IR 05000295/1997006

Discusses Insp Repts 50-295/97-06,50-295/97-02,50-304/97-02, 50-295/97-07 & 50-304/97-07 on 970206-0428 & Forwards NOV & Proposed Imposition of Civil Penalties in Amount of $330,000

ML20217R225
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	09/02/1997
From:	Beach A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Mueller J COMMONWEALTH EDISON CO.
Shared Package
ML20217R227	List: IR 05000295/1997006 ML20217R244
References
50-295-97-02, 50-295-97-06, 50-295-97-07, 50-295-97-2, 50-295-97-6, 50-295-97-7, 50-304-97-02, 50-304-97-07, 50-304-97-2, 50-304-97-7, EA-97-222, EA-97-223, NUDOCS 9709040354
Download: ML20217R225 (6)

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UNITE 3 STATES

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NUCLEAR CECULATORY COMMISSION f S REGloN lli

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'E 801 WARRDNILLE HoAD g USLE. ILUNoIS 60532-4351

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September 2, 1997 EAs 97 222,97 223 Mr. John Site Vice President Zion Generating Station Commonwealth Edison Company 101 Shiloh Boulevard Zion,Illinct 60099

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SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTIES

$330,000 (NRC Augmented Inspection Report 50 295/97006 and inspection s Reports 50-295/304 97002 and 50 295/304 97007) ,

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Dear Mr. Mueller:

The NRC conducted three inspections at the Zion Nuclear Power Plant from February 6,1997, through April 28,1997. These inspections revbwed sever:.1 matters, including the reactivity management event that occurred on February 21,1997, one displacement of reactor coolant from the reactor vessel on March 8,1997, and the failure to comply with a Technical Specificatiori Limiting Condition for Operation on February 24,1997. The reports of these inspections were sent to you by letters dated April 29, May 21. and June 4,1997, Because of the seriousness of the issues evaluated during these inspections, a predeelslonal enforcement conference was held in the Regio,, til office on July 3,1997, to discuss the issues.

Based on the information developed dunng these inspections and the information that was pros ided during the predecisional enforcement conference, the NRC has determined that several violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties (Notice) and the circumstances surrounding thcm are described in detailin the subject Irispection reports.

Section I.A of the Notice refers to the reactivity management event of February 21,1997 in I j

( which a licensed reactor operator was assigned a task of reducing reactor power to the point  ;

of adding heat and inaovertently made the reactor subcritical. When the operator realized that the reactor was substantially subentical-- instead of stopping, evaluating, and communicating the unauthorized change in reactivity - the operator started withdrawing rods [\

}Y to make the reactor critical at the point of adding heat. This activity was observed by a ( Qualified Nuclear Engineer who expressed some concems but failed to adequately /j JJ communicate technical advice for excessive control rod manipulation to shift management.

The plant was in the process of shutting down pursuant to Technical Specifications due to an inoperable containment sp;ay pump. Prior to the shutdown, the shift and site management team failed to appropriately plan the shutdown and effectively communicate to the operating staff their expectations for shutting down the ,eactor. Licensee senior management assumed that Unit 1 was being shut dowri since the containment spray pump could not be repaired within the Technical Specification allowed outage time. However, management was not

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'6 J. aware that the shift engineer directed that the unit be kept criticalin anticipation of the pump being roturned to service. Operations supervision was so focused on pump restoration activities, that appropriato oversight of control rod manipulations was not provir;od. In addition, the licensee's failure to control tne ingress of personnel into the control room resul ed in the impairment of the formality and professionalism of control room activities, which contributed to the reactivity management event. Durinq the 8 minutes betwoon tripping the main turbine and tripping the reactor, the same timo porlod during which the primary nuclear station operator excessively manipulated control rods,39 people were in the control room envelope, with 15 people in the immediate vicinity of the areas where the primary nuclear station operator and unit supervisor were stationed. Accordingly, the violations in this section concem both the direct failure to follow plant operating procedures and the falluto to conform with station administrative procedures regarding responsibilities for reactivity control, supervisory oversight of control room activities, requirements for infrequently performed evolutions, maintenanco of control room decorum, and proper control room communications.

