ML20235Z787

Discusses Insp on 860318-0428 & Two Special Insps on 860513- 0612 & 860804-14 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty

ML20235Z787
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/15/1986
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Withers B PORTLAND GENERAL ELECTRIC CO.
Shared Package
ML20235Z789	List: ML20235Z787 ML20236A011
References
EA-86-113, TAC-3399, TAC-42502, TAC-61405, TAC-61523, TAC-64233, TAC-65291, TAC-6596, TAC-6663, TAC-7329, TAC-7721, NUDOCS 8710210318
Download: ML20235Z787 (3)

Text

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[pra m UNITED STATES j'

NUCLEAR REGULATORY COMMISSION o

i REGION V

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1450 MARIA LANE, sulTE 210 WALNUT CREEK.CAllFORNIA OCT 151986

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{[fd Docket No. 50-344 License No. NPF-1 EA 86-113 Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204 s

Attention:

Mr. Bart D. Withers Vice President - Nuclear Gentlemen:

Subject:

NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-344/86-10, 50-344/86-24, AND 50-344/86-32) 1 This refers to the routine inspection conducted during the period March 18 -

l April 28, 1986 and to two special inspections conducted May'13 - June 12, 1986 and August 4 - 14, 1986 of activities authorized by NRC License NPF-1 for the Trojan Nuclear Power Plant.

Two violations of NRC requirements were identified by NRC inspectors during the inspections and the results of these inspections were sent to you by letters dated May 16, July 1, and August 20, 1986, respectively.

The violations involved the inoperability of the Residual Heat Removal (RHR) system and an unacceptable quality control inspection conducted during the installation of a pressurizer safety valve.

Enforcement conferences were held with you and members of your staff on July 9, 1986 at i

your offices in Portland, Oregon and on September 5, 1986 at our offices in Walnut Creek, California, to discuss the violations, the root causes of these violations, your corrective actions, and the NRC enforcement policy.

Violation I in the enclosed Notice of Violation and Proposed Imposition of Civil Penalty (Notice) involves the inoperability of one of the emergency core cooling system (ECCS) subsystems.

On March 31, 1986, the flow path for RHR system cold leg injection to two of the four reactor coolant system loops was isolated for one hour and ten minutes in violation of technical specification requirements.

This violation appears to be the result of an incomplete under-standing of the safety system design bases by your plant staff, a topic previously discussed with you in a March 27, 1986 enforcement conference involving the control room emergency ventilation system.

Although we recognize that your actions to correct the underlying causes of the violations involving control room emergency ventilation system were in progress at the time that the circumstances described in Violation I occurred, this is another example of a violation that we consider significant.

This violation emphasizes the importance for you to expedite the programs already initiated to establish design basis documents with accurate system descriptions and to CERTIFIED MAIL RETURN RECEIPT REQUESTED B710210318 861015 PDR ADOCK 05000344 G

PDR

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Portland General Electric Company 2

0 CI 151980 l

1 assure that your plant staff understands system design bases to prevent the recurrence of similar types of violations.

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Violation II in the enclosed Notice involves an instance of an incomplete inspection by a contract quality control (QC) inspector.

On May 13, 1986,

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an NRC inspector observed that a QC inspector failed to properly witness the j

torquing of the bolts on the inlet flange for a pressurizer safety valve as prescribed by the established procedures.

Although the QC inspector was in j

the work area, the '}C inspector was not actually witnessing the bolt torquing l

process.

However, apparently because of carelessness and a lack of attention to detail, the QC inspector signed the inspection record to indicate that the witnessing of the bolt torquing had taken place.

Upon learning of this problem, plant personnel took prompt and extensive corrective actions consisting of the immediate suspension of the QC inspector and subsequent investigation, reinspection and evaluations of the individual's work.

As discussed in the July 9, 1986 enforcement conference, Portland General Electric Company management should continue to be alert to conditions that contributed to this violation, including supervision of employees, adherence to established procedures, and training of personnel.

]

To emphasize the importance of ensuring that plant personnel understand the design basis operation of systems and that quality control personnel conscien-tiously perform their duties, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Fifty Thousand Dollars ($50,000) for the violations described in the enclosed Notice.

In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy),

each of the violations described in the Notice have been classified as a Severity Level III.

The base value of a civil penalty for a Severity Level III violation is $50,000.

The escalation and mitigation factors of the Enforcement Policy were considered and no adjustment to the base civil penalty has been deemed appropriate for Violation I.

While the civil penalty could have been mitigated based on your prompt and extensive corrective actions for the indepth system review performed, there were also grounds for escalation of the civil penalty based on this violation being another example of the failure to maintain systems in an operable status because of a lack of understanding the system's design bases.

The base civil penalty was fully mitigated for Violation II because of your prompt and extensive corrective actions and your prior past performance given no similar types of violations have been previously identified.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.

In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.

After reviewing your response to this

' Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.

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-.l' Portland General Electr.ic' Company 3

OCT i h1.980

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'In'accordance with Section 2.790 of the NRC's '! Rules' of Practice," Part 2

-Title 10, Code of. Federal Regulations, a copy of this letter and the. enclosure i

will'be placed in the'NRC's Public Document Room.

'The responses-directed by this. Notice,'are not subject;to the clearance

. procedures of the Office of Management and Budget as. required by'the Paperwork.

Reduction Act of 1980,.PL'96-511.

nce ely,

'l I{21 John B. Martin j

-Regional Admi_nistrator Enclosure-

. Notice ~of Violation cc w/ enclosure:

l W.-S. Orser, PGE I

J. W.' Durham,'Esq.

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W. Dixon, DOE _

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