ML20198A160

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $80,000.Violation Noted:Control Room Emergency Ventilation Sys Inoperable & Not Independent Due to Excessive Makeup Flow Rate in Train CB-1B

ML20198A160
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/14/1986
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20198A139	List: ML20198A135 ML20198A160
References
EA-86-054, EA-86-54, TAC-61289, NUDOCS 8605200349
Download: ML20198A160 (2)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY Portland General Electric Company Docket No. 50-344 Trojan Nuclear Plant License No. NPF-1 EA 86-54 During an NRC special inspection conducted during the period of January 28 -

30, 1986 and February 24 - 28, 1986, a violation of NRC requirements was identified. In a'.cordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to 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 violation and associated civil penalty are set forth below:

Technical Specification Limiting Condition for Op.. .) 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 ctates 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 rem 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 REM beta skin dose. These values are industry recognized limits and are reiterated in the NRC 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 a condensate drain and housing opening) for unfiltered air inleakage (140 cfm) and the excessive makeup flow rate (450 cfm) in l

train CB-1B would cause, under design basis accident conditions, a thyroid

! dose of 195 REM (significantly exceeding the dose equivalent limit of .

l 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.

Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company is hereby required to submit to the Director, Office of Inspection and i Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555 with a l copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region V, within 30 days of the date of this Notice a written statement or explanation, including: (1) admission or denial of the alleged violation, (2) the reascns for the violation if admitted, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps wnich will l l 8605200'349 860514 PDR '

ADOCK 05000344 O PDR

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,. Notice of Violation l be taken to avoid further violation, and (5) the date when full compliance will l be achieved. If an adequate reply is not received within the time specified in this Notice, the Director, Office of Inspection and Enforcement, may issue  !

an crder to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. l Consideration may be given to extending the response time for good cause

{ shown. Under the authority of section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 2.201, Portland General Electric Company may pay the civil penalty by  ;

letter addressed to the Director, Office of Inspection and Enforcement, with a l check, draft, or money order payable to the Treasurer of the United States in the amount of Eighty Thousand Dollars ($80,000) or may protest imposition of the civil penalty in whole or in part by a written answer addressed to the Director, Office of Inspection and Enforcement. Should Portland General Electric Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an orde* imposing the civil penalty in the amount proposed above. Should Portland General Electric Company elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalty, such answer may: (1) deny the violation listad in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error ,

in this Notice, or (4) show other reasons why the penalty should not be imposed."

In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty.

In requesting mitigation of the proposed penalty, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201 but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g., citing page and paragraph numbers) to avoid repetition. Portland General Electric Company's attention is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty. '

Upon failure to pay any civil penalty due which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this

matter may be referred to the Attorney General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to section 234c of the Act, 42 U.S.C. 2282.

E NUCLEAR REGULATORY COW 1ISSION John B. Martin Regional Administrator Dated a Walnut Creek, California, '

this day of May 1986.

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