ML20246A878
| ML20246A878 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/28/1989 |
| From: | Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8907070118 | |
| Download: ML20246A878 (1) | |
See also: IR 05000344/1989013
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JUN 2 8 -1989
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" Docket No. 50-344
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Portland. General Electric Company
121 S. W. Salmon Street
Portland, Oregon '97204
Attention:
Mr. David W. Cockfield
Vice President, Nuclear
Thank you for your letter dated June 23, 1989, in response to our Notice of
Violation and Inspection Report No. 50-344/89-13, dated May 24, 1989,
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informing us of the steps you have taken to correct the items which we orought
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to your attention.
Your corrective actions will be verified during a future
inspection.
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Your cooperation with us is appreciated.
Sincerely,
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M. Mend ca, Act ng Chief
Reactor Projects Branch
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docket file
State of Oregon
A. Johnson-
G. Cook
B. Faulkenberry
J. Martin
Resident Inspector
Project Inspector
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J. Zo111 coffer
M. Smith
REGION V
MMendonca
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David W. Cockfield Vice President, Nuclear
30 JUN2B All : 27
June 23, 1989
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Trojan Nuclear Plant
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Docket 50-344
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License NPF-1
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
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Washington DC 20555
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Dear Sir:
Reply to Notice of Violation
Your letter of May 24, 1989 transmitted a Notice of Violation based upon
Nuclear Regulatory Commission Inspection Report 50-344/89-13 Appendix A.
Our reply to the Notice of Violation is provided in Attachment 1 to this
letter.
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Sincerely,
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Regional Administrator, Region V
U.S. Nuclear Regulatory Commission
Mr. William T. Dixon
State of Oregon
Department of Energy
Mr. R. C. Barr
NRC Resident Inspector
Trojan Nuclear Plant
O N A f" O / m*7
121 S.W. Salmon Street, Portland, Oregon 97204,503'464-8897
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Trojan Nuclear Plant.
Document Control Desk
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Docket 50-344'
June 23, 1989
License NPF-1-
Attachment 1
Page 1 of 2
Response to Notice of Violation
Violation A
Title 10, Code of Federal Regulkcions, Part 50, Appendix B, Criterion KI,
" Test Control", states in part:
"A test program shall be established to
assure that all testing required to demonstrate that systems and components
'will perform satisfactorily in service is identified and performed in
accordance with written test procedures which incorporate the requirements
and acceptance limits contained in applicable design documents".
Contrary.to the above, Temporary Plant Test (TPT)-235, " Remote Shutdown
Station Input / Output Verification", dated April 25, 1988, did not contain
sufficient testing to verify the interlocks and permissives associated with
MO-8702, Residual Heat Removal System suction isolation valve, functioned as
designed subsequent to modification.
Specifically, TPT stated in part,
" verify circuits interrupted by the Remote Shutdown Station (RSS)
installation will perform their control, indication, permissive and/or
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protective functions af ter restoration". However, testing performed'on
May 22. 1988 did not verify the permissive and interlock features of MO-8702
and subsequently, on April 9, 1989, the permissive and interlock features of
MO-8702 were found to be inoperable.
This is a Severity Level IV violation (Supplement 1).
Response
Portland General Electric (PGE) acknowledges the violation.
1.
Reason for the violation.
The reason for the violation was personnel error in determining the
retest requirements for the Temporary Plant Test (TFT) associated with
the instrument loops for MO-8702.
During original construction a
polarity error in the cable plug to Modules PB-405A/B was corrected by
reversing the wiring at the module terminal strip instead of at the
module connector. When Request for Design Change (RDC)85-052 (Remote
Shutdown Station Installation) required the rewiring of the as-designed
module terminal strip, a reversal of the polarity at the input to the
module resulted. Post modification testing should have discovered this
polarity error but it did not.
It was assumed by the engineer preparing
the test that the bistable and controller functions for MO-8702 were not
affected by the rewiring modification to the new Remote Shutdown
Station.
This assumption resulted in the Hagan Rack control, interlock,
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alarm outputs, and some indications not being fully tested. The retest
requirements set forth in the TPT only verified the operability of the
indications on the control room Hasan Racks.
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Trojan Nuclear Plant-
Document Control Desk
Docket 50-344
June 23, 1989
License NPF-1
Attachment 1
Page 2 of 2
2.
Corrective steps that have been taken and the results achieved,
a.
The ability of MD-8702 to be opened and shut from the control room
was verified.
The valve was left in the normal locked-open position
to support Mode 5 (cold shutdown) operation. Additionally,
automatic isolation capability was confirmed for MD-8701, the valve
which prevides a redundant isolation function to MO-8702.
b.
The input module PB-405A/B, to MO-8702, has been rewired to correct
the original polarity error.
c.
Nuclear Plant Engineering (NPE) has reviewed all of the Hagan Rack
circuitry modified by the RDC 85-052 (Remote Shutdown System)
installation. The review determined that all instrument and control
loops affected by RDC 85-052 have been satisfactorily tested or
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otherwise verified to be operating correctly. Plant System
Engineering (PSE) has performed an independent review of the
conclusions reached by NPE and concurs with NPE's findings.
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d.
Plant System Engineering Procedure (PSEP) 20-7 has been revised to
require that the system engineer and design engineer concur with
post-design change test requirements and results. This practice has
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been adopted for all design changes completed during the
1989 Refueling Outage.
e.
The Event Report (89-40) associated with the violation has been
reviewed and discussed at NPE/PSE Electrical Group meetings as a
lessons learned item.
Ensuring that adequate retest requirements
are specified for all components affected by an RDC was emphasized.
3.
Corrective steps that will be taken to avoid further violations.
a.
The Periodic Operating Test (POT-2-5-DB), which tests the interlocks
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for MD-8702, will be satisfactorily completed prior to entering
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Mode 4 (hot shutdown) following the current refueling and
maintenance outage.
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b.
The Quality Assurance Department will become more involved in
post-installation testing. An audit of Plant Systems Engineerin6
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(PSE) in July 1989 will include a review of post-installation
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testing.
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4.
Date when full compliance will be achieved.
Pull compliance has been achieved.
BW/3232W
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