ML20059D083
| ML20059D083 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/30/1990 |
| From: | Cross J PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9009060080 | |
| Download: ML20059D083 (13) | |
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Portland GeneralMConymiry James E. Cross Vice President, Nuclear August 30, 1990 Trojan Nuclear Plant Docket 50-344 f.lcense NPF-1 U.S. Nuclear Regulatory Conuninnion ATTW: Document Control Desk Washington DC 20555
Dear Sir:
Revision to Notice of Violat.lon (NOV)
Responsa. Inspection Report 90-07. Violation C During a review of corrective actions associated with a Notice of Violat.lon response. (Portland General Electric Company to Nuclear Regulat.ory connnission letter dated April 4,1990), it #:ould not be vertfled that the License Docurnent. Change Request (t.DCR) for Request. for Design Change (RDC)83-051, Design Change Package (DCP) 3 had been prepared as was stated.
This letter is to inform you t. hat the LDCR to correct the FSAR discrepancy noted in Appendix A, Violation C for RDC 83-051 has been init. lated and will be incorporated into Final Safety Analyals Report. Amendment.14.
A revision to our NOV response is attached.
Sincerely.
T. D. Walt for Attachment J. E. Cross c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Bare NRC Resident inspector Trojan Nuc,lga,r Plant O 4 s. :q 121 SW Salmon St. Portland, OR 97204 g o(
9009060080 900830 503/464-8897 PDR ADOCK 05000344 9
o PDC I8
Trojan Nuclear Plant Document Control Desk Docket 50-344 August 30, 1990 l
License NPF-1 Page 1 of 12 REPLY TO A NOTICE OF VIOLATION V.iolation_A Trojan Technical Specification (TTS) 3.0.3 states that:
"In the event a Limiting Condition for Operation and/or associated ACTION requirements cannot be satisfied because of circumstances in excess of those addressed 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
.i it, as applicable, in:
1.
At least HOT STANDBY 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 110T 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 SHUTDOWN 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 permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation.
Exceptions to these requirements are stated in the individual Specification."
TTS 3.5.2 requires that both trains of Emergency Core Cooling System i
(ECCS) be operable, does not specify actions if both trains are inoperable, and does not provide for exception from TTS 3.0.3 requirements.
Contrary to the above, on July 4 and 5, 1988, with the reactor in the hot 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 subsystems were disabled for up to two hours to perform survelliance 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 Operation is not applicable.
This is a Severity Level IV violation.
Responac Portland General Electric Company (PGE) acknowledges the violation.
1.
Reason for the violation.
l The reason for the violation that occurred July 4 and 5, 1988 was personnel error; failure to understand that Trojan Technical Specificatfor. (TTS) limitations on inoperable equipment do not allow entry into TIS 3.0.3 for convenience.
PGE revised POT 2-4
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4 Trojan Nuclear Plant Document Control Desk
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Imeket 50-344 August 30, 1990 License NTF-1 i
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.
l 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 POT 2-4 Section 7.6 performed on June 19, 1989 was not adequate 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.
The cause 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 voluntar/ ancry into TTS 3.0.3.
Two 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 TTS 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 i
deleting the subject test until an evaluation could be performed by l
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 additional 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 AJgust 30 1990 License NPF-1 Page 3 of 12 l
To address the issue of an inadequate technical review, a Human Performance Evaluation System (HPES) study will be performed by Performance Monitoring / Event Analysis to determine why the June 19, 1989 revision to POT 2-4, including the technical review and safety evaluation, did not discover the potential for the TTS 3.0.3 entry.
This evaluation will be complete by April 15, 1990.
4.
Date when full compliance will be achieved.
i Full compliance will be achieved by April 15, 1990 following the in-depth review of POT 2-4 for additional potential entries into TTS 3.0.3.
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Trojan Nuclear Plant Document Control Desk i
Docket 50-344 August 30, 1990 License NPF-1 Page 4 of 12 l
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 roni emergency ventilation system in the recirculation mode of operation.*
- 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 gas accident should occur..."
Contrary to the above, at approximately 1:35 p.m. on January 25, 1990, while ventilating the control room with the outside dampers open and the chlorine detection system inoperable, appropriate compensatory measures had not been established in that there was not continuous communication between the southeast access security guard and the control room.
This is a Severity Level IV Violation.
Responae l
PGE acknowledges the violation.
1.
