ML20011D336
| ML20011D336 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/21/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8912260178 | |
| Download: ML20011D336 (6) | |
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- David W. Cockfield Vice President, Nuclear December 21, 1989 Trojan Nuclear Plant Docket 50-344
. License NPF-1 U.S. Nuclear Regulatory Commission
-Attn: Document Control Desk Washington DC 20555
Dear Sir:
Reply to a Notice of Violation
-Your: letter of November 21, 1989 transmitted Notices of Violation associated with Nuclear Regulatory Commission (NRC). Inspection Report 50-344/89-26. Our response to-the violations contained in that report are attached.
Sincerely, Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission
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Mr. David Stewart-Smith
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State of Oregon Department of Energy-Mr. R. C. Barr WRC Resident. Inspector Trojan Nuclear Plant 8912260178 891221 PDR ADOCK 05000344 ig 4
Q PDC 121 SW Sa! mon Street, Portand. Oregon 97204 i
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Document Control Desk' Docket 50-344 Attachment License NPF-1 December 21, 1989 Page 1 of 5 REPtY TO NOTICE OF VIOLATION Violation A-Title 10, Code of Federal Regulations, Part 50 (10 CFR'50), Appendix-B, Criterion V, states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances.
Licensee quality related Emergency Fire Procedure (EFP)-2, " Alternative Shutdown for Complete Loss of Service Water Caused by Fire",
Revision 3, prescribes specific steps for maintaining a supply of service water to affected safety-related components in the event of the loss of norma 1' service water during a fire.
-Contrary to the above, at the time of the inspection Procedure EFP-2 was
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l not appropriate-to the circumstances in that the procedure did not l
prescribe:
1.
The locations where dedicated hoses were stored.
1 2.
The required size of the hoses.
3.
The required length of the hoses.
This is a Severity Level IV Violation (Supplement I).
Response
Portland General Electric Company (PGE) acknowledges the violation.
1.
Reason for the Violation:
The violation is due to personnel error.
Previous instructions from an Appendix-R action plan item to provide the subject hoses for make-up requested only to verify an adequate number of fire hoses of the appropriate length be available on-site. As a result of this action plan item, the individuals responsible for ensuring the six hoses necessary for long-term duration make-up to service water cooling did not dedicate the hoses in a prescribed storage location on-site.
2.
Corrective Steps That Have Been Taken and the Results Achieved:
a.
EFP-2 was revised October 20, 1989 to add the location and required fire hose length and size to Step 23, " Establish Long-Term Alternative Source of Service Water", and the hoses were verified to be in their designated locations on that date (October 20, 1989).
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- Trojan Nuclear Plant Document Control Desk Docket 50-344 Attachment License NPF-1
_ December 21, 1989~
Page 2 of 5 i
b.
Periodic Operating Test (POT) 10-9, " Fire Protection. System -
Fire Equipment Surveillance", was revised ' october 19, 1989 to.
add the required hoses to the Fire Hosc House. Inventory List and corresponding data sheet (POT.10-9-DC).
c.
ALsign was posted on Hose House No. I stating six 2-1/2-inch by.
100-foot hoses located on the top shelf are for EFP-2 use only and are not to be removed.
3.
Corrective Steps That Will be Taken to Avoid Further Violations:
PGE-1012, Volume 1 " Fire Protection Plan - Program Description" will'be revised to include the dedicated hose requirements in r
Section 5.2.5, "Outside Hose Stations". The revision to PGE-1012 is L
scheduled to be completed by July'31, 1990, t
4.-
Date When Full Compliance Will be Achieved:
Full _ compliance was achieved.0ctober.20, 1989 When POT 10-9 and EFP-2 were= revised to include the requirements for the dedicated hose storage to perform the alternate' shutdown actions for a
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complete loss of service water caused by fire.
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Trojan Nuclear Plant Document Control Desk Docket ?,0-344-Attachment.
Licenre'NPF-1 December 21, 1989 Page 3 of 5 Violation B Title 10, Code of Federal Regulations,.Part 50-(10 CFR 50), Appendix B, Criterion V, states, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,... shall be accomplished in accordance with these instructions, procedures, or
- drawings, Trojan Nucicar Safety and Regulation Procedure, " Quality-Rolated Calculation", Revision 1 Section 5.a. effective at the time of i
Revision.1 of Calculation TNP-83-59, states, " Check hand calculations for assumptions, analytical methods, mathematical accuracy, completeness, and - as appropriate - compliance with design criteria and/or design drawings.. (See Form NSR-25, Attachment D.)".
