IR 05000344/1988013

Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-344/88-13

ML20207C141
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/26/1988
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8808050048
Download: ML20207C141 (1)

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l JUL 2 61988 ,

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Docket No. 50-344

Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 i

Attention: Mr. David W. Cockfield l Vice President, Nuclear l Gentlemen:

Thank you for your letter dated July 15, 1988, in response to our Notice of Violation and Inspection Report No. 50-344/88-13, dated June 17, 1988, informing us of the steps you have taken to correct the items which we brought to your attention. Your corrective actions will be verified during a ;

future inspection. l l

Your cooperation with us is appreciated. I

Sincerely, C:f H :t snR Ey l DenSih ['. M rsch, Director Division of Reactor Safety and Projects bec w/ copy of letter dated 7/15/88: l Project Inspector l

Resident Inspector i

docket file G. Cook B. Faulkenberry J. Martin J. Zollicoffer A. Johnson bec w/o copy of letter dated 7/15/88: i M. Smith REGION Vfg DPereira/ dot k

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8800050040 080726 PDR ADOCK 05000344

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. Portland General Electric Catiny aEoioN V I i

David W. Cockfield Vice President. Nuc ulf k5$ 8 Trojan Nuclear Plant Docket 50-344 License NPF-1 l l

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

l Response to a Notice of Violation l

Your letter of June 17, 1988 transmitted a Notice of Violation associated with Nuclear Regulatory Commission Inspection Report 50-344/88-13. (

Attached is our response to that Notice of Violation. l

Sincerely,

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Attachment l

c: Mr. John B. Martin Regional Administrator, Region V U.S. nacicar Regulatory Commission ,

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Mr. Bill Dixon '

State of Oregon Department of Energy i Hr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant

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Trojatn Nuclose Pittnt Documsnt Control Desk

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Docket 50-344 July 15, 1988

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, ticense NPF-1 Attachment l Page 1 of 6 !

RESPONSE TO A NOTICE OF VIOLATION

VIOLATION A Part 50.59(b)(1) to Title 10 of the Code of Federal Regulations l

(10 CFR 50.59(b)(1)) reads, in part, that "The licensee shall maintain records of changes in the facility . .

.made pursuant to this section, to the extent that these changes constitute changes in the facility as des- {

cribed in the safety analysis report .

.These records must include a

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written safety evaluation . . . .".

Final Safety Analysis Resport (FSAR) Figure 6.2-21 specifies that valves l FW-O'/9 through FW-086 are to be closed to fulfill Containment isolation functional requirements.

Contrary to the above, Temporary Modification 87-058 required that valves FW-079, FW-082, FW-083 and FW-086 be open to allow monitoring pressure in ;

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two feedwater lines from August 7, 1987 to March 28, 1988. The written safety evaluation failed to recognize the valves as Containment isolation valves and did not address the change to FSAR Figure 6.2-21.

This is a Severity Level IV vi. .t ;n (Supplement I).

Response Portland General Electric Company (PCE) acknowledges the violation. I t

1. Reason for Violation:

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The reason for this violation was inadequate development and review of the Temporary Modification and its safety evaluation. Personnel who prepared and reviewed the safety evaluation did not recognize ]

I that the four feedwater drain valves are considered to be containment isolation valves and that they are listed in Trojan Technical I

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Specifleation (TTS) Table 3.6-1, Containment Isolation Valves. l 2.

Corrective Action Taken and Results Achieved:

a. i The immediate corrective action step taken was to close the four feedwater line drain valves, FW-079. FW-082, FW-083, and FW-086. )

i The NRC was immediately notified of this event by telephone at 1024 on March 28, 1988.

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Action plans to further evaluate and correct concerns regarding Containment isolation requirements, the adequacy of safety eval-untions, and the cause of this violation were developed. j

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Trojan Nucisar Plant Docket 50-344 Document Control D:sk July 15, 1988

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ticense NPF-1

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Attachment Page 2 of 6 c. The safety significance of operating the Plant with the drain valves open was evaluated, and it was determined the pressure transducers satisfied pressure boundary and seismic design ;

requirements for the feedwater system.

d. The required positions for Containment isolation valvas listed in TTS Table 3.6-1 were reviewed and clarified. Changes to Periodic Operating Test (POT) 3-3, "Containment Penetration Valve Inser- '

vice Test", were made where necessary to ensure that all Tech-nical Specification requirements are clearly defined, e. All Locked Valve List deviations have been reviewed to verify'

that none of them involve Technical Specification violations or ,

i deviations from FSAR assumptions. No problems were found, f.

