ML20054C560
| ML20054C560 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 08/11/1981 |
| From: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Reed C COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20054C561 | List: |
| References | |
| NUDOCS 8204210327 | |
| Download: ML20054C560 (5) | |
See also: IR 05000295/1981004
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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AUG 111981
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Docket No. 50-295
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Commonwealth Edison Company
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ATTN: Mr. Cordell Reed
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Vice President
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P. O. Box 767
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Chicago, Illinois
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Gentlemen:
Subject:
Management Appraisal 50-295/81-04(PAS)
This refers to the management inspection conducted by Messrs. D. G. Hinckley,
W. Ang, J. L. Belanger, G. Napuda, and C. R. Oberg of the Performance Appraisal
Section of the Division of Program Development and Appraisal, Office of Inspec-
tion and Enforcement, on April 20 - May 1, and May 11-15, 1981, of activities
authorized by NRC Operating License DPR-39, for the Zion, Unit 1, Nuclear
Station at Zion, Illinois, and the Commonwealth Edison Company Corporate
Offices in Chicago, Illinois; and to the significant observations discussed
with you and others of your staff on May 1,1981, at the corporate offices and
on May 15,1981, at the Zion station.
This inspection is one of a series of management appraisal inspections being
conducted by the Performance Appraisal Section of the Division of Program
Development and Appraisal, Office of Inspection and Enforcement.
The results
of this inspection will be used to evaluate the performance of your management
control systems on a national perspective.
The enclosed appraisal report
includes observations which may be potential enforcement findings.
These
items will be followed by the IE Regional Office.
The enclosed appraisal
report also addresses other observations and the conclusions made by the team
for this inspection.
Section 1 of the report provides further information
regarding the observations and how they will be utilized.
Appendix A to this
letter is an Executive Summary of the conclusions drawn for the ten functional
areas inspected.
Nine of the areas inspected were considered average and one area was considered
to be above average.
However, weaknesses were identified in all areas.
You are
encouraged to review and evaluate these weaknesses and take appropriate actions
to improve your existing inanagement controls over licensed activities.
In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, your facility security procedures are
exempt from disclosure; therefore, the pertinent section of the Appraisal
Report, Attachment 'A' will not be placed in the Public Document Room and will
receive limited distribution.
8204210327 810811
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Commonwealth Edison Company
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AUG 11 gg;
Attachment B to this report is a detailed listing of the persons contacted and
the documents reviewed during this inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter and the enclosed inspection report will be placed in the NRC's
Public Document Room.
If this letter contains any information that you
believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary
that you:
(a) notify this office by telephone within ten days from the date
of this letter of your intention to file a request for withholding; and (b)
submit within twenty-five days from the date of this letter a written appli-
cation to this office to withhold such information.
If your receipt of this
letter has been delayed such that less than seven days are available for your
review, please notify this office promptly so that a new due date may be
establi shed.
Consistent with section 2.790(b)'(1), such application must be
accompanied by an affidavit executed by the owner of the information which
identifies the document or part thereof sought to be withheld, and a full
statement of the reasons on the basis of which it is claimed that the
information should be withheld from public disclosure. This section further
requires the statement to address with specificity the considerations listed
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The information sought to be withheld shall be incor-
porated as far as possible into a separate part of the affidavit.
If we do
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not hear from you in this regard within the specified periods noted above, the
report will be placed in the Public Document Room.
If you have any questions concerning this inspection, we will be glad to
discuss them with you.
Sincerely,
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Norman C. Moseley, Director
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Division of Program Devel~opment
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and Appraisal
Office of Inspection and Enforcement
Enclosures:
1.
IE Management Appraisal Report 50-295/81-04 (PAS)
2.
Appendix A
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3.
Attachment A*
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Attachment B
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AUG 1 1 GS1
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Commonwealth Edison Company
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Distribution:
(w/ Attachments A* and B)
Chairman Palladino
w/o Attachment A*
Commissioner Gilinsky
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Commissioner Bradford
LPDR
Commissioner Ahearne
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Commissioner Roberts
OCA(3)
RIII Reading Room
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W. J. Dircks, EDO
State of Illinois
H. R. Denton, NRR
All Licensees
W. Haass, NRR
E. P. Wilkinson, INPO
S. H. Hanauer, NRR
D. Godard, Oregon Department
B. Burnett, NMSS
of Energy
G. W. McCorkle, NMSS
C. Michelson, AEOD
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H. Boulden, OIA
SALP Chairman
J. Kohler, NRC Senior Resident Inspector
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J. H. Sniezek, IE
V. Stello, IE
H. D. Thornburg, IE
N. C. Moseley, IE
J. M. Taylor, IE
PAS Files
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Regional Directors
Central Files
NRR Project Managers
SECY
- Contains 10 CFR 2.790 Information
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Aopendix A
Executive Summary
A team of five NRC inspectors from the Performance Appraisal Section conducted
an announced inspection at the Zion Station and Commonwealth Edison Company
Offices during April 20 - May 15,1981.
