ML20134P482

Forwards Insp Repts 50-295/96-21 & 50-304/96-21 on 961203- 970122.Apparent Violations Being Considered for Escalated Enforcement Action

ML20134P482
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/11/1997
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Mueller J COMMONWEALTH EDISON CO.
Shared Package
ML20134P485	List: ML20134P482 ML20134P488
References
EA-97-048, EA-97-48, NUDOCS 9702250490
Download: ML20134P482 (3)

See also: IR 05000295/1996021

Text

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February 11, 1997

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EA 97-48

Mr. J. H. Mueller

Site Vice President

Zion Generating Station

Commonwealth Edison Company

101 Shiloh Boulevard

Zion, IL 60099

SUBJECT: NRC ROUTINE RADIATION PROTECTION INSPECTION REPORTS NO.

50-295/96021(DRS); 50-304/96021(DRS) AND NOTICE OF VIOLATION

Dear Mr. Mueller:

On January 22,1997, the NRC completed an inspection of your Zion Generating Station,

Units 1 and 2. The enclosure to this letter presents the results of this inspection.

As described in the enclosed report, five apparent violations were identified during our

inspection of your radioactive material transportation program. Although the apparent

violations when taken alone would not normally warrant consideration for escalated

enforcement, we are particularly concerned that problems were identified in virtually every

phase of the program. This indicates a basic lack of attention to and oversight of the

program. Additionally, an April 1996 audit conducted by your staff in this area lacked the

depth and thoroughness necessary to identify the fundamental program weaknesses which

the NRC subsequently identified. Lack of an effective audit in this area was particularly

noteworthy given that a major change to applicable transportatico reNirions was made

effective April 1,1996.

The NRC has recently documented several other concerns with your staff's radiation

protection performance and with the poor radiological condition of the plant. In our

May 17,1996 report, a violation was issued for the failure to post the area around a

highly radioactive steam generator gasket which was left unattended inside the Unit 1

missile barrier. In our November 21,1996 report, we documented that a number of

radiologicalimpediments, including high dose rate and high contamination areas,

encumbered access to certain plant safety systems, and that rework had increased the

already high station dose. We also issued several violations that were caused by your

, longstanding radiation monitor operability problems in the November report. These issues

along with those identified in the enclosed report indicate that radiation protection

f.9fformance haS declined over the past year. This decline occurred after a period of

improved radiation protection performance and is an example of cyclical performance at

the station.

Based on the results from the inspection and as noted above, five apparent violations of

NRC requirements were identified and are being considered for escalated enforcement

action in accordance with the " General Statement of Policy and Procedure for NRC

Enforcement Actions" (Enforcement Policy), NUREG-1600.

(, O \

97CQ250490 970211

PDR ADOCK 05000295

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J. Mueller -2- February 11, 1997

No Notice of violation is presently being issued for these inspection findings. In addition,

the number and characterization of apparent violations described in the enclosed inspection ,

reports may change as a result of further NRC review.

A pre-decisional enforcement conference will be scheduled to discuss these apparent

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violations and your plans to improve the general radiation protection performance and the '

radiological condition of your plant. The decision to hold a pre-decisional enforcement

conference does not mean that the NRC has determined that a violation has occurred or

that enforcement action will be taken. The conference will be held to obtain information

to enable the NRC to make an enforcement decision, including a common understanding of I

the facts and circumstances surrounding the violations, their root causes, your

opportunities to identify the apparent violations sooner, your corrective actions, and the

significance of the issues.

In addition, this is an opportunity for you to point out any errors in our inspection reports

and for you to provide any information concerning your perspectives on 1) the severity of

the violations; 2) the application of the factors that the NRC considers when it determines

the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of

the Enforcement Policy; and 3) any other application of the Enforcement Policy to this

case, including the exercise of discretion in accordance with Section Vll.

You will be advised by separate correspondence of the results of our deliberations on this

manner. No response regarding these apparent violations is required at this time.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

and its enclosures will be placed in the NRC Public Document Room.

Sincerely,

/s/ G. E. Grant

Geoffrey E. Grant, Director

Division of Reactor Safety

Docket Nos. 50-295; 50-304

Licenses No. DPR-39; DPR-48

Enclosure: Inspection Reports No.

50-295/96021(DRS);

50-304/96021(DRS)

See Attached Distribution

DOCUMENT NAME: GaDRS\ZIO96021.DRS

To t:ccive a copy of this document, indicate in the box: "C" = Copy w/o attachment / enclosure *E" = Copy with attachment / enclosure 'N" = No copy

0FFICE Rlll:DRS c RIII:DRS I6 Rill:DRP If Rill:EICS 6 Rill:DRS,J

NAME S0rth/kjc/jw#o iTKozak TV ,

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0FFICIAL RECORD COPY

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J. Mueller -3- February 11, 1997

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cc w/ encl: T. J. Maiman, Senior Vice President,

Nuclear Operations Division

<

D. A. Sager, Vice President,

Generation Support

H. W. Keiser, Chief Nuclear

Operating Officer

i G. K. Schwartz, Station Manager

W. Stone, Regulatory Assurance

i Supervisor

j l. Johnson, Acting Nuclear

Regulatory Services Manager

'

Document Control Desk - Licensing

Richard Hubbard

, Nathan Schloss, Economist,

i Office of the Attorney General

. Mayor, City of Zion

State Liaison Officer, Wisconsin

State Liaison Officer

Chairman, Illinois Commerce Commission

Distribution:

Docket File w/enct SRIs, Zion, Braidwood, Enf. Coordinator, Rill w/enci j

PUBLIC IE-01 w/enct Byron w/ encl R. A. Capra, NRR w/enci

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OC/LFDCB w/enci G. E. Grant, Rill w/enci CAA1 w/ encl

DRP w/enci LPM, NRR w/enci J. Lieberman, OE w/ encl

DRS w/enci A. B. Beach, Rill w/enci J. Goldberg, OGC w/ encl

Rlli PRR w/enci W. L. Axelson, Rlli w/enci R. Zimmerman, NRR w/enci

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