ML20012F593
| ML20012F593 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/04/1990 |
| From: | Walt T PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9004160256 | |
| Download: ML20012F593 (13) | |
Text
o 4
W M OIKANC C WT5 M 1f g
April 4, 1990 Trojan Wuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Conenission Attnt Document Control Desk Washington DC 20555 Deer fl at Estly _to a votice of violatiori Your letter of March 5, 1990 transmitted Woticc,s of Violation associated with Wuclear Regulatory Commission (NRC) Inspection Report 50-344/90-02.
Attachment I to this letter contains Portland General Elect ric Company's (PCE's) responses to the Violations containod in the inspection report.
Sincerely.
T. D. Welt.
Acting Vice President. Nuclear Attachment et Mr. John B. Martin Regional Administrator Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Depart.mont of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 1
A i 'C
q\\
e e m_ e__._
l
Trojan Nuclear Plant Document Control Desk
)
Docket 50-344 April 4. 1990 License NPT-1 Page 1 of 12 R12LUO A.NQHCLOU10.1AUQN Vio1AtictLA Trojan Tecimical Specification (TTS) 3.0.3 states that:
"In the event a Limitin6 CMition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed l
in the specification, within one hour action shall be initiated to place the unit in a Mode in which the specification does not apply by placing it, as applicable, int 1.
At least HOT STANDPY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
2.
At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and 3.
At least COLD $11UTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
[
Where corrective measures are completed that perinit operation under the ACTION requirements, the ACTION may be taken in accordante with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requiremeate are stated in the individual Specification."
YTS 3.5.2 requires that both trains of Emergency Core Cooling System t
(ECCS) be operable, does not soecify actions if both trains are inoperable, and does not prov.ide for t'.sception from TTS 3.0.3 l
requirements.
t Contrary to the above, on July 4 and 5, 1988, with the reactor in the hot j
standby (Mode 3) condition, the Limiting Condition for Operation and Action requirements of TTS 3.5.2 were not satisfied when portions of both trains of ECCS subspstems were disabled for up to two hours to perform j
surveillance tests of system check valves. Action was not initiated within one hour to place the unit in Mode 4 where the Technical Specification Limiting Condition for,0peration is not applicable, j
This is a Severity Level IV violation.
[
I Responac t
Portland General Electric Company (PGE) acknowledges the violation.
{
1.
Reason for the violation.
The reason for the violation that occurred July 4 and 5. 1988 was l
personnel errort failure to understand that Trojan Technical l
Specification (TTS) limitations on inoperable equipment do not allow
[
entry into TTS 3.0.3 for convenience.
PGE revised POT 2-4 j
i i
1
e-4 Trojan Nuclear Plant Document Control Desk Docket 50-344 April 4, 1990 License WPF-1 Page 2 of 12 on January 31, 1989 and again on June 19, 1989 to prevent entry into TTS 3.0.3 for testing convenience while in mode 3.
However, on February 21, 1990, during a review of corrective actions taken previously in response to NRC Inspection Report 50-344/88-40, it was noted that a revision of FOT 2-4 fection 7.6 performed on June 19, 1989 was not edequate to prevent performing the test in a condition which resulted in both ECCS trains being rendered inoperable. This finding was reported in Licensee Event Report (LER) 90-06. 1he enuse of this occurrence was determined to be an inadequate procedure due to an inadequate technical and safety review of the revision.
2.
Corrective steps that have been taken and the results achieved.
Operations Supervisors were informed by way of an entry into the Special Orders Notebook, August 8,1988, that TTS 3.0.3 should not be entered voluntarily to do scheduled maintenance.
Concerning NRC unresolved item (88-40-02) pertaining to apparent voluntary entry into TTS 3.0.3, POT 2-4 was revised January 31, 1989 to remove those sections identified in the inspection report as having resulted in voluntary entry into TTS 3.0.3.
Ivo of these sections were revised and incorporated into Plant Engineering Test (PET) 7~7.
The other three sections were revised and reinserted into POT 2-4 on June 19, 1989.