Management controls in ten areas were
Nine areas were considered average and one area was considered to be
inspected.
above average.
A summary of the results of the inspection is given below.
Committee Activities:
Average (Section 2).
Both the onsite and offsite
review and investigative groups were composed of qualified and capable
individuals.
The number of available participants and the practice of evenly
The
distributing review items enhanced the quality of the review effort.
principal weaknesses were the lack of a requirement to document the significant
items discussed or evaluated during the review process, the lack of provisions
for documenting minority opinions or differing viewpoints, and the failure to
routinely review QA audit reports.
Quality Assurance Audits:
Average
(Section 3).
The independent auditing by
offsite teams of the same areas audited by the onsite audit staff was a posi-
tive indication of the licensee's commitment to quality assurance. Management
supported the quality assurance function, and employees accepted QC and QA
activities and requirements.
Weaknesses included the lack of formal documen-
tation of the effectiveness of various program elements audited, the lack of
effective trending of audit findings, end the lack of a formal retraining
program for auditors.
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Design Changes and Modifications: Average
(Section 4).
An effective program
for the control of facility design cnanges and modifications had been estab-
lished and implemented. Significant weaknesses were the lack of external
design interface controls and the lack of a system for correcting generic
design deficiencies.
Average (Section 5).
A maintenance program had been implemented,
Maintenance:
and all maintenance was required to be controlled and documented by the use of
maintenance work requests.
Weaknesses included the lack of control of vendor
technical manuals, the lack of a formalized preventive maintenance program,
and inadequacies in the work request system to keep shift personnel apprised
of maintenance activies.
Plant Ooerations:
Averaae
(Section 6).
An effective program had been imple-
mented for the operation of the Zion station.
Personnel interviewed were
knowledgeable of their responsibilities, exhibited good morale, and had a
Significant weaknesses included
positive attitude toward plant safety.
inadequacies in the control of jumpers and lifted. leads and the lack of a
method to ensure that all records, identified as being maintained in active
working files, were eventually transferred to Central Files.
_ Above Averace (Section 7).
A corrective action procram
Corrective Action Svstem:
had been implemented.
Responsibilities were well defined for tracking and
closecut of identified problems.
Corrective action was timely.
Significant
weaknesses were the lack of a trending program, particularly for equipment
failures and malfunctions, and the lack of a comprehensive listing of
standards and guides to which the licensee was committed.
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Appendix A (Continued)
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Licensed Training:
Average (Section 8).
A strong replacement training
program had been implemented.
The program emphasized safe plant operations.
The retraining program needed additional instructor's to provide a balanced
work load, and there was a lack of training department administrative pro-
cedures.
Non-Licensed Training:
Average (Section 8).
Beyond general employee
training, non-licensed training was the responsibility of the various
departments. Training was being performed; however, a formalized program had
There was
not been fully established in some areas, particularly maintenance.
a need to identify personnel qualifications and subsequent training require-
ments for each job classification.
Management had recognized this need and
was taking action in this area.
Procurement:
Average (Section 9).
Management had established policies and
procedures to control procurement activities.
One weakness in the program
cov2 red the lack of direction for handling potential 10 CFR 21 items identified
In addition, safety-related
by vendors or organizations outside of CECO.
material storage did not conform with certain ANSI N45.2.2 requirements.
Management took immediate action to correct these weaknesses.
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Physical Protection:
Average (Section 10).
Strong management support, adequate
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maintenance support, effective communications M annels, and properly maintained
Weaknesses included
security systems characterized the site securi',y program.
the absence of trending of security deficienc~.es to identify recurring problems,
certain aspects of the training program for the contract security force, and
understaffing within the corporate nuclear security office.
Summary:
The licensee had established written policies and procedures for the areas
Procedures identified those responsible for the various activities.
inspected.
Personnel appeared to be qualified and knowledgeable in their areas of responsi-
The programs had been implemented and were being monitored by management
bility.
Some weaknesses, however, were identified in al-1 areas. These
in most areas.
findings should be evaluated and appropriate actions taken to further enhance
The apparent
the effectiveness of the overall management control system.
major contributors to the existing overall effectiveness of the licensee's
management control system were corporate management's commitment to quality
assurance, their effective communications with station management, and their
continual monitoring of the status of corrective actions taken on audit
findings.