ML20199G194

Forwards Insp Repts 50-295/97-23 & 50-304/97-23 on 970908-1216 & Nov.Violation Involved Failure to Adhere to Scaffolding Procedure Requirements & Failure to Ensure That Proficiency & Qualifications Were Adequately Achieved

ML20199G194
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	01/27/1998
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kingsley O COMMONWEALTH EDISON CO.
Shared Package
ML20199G198	List: ML20199G194 ML20199G327 ML20199G346
References
50-295-97-23, 50-304-97-23, EA-97-606, NUDOCS 9802040237
Download: ML20199G194 (6)

See also: IR 05000295/1997023

Text

{{#Wiki_filter:. o January 27, 1998 EA 97 606 Mr. Oliver D. Kingsley President, Nuclear Generation Group Commonwealth Edison Company ATTN: Regulatory Sen As Executive Towers West lil 1400 Opus Place, Suite 500 Downers Grove, IL 60515 SUBJECT: NRC INSPECTION REPORT 50 295/97023; 50-304/97023 AND NOTICE OF VIOLATION Dear Mr. Kingsley: This refers to the inspection conducted on September 8 through December 16,1997, at the Zion Units 1 and 2 reactor facilities. The enclosed report presents the results of this i~ 'ction. The inspection involved examination of engineering activillas primarily related to the Unit 2 restart with a focus on reviewing corrective actions taken to address engineering issues identified during the Engineering and Technical Support (E&TS) inspection in 1996. The inspectors evaluated the effectiveness of your engineering and support groups in identifying, assessing and resolving technicalissues. The inspectors also evaluated the effectiveness of your self assessment and corrective action processes. The NRC noted that engineering related improvements have occurred (mainly in the design enginecring organization) since the E&TS lnspection conducted in 1996. Various engineering . _ related improvement programs such as the design basis initiative, operating experience and the engineering assurance group have been initiated; however, it was too early to assess the long term effectiveness of these programs. Furthermore, the violations identified by the NRC and discussed in this report, represent continuing chelhnges that remain to be addressed. Based on the results of this inspection, the NRC has determined that five violations of NRC and the circumstances surrounding them are described in detallin the s requirements occurred. These vlotations are cited in the enclosed Notice of Violation (Notice) The subject violations irivolve failure to adhere to scaffoldirg procedure requirements; [ ineffective corrective actions, relating to out of tolerance and oil samples; failure to ensure that proficiency and qualifications were adequately achieved and maintained for Raychem splice applications; failure to report identified discrepancies in the emergency core cooling system small break loss of coolant accident analysis; and a failure to report a condition outside the design basis in a timely manner. Nn013 I,l ,l!. !.!!,[ > !!( !!h ,! )[[f , , ggg20;ggg;;gagg

_ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ - _ _ . 3 2 O. Kingsley 2 ,lanuary 27, 1998 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. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements. In addition, three apparent violations were identified and are being considered for escalated enforecment action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions"(Enforcement Policy), NUREG 1600. The apparent violations involve cross tying 125 Vdc buses from Unit 1 to Unit 2 with the battery and charger disconnected from the bus and the associated buses not being declared inoperable. This situation continued to occur ofter your staff Identified in September 1996 that the cross tying resulted in the plant being outside its design basis. Upon completion of this evaluation you failed to ensure that the design bases were correctly translated into appropriate procedures. Additionally, you failed to adhere to the requirements of T.S. 3.15.2.E when one 125 Vdc battery and/or distribution system for a unit was not operable. Although the NRC began questioning the practice in March 1997, cross-tying was not discontinued until August 1997. While both units were shutdown during this period, your engineering staff did not complete its , evaluation to determine the acceptability of cross tying under shutdown conditions until September 1997, 1 l No Notice of Violation is presently being issued for these three apparent violations. However, we request that you respond within 30 days of the date of this letter to the apparent violations discussed in the enclosed inspection report. Your response should be clearly marked as a

• Response to Apparent Violations in Inspection Report Nos. 50-295/97023; 50-304/97023 and

l should include for each apparent violation: (1) the reason for the apparent violation, or, if ! contested, the basis for disputing the apparent violation, (2) the corrective steps that have been taken and the results achieved, (3) the corrective step = that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response should be submitted under oath os affirmation and may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. We Intend to review your response to the apparent violations described in the enclosed inspection report. Based on the results of this raview, we will determine whether a pre-decisional enforcement conference is necessary to enable the NRC to make an enforcement decision. You also have the right to request a conference if you deem it necessary. 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. You will be advised by separate correspondence of the results of our deliberations on this matter.

. , O. Kingsley 3 January 27, 1998 in accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR). < Sincerely, original signed by C. E. Grant Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos: 50-295; 50 304 License Nos: DPR 39; DPR-48 Enclosures: 1. Notice of Violation 2. Inspection Report Nos, 50-295/97023; 50 304/97023 cc w/encls: M. Wallace, Senior Vice President, Corporate Services H. G. Stanley, Vice President, PWR Operations J. Perry, Vice President BWR Operations Liaison Officer, NOC-BOD D. A. Sager, Vice President, Generation Support D. Farrar, Nuclear Regulatory Services Manager 1. Johnson, Licensing Operations Manager Document Control Desk - Licensing R. Starkey, Plant General Manager R. Godley, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General Mayor, City of Zion State Liaison Officer State Liaison Officer, Wisconsin Chairme.n, Illinois Commerce Commission See Attached Distribution DOCUMENT NAME: G:DRS\\ZIO97023.DRS (See Previous Concurrence) 1. ,.c.~. . ..,y .e in co oow.i. i. is. .., c . ceny -isoui .,i.com.~i,.ac,n.o,. v . cccy in .,,,cs, v.acin.o,. v . we cory OFFICE Rlll/DRS Rill /DRS Rlll/DRP Rlil/ENF Rill /DRS Rlli/DRP NAME Guzman Lougheed Hills Clayton Grobe Gran Falevits:sd Vegel Ak DATE 01/ /98 01/ /98 01/ /98 01/ /98 01/ /98 01tTftW ~' OFFICIAL RECORD COPY