Reason for violation.
The reason for the violation is procedural inadequacy. The compensatory actions to be taken when ventilating the control room were not adequately specified in the procedure and as a consequence, continuous communications were not maintained.
l The actual wording of the emergency TTS change and the associated compensatory measures did not specifically state that continuous l
communication would be established during control room ventilation.
Temporary Operating Instruction (01)-T-64, " Operating the Control Room HVAC Systems Until Both Chlorine Monitors are Returned to Operable Status", Revision 0 was used to control _the venting evolution.
Communications were to be established between the control room and the southeast access security gate. Should a train approach the Plant from any direction during control room ventilation, the guard on duty at the watch station would immediately contact the control room and warn of the approaching train. Ventilation was to be secured immediately regardless of the type of train approaching.
o Trojan Nuclear Plant Document Control Desk Docket 50-344 August 30, 1990 License NPF-1 Page 5 of 12 i
Normally, two guards were stationed at the southeast security access area. At the time of this event, only one guard was present to 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 Plant.
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 had passed the Plant.
2.
Corrective steps that were taken and the results achieved.
A review of this event indicated the need to explicitly require continuous communications between the control. room and the guard during control room ventilation.
Innediat. corrective action included issuing a temporary revision to 01-T-64 to require establishing continuous communications 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 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 steps that will be taken to avoid further violations.
The Nuclear Safety and Regulation Department will increase its depth of involvement in the verification of commitments made to the NRC for Technical Specification exemptions granted based upon the l
implementation of compensatory actions.
4.
Date when full compliance will be-achieved.
Full compliance was achieved January 24, 1990 with the deviativ 01-T-64 to require continuous communication between the lower guaa?
station and the control room.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 30, 1990 License NPF-1 Page 6 of 12 l
Einlation c Title 10 of the Code of Federal Regulations, Part 50.71(e)
[10 CFR 50.71(e)] states in part that:
"Each person licensed to operate a nuclear power reactor... shall update periodically... the Final Safety Analysis Report (FSAR) originally submitted as part of the l
application for the operating license, to assure that the information included in the FSAR contains the latest material developed.- This submittal shall cantain all the changes necessary to reflect information j
and analyses submitted to the Commission by the licensee or prepared by the licensee pursuant to Commission requirement since the submission of l
the original FSAR or, as appropriate, the last updated FSAR. 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 CFR 50.71(e)(4), insofar as here applicable, requires the annual submission of the required FSAR 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):
i 1.
In 1985, RDC 83-051, DCP 3. removed the boron injection tank pressure j
indication and annunciation in the control room.
2.
In 1983, RDC 76-068, DCP 2. Revision 1, modified the component cooling water surge tank pressure controls by installing hand switches.
Contrary to the above, the Plant was modified without accurately updating the FSAR 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 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 l
controls for Component Cooling Water (CCW) system surge tank 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 adjust tank preseure to bring levels back into the normal control band during operation of the makeup pumps, as required."
There are no manual push-button controls for control of CCW surge tank pressure.
This is a Severity Level V violation.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 August 30, 1990 License NPF-1 Page 7 of 12
Response
PGE 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 to fully meet the requirements of 10 CFR 50.71(e) and 10 CFR 50.71(e)(4) by not having adequate procedures in place to ensure revisions to the FSAR 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 or other license document change is required. During a Nuclear Quality Assurance Department (NQAD) audit, PGE identified an apparent problem with incorporating the design changes into the FSAR and a Nonconforming Activity Report (NCAR) was written (December 29, 1989) documenting instances where the responsible engineers did not initiate an LDCR for RDCs identified in the audit. NDP 200-1 was recognized to have an additional weakness by not having a time requirement to submit the LDCR following issuance of the DCP into the fleid.
2.
Corrective steps that have been taken and the results achieved.
NDP 200-1 was revised March 5, 1990 to require an LDCH be submitted in accordance with WDP 700-2, " Control of the Trojan Operating License and Licensing Documents", Attachment C (control of the Trojan l
Operating License and Licensing Documents, Licensing Document Change Request) within 31 days of the DCP issuance.
Update for RDC 76-068, DCp-2 (Revision 1) was incorporated into FSAR Ammendment 13 issued April 30, 1990.
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3.
Corrective steps that will be taken to avoid further violations.
l The update for RDC 83-051, DCP-3 will be included in Amendment 14 to the FSAR.
