ML20055B770
| ML20055B770 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/02/1982 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20055B771 | List: |
| References | |
| NUDOCS 8207230284 | |
| Download: ML20055B770 (7) | |
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u o/ w, n o Pres e m July 2, 1982 Trojan Nuclear Plant Docket 50-344 7
License NPF-1 Mr. R. H. Engelken Regional Administrator, Region V U. S. Nuclear Regulatory Commission Creekside Oaks Office Park 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368
Dear Mr. Engelken:
Response to Notice of Violation and Proposed Imposition of Civil Penalty Your letter of June 2,1982 forwarded a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $60,000. We have reviewed the circumstances surrounding the occurrence described in the Notice of Violation and Proposed Imposition of Civil Penalty and have provided the attached responses in accordance with the instructions provided. to this letter is our response to the Notice of Violation in accordance with the provisions of 10 CFR 2.201. is our response to the Proposed Imposition of Civil Penalties requesting recon-sideration of the emount of the proposed penalty due to mitigating circum-stances in accordance with Appendix C of 10 CFR Part 2. is a revised Reportable Occurrence / Licensee Event Report.
Sincerely, us Bart D. Withers Vice President Nuclear Attachments c:
Mr. Lynn Frank, Director
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State of Oregon
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Department of Energy u U ""
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PDR ADOCK 05000344 Gu,~u c1 G
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121 SW Salmon Street Portand. Oregn 97204
ji Trojan Nuclear Plsnt R. H. Engalkan Dackat 50-344 July 2, 1982 License NPF-1 Page 1 of 4 10 CFR 2.201 RESPONSE TO NOTICE OF VIOLATION Portland General Electric Company (PGE) provides the following response to R. H. Engelken's letter to B. D. Withers dated June 2, 1982.
I NRC FINDING
" Pursuant to the NRC enforcement policy and Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42.U.S.C. 2282, PL 96-295, and 10 CFR 2.205, the particular violation and associated civil penalty is set forth below:
Facility Operating License NPF-1 states in Section 2.C(7) that, all activities to which a quality assurance program is applicable shall... be conducted in accordance with the Quality Assurance Program for Operation.
4 Criterion XVI of 10 CFR 50, Appendix B states in part, that ' Measures shall be established to assure that conditions adverse to quality, i
such as failures, malfunctions, deficiencies, defective material and equipment, and nonconformances are promptly identified and corrected'.
The Portland General Electric Nuclear Projects Quality Assurance Program for Operation, in Section 16.3.1, states that, ' Procedures are established to assure that conditions adverse to quality and the i
cause of these conditions are letermined and corrected in a timely manner'.
Trojan Nuclear Plant Quality Assurance Procedure QAP-5-1, Revision 1, (issued September 18, 1975), stated in Section III.B.2 that, ' Procedures or instructions shall be written to cover as many of the following points as necessary to easure that the activity will be satisfactorily accomplished without compromising the quality of the item:
.d.
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shall contain any precautions or limitations a person should observe to accomplish the activity'.
Technical Specification 3.8.1.1, in Action Step a, states, 'With either an offsite circuit or diesel generator set of the above required A.C.
electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirements 4.8.1.1.1.a and 4.8.1.1.2.a.5 within one hour and at least once per eight hours thereafter; restore at least two offsite circuits and two diesel generator sets to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />'.
" Contrary to the above, elfective corrective actions were not taken following the discovery in May 1977 that the train
'B' emergency diesel generator output breaker was inoperable when Preferred Instrument Bus Y24 was being 'ed from Nonpreferred Instrument Bus YO2. The design change to correct t..e deficiency was initiated but was not completed. A facility 3
Trojtn Nuclear Plant R. H. Engsiksn Docket 50-144 July 2, 1982 License NPF-1 Page 2 of 4 Standing Order was issued to address the deficiency on an interim basis, but all reference to Preferred Instrument Bus Y24 was removed in a 1981 revision. In addition, no change was made to pertinent facility procedures, nor was other corrective action taken to ensure that the identified deficiency did not result in emergency diesel generator inoperability. The consequence of this failure was that the train
'B' emergency diesel generator was inoperable during the periods November 8 through 12, 1981 (87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br />), and December 1, 1981 through January 4, 1982 (34 days). During these periods, no action was initiated to perform the specified surveillance and no steps were taken to commence a shutdown of this facility to cold shutdown conditions."
This is a Severity Level III violation (Supplement I).
(Civil penalty - $60,000).
RESPONSE
PGE acknowledges the violation of Technical Specification 3.8.1.1 in November and December 1981 and January 1982 as described above. However, PGE disagrees with the statement that ".... effective corrective actions were not taken following the discovery in May 1977 that the train
'B' emergency diesel generator output breaker was inoperable when Preferred Instrument Bus Y24 was being fed from Nonpreferred Instrument Bus YO2".
Furthermore, the NRC Notice of Violation identifies the cause of the failure as a design deficiency when in fact it was not.