These changes provided means to perform the ECCS check valve testing without entering TIS 3.0.3.
LER 90-06 was issued on March 23, 1990, informing the NRC of the February 21, 1990 discovery of an inadvertent entry into TTS 3.0.3 on July 24, 1989.
POT 2-4 Section 7.6 and Data Sheet POT 2-4-DF were revised by Deviation 90-058 on February 23, 1990, temporarily deleting the subject test until an evaluation could be performed by Plant Systems Engineering of the testing method for Residual Heat Removal Check Valves 8736A and B and a revised testing methodology could be implemented.
3.
Corrective actions to be taken to avoid further violations.
Plant System Engineering will provide an in-depth review of POT 2-4 to ensure no addAtional entries into TTS 3.0.3 are contained in the procedure. This review will be completed by April 15, 1990.
A detailed technical review of each step in the POTS which could have a similar problem will be performed.
This review will be completed by August 20, 1990.
Trojan Nuclear Plant Document Control Desk Docket 50-344 April 4, 1990 Licen; NFF-1 Attachnent 1 Page 3 of 12 To address the issue of an inadequate technical review, a Human Performance Evaluation System (NFES) study will be performed by Ferf ormance Monitoring / Event Analysis to determine why the June 19, 1989 revision to FOT 2-4, including the technical review and saf ety evaluation, did not discover the potential f or the TTS 3.0.3 entry.
This evaluation will be complete by April 15, 1990.
4 Data when full compliance will be achieved.
Full compliance will be achieved by April 15, 1990 following the in-depth review of FOT 2-4 for additional potential entties into TTS 3.0.3.
l
i Trojan Nuclear Plant Document Control Desk Docket 50-344 April 4, 1990 1,1 cense NPF-1 Page 4 of 12 l
r Violation _B TTS 3.3.3.6.b states:
"With both chlorine detection systems inoperable, within one hour initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation.*
t
- For the purposes of meeting Specification 4.7.6.1.b. or for providing periodic air exchanges to maintain air quality in the control room, the outside dampers for the normal and/or emergency control room ventilation systems may be opened for up to one hour provided that appropriate compensatory measures are taken to isolate the control room if a toxic l
gas accident should occur..."
Contrary to the above, at approximately 1:35 p.m. on Jsnuary 25, 1990, while ventilating the control room with the outside dampers open and the chlorine detection system inoperable, appropriate compensatory measures L
had not been established in that there was not continuous communication between the southeast access security guard and the control room.
l This is a Severity Level IV Violation.
Response
PGE acknowleoges the violation.
i 1.
Reason for violation.
The reason for the violation is procedural inadequacy.
The l
compensatory actions to be taken when ventilating the control room were not adequately specified in the procedure and as a consequence, i
continuous communications were not maintained.
The actual wording of the emergency TTS change and the associated l
compensatory measures did not specifically state that continuous l
conmuunication would be established during control room ventilation.
Temporary Operating Instruction (OI)-T-64, " Operating the Control i
Room HVAC Systems Until Both Chlorine Monitors are Returned to t
Operable Status", Revision 0 was used to control the venting j
evolution.
Communications were to be established between the control room and the southeast access security gate. Should a train approach i
the Plant from any direction during control room ventilation, the guard on duty at the watch station would immediately contact the r
control room and warn of the approaching train. Ventilation was to be secured immediately regardless of the type of train approaching.
t
o i
Trojan Nuclear Plant Doerment Control Desk Iceket 50-344 April 4, 1990 j
License NFF-1 Attacionent 1 l
Fage $ of 12 I
Normally, two guards were stationed at the southeast security access area. At tbe time of this event, only one guard was present to i
monitor traffic and to watch for oncoming trains as the second guard was in training. This situation could have contributed to the event as the guard on duty was distracted issuing a parking pass at the time the train was first seen approaching the Trojan Nuclear Flant.
When the guard attempted to call the control room, the Plant telephone that was used received no answer after four rings. The guard realized a problem existed and switched immediately to another Plant telephone system.
By the time the control room was notified, the train t.ad pasJed the Plant.
l
(
2.
