ML20151B639

Responds to NRC 880617 Ltr Re Violations Noted in Insp Rept 50-344/88-13.Corrective Actions:Nuclear Dept Procedure 100-5 Will Be Revised to Clarify Depth & Detail Required for Safety Evaluations & to Specify Personal Qualifications

ML20151B639
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/15/1988
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8807210051
Download: ML20151B639 (7)

Text

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~- Portland GeneralElectrich f~

David W. Cockfield Vice President, Nuclear July 15, 1988 Trojan Nuclear Plant Docket 50-344 Licenso NPF-1 U.S. Nuclear Regulrnory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

Responso to a Notico of Violation Your lettoc of June 17, 1988 transmitted a Notice of Violation associated with Nuclear Regulatory Commission Inspection Report 50-344/88-13.

Attached is our responso to that Notico of Violation.

Sincoroly, Attachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. Bill Dixon State of Oregon Department of Energy Mr. R. C. Bare NRC Resident Inspector Trojan Nuclear Plant 8807210051 880715 PDR ADOCK 05000344 1 1 i

O PDC 121 SW. S3: mon St'eet. Ptx+brd. Oregon 97204

Trojen Nuclear PIEnt Docum:nt Control Disk-Dockst 50-344 July 15, 1988 License NPF-1 Attachment Page 1 of 6 RESPONSE TO A NOTICE OF VIOLATION VIOLATION A Part 50.59(b)(1) to Title 10 of the Code of Federal Regulations 110 CFR 50.59(b)(1)] reads, in part, that "The licensee shall maintain records of changes in the facility . . .made pursuant to this section, to the extent that these changes. constitute changes in the facility as des-cribed in the safety analysis report . . .These records must include a written rafety evaluation . . . .".

Final Safety Analysis Report (FSAR) Figure 6.2-21 specifies that valves FW-079 through FW-086 are to be closed to fulfill Containment isolation functional requirements.

Contrary to the above, Temporary Modification 87-058 required that valves FW-079, FW-082, FW-083 and FW-086 be open to allow monitoring pressure in two feedwater lines from August 7, 1987 to March 28, 1988. The written safety evaluation failed to recognize the valves as containment isolation valves and did not addroso the change to FSAR Figure 6.2-21.

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

Kesponse Portland General *dlectric Company (PGE) acknowledges the violation.

1. Reason for Violation:

The reason for this violation was inadequate development and review of the Temporary Modification and its safety evaluation. Personnel who prepared and reviewed the safety evaluation did not recognize that the four foodwater drain valves are considered to be containment isolation valves and that they are listed in 1.ojan Technical Specification (TTS) Table 3.6-1, Containment Isolation Valves.

2. Corrective Action Taken and Results Achieved:

a. The immediate corrective action step taken was to close the four feedwater line drain val as, FW-079, FW-082, FW-083, and FW-086.

The NRC was immediately notified of this event by telephone at 1024 on March 28, 1988.

b. Action plans to further ev F, ate arid correct concerns regarding Containment isolation requirements, the adequacy of safety eval-uations, and the cause of this violation were developed.

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Trajtn Nucisar Pltnt Document C ntral D3ak Dockst 50-344 July 15, 1988 License NPF-1 Attachment Page 2 of 6

c. The safety significance of operating the Plant with the drain valves open was evaluated, and it was determined the pressure transducers satisfied pressure boundary and seismic design-requirements for the feedwater system.

d. The required positions for Containment isolation valves listed in TTS Table 3.6-1 woro reviewed and clarified. Changes to Periodic Operating Test (POT) 3-3, "Containment Penetration Valve Insor-vice Test", were made whero necessary to ensure that all Tech-nical Specification requirements are clearly defined,

e. All Locked Valve List deviations have been reviewed to verify that none of them involvo Technical Specification violations or deviations from FSAR assumptions. No problems were found.

f.

All existing temporary modifications wore reviewed for potential Technical Specification violations. No violations were found.

g.

