ML20235U656
| ML20235U656 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/02/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8903090311 | |
| Download: ML20235U656 (6) | |
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Portland General ElectricCoipiny r -E David W. Cockfield V7ce President, Nuclear March 2, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk l
Washington DC 20555
Dear Sir:
Reply to Notice of Violation Your letter of January 31, 1989 transmitted a Notice of Violation associated with Nuclear Regulatory Commission (NRC) Inspection Report No. 50-344/87-18.
Attached is'our reply to that Notice of Violation.
Sincerely, y
Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission
.Mr. William T. Dixon State of Oregon Department of Energy i
Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 8903090311 890302
[h0(3 PDR ADOCK 05000344 O
PDC I \\
121 S.W Samn Speet, Portal Oregon 97204 l
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Trojan Nuclear Plant Document Control Desk Docket 50-344 Attachment License NPF-1 March 2, 1989 j
Page 1 of 5 l
l REPLY TO A NOTICE OF VIOLATION VIOLATION A Trojan Technical Specification 6.8.1 required that written procedures shall be established, implemented and maintained covering the applicable activities recommended in Appendix A of Regulatory Guide 1.33, November 1972. Regulatory Guide 1.33, Appendix A recommends " Procedure Adherence" as a written procedure to be implemented.
In partial implementation of this requirement, Trojan Procedure AO-4-2, Revision 14, "Use of Procodures" in Section 3.11 requires that the proco-dures contained in the Plant Operating Manual shall be followed in the performance of Plant activities. The Plant Operating Manual's Operating Instruction (OI) 5-2, " Safety Injection", Section 3.0, " Sluicing Accumu-lators", required sluicing to be performed using the sample lines.
Contrary to the above, on May 12, 1987 and again on May 23, 1987, borated water was sluiced between the "A" and the "D" safety injection accumu-lators using a fill line rather than the required sample line.
This is a Severity Level IV Violation (Supplement 1).
Reply to Violation A Portland General Electric (PCE) Company acknowledges the violation.
1.
Ecason for Violation:
The reason for this violation is personnel error in not following established Plant procedures. OI 5-2 contains a procedure for transferring water between safety injection accumulators. The procedure calls for the transfer to be done using the sample lines which interconnect the accumulators.
On May 12 and 23, 1987, the Plant was shut down for the annual refueling outage and the sample lines were tagged-out for maintenance. Operations personnel needed to transfer water between accumulators and determined that an alter-nate interconnecting path existed through the fill lines.
This alternate path was used on May 12 and 23 to transfer water between the "A" and "D" accumulators without processing a procedure devia-tion or revision.
2.
Corrective Steps Taken and Results Achieved:
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The evaluation of the problems experienced with the safety injection accumulator fill line identified several operational areas where improvements were required. These were summarized in an Operational l
Trojan Nuclear Plant Document Control Desk Docket 50-344 Attachment License NPF-1 March 2, 1989 Page 2 of 5 Improvement Plan that was forwarded to the U.S. Nuclear Regulatory Commission, Region V on June 16, 1987. As part of the plan, the need for immediate improvement in procedure compliance was emphasized to Nuclear Division managers in a meeting with the Vice President, Nuclear on June 8, 1987.
Subsequent meetings with all division personnel were held between June 9 and June 15, 1987 to discuss procedure compliance and other lessons learned from these events. The focus on procedure compliance has continued, with this area still identified as a key division issue and included in our
" Conduct of Nuclear Plant Operation" guidance provided to emplo-yees. Although subsequent improvements have been noted, continued management attention to this area is provided to ensure full compliance.
3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
Accountability of the workers and their managers and supervisors for procedure compliance continues to be reinforced. This has been accomplished through periodic meetings, general employee training, and increased management involvement in day-to-day Plant activities.
4.
Date When Full Compliance Will Be Achieved:
The Plant is presently in full compliance.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 Attachment License NPF-1 March 2,1989 Page 3 of 5 VIOLATION B Title 10 to the Code of Federal Regulations, Part 50, Appendix B,Section V, " Instructions, Procedures and Drawings" reads, " Activities affecting quality shall be prescribed by documented instructions, proco-dures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Portland General Electric Nuclear Division Procedure (NDP) 600-1,
" Control of Nonconforming Materials, Parts and Components", Section 5.4, "QA Operations Branch Actions", Part C, stated, " Ensure the nonconforming items are identified and controlled to prevent their inadvertent use by use of QC hold tags and/or the necessary danger and caution tags as determined appropriate by the QA Operations' Branch Manager."