Upon determining in May 1977 that the "B" emergency diesel generator breaker would repeatedly close and trip open upon demand for power from the emergency diesel generators when Preferred Instrument Bus Y24 was being supplied by its alternate power source, Nonpreferred Instrument Bus YO2, a Standing Order was written to direct the operators to declare the emergency diesels inoperable whenever any of the Preferred Instrument Buses (Yll, Y13, Y22, and Y24) were being supplied from their alternate sources, the Nonpreferred Instrument Buses (Y01 and Y02). A Request for Design Change (RDC 770-093) was also initiated to change the emergency diesel generator breaker trip circuitry. A Standing Order is a permissible mechanism to alert operators to a unique aspect of plant operation and direct them to take certain actions, in accordance with the PCE Nuclear Projects Quality Assurance Program for Operations (NPQAP/0) and Cri-terion XVI of 10 CFR 50, Appendix B.
In 1977 a Standing Order could have been a permanant administrative control; presently, Standing Orders are reviewed and updated annually. The design of the breaker control cir-cuitry was such that a problem with operability of the emergency diesel generators would have existed only if all three of the following condi-tions had eccurred:
(1) Preferred Instrument Buses Yll, Y22, or Y24 supplied bt their alternate power sources, Nonpreferred Instrument Buses Y01 or 'iO2, (2) a turbine trip / generator trip; and (3) an unsatisfactory transfer of electrical power to the offsite sources, or loss of offsite power. RDU 77-093 was initiated to eliminate the need for an Administra-tive Control, not to correct a design deficiency, and was assigned a low priority since no safety considerations were involved. The corrective action taken was adequate to prevent the occurrence reported by LER 82-01.
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Trojan Nuclear Plant R. H. Engelken Docket 50-344 July 2, 1982 License NPF-1 Page 3 of 4 On November 21, 1980, a Training Information Bulletin (TIB) was issued to i
explain why the emergency diesel generators should be declared inoperable when their preferred instrument buses are powered from their alternate supply. There was an error in the analysis which provided the basis for the TIB that implied that the electrical circuitry for the "B" emergency
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diesel generator breaker was symmetrical with the "A" emergency diesel generator breaker electrical circuitry. In light of the information l
contained in the Training Information Bulletin published on November 21,
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1980, the Standing Order was revised incorrectly to state that the j
emergency diesel generators would be inoperable only if Preferred Instru-l ment Buses Y11 or Y22 were powered from their alternate power supplies and not if Preferred Instrument Buses Y13 and Y24 were. It was later determined that the "B" emergency diesel generator power supply to its breaker and protective relays was not the same as for the "A" emergency diesel generator. The "B" emergency diesel generator depended on both Preferred Instrument Buses Y22 and Y24, whereas "A" emergency diesel generator depended only upon Preferred Instrument Bus Yll. Therefore, the cause of the occurrence reported in LER 82-01 was the analytical error that led to the incorrect Training Information Bulletin.
As a result of the revision to the Standing Order, when the inverter supplying bus Y24 failed, leaving Y24 powered from its backup power supply, "B" emergency diesel generator was not declared inoperable.
Thus, "B" emergency diesel generator was inoperable for 87 hours0.00101 days <br />0.0242 hours <br />1.438492e-4 weeks <br />3.31035e-5 months <br /> in November 1981 and 34 days from December 1,1981 through January 4,1982 and no steps were taken during those periods to perform the specified surveillance or commence a shutdown of the facility to cold shutdown conditions.
i Upon discovery of this occurrence on January 16, 1982, a new Standing Order was issued to indicate that the emergency diesel generator for train "A" must be declared inoperable should Preferred Instrument Bus Yll be powered from its alternate source, Y01, and that the emergency diesel generator for train "B" must be declared inoperable should either Preferred Instrument Bus Y22 or Y24 be powered from its alternate source, YO2. Additionally, a revision to Operating Instruction 01-1-7, "120V AC Preferred Instrument Bus Operation", was initiated to incorporate these i
precautions. A Request for Design Change, RDC 82-13, was initiated to incorporate the design change originally proposed in RDC 77-093 and, additionally, change the power supply for the diesel generator automatic start relay and the diesel generator output circuit breaker automatic close relay from the preferred instrument buses to the respective train de buses. As a result of these design changes, the emergency diesel generators are independent of any failures of a Preferred or Nonpreferred Instrument Bus. These design changes were completed during the 1982 refueling outage and the system has undergone its functional testing and been declared operable. The Standing Order will once again be revised to reflect the independence of the emergency diesel generators from either the Preferred or Nonpreferred Instrument Buses and 01-1-7 will again be revised to reflect this design modification. These procedural changes will be made prior to returning the Plant to power operation.
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Trojtn Nuclear Plcnt R. H. Engsiken Dockst 50-344 July 2, 1982 License NPF-1 Page 4 of 4 In addition, Training Information Bulletins are now required to undergo a more thorough level of review and approval prior to their distribution and use. It has been emphasized that Training Information Bulletins have no operational significance, but are to be used to amplify and provide more detailed and backup information and to provide the basis for cer-tain operations.
