ML20195B321

Responds to 860514 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $80,000 Re Control Room Emergency Ventilation Sys.Cooler Housing Seam Properly Sealed

ML20195B321
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/22/1986
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8605290194
Download: ML20195B321 (6)

Text

hN m sammu N M M COIi(JallY Dart D Wens Vce Prew" May 22, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek CA 94596

Dear Mr. Martin:

Response to Notice of Violation and Proposed Imposition of Civil Penalty (NRC Inspection Report No. 50-344/86-06)

Your letter of May 14, 1986 forwarded a Notice of Violation and Proposed Imposition of Civil Penalty concerning the control room emergency ventila-tion system. In accordance with 10 CFR 2.201, Attachment 1 is our response to the Notice of Violation and Proposed Imposition of Civil Penalty. In your letter, you identified a concern that weaknesses may exist in certain areas regarding the operation of the Trojan Nuclear Plant. Attachment 2 is a response to those concerns. Also attached is a voucher for $80,000 for payment of the Civil Penalty.

( Sincerely, e

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n-s a Bart D. Withers N l Vice President _ . ,

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State of Oregon Department of Energy Subscribed and sworn to before me this 22nd day of May 1986.

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My Commission Expires: W&[ '

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 May 22, 1986 License NPF-1 Attachment 1 Page 1 of 3 10 CFR 2.201 RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY

Violation

Technical Specification Limiting condition for operation 3.7.6.1 requires when the reactor is in Modes 1, 2, 3, and 4 that two independent control room emergency ventilation systems shall be operable. The bases for this Technical Specification states in 3/4.7.6, "The operability of this system in conjunction with control room design provisions is based on limiting the radiation exposure to personnel occupying the control room to 5 ram or less whole body, or its equivalent. This limitation is consistent with the requirements of General Design Criteria 19 of Appendix 'A', 10 CFR 50." The equivalent radiation dose of 5 rem whole body is 30 rem thyroid and 30 ram beta skin dose. These values are industry recognized limits and are reiterated in the NRC's Standard Review Plan, Revision 2, Section 6.4, Paragraph II.6.

Contrary to the above, on February 24, 1986, and for an indeterminate period of time, possibly since initial plant operation, the control room emergency ventilation systems (CB-1) were inoperable and were not independent because:

1. Pathways (through the condensate drain and housing opening) for unfiltered air inleakage (140 cfm) and the excessive makeup flow rate (450 cfm) in Train CB-1B would cause, under design basis accident conditions, a thyroid dose of 195 rem (significantly exceeding the dose equivalent of 30 rem) and a skin dose of 30.6 rem (slightly exceeding the dose equivalent limit of 30 rem).

2. The two control room emergency ventilation systems (CB-1A and CB-1B) were not independent in that a cross connection existed which allowed air flow between each system.

This is a Severity Level II Violation (Supplement I).

Civil penalty - $80,000. ,

Response

PGE acknowledges and admits the violation described above and as reported in LER 86-02. The pathway for unfiltered makeup air inleakage of approximately 100 cfm into the control room was due to a gap in the CB-1B cooler housing seam. The cause of the gap was personnel error in that the duct casting was broken and had been improperly repaired. This gap was repaired by hard casting on February 24, 1986, the same day it was discovered. The excessive makeup air flow rate of 450 cfm in CB-1B was attributed to the flow balancing damper position having been incorrectly

Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 May 22, 1986 License NPF-1 Attachment 1 Page 2 of 3 set during preoperational testing. The flow rate was lowered to the design value of 150 cfm on February 28, 1986. The cross-connected condensate line, which allowed approximately 40 cfm of unfiltered air inleakage, was attributsd to a design deficiency from initial construc-tion. The cross-connected drain lines were separated and valves were installed to prevent unfiltered inleakage on February 27, 1986, the day-of discovery.

The corrective actions that have been taken were to properly seal the gap

'in the cooler housing seam, properly set the flow balancing damper posi-tion in CB-1B, and temporarily install valves in the drain lines from the coolers. These corrective actions immediately brought the control room emergency ventilation system into compliance with regard to the specific items noted in this violation. All of those corrective actions were completed either on the day of discovery or within two or three days following.

The issue of control room habitability continues to receive the highest attention. In that regard, PGE commenced a thorough investigation and evaluation of the CB-1 system. To date, several problems have been identified resulting in numerous design and procedure changes to improve control room habitability. These changes include, but are not limited to, the following (identified problems are also described):

1. An extensive program of identifying and sealing control room boundary leaks (leaks have been found above the control room door as well as through incompletely closed dampers).