RDC 83-051 and RDC 76-068 will be reviewed for FSAR updating completeness.
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l Trojan Nuclear Plant Document Control Desk I
Docket 50-344 August 30, 1990 Licence NPF-1 kttachment I r
Page 8 of 12 Nuclear Plant Engineering will review all DCPs issued since January 1, 1988.
LDCRs will be initiatei for any design changes affecting the FSAR for updates that are needed. This review will be 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.
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.
l NDP 100-5, " 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 upon completing reviews of RDC 83-051 and RDC 76-068 and subsequent updating of the FSAR.
Any additional LDCRs generated from these reviews will be incorporated in the next available update to the FSAR.
l Trojan Nuclear Plant Document Control Desk Docket 50-344 August 30. 1990 License NPF-1 i
Pege 9 of 12 Violation _D 10 CFR 50 Appendix B, Criterion V, states in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures or drawingst of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
1.
Adminf 'rative Order (A0) $-8, Revision 4, " Temporary Modification" (TM), et.p 4.11.1, statest "The PSE Branch Manger shall direct a PSE engineer to perform a periodic TM Review when one of the following conditions exists a.
Any TM has been installed for more than six months and no TM Review has been initiated or completed DE b.
More than one year has passed since the last periodic TM Review."
Contrary to the ab:*re, the fallowing TM reviews exceeded time requirements.
Iti_ Number Installed first_ Review Day.a_ Late Secondleriev Days Late 89-072 07/13/89 28 N/A 89-058 06/19/89 53 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 inspection period (02/10/90).
2.
no 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 eesurance record, was corrected with white-out.
3.
A0 5-8, Revision 4, TM Step A.8.1, statest "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."
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Trojan' Nuclear Plant-Document Control Desk Docket 50-344 August 30, 1990-
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License-NPF-1 Page 10 of 12 l
i Contrary to the above, on January'31, 1990,- TM tags _for.TM 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 Level V violation.
1 Reasonam PGE acknowledges the violation.
For D.1 s
1.
Reason for the violation.
The reason for the violation was personne1' error, failure to follow-the' procedure.
The intent of the procedure as written was to perform l
a TM review by sending the TM checklist to the responsible TM engineer within six months after a TM was installed.
This would alert the TM engineer that a TM review.was forthcoming and would 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 after the TM was installed was not clearly specified in A0 5-8, Revision 4, Step 4.11.1.
The procedure wastnot-meant to require a six month TM review.
l-PGE 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 review cycle. The failure to perform these TM reviews on schedule constituted a failure to comply with the requirement of procedure A0 5-8.
2.
Corrective steps that have been taken and the results achieved.
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A review of all outstanding TMs was performed. As a result of this l
review, TM 89-007 was also found to be outside 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.
3.
Corrective steps that will be taken to avoid further violations.
A0 5-8, Section 4.11.1 will be rd,' sed to clarify that a TM review shall be completed on a yearly basis.- This revision will be completed by July 19, 1993.
.6 Trojan Nuclear Plant Di -Esnt Control Desk-Docket 50-344-Augus'. 30, 1990 License NPF-1 AtDachment 1 Pegl 11 of 12 1
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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 i
1.
Reason for the violation.
l The reason for the violation is personnel error, failure to follow
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the procedure. The use of white-out is not to be used on QA records.
j 2.
Corrective steps that have been taken and the results achieved.
-j An NCAR was initiated February 9, 1990 to document the occurrence.
3 The restoration section of TM 89-072 that was altered with white-out_
7 was corrected.
p 3.
Corrective steps that will be taken to avoid further violations.
PGE will issue a lessons learned memorandum to:all Trojan employees from the Plant 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..
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Date when full compliance will be achieved.
l Full compliance was achieved February 9,1990 when the altered l
section of TM 89-072 was corrected.
- For D.3 1.
Reason for the violacion.
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 taken and the results achieved.
The TM tags associated with TM 87-076 were removed February 5, 1990.
An NCAR was initiated February 9,1990 to evaluate the nonconformance-and make corrective action recommendations.
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4 Trojan Nuclear Plant' Document Control Desk j
Docket 50-344-August 30, 1990 l
License NPF-1 Page 12 of 12 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.
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 August 30, 1990..
4.
The date when full compliance will be achieved.
Full compliance was achieved February 5,-1990 when the TM tags for TM 87-076 were removed and discarded.
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