ML20236A011

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $50,000.Noncompliance Noted:Portions of Two ECCS Subsys Inoperable When Valve MO-8809A Closed & QC Inspector Failed to Follow Procedures

ML20236A011
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:
Shared Package
ML20235Z789	List: ML20235Z787 ML20236A011
References
EA-86-113, TAC-61523, NUDOCS 8710210332
Download: ML20236A011 (3)

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.e, NOTICE OF VIOLATION AND PROPOSED IMPOSITION 0F CIVIL PENALTY Portland General Electric Company Docket No. 50-344

(Trojan Nuclear Power Plant) License No. NPF-1 EA 86-113 '

During NRC routine and special inspections conducted during the period-of March 18 - August 14, 1986, violations of NRC requirements were identified. I

The violations. involved operability of the residual heat removal system and

.the quality control' inspection of a pressurizer safety valve. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"

10 CFR Part 2, Appendix C (1986), the Nuclear Regulatory Commission proposes  ;

to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of

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l 1954,'as amended, ("Act"), 42 U.S.C. 2282, PL 96-295, and 10 CFR 2.205. The violations and associated civil penalty are set forth below:

- I. Violation Assessed a 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.

TechnicalLSpecification LC0 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. 1 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), l Section 6.3 which shows that RHR flow will be injected into all four cold legs of the reactor coolant system. l l

Contrary to the ab'ove, on March 31, 1986 while in Mode 1 for one hour and i ten minutes, portions of two ECCS subsystems (the RHR system) were inoperable j when valve M0-8809A was closed. With valve M0-8809A 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).

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

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. Notice of Violation ~ 2 OCT 151986 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 torquingsof 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 confirmation, by means of actual physical observation, that a condition or process complies with specified requirements."  !

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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 s inspection record to document that the inspection had been completed.  ;

This is a Severity Level III violation (Supplement I). j Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company

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is hereby required to submit to the Director, Office of Inspection and Enforcement, U.! Nuclear Regulatory Commission, Washington, D.C. 20555 with a i 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 violations,

.(2) the reasons for the violations if admitted, (3) the corrective steps that f have been taken and the results achieved, (4) the corrective steps which will

• be taken.to avoid further violation, and (5) the date when full compliance

, will 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 order to show cause why the license should not be modified, i suspended, or revoked or why such other action as may be proper should not be  ;

L taken. 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. I 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 check, draft, or money order payable to the Treasurer of the United States in the amount of Fifty Thousand Dollars ($50,000) 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 4 Electric Company fail to answer within the time specified, the Director, Office of Inspection and Enforcement, will issue an order 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 i civil penalty, such answer may: (1) deny the violations listed in this i l Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) 1 show error in this Notice, or (4) show other reasons why the penalty should g 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. ]

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l Notice of-Violation- 3 OCT 151986 In-requesting mitigation of the proposed penalty, the five factors addressed j 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 refarence (e.g., citing page and paragraph numbers) to avoid repetition. Portlarid 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 J compromised, remitted, or mitigated, may be collected by civil action pursuant i to Section 234c of the Act, 42 U.S.C. 2282. 1 i

R TH NUCLEAR REGULATORY COMMISSION ]

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~~~. 1 John B. Martin  !

Regional Administrator i

Dated'at. Walnut Creek, California <

thisgj[dayofOctober1986 ]

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