ML20129E310

Forwards Insp Repts 50-295/96-11 & 50-304/96-11 on 960722- 0822 & Violations Noted.Lack of Safety Evaluations or Inadequate Safety Evaluations,Failure to Ensure That Field Installed Design Change Mods Properly Evaluated

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: ML20129E310 ML20129E340
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

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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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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

,

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

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Division of Reactor Safety

Docket Nos. 50-295;50-304

License Nos. DPR-39; DPR-48

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Enclosure:

Inspection Report

No. 50-295/96011(DRS);

,

No. 50-304/96001(DRS)

4

4

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

4

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

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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

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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

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