Guidance has been provided w' thin the Nuclear Division describing the Technical ' yecification Information System (TSIS) and inform-ing personnel of its availability as an aid in performing safety '

evaluations. The TSIS is a PC-based computer program that allows word searches of the Technical Specifications to be done,

h. An independent evaluation of this event has been performed by the Performance Monitoring / Event Analysis Group. A number of recom-mendations were made and are currently being considered by management personnel.

3. Cort -tive Action to Avoid Further Violations:

a.

Nuclear Department Procedure (NDP) 100-5, "Preparation of Safety Evaluations Required by 10 CFR 50 and Trojan Technical Speci-fications" will be revised to: (a) clarify the depth and detail  ;

required for safety evaluations, and (b) to specify qualifica-tions of persons performing and reviewing safety evaluations.

The revised procedure is scheduled to be implemented on October 31, 1988. This schedule includes approval of the proco-dure, development of lesson plans to conduct training on the procedure, and training of selected personnel in the new proce-dural requirements.

b. Trojan Nuclear Operations Board Proceduro 110-1, "Functions and Procedures of Trojan Nuclear Operations Board Staff", will be revised to improve the methods used for reviewing safety eval-uations. The revision is scheduled to be complete by August 15, 1988.

Trajcn Nucis:r P1 tnt Document C ntrol Desk D:ckst 50-344 July 15, 1988 License NPF-1 Attachment Page 3.of 6

c. The Technical Staff / Technical Manager Training Program. lesson plans will be revised to incorporate information on qualification requirements, itprovements made to NDP 100-5,.and lessons learned from the seminar for persons to be qualified for performing and reviewing safety evaluations. .The lesson plans are scheduled to be revised by November 30, 1988.

d. The design basis docume . on Containment will include a discus-sion of what constitutes a Containment boundary and why. The ,

document is expectmd to be completed by January 27, 1989.

4 Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.since the feedwater valves were closed to conform to FSAR requiren.iits.

Our ast essment of how this find ing reflects on PCE's 10 CFR 50.59 safety evaluatAon and engineering cer uation programs is as follows:

We acknowledge that our 10 CFR 50.59 safety evaluation and engineer-ing evaluation programs require improvement. In order to make the required improvements, we have developed an action plan to further evaluate and correct concerns regarding the adequacy of safety evaluations. Section 2 above lists corrective steps that have been taken. Section 3 above includes corrective steps that will be taken.

These steps will ensure that all engineers who perform safety eval-uations have a greater understatiding of the complexi~cies and inter-relationships of the Trojan FSAR and Technical Specifications. In the interim, the additional guidance given to Nuclear Division Managers regarding the av.ilability of the TSIS and increased empha-sis on the adequacy of safety evaluations will help prevent a recurrence of this type of ever VIOLATION B 10 CFR 50, Appendix B, Criterion V, states in part, "Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accom-plished in accordance with these instructions, procedures or drawings".

Administrative Order, A0-3-13. "Control of Locked Valves and ESF Equip-ment" Revision 41, dated October 26, 1987, specifies in part that valvo locking devices on administrativo1y controlled valves must be installed at all times except when actually manipulating a valve.

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e Trojen Nucisse Plant D cument Cantrol Dssk' Dockst-50-344 July 15, 1988 License NPF-1 Attachment Page 4 of 6 Contrary to the above, on March 25, 1988,~ three feedwater drain valves (FW-079, FW-083 and FW-086) each an~ administratively controlled valve, were found unlocked.

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

Response

PGE acknowledges the violation.

1. Reason for Violation:

The reason for the violation was personnel error in that operators failed to properly reinstall locking chains on the three feedwater drain valves as required by A0-3-13 following valve manipulation.

2. Corrective Action Taken and Results Achieved:

The locking chains were properly installed, thereby re-establishing preper administrative control of the valves.

, 3. Corrective Action to Avoid Further Violations:

A complete verification of the Locked Valve !.ist was' performed following the 1988 refueling outage. All locking devices were found to be properly installed. The Operations Supervisor has instructed Operations personnel on the need to ensure locking devices are properly installed.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved since the locking devices were correctly reinstalled.

