IR 05000344/1988036

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/88-36. Corrective Actions Will Be Verified During Future Insp

ML20195D471
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/28/1988
From:	Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8811070015
Download: ML20195D471 (1)

Text

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.      PD6 00T 2 81999 Docket No. 50-344 Portland Genetal Electric Company 121 S.W. Salmon Street, TB-17 Portland, Oregon 97204 Attention: Mr. David W. Cockfielu Vice President, Nuclear Gentlemen:   -
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Thank you for your letter of October 14, 1988, in response to our Notice of Deviation and Inspection Report No. 50-344/88-36, dated Septe,nber 16, 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, Your cooperation witii us is appreciated.

Sincerely, ' Ro ert J,

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ate, Chiel' Reactor Safety Branch bec w/ copy of letter dated 10/14/88: Docket File Resident Inepector Project Inspector ' G. Cook A. Johnson 8. Faulkenberry J. Martin LfM8 State of Oregon bec w/o copy of letter dated 10/14/?8 M. Smith REGION V f, JMelfi/Joan SRichards kPate CA5 /88 #/1 0/88 4'/g/88 Tcm RQUESTCOPY]5QUESTCOPY]REQUESTJCPC] YES) / NO ] YES / (NO ) ] YES //NOJ HND TO POR ] I NO ] \( 8G11. 1015 881028 - - PDR ADACK 05000344 - I O PDC w. l

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David W. Cockfield Vice President, Nuclear 3 00,T f g , October 14, 1988 Trojan Nuclear Plant Docket 50-344 License NPF-3 U.S. Nuclear Regulatory Comission Attn: Document Cor. trol Besk Washington DC 20555

Dear Sir:

Response to Notic9 of Deviation Your letter of september 16, 1988 forwarded a Wotice of Deviation (NOD) concerning a miwsed comitment associated with the qualification of the Condensate Storage Tank lo wl indication used for postaccident monitoring in accordance with Regulatory Cuide (RC) 1.97. "Instrumentation for Light-

Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident". In addition to the N0D, you requested that Portland General Electric (PCE) provide (1) an assessment of our program established to assure fol?ow-up of comitments and open items.

(2) an assessment of the adaquacy of PCE's Licensee Event Report (LER) reporting system, and (3) identification of actions planned to resolve the conflict betueen the Detailed Control Room Desigt: Review (DCRDR) ind RC 1.97 with regard to the RC 1.97 redundancy requirements for Steam Generator Wide-Range Level and Eeactor Coolant System Temperature indication.

Attachment A to this letter provides PCE'c response to the NOD. Attach-ment B provides the assessments of our comitment tracking and LER repcrting systems. Attachment B also provides a discussion of PCE's position and act ions planned to address the DC.RDR/RC 1.97 conflicts identified above.

Sincerely .

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Attachmerits c r. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Comission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant Q' S W Eav Sreet P:: cam Cre;pn 9'2N O Ax,s yQ1n e

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. Responge to Notice of Deviation Deviation In response to MRC concerns with your Regulatory Guide 1.97 submittal of December 20, 1984, a letter, Withers to Varga, dated May 13, 1986 stated, in part, that full Seismic Class I qualified instrumentation for the Condensate Storage Tank (CST) would be provided by the end of the 1986 refueling outage.

Contrary to the above, at the time of the inspection, the indicators for the CST level were not qualified as seismic Class 1.

This is a deviation.

Response i portland General Electric (PCE) acknowledges the deviation.

A. Reason for Deviation.

The subjec^. deviation is the result of a misstated commitment in PGE's May 13, 1986 letter. Although the letter stated that Seismic Category I qualified indication would be pro'.'ided for the CST level instrumentation by the and of the 1986 refueling estage, seismic upgrade of the indica-tion was not included within the scope of CST level instrumentation modifications being made at the time. The connitment to upgrade the i CST level indication was due to a misunderstanding between the Licensing l personnel who made the comniitment and the Engineering personnel involved in the instrumentaticn modifications.

The CST level instrumentation design change being performed during the 1986 refueling outage was assigned to PCE's Cossnittent Tracking List (CTL). The CTL record assocluted with the instrumantatiot. spgrade was closed out when the planned modifications were cesplete. At the time ' of closeout of the CTL record, it was th6 understanding of the person-nel involved that the commitment had been set. As stated above, the i commitment to upgrade the indf. cation portion of the CST level instru-mentation was due to an intertal misunderstanding of the scope of the modific.tions. For this reason, the resultant deviation is considered to be an unique case rather than a f ailure of the PCE Commitment , ' Trackins System.

l 3. Corrective steps that have been taken and the results achieved.

I l Upon discovery of the apparent missed commitment, Non-Conforming l Activity Deport (NCAR) H88-t3M was issued on July 21, 1988. The NCAR evaluation determined the root cause to be inadsq*isto technical review l l of the May 13, 1986 letter to the NRC. In addition to the NCAR, the issue was discussed with the Trojan project Manager in the NRC Of fice l

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Docket 50-344 October 14 License NPF-1 *ttachment *

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Page 2 of * of Nuclear Reactor Regulation (NRR) and a letter clarifying PCE's position concerning qualification of the CST level instrumentation mes transmitted to NRR on October 14, 1988.

C. Corrective steps that will be taken to avoid further deviations.

Additional corrective actions will be to revise PGE's RG 1.97 submittel, Topical Report PGE-1043, "Accident Monitoring Instrumentation Review", to describe the as-built condition of the instrumentation. The revision

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to PGE-1043 will be issued by December 15, 1988. As part of this revision the as-built condition of the CST-level instrumentation will be verified.