. - - -. - - _ .. -. - - . - - - - - - . '. J. Brons 3 . In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosures, and your response will be placed in the NRC Public Document Room (PDR), Sincerely, Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos: 50 295;50 304 License Nos: DPR 39; DPR-48 Enclosures: 1. Notice of Violation 2. Inspection Report Nos. 50 295/97023; 50 304/07023 " cc w/encis: O. Kingsley, Nuclear Generation Group President & Chief Nuclear Officer M. Wallace, Senior Vice President; Corporate Services H. G. Stanley, Vice President, PWR Operations Liaison Officcc. NOC-BOD D. A. Sager, Vice President, Generation Support D. Farrar, Nuclear Regulatory Services Manager 1. Johnson, Licensing Operations Manager Document Control Desk - Licensing R. Starkey, Plant General Manager R. Godity, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General Mayor, City of Zion State Liaison Officer State Liaison Officer, Wisconsin Chairman, Illinois Commerce Commission Distribution Docket File w/encls Ril; PRR w/encls Rill Enf. Coordinator w/encls PUBLIC IE-01 w/ enc!s SRI, Zion w/encls TSS w/encls LPM, NRR w/encls J. L. Caldwe'l, Rlli w/encls R. A. Capra, NRR w/enets DRP w/encls A. B. Beach, Rlli w/ene!s DOCDESK w/encls DRS w/encls G. E. Grant, Rlli w/encls CAA1 w/encls DOCUMENT NAME: G:DRS\\ZIO97023.DRS. 4<su mvous coecumeco v. .~..e m enein e.e m i.,se. mie w ca. c e m . w w . r . e m .+ .n. w ., e . ir . wo m OFFICE Rill /DRS l Rlll/DRS Rill /DRP Rlll/ENF Rlll/DRS,l Pill /DRP NAME Guzman g Loughded Hills * Clayton Gro Grant 4 Falevits:sd Vegel4 DATE 01/ /98 01/ /98 01/ /08 01/ /98 01/lP98 01/ /98 OFFICIAL RECORD COPY _

_ _ - _ . _ _ _ _ _ _ - _ - _ - - _ , '. ' J. Brons 3 . In accordance with 10 CFR 2.700 of the NRC's " Rules of Practice," a copy of this letter,its

enclosures, and your response will be placed in the NRC Public Document Room (PDR). Sincerely, Geoffrey E. Grant, Director Division of Reactor Projects Docket Nos: 50 295;50-304 License Nos: DPR 39; DPR-48 Enclosures: 1. Notice of Violatloc 2. Inspection Report Nos. 50-295/97023; 50-304/97023 cc w/encts: O. Kingsley, Nuclear Generation Group President & Chief Nuclear Officer M. Wallace, Senior Vice President, Corporate Services H. G. Stanley, Vice President, l PWR Operations ! Liaison Officer, NOC-BOD l D. A. Sager, Vice President, l Generation Support l D. Farrar Nuclear Regulatory Services Manager I. Johnson, Licensing Operationa Msnager , ' Document Control Desk - Licensing R. Starkey, Plant General Mana0er R. Godley, Regulatory Assurance Supervisor Richard Hubbard Nathan Schloss, Economist, Office of the Attomey General Mayor, City of Zion State Liaison Officer State Liaison Officer, Wisconsin Chairman, Illinois Commerce Commission Distribution Docket File w/encls Rlli PRR w/encls Rlli Enf. Coordinator w/encls PUBLIC IE-01 w/encls SRI, Zion w/encls TSS w/encls LPM, NRR w/encls J. L. Caldwell, Rlll w/encls R. A. Capra, NRR w/encls DRP w/encls A. B. Beach, Rlll w/encls DOCDESK w/encls DRS w/encls G E. Grant, Rlli w/encls CAA1 w/encls DOCUMENT NAME: G:DRS\\ZIO97023.DRS tomo...m wmi.*e-au,*. mm..m c em e . e t % . e.e w ..= ~ ~ . >c.wem OFFICE Rlll/DRS lc Rlll/DRS b/ Rlll/DRP E Rlll/DRP 6 Rill /DRP Rlll/DRg ~$AME Guzmanf[ L9vgheed Hills Vogel Grant Grobe Falevite:sd @ *e gM DATE 01/1/98 01/2/98 01/5/98 01/fl98 01/ /98 01/ /98 OFFICIAL RECORD COPY

. . . . . . - . - - . . . . . - - - . - . _ . . ~ . - . - . - . . - - _ - . - - - - . , . r - - O. Kingsley 4 January 27, 1998 . 4 Distribution Docket File w/encls Rlli PRR w/encls Rill Enf. Coordinator w/encls PUBLIC IE-01 w/encls SRI, Zion w/ enc ls TSS w/encls LPM, NRR w/encls J L. Caldwell, Rlli w/encls R. A. Capra, NRR w/encls DRP w/encls A; B. Beach, Rlli w/encls DOCDESK w/encls , DRS w/encls G. E. Grant, Rlli w/encls CAA1 w/encls J. ~ Lieberman, OE J. Goldberg, OGC R. Zimmerman, NRR i ' i Y i 4 5 5. 1- .- +

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