2. Installation of permanent instrumentation for measuring the differential pressures between the control room and surrounding areas (pressurization of the control room to 1/8-in, water pressure to meet the Technical Specification limit may not be obtained without design changes and probably was not met by previous testing).

3. Installation of makeup air duct flow measurement ports (makeup air flow had not been measured).

4. Revisions to periodic operating tests, periodic engineering tests, operating instructions, off-normal instructions, periodic instrument and control tests, and emergency instructions related to control room habitability (other Control Building HVAC systems were not properly addressed in procedures to preclude their interference with CB-1).

A complete description of the corrective actions taken or being taken for in the control room emergency ventilation system can be found in our letter of May 19, 1986, to the Director of Nuclear Reactor Regulation (Attn: Mr. Steven A. Varga).

Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 May 22, 1986 License NPF-1 Attachment 1 Page 3 of 3 Full compliance with current regulatory requirements is expected to be achieved prior to startup from the 1986 refueling outage. In the event that significant design changes are required to fully comply with regulatory requirements, we will apprise you of any schedule changes.

BDW/CAZ/BLK/mr 0572P i

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Trojan Nuclear Plant ,

Mr. John B. Martin Docket 50-344 May 22, 1986 License NPF-1 Attachment 2 Page 1 of 2 RESPONSE TO NRC CONCERNS NRC Concerns:

"The violation and it's duration, which may have been since initial plant operation, reveals weaknesses in: (1) The conduct and documentation of technical work at Trojan; (2) the knowledge and understanding of your Operations and Engineering personnel regarding the actual plant con-figurations; and, (3) the thoroughness of audits conducted by Quality Assurance personnel. In addition, weaknesses existed in the surveillance testing procedures for the control room emergency ventilation system, the most significant of which involved positioning the makeup air dampers and determination of the proper makeup flow rate. We note that this viola-tion is the latest in a series of problems which has included escalated enforcement that have occurred over the past few years, indicating a need for you to review and implement more effective controls to ensure that NRC requirements are satisfied".

Response

Problems with the control room emergency ventilation system are attributed to failure to install, maintain, test, and operate this system in accor-dance with the design and safety analysis. In addition, the Updated Final Safety Analysis Report contained inaccurate and contradictory statements concerning certain assumptions that were made in the safety l analysis for this system.

l

! Because of a PGE concern that problems with the control room emergency ventilation system may not be unique to only that system, and because problems have occurred during the past year with other systems, an l organized program has been established to investigate and correct any weaknesses that exist.

l This program involves the following:

1. System design basis documents will be prepared for 12 identified j safety-related systems previously discussed with NRC Region V to l assure that the design bases are well understood and documented in an easily-accessible manual. During preparation, the Updated FSAR will be reviewed for consistency. This will be completed by the end of 1986, and any associated FSAR changes made by July 1, 1987.

I l 2. System description documents will be reviewed by the Plant System Engineers and Plant Training personnel to assure that details of the design are well understood by those who operate, maintain, and test the systems. The reviews will be coordinated with scheduled work on Item 1 above, for expeditious attention and completion by the end of the first quarter of 1987.

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'. o Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 May 22, 1986 License NPF-1 Attachment 2 Page 2 of 2

3. Plant Systems Engineers will expeditiously complete walkdowns/

checkouts of their applicable safety systems, and will complete reviews of the system design bases documents, FSAR, system descriptions, technical manuals, system drawings, and maintenance, operating, and test procedures to assure that the systems are being maintained, tested, and operated in accordance with the design and safety analysis. Verification walkdowns/ checkouts and reviews will be commenced following completion of the design basis documents and will be completed by the end of 1987. In addition, selected systems will be audited by Quality Assurance in 1986 and 1987 following completion of the system reviews to provide an appropriate level of confidence that the problem of properly Laplementing'the design and safety analysis into operations is resclved.

The recent change in the organization and management of the QA Department has resulted in some major shifts in emphasis. One of these changes has been the development of a much more critical and questioning approach to auditing the adequacy of compliance to the Technical Specifications and FSAR commitments. These audits now are evaluating the implementing procedure against the corresponding Technical Specification and FSAR section, rather than just verifying that the procedure is completed and followed. A determination is made as to whether the procedure actually tests or verifies the Technical Specification and FSAR requirement. This methodology is ongoing and will be further emphasized in future audits.

BDW/JWL/GAZ/mr 0572P

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