Form NSR-25. " Calculation Ceneral Checking Criteria", requires, for. hand l
calculations, determinations that all assumptions are ccrrect, and that calculational parameters comply with design criteria and dimensions.
Contrary to the above, at the time of the inspection, Calculation TNP-83-59. Revision 1, " Fire Pump Flow Capability for Appendix R L
Alternato Cooldown without Service Water System Pumps and Offsite Power",
failed to assure the adequacy of the assumption that a 50-foot hose would be used to connect the fire pump discharge header and the Service Water System.
In fact, a 100-foot hose would have been used under the conditions to which the calculations applied.
L This is a Severity Level IV violation.
Response
PCE acknowledges the violation.
1.
Reason for the Violation:
The reason for the violation is personnel error for not verifying an assumed value used in Calculation TNP-83-59.
The assumption that a 50-foot fire hose could be used to supply water from the fire pump dischargo heador_ at the 29-foot olevation of the Intake Structuro to the Service Water System (SWS) siamese connection at the 45-foot elevation of the intake structure, was not verified by actual measuromont.
Calculation TNP-83-59, Revision 0, "Firo Pump Flow Capability for Appendix R Alternate Cooldown", made the assumption that a 50-foot length of fire hose could be used to connect the fire pump discharge heador to the SWS.
Review of the calculation indicatos that this number was not verified by the person performing the calculation nor the reviewer of the calculation.
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. Trojan. Nuclear Plant Document Control Desk Docket 50-344 Attachment
- License NPF-1 December 21, 1989 Page 4 of 5 1
Revision 1 to Calculation TNP-83-59 carried over the hose length assumption from Revision O.
Both Revision 0 and Revision 1 were p
checked by the same reviewer.
Since the assumption was accepted in l:
TNP-83-59,-Revision 0, by the same reviewer, no verification of the j
hose length was performed ~for Revision 1.
l E2.
Corrective Steps That Have Been Taken and the Results Achieved.
1-a.
Nuclear Safety and Regulation Procedure 250-1, " Quality-Related
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l Calculations", Which was in affect at the time that calculation TNP-83-59, Revision 0 and Revision 1, were performed, was lC deleted in July 1986 in favor of a Nuclear Division Procedure (NDP) 200-4, " Quality-Related Calculations". NDP 200-4 more clearly states the responsibilities of the individuals performing and checking assumptions used in calculations, requiring in part that the source and/or rationale for the l
assumption be provided in the calculation, and verified by the L
checker.
1.
b.
The NRC first reviewed Calculation TNP-83-59 as part of an i
audit of PGE's alternative shutdown for loss of service water as. documented in paragraph 4.B.(1) of' Inspection Report No. 50-344/87-34, dated November 25, 1987. As a result of the l
inspection, the inspectors recommended that an actual test be l
l performed to verify the ability to supply adequate flow to the l
SWS from'the fire pump discharge header via the hose l
l connection. This recommendation was tracked as Unresolved Item 50-344/87-34-10.
PGE's response to Inspection Report 50-344/87-34 dated L
December 28, 1987, committed PGE to perform the recommended flow test prior to startup from the 1988 refueling outage.
Temporary Plant Test (TPT)-251, " Fire Pump Discharge to Service Water", was subsequently, and successfully, performed in June 1988. The successful completion of the flow test was j.
j verified by NRC inspectors during the August 1988 fire protection audit as documented in Inspection Report No. 50-344/88-34, dated October 20, 1988. Based on their I
review of test results from TPT-251, the inspectors closed Item 50-344/87-34-10 as discussed in paragraph 2.W of the report.
The successful completion of the flow test to verify the assumption that the fire pumps can supply the SWS through the fire hose connection provides empirical data which eliminated the need for Calculation TNP-83-59.
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Lr-g Trojan Nuclear Plant Document Control Desk-Docket 50-344.
. Attachment-License NPF-1 December 21, 1989 Page 5 of 5 t
3.
Corrective Actions That Will be raken to Avoid Further Violations.
a.
Calculation TNP-83-59 will be voided as the ability to provide service water supply from the fire pump discharge header was verified by testing, b.
TFT-251 test results will be re-evaluated by Plant Systems Engineering prior to the end of the 1990 refueling outage.
Should it be determined that the test needs to be run again to address-any aspect of the previous test conclusions, a new TPT j
will be re-performed at that time.
-i The reperformance of.TPT-251 will document the size and length of the. hose (s) used and reverify the previous results.
4.
The Date When Full Compliance Will be Achieved.
I Full compliance was achieved when the flow test for TPT-251 was satisfactorily completed in June'1988, verifying required flow through empirical data thereby eliminating the need for calculation TNP-83-59.-
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