Corrective steps that were taken and the results achieved.
A review of this event indicated the need to explicitly require continuous consuunications between the control room and the guard l
during control room ventilation.
Insnediate corrective action included issuing a temporary revision to 01-T-64 to require j
establishing continuous consuunications between the control room and security using a dedicated radio prior to ventilating the control i
room. The security watch at the lower gate was augmented to require j
two guards on station in case of an emergency requiring the attention of one guardt the second guard at the lower gate would devote his attention to the train watch as long as the ventilation was in progress. No further incidents of not being able to warn the control room of approaching trains has occurred.
The chlorine detectors for control room ventilation isolation were declared operable on March 14, 1990. OI-T-64 was cancelled. No additional corrective actions are required.
3.
Corrective stepo that will be taken to avoid further violations.
The Nuclear Safety and Regulation Department will increase its depth of involvement in the verification of consnitments made to the NRC for t
Technical Specification exemptions granted based upon the implementation of compensatory actions.
l 4.
Date when full compliance will be achieved.
rull compliance was achieved January 24, 1990 with the deviation of OI-T-64 to require continuous communication between the lower guard station and the control room.
l
T i
Trojan Nuclear Plant Document Control Derk Docket 50-344 April 4, 1990 License NFT-1 Attactment 1 Page 6 of 12 i
i Yiolation_C Title 10, of the Code of rederal Regulations Part 50.71(e)
(10 CrR 50.71(e)) states in part that:
"Each person licensed to operate a nuclear power reactor... shall update periodically... the Final Safety Analysis Report (TSAR) originally submitted as part of the application for the operating license, to assure that the information included in the FSAR contains the latest material developed.
This submittal shall contain all the changes necessary to reflect information l
and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of the original FSAR or, as appropriate, the last.pdated TSAR. The updated FSAR shall be revised to include the effects oft all changes made in the facility or procedures as described in the FSAR.
10 CPR 50.71(c)(4), insofar as here applicable, requires the annual submission of the required TSAR updates to reflect all changes up to a maximum of six months prior to the filing of the updates.
The Plant was modified by the following Detailed Construction Packages (DCPs) in response to Requests for Design Change (RDCs):
1.
In 1985, RDC 83-051 DCP 3, removed the boron injection tank pressure indication and annunciation in the control room.
l 2.
In 1983, RDC 76-068. DCP 2, Revision 1, modified the component l
cooling water surge tank pressure controls by installing hand l
switches.
Contrary to the abovs, the Plant was modified without accurately updating I
the TSAR as of December 1989, as noted below:
{
1.
FSAR Paragraph 6.3.5.1 incorrectly states that:
" Boron injection tank pressure is indicated in the control room and a high-pressure I
alarm is provided." Neither pressure indication nor a high-pressure alarm are provided in the control, room.
2.
FSAR Paragraph 9.2.2.2.2.3, describing the solenoid valve automatic controls for Component Cooling Water (CCW) system surge tank i
pressure, states in part:
" Manual push-button controls for the solenoid valves are installed on Panel C18 in the control room near the surge tank level and pressure indicators to allow operators to manually adjurt tank pressure to bring levels back into the normal control band during operation of the makeup pumps, as required."
i There are no manual push-button controls for control of CCW surge tank pressure.
i This is a Severity Level V violation.
I Trojan Nucleur Plant Document Control Desk Docket 50-344 April 4, 1990 License NPT-1 Page 7 of 12 Responst PCE acknowledges the violation.
1.
Reason for the violation.
Licensing Document Change Requests (LDCRs) were not provided for updating the FSAR following the completion of the Design Change Packages (DCPs) to Request for Design Changes (RDCs)83-051 and 76-068, that were issued in 1985 and 1983 respectively.
Therefore, the reason for the violation was personnel error, failure l
to fully meet the requirements of 10 CTR 50.71(e) and 10 CFR 50.71(e)(4) by not having adequato procedures in place to ensure revisions to the PSAR were made as required.
