ML20247C148

Notice of Violation from Insp on 890522-0721.Violations Noted:Calculation TC-508 Did Not Assess Supports for Ability to Withstand Design Basis Wind Loads & Control Room Emergency Ventilation Sys Demonstrated Inoperable

ML20247C148
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/29/1989
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20247C147	List: IR 05000344/1989009 ML20247C143 ML20247C148
References
50-344-89-09, 50-344-89-9, NUDOCS 8909130261
Download: ML20247C148 (3)

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o APPENDIX A NOTICE OF VIOL /. TION Portland General Electric Company Docket No. 50-344 121 S. W. Salmon Street, TB-17 License No. NPF-1 Portland, Oregon 97204 During an inspection conducted on May 22 through July 21, 1989, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1988), as modified by 53 Fed. Reg. 40019 (October 13,1988), the following violations were identified:

A. Trojan Technical Specification 4.7.6.1 requires that the control room emergency ventilation system be demonstrated OPERABLE at least every 31 days by initiating finw and verifying that the train operates for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> with the preheaters on and maintains the control room air temperature less than or equal to 110 degrees F.

Contrary to the above, since May 1988, licensec surveillance testing of the control room emergency cooling system did not demonstrate the system cperable in that a recently installed non-safety, supplemental control room cooling system (08-16) had been in service during the required tests of the control room emergency ventilation system.

This is a Severity Level IV Violation (Supplement I).

B. 10 CFR 50 Appendix B, Criterion V, states, in part, " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...and shall be accomplished in accordance with these instructions, procedures, or drawings."

1. PGE Procedure NDP No. 200-4, Revision 2. " Quality-Related Calculations," Section 5.2.A.7, states, in part, " calculations shall be sufficiently detailed as to purpose, method, assumptions, design input...."

Contrary to the above, as of May 24, 1989 Calculation No. TC-508,

" Roof Mounted Chiller Support for CB-1," Revision 0, was not sufficiently detailed in that all the appropriate design inputs were not included. Specifically, Calculation No. TC-508 did not assess the supports for their ability to withstand design basis wind loads.

2. Section 5.2.C.2 of procedure NDP No. 200-4 states, in part, " check hand calculations for assumptions, analytical methods, mathematical accuracy, completeness, and, as appropriate, compliance with design c ri te ria. . . . "

Contrary to the above, as of May 24, 1989, Calculation No. TC-351, "CB-1 Intake Pipe and Supports RDC 86-021" dated June 17, 1986 calculated a concrete anchor bolt load of 4215 lbs while the specified design allowable concrete anchor bolt load was 2880 lbs.

This is a Severity Level IV Violation (Supplement I).

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3. NDP No. 200-4, Revision 2, dated October 6, 1987, entitled "0uality Related Calculations," states in Section 5.1E, " Calculations i prepared for one job may be used or referenced for another job.

Previously used calculations shall be checked for applicability, assumptions, and mathematical accuracy...."

Contrary to the above, as of May 24, 1989, a design change to replace vital inverters, design change package RDC 86-031, included an analysis of the impact of the DC system based on unverified, incorrect assumptions of the inverter performance characteristics

nade in a previously used calculation.

4. NPEP No. 200-14. Revision 6 dated October 19, 1988, entitled

" Detailed Construction Package Preparation and Control," states in Section 4.1.2 "If the RDC modification for which 6 DCP is prepared involves quality-related systems, structures or components, a design verification nust be completed for the DCP...."

Contrary to the above, design change RDC-86-045, which added a supplemental control room cooling system, CB-16, did not include a design verification that 480 volt motor loads, added in May 1988, would not adversely impact the vital 480 volt system or overload the Emergency Diesel Generators.

This is a Severity Level IV Violation (Supplement I).

C. 10 CFR Part 50, Appendix B, Criterion XV states, in part, that " Measures shall be established to control materials, parts or components which do not conform to requirements in order to prevent their inadvertent use or installation. These measures shall include, as appropriate, procedures for identification, documentation, segregation, disposition and notification to the affected organizations."

NDP No. 600-1, Revision 6, dated March 2, 1989, entitled " Control of Nonconforming Materials, Parts and Components", Section 3.1, defines nonconforming components as "... components that exhibit a deficiency in one or more characteristics or documentation which makes the quality of the item unacceptable or indetenninete".

Contrary to the above, as of May 24, 1989, the licensee had failed to issue nonconformance reports for nonconforming conditions relating to the inverters installed in 1987 and 1988 outages for the Class IE 120 Volt Preferred Instrument AC System. Specifically, the inverters exhibited frequency swings and voltage characteristics outside the existing design basis making their acceptability indeterminate.

This is a Severity Level IV Violation (Supplement I).

D. 10 CFR Part 50, Appendix B, Criterion XII, states, in part, that

" Measures shall be established to assure that . . . instruments . . . 1 used in activities affecting quality are properly . . . calibrated . . ."

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Top' 21 Report (PGE-8010) entitled PGE " Nuclear Quality Assurance Program," Revision 11, Chapter 12.0, Control of Measuring and Test  !

Equipment and Installed Instrumentation, states, in part, tha*,, "A l calibration control program is utilized to assur ' hat . . . instruments

. . . are calibrated . . ."

Contrary to the above, as of June 7,1989, an ammeter, a frequency meter, and a voltmeter, all part of Elgar Inverter Y-26, installed during the 1988 refueling outage, were not calibrated prior to being placed into operation.

This is a Severity Level IV Violation (Supplement I).

E. Technical specification 6.8.1 requires, in part, that written procedures shall be established, implemented and maintained covering the activities recommended in Appendix "4 of Regulatory Guide 1.33, November, 1972.  ;

Regulatory Guide 1.33, Appendix "A", requires procedures for combating m gencies and other significant events, including loss of electric p 2r.

Contrary to the above, as of June 6,1989, PGE procedure, Off Normal Instruction ONI-46, " Loss of 120-V AC Instrument Bus," Revision 1, dated April 16,1984, was not maintained in that it had not been revised to reflect she control room configuration as effected by a design modifi. nion. Procedure ONI-46 identified that one of the symptoms of loss of AC instrument bus was a " Preferred AC Bus Undervolt" annunciation. As a result of a design change during 1987-1988, the control room annunciator panel K-06 was modified to annunciate " Inverter Trouble" instead of " Preferred AC bus Undervolt".

This is a Severity Level V violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company (Licensee), is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the I reasons for the violation if admitted, (3) the corres tive steps that have been j t6 ken and the result achieved, (4) the corrective steps that will be taken to l avoid further violations, and (L) the date when full compliance will be I achieved. If an adequate reply is not received within the time specified in this Hotice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good caus* shown. Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response shall be submitted under oath or affirmation.  !

FOR TH NUCLEAR REGULATORY COMMISSION TT6 Dated at Walnut Creek, Califu nia John 8. Maitin l A1)G 2 91983 Regional Administrator l

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