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Forwards Insp Repts 50-295/97-02 & 50-304/97-02 on 970206-0402 & Notice of Violation.Event Re Reactor Vessel Voiding,Identified by Staff on 970307 Discussed
	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: ML20140G772; ML20140G816; ML20140G829;
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)
	v • d • e

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l Mr. J. H. Mueller

l Site Vice President

j Zion Station

l Commonwealth Edison Company

l 101 Shiloh Boulevard

Zion, IL 60099

SUBJECT: NRC INSPECTION REPORT 50-295/97-02; 50-304/97-02 AND

NOTICE OF VIOLATION

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 i

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 )

industry problems. In addition, the recurring 1C containment spray pump starting '

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 l

violation involves the failure to implement timely and effective corrective actions for a f !

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 f

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include measures to diagnose or prevent the undetected accumulation of gas in the reactor 1

i coolant system. The third apparent violation involves the failure to make a four-hour non- l

l emergency report, for a condition that alone could have prevented the fulfillment of the

l safety function to remove residual heat in accordance with 10 CFR Part 50.72(b)(2)(iii)(B).

l The fourth apparent violation involves the failure to submit a written Licensee Event Report

l within 30 days, for a condition that alone could have prevented the fulfillment of the

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J. H. Mueller -2-

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 -3-

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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

j (PDR).

Sincerely,

/s/ G. E. Grant

Geoffrey E. Grant, Director

Division of Reactor Projects

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Docket Nos. 50-295; 50-304

License Nos. DPR-39; DPR-48

Enclosures: 1. Notice of Violation

2. Inspection Report 1

Nos. 50-295/97-02; 50-304/97-02 I

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

Nuclear Operations Division l

D. A. Sager, Vice President, l

Generation Support

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

Commission

Document Control Desk-Licensing

PLEASE SEE PREVIOUS CONCURRENCES

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J. H. Mueller -3- i

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

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,

]

l Geoffrey E. Grant, Director

'

Division of Reactor Projects

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Docket Nos. 50-295; 50-304 ,

i License Nos. DPR-39; DPR-48 '

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Enclosures:

1. Notice of Violation

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

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 !

Commission

Document Control Desk-Licensing

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l OFFIC AL RECORD COPY

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l Distribution:

l 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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ML20140G772

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