ML20129E310
| ML20129E310 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 10/22/1996 |
| From: | Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Mueller J COMMONWEALTH EDISON CO. |
| Shared Package | |
| ML20129E314 | List: |
| References | |
| NUDOCS 9610280022 | |
| Download: ML20129E310 (3) | |
See also: IR 05000295/1996011
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October 22, 1996
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EA 96-355
Mr. J. H. Mueller
Site Vice President
Zion Generating Station
Commonwealth Edison Company
101 Shiloh Boulevard
Zion, IL 60099
SUBJECT:
NRC ENGINEERING AND TECHNICAL SUPPORT (E&TS) INSPECTION
REPORT NO. 50-295/96011(DRS); 50-304/96011(DRS)
Dear Mr. Mueller:
This refers to the engineering and technical support inspection conducted by
Mr. Z. Falevits and others of this office from July 22 through August 22,1996. The
inspection included a review of activities authorized for your Zion Nuclear Generating
Station. At the conclusion of the inspection, the findings were discussed with those
members of your staff identified in the enclosed report.
The areas examined during the inspection are identified in the report. Within these areas,
the inspection consisted of a selective examination of design documents, procedures and
representative records, interviews with personnel, and observations of activities in
progress. The purpose of the inspection was to determine whether activities authorized by
your license were conducted safely and in accordance with NRC requirements.
The team determined that significant problems existed in several technical areas and
engineering processes. Examples included: an ineffective 10 CFR 50.59 safety evaluation
process, inadequate modification closecut and post-modification testing process, lack of
control and understanding of the Technical Specification Interpretation process that
allowed inappropriate interpretations, inadequate identification and resolution of recurt.ing
equipment deficiencies and examples of failure to follow procedures and inadequate
procedures. Oversight of the above engineering activities was considered weak.
When viewed in the aggregate, the problems described in this report represent a significant
deficiency in the overall execution of engineering activities. Your close and immediate
attention to these problems is warranted. The specific areas of apparent violation are
described in the paragraph below.
Based on the results of this inspection, five apparent violations were identified and are
Q'i
Statement of Policy and Procedme for NRC Enforcement Actions" (Enforc
being considered for escalated enforcement action in accordance with tne " General
evaluation process, which resulted in lack of safety evaluations or inadequate safety
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9610200022'961022
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ADOCK 05000295
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J. H. Maoller
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evaluations. The second apparent violation involved a failure to ensure that field-installed
design change modifications had been properly evaluated, tested or signed off prior to
placing them in service. The third apparent violation concerned failure to indicate the
operability status of systems, structures and components that had been modified and
placed in use, but not yet fully tested. The fourth apparent violation concerned failure to
take timely corrective actions for an extended period of time to address equipment
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nonconforming conditions. The fifth apparent violation concerned inadequate procedures
and failure to follow procedures, which contributed to Technical Specification
interpretation deficiencies and the failure to enter the discrepancies generated by your
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Updated Final Safety Analysis Report (UFSAR) conformance review into your problem
identification process.
Accordingly, no Notice of Violation is presently being issued for these inspection findings.
In addition, please be advised that the number and characterization of the apparent
violations described in the enclosed inspection report may change as a result of NRC
review.
A pre-decisional enforcement conference to discuss these apparent violations will be
scheduled on a date to be determined. 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. 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 violations sooner,
corrective actions, significance of the issues, and the need for lasting and effective
corrective actions. In particular, we expect you to address any extenuating circumstances
that led to the apparent breakdown in the engineering processes depicted in the apparent
violations noted above.
In addition, this is an opportunity for you to point out any errors in our inspection report
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 the 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 exercise of discretion in accordance with Section Vll.
You will be advised in 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 Commission's regulations, a copy of this letter,
its enclosures, and your response to this letter will be placed in the NRC Public Document
Room.
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J. H. Mueller
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We will gladly discuss any questions you have concerning this inspection.
Sincerely,
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Original signed by Geoffrey E. Grant
Geoffrey E. Grant, Director
]
Division of Reactor Safety
Docket Nos. 50-295;50-304
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Enclosure:
Inspection Report
No. 50-295/96011(DRS);
,
No. 50-304/96001(DRS)
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cc w/ encl:
D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
G. K. Schwartz, Station Manager
W. Stone, Regulatory Assurance
Supervisor
1. Johnson, Acting Nuclear
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Regulatory Services Manager
Document Control Desk - Licensing
Richard Hubbard
Nathan Schloss, Economist,
Office of the Attorney Goneral
Mayor, City of Zion
,
State Liaison Officer, Wisconsin
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Stato Liaison Officer
'
Chairman, Illinois Commerce Commission
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Distribution:
Docket File w/ encl
SRis, Zion, Braidwood,
Enf. Coordinator, Rlll w/ encl
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PUBLIC IE-01 w/enci
Byron w/ encl
RAC1 w/enci (E-mail)
OC/LFDCB w/enci
G. E. Grant, Rlli w/enci
CAA1 w/enci (E-mail)
DRP w/enci
LPM, NRR w/enct
W. L. Axelson, Rill w/enci
Rlli PRR w/enci
DRS w/enci
A. B. Beach, Rill w/enct
"
DOCUMENT NAME: G:\\DRS\\ZIO96011.DRS
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To receive e copy of this document, ind6cate in the boa: 'C' = Copy without ettschment/ enclosure
- E' = Copy with attachment / enclosure
- N" - No copy
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DATE
10/M/96 '
10/6/96M 10/ ']/96
10/14/96
10/Tk96
0FFIChlL RECORD COPY
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