Revision 2 to Nuclear Division Procedure (NDP) 200-1, " Design Change Control", was incorporated May 2, 1986 to require the responsible engineer to submit an LDCR if an FSAR ot other license document change is required.
During a Nuclear Quality Assurance Department (NQAD) audit, PGE identified an apparent problem with incorporating i
the design changes into the TSAR and a Nonconforming Activity Report (NCAR) was written (December 29, 1989) documenting instances where l
the responsible engineers did not initiate an LDCR for RDCs i
identified in the audit. NDP 200-1 was recognized to have an I
additional weakness by not having a time requirement to submit the LDCR following issuance of the DCP into the field.
2.
Corrective steps that have been taken and the results achieved.
NDP 200-1 was revised March 5, 1990 to require an LDCR be submitted in accordance with NDP 700-2, " Control of the Trojan Operating License and Licensing Documents". Attachment C (control of the Trojan Operating License and Licensing Documents. Licensing Document Change Request) within 31 days of the DCP issuance.
LDCRs were prepared for RDC P1-051, DCP 3 and RDC 76-068, DCP 2 i
(Revision 1).
i 3.
Corrective steps that will be taken to avoid further violations.
Updates for RDC 76-068 will be incorporated into the FSAR changes currently scheduled to be issued April 30, 1990.
The update for RDC 83-051 will be included in the August 31, 1990 revision.
Nuclear Plant Engineering will review all DCPs issued since January 1, 1988.
LDCRs will be initiated for any design changes affecting the FSAR for updates that are needed. This review will be i
completed by November 1, 1990.
Based upon the results of this review, a determination will be made at that time whether to expand the scope of the DCP review to include earlier design changes.
F' o
Trojan Nuclear Plant Document Control Desk Ibeket 50-344 April 4, 1990 License NPF-1 Page 8 of 12 Nuclear Plant Engineers will complete training to the requirements of NDP 200-1 (initiation of LDCRs during the Design Change Process) as part of the corrective actions by April 30, 1990.
);tiP 100-$. " Preparation of safety Evaluations Required by 10 CFR 50 and Trojan Technical Specifications", will be revised to include a reminder in Attachment A. " Screening Criteria Check List", that a "Yes" answer will require an LDCR to revise the appropriate licensing document.
This revision will be completed and implemented by August 30, 1990.
4.
Date when full compliance will be achieved.
Full compliance will be achieved by August 31, 1990, following the updates to the FSAR that will include the changes identified to RDC 83-051, DCP 3 and RDC 76-068, DCP 2 (Revision 1).
f I
l
?
Trojan Nuclear Plant Document Control 14sk Docket 50-344 April 4, 1990 License NFT-1 Page 9 of 12 i
Violation _D 10 CFR 50 Appendix B, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
1.
Administrative Order (AO) 5-8, Revision 4, " Temporary Modi'tiatior."
(TM). Step 4.11.1, states:
"The PSE Branch Manger shall direct a PSE engineer to perform a periodic TM Review when one of the following conditions exists a.
Any IM has been' installed for more than six months and no TM Review has been initiated or completed OR b.
More than one year has passed since the last periodic TM Review."
Contrary to the above, the following TM reviews exceeded time requirements.
Iti_Numbar Installed firaLRevity Days h ts SeCDAd Revity Dayg_ late 89-072 07/13/89 28 N/A 89-058 06/19/89
$3 N/A 89-002 04/27/89 105 N/A 88-080 06/30/88 07/05/89 186 N/A 88-011 02/08/88 11/28/88 122 12/19/89 21 88-004 01/15/88 10/06/88 83 10/18/89 12
- Not as of the end of the inspeqtion period (02/10/90).
2.
A0 7-1, Revision 17, " Plant Records", Step 4.7.1, statest
" Erasures and white-out shall not be used on QA records."
Contrary to the above, the restoration section of TM 89-072, a quality assurance record, was corrected with white-out.
3.
A0 5-8, Revision 4, TM Step 4.8.1, states:
"Upon receipt of the As-Built cover letter and processing of a turnover check list NPE onsite shallt
- a. Remove the TM tags and discard.
