ML20214F577

Responds to NRC Re Violations Noted in Insp Repts 50-344/86-10,50-344/86-24 & 50-344/86-32.Corrective Action: New QA Training Procedure Developed.Payment of Proposed Civil Penalty in Amount of $50,000 Also Encl

ML20214F577
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/14/1986
From:	Linblad W PORTLAND GENERAL ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
TAC-61523, NUDOCS 8611250354
Download: ML20214F577 (4)

Text

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. - DCS POllTLANn GENElf AL ELECTitIC CO)1PANY 121 S. W. S A L M o rJ STREET WILLIAM J. LINoBLAD PO RTLA N D. O R EGO N 97204 W , k 15031226-8875 '-  %

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November 14, 1986 ',,,

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Trojan Nuclear Plant N Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator, Region V U.S. Nucicar Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Martin:

Response to Notice of Violation and Proposed Imposition of Civil Penalty Your letter of October 15, 1986 transmitted a Notice of Violation and Proposed Imposition of Civil Penalty based upon NRC Inspection Report Nos. 50-344/86-10, 50-344/86-24, and 50-344/86-32. Attached to this letter is our response to that Notice of Violation and Proposed Impocition of Civil Penalty, and a voucher in the amount of $50,000 for payment of the Proposed Civil Penalty.

Sincerely, Attachment c: Mr. Lynn Frank, Director State of Oregon Department of Energf Mr. Steven A. Varga Director, PWR-A Project Directorate No. 3 Subscribed and sworn to before me this 14th day of November 1986.

NotaryPublicofOregof My Commission Expires: M #

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 November 14, 1986 License NPF-1 Attachment Page 1 of 3 PGE RESPONSE TO NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY I. Violation Assessed as Civil Penalty Technical Specification Limiting Condition for Operation (LCO) 3.5.2 requires in Modes 1, 2, and 3 that two independent emergency core cooling system (ECCS) subsystems be operable with each subsystem comprised in part of a residual heat removal (RHR) pump and an operable flow path.

Technical Specification LCO 3.0.3 requires that when a Limiting condition for Operation and/or associated action requirements cannot be satisfied, the reactor be placed in at least hot standby within one hour.

The operability for the RHR system flow path for a Loss-of-Coolant Accident is represented in the Trojan Updated Final Safety Analysis Report (FSAR), Section 6.3 which shows that RHR flow will bo injected into all four cold legs of the Reactor Coolant System.

Contrary to the above, on March 31, 1986 while in Mode 1 for one hour and 10 minutes, portions of two ECCS subsystems (the RHR system) were inoperable when Valve MO-8809A was closed. With Valve MO-8809A closed, the flow path for both trains of RHR cold leg injection was such that RHR flow to only two of the four Reactor Coolant System cold legs would have been achieved.

This-is a Severity Level III violation (Supplement I). ,

(Civil penalty - $50,000) L PCE Response

??" acknowledges that on March 31, 1986, while in Mode 1, with Valve MO-8809A closed, portions of two ECCS subsystems were inoperable for 10 minutes longer than that permitted by Technical Specification LCO 3.0.3. The reason for the violation has been determined to be the unavailability of accurate and detailed design basis documents. As such, the specific requirements to maintain Valves MO-8809A and B open while in Modes 1, 2, and 3 were not being implemented by the appropriate Plant Operating Procedures. Correc-tive actions that have been taken include revising Plant Operating Manual Procedures to specify appropriate cautions and warnings to ensure that Valves MO-8809A and B remain open while operating in Modes 1, 2, and 3. Other ECCS subsystems were reviewed to see if there are other valves that could be inadvertently mispositioned and likewise affect the operability of their ECCS subsystems similar to

{ Valves MO-8809A and B. This review has been completed and no other  ;

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a Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 November 14, 1986 License NPF-1 Attachment Page 2 of 3 valves were determined to be subject to the same mispositioning as Valves MO-8809A and B. However, 1dditional precautions have been added to Plant Operating Procedures to ensure that all ECCS subsystems are ma!r.tained operable in Modes 1, 2, and 3.

A design basis document effort was initiated for 12 safety-related systems at Trojan, one of which is the RHR system. Formal comple-tion of the design basis document program was expected to occur by December 31, 1986. Subsequently, it appears that some systems will not be completed until the end of April 1987. The RHR system design basis document is scheduled to be completed by February 28, 1987.

Full compliance with the Trojan Technical Specifications was achieved on March 31, 1986 when Valve MO-8809A was reopened. Full compliance was ensured by April 30, 1986, when the appropriate procedures were revised to add precautions.

II. Violation Not Assessed a Civil Penalty 10 CFR 50, Appendix B, Criterion V, as implemented by the Trojan Nuclear Quality Assurance Program, Section 5.0, requires in part that activities affecting quality be prescribed by and accomplished in accordance with documented procedures.

Maintenance Procedure MP-5-1, Pressurizer Safety Valve Inservice Test, Attachment I.B.5, Steps 6.h and 6.k, and Maintenance Request 86-2120, Work Instructions, Step 7, required a quality control inspector to witness the bolt torquing of the inlet flange of Pressurizer Safety Valve PSV-8010A in accordance with Quality Control Procedure QCP-3, Verification / Witnessing Inspections.

QCP-3,Section II, defines witnessing as, "An independent confirma-tion, by means of actual physical observation, that a condition or process complies with specified requirements".

Contrary to the above, on May 13, 1986, a quality control (QC) inspector failed to properly follow Procedures MP-5-1 and QCP-3 for the installation of the inlet flange of Valve PSV-8010A. The QC inspector failed to witness the bolt torquing process, including requirements for stretch and reference marks on the nuts and flange, and signed the inspection record to document that the inspection had been completed.

This is a Severity Level III violation (Supplement I).

PCE Response PGE acknowledges and admits this violation of the Nuclear Quality Assurance Program and implementing procedures. The reasons for the violation have been determined to be inadequate indoctrination

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 , November 14, 1986 License NPF-1 Attachment i Page 3 of 3  :

training and field supervision of contracted QC personnel. Contrib-uting causes were inadequate pen-job planning, improper implementa-tion of QC and maintenance procedures and inaccurate documentation of inspections due to carelessness and/or negligence on the part of the contracted QC inspector. Corrective steps that were taken involve the following:

A. Reinspection of cleanliness and bolt torques on PSV-8010A.

B. All work inspected by thic contracted QC inspector was either reinspected or evaluated to have been performed satisfactorily by some other means (eg, testing). All of the items reinspected were found to be acceptable.

C. The contracted QC inspector was terminated on May 15, 1986, two days after his failure to follow procedures.

D. A new Quality control Procedure, QCP-25, was developed and implemented to provide for the " Indoctrination and Training of Contracted nnd Temporary Quality Control Personnel".

Corrective steps to be taken to avoid further violations of this type include the following:

A. Surveillances of contractor QC personnel will be performed in sufficient depth and early in the outages beginning with the 1987 audit / surveillance schedule and 1987 refueling outage to provide a high confidence level that contractors are performing as expected.

B. The number of permanent PCE QC inspectors assigned to " lead" or supervisory positions will be increased to ensure contracted QC inspectors are periodically monitored for effectiveness and procedural compliance.

C. QC contractor representatives designated as " lead-men" will commence work at Trojan four weeks prior to the refueling out age for extensive training and indoctrination. The additional con-tracted QC personnel will commence work one week prior to the outage in order to complete their training and indoctrination required by QCP-25.

Although these items will not be implemented until 1987, full com-pliance with the Nuclear Quality Assurance Program and implementing

, procedures has been determined to be achieved.

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