ML20140G772
| ML20140G772 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 06/04/1997 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Mueller J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20140G777 | List: |
| References | |
| 50-295-97-02, 50-295-97-2, 50-304-97-02, 50-304-97-2, EA-97-222, NUDOCS 9706170075 | |
| Download: ML20140G772 (5) | |
See also: IR 05000295/1997002
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June 4, 1997
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EA 97-222
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Mr. J. H. Mueller
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Site Vice President
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Zion Station
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Commonwealth Edison Company
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101 Shiloh Boulevard
Zion, IL 60099
SUBJECT:
NRC INSPECTION REPORT 50-295/97-02; 50-304/97-02 AND
Dear Mr. Mueller:
This refers to the inspection conducted on February 6 through April 2,1997, at the Zion
Units 1 and 2 reactor facilities. The enclosed report presents the results of this inspection.
During this eight-week inspection period, your staff's performance was characterized by
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frequent operational events. In some instances, the continuing recurrence of problems,
some of which resulted in events, was due to the failure of your staff to implement timely
and effective corrective actions. Of particular concern was the reactor vessel voiding,
identified by your staff on March 7,1997, which presented potential safety consequences
regarding the ability to maintain shutdown cooling to the reactor core. This event could
have been avoided had your staff more aggressively pursued corrective actions to a similar
September 1,1996, Zion Station event and generic communications issued for similar
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industry problems. In addition, the recurring 1C containment spray pump starting
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problems were caused by equipment deficiencies and inadequate control of maintenance
activities, which resulted in repeated challenges to the operations staff and ultimately
contributed to the reactivity management event on February 21,1997.
Four apparent violations 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. The first apparent
violation involves the failure to implement timely and effective corrective actions for a
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previous instance of undetected gas accumulation in the reactor coolant system in
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September 1996. The second apparent violation involves the failure to have procedures
for extended operation while in cold shutdown conditions and for operating procedures to
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include measures to diagnose or prevent the undetected accumulation of gas in the reactor
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coolant system. The third apparent violation involves the failure to make a four-hour non-
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emergency report, for a condition that alone could have prevented the fulfillment of the
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safety function to remove residual heat in accordance with 10 CFR Part 50.72(b)(2)(iii)(B).
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The fourth apparent violation involves the failure to submit a written Licensee Event Report
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within 30 days, for a condition that alone could have prevented the fulfillment of the
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safety function to remove residual heat in accordance with 10 CFR Part 50.73(a)(2)(v)(B).
Accordingly, no Notice of Violation is presently being issued for these inspection findings.
In addition, please be advised that the number and characterization of apparent violations
described in the enclosed inspection report may change as a result of further NRC review.
A predecisional enforcement conference will be scheduled to discuss these apparent
violations. The decision to hold a predecisional enforcement conference does not mean
that the NRC has determined that a violation has occurred or that enforcement action will
be taken. This conference is being held to obtain information to enable the NRC to make
an enforcement decision, such as a common understanding of the facts, root causes,
missed opportunities to identify the apparent violation sooner, corrective actions,
significance of the issues and the need for lasting and effective corrective action.
We are also concerned about four violations of NRC requirements that were identified.
The first violation pertains to a failure to test both battery starting circuits for the "C"
containment spray pumps to ensure that the design starting time requirements were met.
The second violation involves two examples of the failure to implement timely and
effective corrective actions. The third violation relates to the failum to follow the station
operability determination procedure to complete the appropriate operability assess nent
within five days of discovery of the slow starting time on the 1C containment spray pump.
The fourth violation involves the failure to control access to a locked high radiation area in
accordance with Technical Specification requirements.
These violations are cited in the enclosed Notice of Violation (Notice) and the
circumstances surrounding them are described in detail in the subject inspection report.
Please note that you are required to respond to this letter and should follow the
instructions specified in the enclosed Notice when preparing your response. In your
respcnse to Violation 2, please ensure you describe actions being taken to prevent further
instances of inadequate correction actions. In regards to Violation 3, other examples of
untimely operability assessments were also the subject of a previous violation identified in
NRC Inspection Report 50-295/96-17; 50-304/96 17. Therefore, please include in your
response any corrective actions you deem necessary to ensure timely operability
assessments beyond those actions already identified in previous correspondence. The
NRC will use your response, in part, to determine whether further enforcement action is
necessary to ensure compliance with regulatory requirements.
In addition, this is an opportunity for you to point out cny errors in our inspection report
and for you to provide any information conceming 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
matter. No response agarding these apparent violations is required at this time.
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J. H. Mueller
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In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
its enclosure (s), and your response will be placed in the NRC Public Document Room
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(PDR).
Sincerely,
/s/ G. E. Grant
Geoffrey E. Grant, Director
Division of Reactor Projects
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Docket Nos. 50-295; 50-304
Enclosures:
1.
2.
Inspection Report
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Nos. 50-295/97-02; 50-304/97-02
cc w/ encl:
T. J. Maiman, Senior Vice President
Nuclear Operations Division
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D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
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Operating Officer
R. Starkey, Plant General Manager
R. Godley, Regulatory Assurance
Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
Mayor, City of Zion
State Liaison Officer, Wisconsin
State Liaison Officer
Chairman, Illinois Commerce
Commission
Document Control Desk-Licensing
PLEASE SEE PREVIOUS CONCURRENCES
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You will be advised by separate correspondence of the results of our deliberations on this
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matter. 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,
its enclosure (s), and ycur response will be placed in the NRC Public Document Room
(PDR).
Sincerely,
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Geoffrey E. Grant, Director
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Division of Reactor Projects
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Docket Nos. 50-295; 50-304
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Enclosures:
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1.
2.
Inspection Report
Nos. 50-295/97-02; 50-304/97-02
cc w/ encl:
T. J. Maiman, Senior Vice President
Nuclear Operations Division
D. A. Sager, Vice President,
,
Generation Support
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H. W. Keiser, Chief Nuclear
Operating Officer
R. Starkey, Plant General Manager
R. Godley, Regulatory Assurance
Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
Richard Hubbard
Nathan Schloss, Economist
Office of the Attorney General
Mayor, City of Zion
State Liaison Officer, Wisconsin
State Liaison Officer
Chairman, Illinois Commerce
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Commission
Document Control Desk-Licensing
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Distribution:
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Docket File w/enci
Project Manager, NRR w/enct
PUBLIC IE-01 w/ encl
DRP wiencl
OC/LFDCB w/enci
Rlll PRR w/enct
SRI Byron, Braidwood,
CAA1 w/enci(E-mail)
Zion w/enci
Deputy RA, w/ encl
A. B. Beach, w/ encl
RAC1 (E-Mail)
Rill Enf. Coordinator, w/ encl
ORS (2) w/ enc!
TSS w/enci
-. Lieberman, OE w/ encl
J. Goldberg, OGC w/enct
R. Zimmerman, NRR w/enci
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