Contrary to the above, af ter the rupture of the "A" Safety Injection accumulator fill line on May 12, 1987, adequate controls were not established in that the fill line was used again to sluice borated water from the "A" to the "D" accumulator and a second rupture of the "A" accumulator fill line occurred on May 23, 1987.
This is a Severity Level IV Violation (Supplement I).
Reply to Violation B PGE acknowledges the violation.
1.
Reason for Violation:
The reason for the violation was personnel error.
Following the accumulator fill line failure on May 12, 1987, Nonconformance Report (NCR)87-163 was initiated documenting the failed condition of the pipe.
At the time of the failure, Quality Control (QC) hold tags were seldom used for controlling defective installed equipment and the QA Operations Branch Manager relied on the Plant's use of danger tags. However, no controls were placed on the release of the danger tags to ensure that the equipment NCR evaluation was complete and the cause of the failure was identified and corrected.
As a result, the danger tags were removed when the fill line repair was comple-ted, even though the NCR was still being evaluated.
Subsequently, the fill line was again improperly used to transfer water between accumulators and a second failure occurred.
2.
Corrective Steps Taken and Results Achieved:
After the second failure of the "A" accumulator fill line on May 23, 1987, QC hold tags were used to quarantine the valves and piping in the accumulator fill line. The final QC hold tag was not removed
Trojan Nuclear Plant Document Control Desk
- Docket 50-344 Attachment License NPF-1 March 2, 1989 Page 4 of 5 until after the NCR associated with the two failures was disposi-
-tioned and the cause of the failures was understood and corrected.
The controls used after the second failure were effective and no-further failures occurred.
As follow-up corrective action, Nonconforming Activity Report (NCAR) P87-074 was issued on June 16, 1987. This NCAR identified-the failure to properly control the accumulator fill line after the first pipe break. The resolution of the NCAR was.a joint effort by Quality Assurance (QA) and Trojan Operations to improve the use of QC hold tags to ensure that. adequate evaluations and corrective actions have been completed prior to returning equipment to service. QA tuok the lead in developing a revision to Nuclear Division Procedure (NDP) 600-1.
In the interim, QC hold tags were used extensively to control significant equipment and component non-conformances.
Examples of where they were used include:
temporary covers on steam generator feedwater nozzles, a leaking service water line to cable spreading room coolers, a cracked seat in the main steam root valve to the turbine-driven auxiliary feedwater pump, defective snubbers and hangers in the Plant, and a potential defect in the pressurizer surge line.
On October 5,1988, Revision 5 to NDP 600-1 was approved, which implemented the use of a new tag specifically designed for NCRs.
Quality Assurance actions relative to the use of these NCR tags are contained in Paragraph 5.4.C of the revised procedure as'follows:
" Consult with the Shift Supervisor and take action to hang NCR tags on the nonconforming items when deter-mined appropriate. Additional controls such as use of operations tagout/ clearances or safety-related equip-ment outages may be used in conjunction with NCR tags.
Enter on the tag if continued use is acceptable and any necessary precautions and limitations. Add addi-tional information necessary to control the item or prevent inadvertent use."
As a result of this procedure revision, the control of systems with installed nonconforming material now includes the use of NCR tags issued and cleared by QA.
3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
The corrective action instituted in June 1987 has proven effective in controlling operation of systems and equipment following major failures by defining appropriate precautions and limitations prior to returning them to service. Following Revision 5 to NDP 600-1, the use of NCR tags in the Plant has become an accepted practice.
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-0 f8 Trojan Nuclear Plant Document Control Desk l
l Docket 50-344 Attachment License NPF-1 March 2, 1989 Page 5 of 5 l
llowever, as part of an overall effort to improve our corrective action programs, NDP 600-1 has been further improved to more expll-citly describe when an NCR must be initiated and when NCR tags must be used to control the equipment or system until the failure mech-anism has been analyzed and understood.
4.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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