The fdlure to comply with plant operating and station administrative procedures during a power descent resulted in eight violations of NRC requirements, as discussed in Section I.A of the Notice. Collectively, these violations reflect a breakdown in management oversight and control of operational activities. Accordingly, those violations are classified in the aggregate, in accordance with the " General Statement of Policy and procedure for NPC Enforcement Actions," (Enforcement Polley), NUREG 1600, as a Severity Level lli proolem.

Section 1.B of the Notice addresses the tailure to implomont offectivo corrective actions for previous reactivity control pmblems that had either been documented in the licensco's corrective action system or were the subject of NRC Noticos of Violation. In April 1990 and January 1997, the licensee experienced previous reactivity managen,ent issues in which inadequate command, control, and communications were identified as causal factors. The NRC issued a Notice of Violatior,in each instance. Additionally, an internal Zion station memorandum dated February 1900, cicarly identified an adverse trend in reactivity management to operations management, and correctivo actions were not offectively implemented. The failure to implement effoetive corrective actions for previous reactivity control problems resulted in three violations of NRC requirements as discussed in section I.B of the Notice. The violations are classified in the aggregate, in accordance with the Enforcement Policy, as a Severity Level ill problem.

Section I.C of the Notice addresses the failure to prevent the recurrence of reactor coolant displacement from the reactor vessel caused by undetected gas (primarliy nitrogen)

accurnulation in the Unit 2, and to a lesser extent, Unit i reactor coolant systems while the units woro in cold shutdown on March 8,1997 This gas accumulation or volding is of concem because It presents a threat to the ability to maintain shutdown cooling flow. T his topic had been the subject of several generic correspondences and had previously occurred at Zion in September 1990, when Unit 1 was in cold shutdown. Correctivo actions to preclude recurrence had been identified, but implementation of necessary procedure changes was deferred. The failure to implement effective corrective action for a previous occurrence of undetected gas accumulation in the reactor coolant resulted in one violation of NRC requirements es discussed in section I.C of the Notice. This violation is classified in accordence with the Enforcement Policy as a Severity Level 111 violation.

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J. Collectively, the violations are of significant regulatory concern in that several administrative and managerial control systems were ineffective. The violations indicate that severallicensee processes and barriers were not used to their fullest potential to permit the early detection and timely resolution of significant performance deficiencies For example the licensee's line organization hcd failed to maintain command and control of control room activities during non.

routine activities such as the February 21,1997, plant shutdown and reactMty changes, in addition, the cite management team failed to adequately plan activities with the potentla! for risk significance, and failed to adequately communicate their expectations for shutting down the unit. Lastly, the corrective action system suffered from a noticeable lack of senior management review, oversight, and prioritization which resulted in significant conditions

- adverse to quality - such as the precursors to the reactivity management event and reactor coolant displacement by gas - not being resolved in a timely manner. The NRC's concerns were heightened by continued poor performance in the area of plant operations and in a recent escalated enforcement action' caused by ineffective management of plant operation.

The actual safety consequences of these events were low. For the reactivity management event, numerous reactor protection system plant trips were enabled that would have precluded safety limits from being exceeded due to a power excursion. The reactor coolant displacement due to gas accumulation was detected by operators before the capab!!ity to remove decay heat was affected However, the underlying causes for these events could have resulted in events of greater ccqsequence. Had plant operating and administrative procedures been properly implemented and had effective corrective actions for previous precursor and actual events been taken, neither of these events would have occurred and operations personnel would not have been unnecessarily challenged to prevent further degracation of plant conditions, Furthermore, the NRC considers the action taken by your facility management In returning the Individuals involved in the reactivity management event to licensed shift duties prior to understanding the causes of the event and prior to the completion of the operators' remediation training, to be a further indication of a lack of -

management oversight, Therefore, the regulatory significance of the reactMty management event and the coolant displacement event is high.