Prior to the time this problem was identified a comprehensive review of RDCs which had not been worked was initiated to review the priority assigned to each and to eliminate any which were no longer required.
This review has been completed resulting in an up-to-date priority for those items yet to be done. No situations were found where RDCs with safety significance had been unduly delayed.
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CAZ/41ml0.2A18
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TrojIn Nucisar Plcnt R. H. Engelks:
Docket 50-344 July 2, 1982 License NPF-1 Pag
- 1 of 2 10 CFR 2 RESPONSE TO PROPOSED IMPOSITION OF CIVIL PENALTIES Portland General Electric (FGE) has reviewed the Proposed Imposition of Civil Penalties and feels that the proposed amount is not consistent with the nature of the occurrence. Therefore, PGE requests that the civil penaltiec be reduced in accordance with Section IV.3. of 10 CFR Part 2, Appendix C for the following reasons:
1.
Prompt Identificatioc and Reporting. Upon identification of the specific dates of this occurrence on January 16, 1982 (Saturday), PGE took immediate action to report the event to the NRC at the first opportunity (the next working day) on January 18, 1982. The event 1 was reported orally to the Onsite Regional Inspector, to the Regional Headquarters within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by a follow up letter, and formally to the Regional Administrator by means of a Licensee Event Report.
It is therefore requested that the civil penalty be appropriately adjusted because of PGE's prompt reporting of the occurrence.
2.
Corrective Action to Prevent Recurrence. PGE immediately took corrective action by means of a Standing Order to prevent recurrence of this event and then subsequently followed up with a formal proce-dure change and a design modification. Either the administrative control or design modifications would have been satisfactory to solve the problem. The design modification was accomplished within approxi-mately 6 months of the discovery of this occurrence.
It is requested that the proposed civil penalty be reduced to account for this unusually prompt and extensive corrective action.
3.
Enforcement History. PGE does not have a history of extensive enforcement actions. The proposed imposition of civil penalties does not reflect the Company's consistent commitment toward safe and efficient operation of the Trojan Nuclear Plant. Although the proposed civil penalty was not increased for Enforcement History, it is requested that this factor be considered in the reduction of the proposed civil penalty.
4.
Prior Notice of Similar Events.
It appears that the base civil penalty was increased by 25 percent because of this item, IV.B.4 of 10 CFR 2, reflected by the statement, ".... the penalty is increased 25 percent because the licensee became aware of the potential inoper-ability problem in 1977 and did not take effective corrective action."
As pointed out in Attachment 1, Response to Notice of Violation, this was not the case. PGE did take corrective action in 1977, and that action was sufficient to prevent an occurrence reported in LER 82-01
Trojan Nuclect Plant R. H. Engalk:n Dockat 50-344 July 2, 1982 License NPF-1 Page 2 of 2 had it not been incorrectly changed in 1980. The corrective action taken in 1977 was in compliance with Criterion XVI of Appendix B to 10 CFR 50 and the PCE Nuclear Projects Quality Assurance Program for Ope rations. It is requested that the 25 percent increase be reevalu-ated and eliminated in light of this information.
5.
Multiple Occurrences.
Item IV.B.5 of 10 CFR 2 is not a factor in the Proposed Imposition of Civil Penalties, either in the assess-ment or request for a reduction, inasmuch as it is applicable only,
".... where NRC identifies the violation, or for violations associa-ted with self-disclosing incidents." The occurrence associated with LER 82-01 did not fall into either of those categories.
If the proposed civil penalty was increased by 25 percent because of the duration of the violation, as discussed in separate paragraphs of 10 CFR 2,Section IV.B., the safety significance should be considered.
When the "B" emergency diesel generator was inoperable, the "A" emergency diesel generator was available and ready to support needed operation, except for those two isolated cases identified in LER 82-01.
The "B" emergency diesel generator would start automatically and could have had its breaker maintained shut by means of manual action should it have been necessary. At no time were the emergency diesel generators needed to support operations or accident mitigation.
The Notice of Violation suggested potential deficiencies in PGE's implementation of its Quality Assurance Program inasmuch as the deficiency was originally identified in 1977 but not actually corrected until 1982.
This was not the case. The problem was not completely identified in 1977. However, the corrective actions taken in 1977 were conservative and consistent with the requirements of 10 CFR 50.
The Plant was not being operated unsafely.
An administrative control (Standing Order) properly identified under what conditions the emergency diesel generators should be considered inoperable. It was not until 1980, when the Stand-ing Order was incorrectly changed due to an erroneous Training Informa-tion Bulletin, that the likelihood of an occurrence, as reported in LER 82-01, was increased.
In this case, as in all cases, deficiencies in design, training, or operator knowledge are immediately responded to and corrected, par-ticularly when they have a potential impact upon the safe operation of the Trojan Nuclear Plant. It is requested that this also be considered in mitigation of the civil penalty.
GAZ/41m10.2A21