IR 05000344/1989020

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Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-344/89-20
ML19332E957
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 11/29/1989
From: Chaffee A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Cockfield D
PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8912130196
Download: ML19332E957 (1)


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NOV 2 91989

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. Docket No. 50-344

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Portland General Electric Company i

121 SW Salmon Street. TB-17

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Portland, Oregon 97204

. Attention: Mr. David W. Cockfield

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Vice President, Nuclear p

Thank you for your letter of October 30, 1989, in response to'our Notice of

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Violation and Inspection Report No. 50-344/89-20, dated September 29, 1989.

We appreciate you informing us that the violation was against Trojan Technical

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Specification 4.1.3.2 instead of 4.1.3.1.1.

Also, we appreciate you informing us of the steps you have taken to correct the items which we brought to your attention regardless of ~ Technical Specification section violation. Your corrective actions will be verified during a future inspection.

t Your cooperation with us is appreciated.

Sincerely,

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f(f), S ig k A. E. Chaffee,pcting Chief

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Reactor Projects Branch bec w/ copy of letter dated 10/30/89:

docket file State of Oregon

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A. Johnson G. Cook B.,Faulkenberry L

J. Martin LResident Inspector Project Inspector

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David W. Cockfield Vice President, Nuclear October 30, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN Document Control Desk Washington DC 20555

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Dear Sir:

Reply to a Notice of Violation Your letter of September 29, 1989 transmitted a Notice of Violation

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associated with Nuclear Regulatory Commission (NRC) Inspection Report 50-344/89-20. Attachment 1 is our response to that Notice of

Violation.

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Sincerely, l'

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. Attachment

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Mr. John B. Martin l

Regional Administrator, Region V

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U.S. Nuclear Regulatory Comission Mr. David Stewart-Smith l

State of Oregon Department of Energy Mr. R. C. Barr URC Resident Inspector Trojan Nuclear Plant

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Trojan Nuclear Plant Document Control Desk Docket 50-344 October 30, 1989 License NPF-1 Attachment 1 Page 1 of 2 REPLY TO A NOTICE OF VIOLATION Violation Trojan Technical Specification (TTS) Surveillance Requirement 4.1.3.1.1 states "The position of each rod shall be determined to be within the group demand limit by verifying the individual rod positions at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> except during time intervals when the Rod Position Deviation Monitor is inoperable, then verify the group positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />."

Contrary to above, from July 16, 1989, through August 1, 1989, while the reactor was in Mode 1 or Mode 2 with the Rod Position Deviation Monitor inoperable, the position of each rod was not determined to be within the group demand limit by verifying the individual rod positions at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; rather the rod positions were verified once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

This is a Severity Level IV violation.

Response Portland General Electric (PGE) Company acknowledges that a violation of the Trojan Technical Specification (TTS) did occur.

However, the

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violation acknowledged is not the violation stated pertaining to

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TTS 4.1.3.1.1, Movable Control Assemblies - Group Height.

During the time period the Plant Computer Rod Position Deviation Monitor

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Alarm was inoperable, TTS Surveillance Requirement 4.1.3.1.1 was not l

, required as Special Test Exceptions, (i.e. Physics Testing), for the applicable Modes were in effect.

However, during the investigation of this apparent violation, it was discovered a violation of the surveillance requirements of TTS 4.1.3.2, Reactivity Control Systems - Position Indication Channels, did occur as

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this TTS was not superceded by the Special Test Exceptions.

From July 16 to July 26, 1989 Trojan was in Mode 3 and no control rod position monitoring was required. However, during the time periods l

July 26 and 27, 1989 and August 1 to August 4, 1989, when the Rod Position Deviation Monitor was out of service, the comparisons of the demand position indication system and the rod position indication system were not made at least once per 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> as required.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 October 30, 1989 l

License NPF-1 Attachment 1 j

Page 2 of 2 j

1.

Reason for the Violation:

The reason for the violation is personnel error in that a plant computer variable was not restored following a computer outage.

This caused the portions of the Rod Supervision Deviation Monitor

~that alarms during abnormal rod movement to become inoperable.

2.

Corrective Steps that Have Been Taken and the Results Achieved:

The Rod Position Deviation Monitor was determined to be inoperable st 12:00 p.m., August 1, 1989 and control room personnel began logging rod positions in accordance with Periodic Operating Test (POT) 24-1, Shift Operating Routines.

During a review of POT 24-1 data on October 18, 1989, PGE discovered that the position of the Shutdown Banks were not recorded from August 1, 1989 to August 4, 1989 as required. Further review identified that POT 24-1 had a weakness in that the form attached for recording Control and Shutdown Bank position did not allocate space for documenting Shutdown Banks during Rod Position Deviation Monitor.inoperability.

POT 24-1 was deviated October 18, 1989 to provide the required form for recording Shutdown Bank position.

Training Information Bulletin (TIB).-65 was issued on August 2,1989 to Plant Operations personnel giving information and guidance on the Rod Position Deviation Alarm and the increased surveillance requirements should the computer alarm be unavailablo.

The computer problem causing the Rod Position Deviation Alarm to be inoperable was corrected and the Rod Position Deviation Monitor was returned to service August 4, 1989. To lessen the probability of a reoccurance, a sof tware change to the Plant computer disk was made to restore the variable to its proper value following a restart of the computer.

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A deviation was issued on July 28, 1989 to POT 15-1. Full Length Rod Movement Verification, to periodically check that the Rod Supervision Computer Program is active in Modes 1 and 2 (every 31 days) and prior to Plant Startups.

Similar procedure changes were made for the computer programs for Axial Flux Difference and Quadrant Power Tilt Ratio monitoring.

3.

Corrective Actions to Avoid Further Violations:

No further actions are required.

4.

Date When Full Compliance Will be Achieved:

Full compliance was achieved October 18, 1989 when POT 24-1, Shift Operating Routines, was corrected.

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