With regard to PCE's Commitment Tracking System, this deviation is consiftred to be a unique case rather than a failure of the PGE Commit-ment Tracking System. However, PCE is in the process of assessing the adequacy of the system to determine if changes are necessary. PCE will continue to stress to its personnel the need to ensure adequate review of all work to avoid similar situations in the future.

D. The date when corrective actions will be completed.

Verification of the as-built design for CST-level instrumentation and the update of PCE-1043 will be completed by December 15, 1988.

The assessment of PCE's commitment Tracking System will be completed by

December 31, 1988. - l

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Page M 2 PORTLAND GENERAL ELECTRIC RESPONSE TO ADDITIONAL INFORMATION l RE0 VESTED BY THE NUCLEAR REGULA7ORY C000tISSION 1. Assessment of Comitment Trackina system

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Portland General Electric (PCE) perfomed a review of the Comitment Tracking List (CTL) records upon discovery of the apparent missed  ! comunitment identified in the Nuclear Regulatory Cossaission's (NRC) [ Notice of Deviation dated September 16, 1988. PCE determined that t the root cause in this case was not a failure of the CTL. The ! condensate storage tank (CST) instrumentation modifications for , Regulatory Guide (RC) 1.97 were tracked by CTL Record No. 01211, I which was closed-cut following completion of the as-built verifica-  ; tion. The CTL record was closed with the understanding that the  ! RC 1.97 cossaitments had been met by the completed modifications.  ! The root cause of the apparent missed comitment has been detemined , to be an inadequate technical review of the cossaltment as it was stated in PCE's May 13, 1986 letter. A contributing cause was a misunderstanding between Engineering and Licensing personnel as to , the scope of the planned instrumentatien modifications. The result I was a misstated coesnitment whir.n was beyond PCE's intended modifica- i tions. Based on PCE's evaluation, this is considered a unique case rather than a f ailure of the consnitment Tracking System.

i PCE does recognize, however, that the comitment Tracking System requires some improvement, and is currently assessing this issue.

Changes implemented to-date include the addition of CTL numbers to the tout of Licensee Event Reports (LERs), and the assignment of CTL numbers to cosenitments made in other regulatory correspondence prior i to the internal approval of the correspondence. Additional improve-  ; monts w!!1 be identified and implemented following completion of the > Cosenitment Tracking Sy6 tem assessment. The assessstent should be ' complete by December 31, 1988. 5

I 2. Assessment of LER Reportina system.

PCE is currently in the process of improving our Event Report (ER) [ , and t.ER evaluation and reporting system. An action plan has been  ; I issued to identify and track corrective actions needed to enhance ' I

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      . quality and timeliness of LIRs.

I corrective actions completed to-date include the following: i l a. Checklists to ensure thorough and complete evaluation and review ! of ERs and LERs have been prepared and distributed. - l b. A standard schedule has been issued to ensure timely IR evalua- [ tions and LER preparation and review. I I ! !  ; I l l . - . .

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Ps;w 2 of 3 c. Weekly Plant management review of open ER status and priority of LER preparation has been initiated to monitor ER/LER progress.

d. Commitment Tracking List numbers have been added to the text of LERs to designate and control commitments.

e. Other changes have been made to the LER review and approval process to ensure greater attention by responsible management.

In addition to the completed actions listed above, the following corrective actions will be taken a. The current LER format will be evaluated to determine if changes will result in laprovert LERs.

b. Comparisons will be made between Trojan LER preparation proce-dures and those of other Region V plants in order to determine ways to improve, c. Event Report procedures will be revised and a new LER preparation procedure will be issued incorporating the program improvements.

r All corrective actions on the LER improvement action plan are cur- . rently scheduled to be completed by January 31, 1989.

3. Actions to Resolvo Conflicts Between Regulatory Guide 1.97 and Trojan Detailed Control Room Design Review (DCR9R) L During the RG 1.97 audit perforwed August 8 to August 12, 1988, the inspectors noted that redundancy requirements for reactor coolant system (RCS) temperature and steem Senerator wide-range level indica-tion were not met by Trojan's design. The reason for this apparent discrepancy is a conflict betwe9n Trojan's DCRDR and RG 1.97 requirements.

PCE's original RG 1.97 submittal. Topical Report PCE-1043. "Accident , Monitoring Instrumentation Review" took exception to the redundancy l requirements based on the availability of backup indication. The NRC accepted PGE', position in their Esfety Evaluation dated September 29, 1986. Subsequent to the August 1988 audit. PCE's position in Topical Report PCE-1043 was reviewed and found to be in error with regard to its description of the channel availability for monttoring RCS temperatures and steam generator level.

, PCE-1043 statis that in the event of a loss of one train of electri-cal power, hot- and eJ-leg indication will be availablu on two RCS loops. However, as s ,Jsed in the audit report, the actual con-figuration of the pow supplies and monitoring channels will result in a loss of indication for three out of four loops. This is also true for steam generator wide-range level.

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loops. However, as discussed in the audit report, the actuel con-figuration of the power supplies and monitoring channels will result in s loss of indication for three out of four loops. This is also true for steam generator wide-range level.

To correct the problems discussed above, the fellowing actions have been or will be taken: a. A Wonconforming Activity Report (NCAR) has been initiated to evaluate and correct the errors jn PCE-2043. A revir, ion to Pct-1043 will be issued by December 15, 1988 to correct these errors.

b. A Justification for Continued Operation will be written for the RCS toeparature and steam generator levei loss of redundancy by October 31. 1988.

c. Design alternatives to resolve the conflicts between the DCRDR

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dnd BC 1.97 will be evaluated by PCF. to determine a means of meeting the requirements of both. This evaluation will be completed by February 28, 1969.

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