All existing temporary modifications were reviewed for potential Technical Specification violations. No violations were found. 1 I

g.

Guidance has been provided within the Nuclear Division describing the Technical Specification Information System (TSIS) and inform- ;

ing personnel of its availability as an aid in performing safety evaluations. The TSIS is a PC-based computer program that allows word searches of the Technical Specifications to be done.

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An independent evaluation of this event has been performed by the Performance Monitoring / Event Analysis Group. A number of recom-mendations were made and are currently being considered by management personnel.

3.

Corrective Action to Avoid Further Violations:

a.

Nuclear Department Procedure (NDP) 100-5, "Preparation of Safety Evaluations Required by 10 CFR 50 and Trojan Technical Speci-fications" w*.ll be revised to: (a) clarify the depth and detail required for safety evaluations, and (b) to specify qualifica-tions of persons performing and reviewing safety evaluations.

The revised procedure is scheduled to be implemented on )

October 31, 1988. This schedule includes approval of the proce-dore, development of lesson plans to conduct training on the procedure, and training of selected personnel in the new proce-dural requirements, i

b. Trojan Nuclear Operations Board Proced're 110-1, "Functions and i Procedures of Trojan Nuclear Operations Board Staff", vill be revised to improve the methods used for reviewing safety eval-uations. The revisien is scheduled to be complete by August 15, 1988.  !

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, , Trojtn Nucisse Plcnt Dockat 50-344 Docum nt Control D2sk ;

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License NpF-1 July 15, 1988 Attachment t Page 3 of 6 c. The Technical Staff / Technical Manager Training Program lesson plans will be revised to incorporate information on qualification requirements, improvements made to NDP 100-5, and lessons learned from the seminar for persons to be qualified for performing and reviewing safety evaluations. The lesson plans are scheduled to 1 be revised by November 30, 1988. )

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d. The design basis document on Containment will include a discus- !

sion of what constitutes a containment boundary and why. The document is expected to be completed by January 27, 1989.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved since the feedwater valves were l closed to conform to FSAR requirements. '

Our assessment of how this finding reflects on PGE's 10 CFR 50.59 safety evaluation and engineering evaluation programs is as follows: i We acknowledge that our 10 CFR 50.59 safety evaluation and engineer-ing evaluation programs require improvement. In order to make the ,

j required improvements, we have developed an action plan to further evaluate and correct concerns regarding the adequacy of safety evaluations. Section 2 above lists corrective steps that have been i taken. Section 3 above includes correctivo steps that will be taken. !

These steps will ensure that all engineers who perform safety eval-uations have a greater understanding of the complexities and inter- ,

relationships of the Trojan FSAR and Technical Specifications. In l the interim, the additional guidance given to Nuclear Division  !

Managers regarding the availability of the TSIS and increased empha-sis on the adequacy of safety evaluations will help prevent a recurrence of this type of event. )

i VIOLATION B 10 CFR 50, Appendix B, Criterion V, states in part, "Activities affecting I quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures or drawings".

Administrative Order, A0-3-13 ment", Revision 41, dated Octc,ber "Control of Locked Valves and ESF Equip-26, 1987, specifies in part that valve locking devices on administra:ively controlled valves must be installed at all times except when actually manipulating a valve.

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Trojan Nucisse Pir.nt

Dockst 30-344 Docum:nt Control Desh July 15, 1988

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License NPF-1 )

Attachment Page 4 of 6

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Contrary to the above, on March 25, 1988, three feedwater drain valves (FW-079 FW-083 and FW-086) each an administratively controlled valve, were found unlocked.

This is a Severity Level IV violation (Supplement I).  ;

Response PGE acknowledges the violation.

l 1. Reason for Violation: i The reason for the violation was personnel error in that operstors  !

failed to properly reinstall locking chains on the three feedwater i drain valves as required by A0-3-13 following valve manipulation.

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2. Corrective Action Taken and Results Achieved:

The locking chains were properly installed, thereby re-establishing proper administrative control of the valves, 3.