Initial TM original for tags removed."
i Trojan Nuclear Plant Document Control Desk Docket 50-344 April 4, 1990 License NFF-1 Page 10 of 12 Contrary to the above, on January 31, 1990 TM tags for IM 87-076, which had been closed in August 1989, had not been removed, nor had the TM original been initialed for tag removal.
This is a Severity bevel V violation.
Response
POE acknowledges the violation.
For D.1 1.
Reason for the violation.
The reason for the violation was personnel error, failure to follow the procedure. The intent of the procedure as written was to perform a TM review by sending the TM checklist to the responsible TM engineer within six months af ter a TM was installed.
This would alert the TM engineer that a TM revier was forthcoming and woulo need to have a review by the end of the 12 month period following installation. The requirement for only a yearly review to be performed af ter the TM was installed was not clearly specified in A0 5-8, Revision 4. Step 4.11.1.
The procedure was not meant to require a six month TN review.
PCE did miss the yearly TM review requirement by 21 days for TM 88-011 and by 12 days for TM 88-004 during the 1988-89 rev4.-w cycle. The failure to perform theWe TM reviews on schedule constituted a failure to comply with the requirement of procedure A0 5-8.
'l 2.
Corrective steps that have been taken and the results achieved.
A review of all outstanding TMs was performer As a result of this review, TM 89-007 was also found to be outsioe of the intent of an annual review. A review of this TM has been initiated.
TM 88-004 and TM 88-011 were reviewed October 18, 1989 and December 19, 1989 respectively.
Corrective steps that will be taken to avoid further violctions.
3.
(
A0 5-8 Section 4.11.1 will be revised to clarify that a TM review shall be completed on a yearly basis.
This revision will be completed by July 19, 1990, i
i L
Trojan Nuclear Plant Document Control Desk Docket 50-344 April 4, 1990 License NPF-1' Page 11 of 12 t
4.
Date when full compliance will be achieved.
}
Full compliance will be achieved following the review of outstanding TM 89-007 by April 10, 1990.
For D.2 1.
Reason for the violation.
The reason for the violation is personnel error, failure to follow I
the procedure. The use of white-out is not to be used on QA records.
l 2.
Corrective steps that have been taken and the results achieved.
f An NCAR was initiated February 9,1990 to document the occurrence.
j The restoration section of TM 89-072 that was altered with white-out was corrected.
3.
Corrective steps that will be taken to avoid further violations.
PCE will issue a lessons learned memorandum to all Trojan employees from the Plent General Manager reiterating the requirements of A0 7-1, Step 4.7.1, " Erasures and white-out shall not be used on QA records." This memorandum shall be issued by April 15, 1990.
l 4.
Date when full compliance will be achieved.
r o
Full compliance was achieved February 9,1990 when the altered section of TM 89-072 was corrected.
i for D.3 1.
Reason for the violation.
The reason for the violation is personnel error, failure to follow the procedure. A memorandum identifying the closure of TM 87-076 was provided to Plant Systems Engineering August 8,1989.
The TM was not properly closed as required by procedure.
2.
Corrective steps that have been t.aken and the results achieved.
j The TM tags associated with TM 87-076 were removed February 5, 1990.
An NCAR was initiated February 9,1990 to evaluate the nonconformanes I
and make corrective action recommendations.
Trojan Nuclear Plant
'Jocuenent Control Desk Docket 50-344 April 4, 1990 License NPT-1 Fage 12 of 12 l
3.
Corrective steps that will be taken to avoid further violations.
Plant Systems Engineering will review the requirements of A0 5-8 in branch meetings to ensure the requirements of the procedure are understood.
These reviews will be complete by April 30. 1990.
l Plant System Engineering will review previously submitted as-built cover letters and turnover checklists to ensure restored TM tags have been removed and discarded.
This review will be complete by l
August 30, 1990.
6.
The date when full compliance will be achieved.
Full compliance was achieved February $. 1990 when the TM tags for TN 87-076 were removed and discarded.
bsh 4l-7W.0390 i
i f
5
)
i i
i o
1