be re-emphasized to all licensed operators.

Thus, Dresden-has implemented'the following actions:

1.

LQuality' Assurance Operations Auditors have discussed attentive-nessLand reading material.with each of the operating crews during

]-- 1 the six-week' lecture series attended by each' crew during June and July of 1983.

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2.

Operating Department Management reaffirmed.the station policy concerning attentiveness and reading material to each crew during

.the six-week' operating. training program.

In each case, an open

-discussion'followed during which the disciplinary actions for a.

~lackLof attentiveness was restated.

3.-

~ Attentiveness w'as discussed with Shift Engineers during a meeting in' August. 1983.

ObservationL60 2

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The' Nuclear Station Operator.(NS0) turnover checklists are reviewed each. shift by Shift Management, and subsequently. reviewed when

! complete byLthe Surveillance Engineer.

Upon review, occasionally the NSO

. shift. turnover:is conducted:such that each turnover item 11s completed but U

.notJimmediately checked completed.,We can: find no' instance.of incomplete turnover:cnecklista.-

We have, however, identified ^ several incorrect refer-snces t@ the Dail-y(Surveillance Log pagennumber, contained in DAP 7-2, under tha?section(discussing duties,of theLoncoming and nffgoing NS0s.

Procedure: chad es have been submitted to-correct those errors.

2 Observat' ion 6E

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1.

q Use of -procedures in all facets of plant operation..is strongly

?cmphasized to all operations personnel.

Areas in the plant where step-by-Lstep sequences of operations are required have controlled procedures posted for operator'use. ' Routine: operations, such as the removal of a CRC'accumu-lator from service, ' requires awareness of precautions only,- and are s

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referenced by the operators in the Control Room prior to going to the work location.

As stated in the observation, both the operator and the Shift Foreman were totally aware of the procedure and were experienced in this operation, and we do not feel that further action is required.

Observation 6F

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, As stated in the Equipment Attendants' Round Book, a Shift Supervisor is only notified if_the last spare bottle is being installed.

The intent is to ensure that spare bottles are available.

The calibration gas for the hydrogen monitors is typically 1% hydrogen, far less than the concentration required for an explosion, thus no area monitoring is required.

s Observation 6G 1.

DAP 7-5 specifically allows the NSO to omit logging normal alarm conditions, such as " Control Rod Drive (CRD) High Temperatures".

However, a change to the DAP was submitted that clarifies the logging requirements and further defines normal alarms that need not be logged.

This change has been on-site reviewed and is now approved for i

use,

~2.

DAP 7-5 allows the omission of normally occurring alarms from the Unit logs.

The DAP has, however, been revised to give more specific guidance for those alarms that denote normal conditions.

1 3.

A review of the Unit logs disclosed no instance in which power level changes were not logged.

DAP 7-5 required individual logging of step changes in reactor power.

However, for ramp power changes it is

. permissible to log the start of the ramp, ramp rate and end of the ramp.

4.

A review of the Unit log for May 18, 1983 disclosed that both the y

removal from service and return to service of major equipment were logged in accordance with DAP 7-5.

We see no evidence of omission of any required logging requirements.

Observation 6H 4

An audit by the. Quality Assurance Department, prior to the PAT audit; disclosed a need to review the applicable Equipment Attendant (EA) e, and Eculpment Operator (EO) logs once a day.

A review on a shift basis 9

'would impose an unnecessary administrative burden on our Shif t Supervisors.

Moreever, immediate notification of critical parameters when out of tolerance is required and adhered to by the EA's and E0's.

The tolerance levels ore identified in each EA and EO log book.

However, a

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-proposed Nuclear Station Directive is under review which addresses operators log review by Shift Supervision.

When issued it will be i

implemented at Dresden Station, a

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.0bservation?6I-1The.NSO Unit 2-and 3. Log Booksifor the period of'the PAT Audit

were reviewed;and'~no evidence of

pencil usage could be~found.