Corrective Action to Avoid Further Violations * l i

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A complete verification of the Locked Valve List was performed following the 1988 refueling outage. All locking devices were found to be properly installed. The Operations Supervisor has instructed {

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Operations personnel on the need to ensure locking devices are properly installed.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved since the locking devices were correctly reinstalled,  !

l VIOLATION C

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Technical Specification 4.0.5 states in part, that "inservice testing of l ASME Code Class 1, 2 and 3 pumps and valves shall be performed in {

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accordance with Section XI of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR 50, Section 50.55(a)(g)". i PGE letter dated November 14, 1986 committed to the use of the ASME Section XI 1983 Edition, Summer 1983 Addenda.

IWV-3417 of Section XI of the ASME Boiler and Pressure Vessel Code 1983 Edition, Summer 1983 Addenda states in part, "if, for power-operated valves, an increase in stroke time of . .

. 50% or more for valves with

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Trojcn Nucletr P1 tnt Dockst 50-344 Docum:nt Control Dask l July 15, 1988

. License NPF-1 Attachment

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with full-stroke times less than or equal to 10 seconds is observed, test frequency shall be increased to once each month until corrective action is taken".

Contrary to the above, power-operated valves CV-10015 and CV-10014 (with i full-stroke times less than or equal to 10 seconds) experienced an

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increase in stroke time of more than 50 percent during testing conducted !

on January 12, 1988 and were subsequently tested on February 25, 1988 which exceeded the specified time interval with the allowable 25 percent extension.

This is a Severity Level IV violation (Supplement I). l Response PGE acknowledges the violation.

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1. Reason for Violation:  !

The reason for the violation was personnel error. The Inservice Test (IST) Engineer responsible for recording and trending data mistakenly l recorded the test data for CV-10015 and CV-?.0014 as being taken on January 19, 1988 rather than January 12, 1988. Subsequently, the increased frequency testing was scheduled based on the January 19 date. When the two valves wire tested on February 25, 1988 the monthly interval (31 days) wit' the allowable 25 percent extension had been exceeded.

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Corrective Action Taken and Results Achieved: 1 Periodic Engineering Test (PET) 9-4, "Documentation of Inservice !

Testing Data for Pumps and Valves", was revised to include a review '

by the Surveillance and Test Group supervising Engineer when specify-ing corrective action.

of any further mistakes This additional of this nature. review will reduce this risk !

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Corrective Action to Avoid Further Violations: j l

Discussions have been held with the Surveillance an! Test Group emphasizing the importance of accurately recording IST test data and acquisition dates, and the need to ensure retesting on an increased frequency is completed on schedule without entering the 25 percent allowable extension period. )

l 4. Data When Full Compliance Will Pe Achieved:

Revision 8 to PET 9-4 was approved on May 17, 1988 and has been implemented. Full compliance has been achieved.

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Trojen Nuc1str Plint

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Dockst 50-344 Documint Control Dask

• July 15, 1988

, License NFF-1 Attachment l Page 6 of 6 VIOLATION D l

10 CFR 50, Appendix B, Criterion V states, in part, "Activities affecting quality shall be prescribed by documented instructionc, procedures, or l drawings, of a type appropriate to the circumstances, and shall be accom-plished in accordarce with these instructions, procedures or drawings".

POT 3-3, Revision 22, "Containment Panetration Valve Inservice Test",

dated February 16, 1988, Paragraph 9.2 states, "Action taken shall be l

described in the data sheet comments section".

Contrary to the above, alert testing of valves CV-10014 and CV-10015 on l February 25, 1988, and valve CV-10014 on March 24, 1988 initially showed unacceptable valve stroke times, and operator response actions were not described in the comments section of the applicable POT 3-3-DB data sheets.

l This is a Severity Level IV violation (Supplement 1). I l

Response PGE acknowledges the violation. l 1. Reason for Violation:

The reason for the violation was personnel error. The operators performing the stroke tieo testing incorrectly recorded responce actions at the bottom of the data sheet page instead of the comments section as required by Section 9.2 of POT 3-3.

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Corrective Action Taken and Results Achieved:

Ihe Operations Supervisor issued a special order to his department on April 6, 1988 specifying the use of the comments section for corree-tive action when valves or equipment fail to meet acceptance criteria and instructing operators to sign their comment. The special order also directed that if a Maintenance Request (MR) is issued, the MR number should be included. l l

3. i Corrective Action to Avoid Further Violations:

The Surveillance and Test Group and the System Engineering Group which review and trend the information recorded on the test data sheets are nov verifying the comments section of the data sheets describe and document problems encountered.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

TDW/SAB/DLN/mr/2799P.788

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