In accordance with the enforcement policy a base civil penalty of $55,000 is assessed each Severity Level lli violation or problem. The NRC considered whether discretion was warranted to escalate the enforcement sanction in accordance with Section Vll,B of the Enforcement Policy. After reviewing the merits of this enforcement action, the NRC has determined that discretion is warranted to double the base civil penalty for the reactivity management and command and control problems (discussed in Section I.A of the Notice) due

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to particularly poor licensee performance manifested in the poor management o"might of these plant activities, in addition, for the corrective action problem and correctivc x.tlon 1 EA 96 216 ist,ued a NoV with Severity Level 111 Violation with a 6 5o,000 civil penalty for a number of operator errors and unplanned modo changes that occurred from January . June,1996 time frame,

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J. ! violation (dis :ussed in Sections 1.0 and I.C of the Notice), the NRC has determined that discretion is warranted to double the base civl! penalty because the violations represent a

, history of poor past performance in the corrective action area.

Ineffective or untimely corrective actions at Zion have been the subject of previous enforcement action and have been discussed at a number of management meetings with Commonwealth Edison Company over the past year. Cor the violations in this case your short term Corrective Actions were only marginally e . gable as demonstrated by the previously detailed failure of the management oversight team to keep crew members involved in the reactivity management event off shift until they had completed remedial training and the failure to ensure compliance with a Technical Specification action statement. By contrast, your plans for long term Corrective Actions were globalin nature and pertained to developing communication skills, enhancing command and control, establishing an organization to preplan activities with the potential to be risk significant and manage the flow of work to the control room, Irnproving the support of engineerira organizations to plant operations, resolving plant material condition problems, improving the corrective action system, developing an effective plarn oversight group, and the removal of both units from service until the corrective plan can be implemented. However, the inability to implement offective,long.

standing corrective actions continues to impact performance at Zion.

Therefore, to emphas!ze the importance of offective management oversight of plant operations and the importance of timely, offective and lasting corrective actions, I have bo( n authorized, after consultation with the Direct 3r, Office of Enforcement and the Deputy Executive Director for Regulatory Effectiveness, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalties in the amount of $110,000 (twice the base) for each of the two Severity Level lll problems and the Severity Level 111 violation described in the Notice.

This results in total Civil Penalties of $330,000.

The violations described in Section ll of the Notice discussed three Severity Level IV violations that were not assessed a Civil Pencity. These violations address a less significant failure to comply with the action statement for a Technical Specification Limiting Condition for Operation, the failure to establish upper tier procedures to manage plant activities while a unit was in cold shutdown for an extended period of time, and the failure to make required repoits.

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J. You are required to respond to this letter and should follow the Instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further3nforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice,"

a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room (PDR).

Sincerely, m

A. Bill Beach Regional Administrator ,

Docket Nos: 50 295,50 304 Lloense Nos: DPR 39, DPR 48 Enclosuie:

Notice of Violation and Proposed imposition of Civil Pe' alties cc w/ encl:

D. A. Sager, Vice President, I Generation Support H, W. Keiser, Chief Nuclear Operating Officer R. Starkey, Plant General Manager R. God!cy, Regulatory Assurance Supervisor 1. Johnson, Acting Nuclear Regulatory Services Manager Document Control Desk - Licensing Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General l'

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DISTRIBUTION:

SECY

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-LaCallan EDO AThadani, DEDE JLloberman, OE ABBeach, Rlll SCollins, NRR RZimmerman, NRR

- LChandler,000

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JGoldberg,000 Enforcement Coordinators Rl, Ril, Rlli, RIV WBeecher, OPA LTromper, OC HBell, OlG -

TMartin, AEOD GCaputo,01 '

TReis,01 EA File (2)(Also by E Mail)

NUDOCS

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