In-Teddition,nthe: NSO Log Books are-frequently reviewed 1by management:

. personnel.1 :NS0' stare-permitted and.have'been observed using pencils to take.notestbut'not for permanent log entries.

The EA and EO-Round Books are frequently done11n pencil,.butfall-Technical Specification or NRC 2 committed parameters'are-subsequently' logged on the Unit Surveillance rSheets or in the UnitELogs. "These Round Books-_areLdesigned for equiprant performance-monitoring,7not' documentation of regulatory requirementL.

Observation'7-s

.The: station realizes'the importance of' good plant housekeeping in the' performance -of equipment and the ' control of contamination in the plant._-HighLpriorities to-maintain clean area's-in the plant receive cmphasis through weekly inspections-of' working areas by Department Heads, documented inspection 1 tours:by the Station: Fire Marshal, and: specific LcleaningLassignments'of' equipment to the operating. crews by the Station r0perating Engineers.. This program.has improved plant cleanliness as

_ovidenced by favorable comments by other: inspection agencies.

None:the less, we agree that further improvements in the cleaning ofL operating; equipment are necessary'.. Painting of. equipment ~when taken

out-of-service

for major maintenance has been instituted earlier this-year, while re enforcement off plant 1 equipment cleaning was the subject. of-a

Operating, Maintenance and Radiation Protection Supervisor's': Meetings held

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quarterly.since;the;beginning.,of the1 year.; These actions.have instituted 1the-properiattention'the equipment has' required and has shown considerable improvement in equipment appearance and' performance.

Management attention

will continue to strengthen this area of concern.-

10bservation-8A

The

cleanup of. contaminated areas within the plant is being cddressed-as'partiof the? Station'ALARA Program. ' Initial discussions have

beencheldito determineLthe best-management system _to_ identify ~ areas and

= schedule theirJcleanup.-

Efforts to~ develop-a working system to ensure

~ cleanup 'of contaminated areas on.a systematic basis will be continued.

1This1 system is expected to be developed and implemented by June _1, 1984.

40bservation 8B-

The specific concerns identified with the observed removal from' n. service of a:UnitJ2 Control' Rod Drive (CRD) accumulator have been reviewed.

Those ' concerns which are : contrary to the established Radiation Protection Standards atDDresden 'will be emphasized to the operating crews in the

six-week' lecture. series.- This training will be tasks oriented rather than generic lin nature =and will cover operations on a CRD accumulator, as well Tes other tasks,Lasideemed necessary.

Other concerns which reflect efforts Eto: minimize. the' contamination ofomaterials and maximize contamination surveyre f ficiencyf and _ ef fectiveness will be: continued.

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,. Observation 9 The items to be investigated, methods to be used and personnel responsible for obtaining clearance to startup following a plant trip are specifically addressed in a Nuclear Stations Division Directive that is currently in preparation.

Following issuance of the directive, these requirements will be included in the applicable station procedures by January 1, 1984.

Observation 10 The issue of preplanned fire fighting strategies is currently an unresolved item that has been identified in I.E.

Inspection Report No.

50-237/81-09; 50-249/81-06.

This item was forwarded to NRC Headquarters for I.E./NRC staff evaluation as stated in the above I.E.

Inspection Report.

Observation 11 Dresden Station has previously implemented and currently uses a system of closely tracking required reading assignments.

Our system consists of a weekly required reading package which is distributed to six identical-books in various plant locations.

Every week the Training Department collects the oldest package of four (4) in each of the books and tabulates those personnel who have read the material.

A list of delinquent personnel (greater than four (4) weeks behi the current package) is provided weekly to the Training Supervisor and the Assistant Superintendent for Operating.

Operating personnel who are six weeks behind are required to complete their required reading in their six week scheduled training program.

We agree that many of our k1 censed operators at the time of review ahd not completed the previous fouf weeks of required reading.

This is not a routine situation.

Normally the number of delinquent personnel has been limited.

We feel that the current program has been demonstrated to be effective in correcting required reading delinquency.

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