VIOLATION C Technical Specification 4.0.5 states in part, that "inservice testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in .l accordance with Section XI of the ASME Boiler and Pressure Vessel Code l and applicable addenda as required by 10 CFR 50, Section 50.55(a)(g)". '

PGE letter dated November 14, 1986 committed to the use of the ASME Section XI 1983 Edition, Summer 1983 Addenda.

l IWV-3417 of Section XI of the ASME Boiler and Pressure Vessel Code 1983 Edition, Summer 1983 Addenda states in part, "if, for power-operated valves, an increase in stroke time of . . . 50% or more for valves with-l

. 1 Trajan Nuclear Plant Document Centrol Disk Dock 2t 50-344 July 15, 1988  :

License NPF-1 Attachment Page 5 of 6 i

with full-stroke times less than or equal to 10 seconds is observed, test I frequency shall be increased to once each month until corrective action is taken".

Contrary to the above, power-operated valves CV-10015 and JV-10014 '(with full-stroke times loss than or equal to 10 seconds) experienced an increase in stroke time of more than 50 percent during testing conducted on January 12, 1988 and were subsequently tested on February 25, 1988 which exceeded the specified time interval with the allowable 25 percent ,

extension.

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

Response

PGE acknowledges the violation.

1. Reason for Violation:

The reason for the violation was personnel error. The Inservico Test (IST) Engineer responsible for recording and trending data mistakenly recorded the test data for CV-10015 and CV-10014 as being taken on January 19, 1988 rather than January 12, 1988. Subsequently, the increased frequency testing was scheduled based on the January 19 date. When the two valves were tested on February 25, 1988 the monthly interval (31 days) with the allowable 25 percent extension had been exceeded.

2. Correctivo Action Taken and Results Achloved:

Periodic Engineering Test (PET) 9-4, "Documentation of Inservice Testing Data for Pumps and Valves", was revised to include a review by the Surveillance and Test Group Supervising Engineer when specify-ing corrective action. This additional review will reduce the risk of any further mistakes of this nature.

3. Corrective Action to Avoid Further Violations:

Discussions have been hold with the Surveillance and Test Group emphasizing the importance of accuratoly recording IST test data and acquisition dates, and the need to ensure retesting on an increased frequency is completed on schedule without entering the 25 percent allowable extension period.

4. Data When Full Compliance Will Be Achieved:

Revision 8 to PET 9-4 was approved on May 17, 1988 and has been implemented. Full compliance has been achieved.'

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Trojen Nuclear. Pltnt . Document Control Desk Dockst 50-344 July 15, 1988-License NPF-1 Attachment Page 6 of 6 VIOLATION D-10 CFR 50, Appendix B, Criterion V states ir. part, "Activities affecting quality shall be prescribed by documer.ted instructions, procedures, or drawings, of a type appropriate to tne circumstances, and shall be accom--

plished in accordance with these instructions, procedures or drawings".

POT 3-3, Revision 22, "Containment Penett ation Valve Inservice Tast",

dated February 16, 1988, . Paragraph 9.2 staces, "Action taken shall'be described in' the data sheet comments section".

Contrary to the above, alert testing of valves CV-10014 and CV-10015 on February 25, 1988, and valve CV-10014 on March 24, 1988 initially showed unacceptable valve stroke times, and operator response actions were not described in the comments section of the applicable POT 3-3-DB data sheets.

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

Response

PGE acknowledges the violation.

1. Reason for Violation:

The reason for the violation was personnel error. The operators performing the stroke time testing incorrectly recorded response actions at the bottom of the data sheet page instead of the comments  !

section as required by Section 9.2 of POT 3-3.

I

2. Corrective Action Taken and Results Achieved:

The Operations Supervisor issued a special order to his department on April 6, 1988 specifying the use of the comments section for correc-tive action when valves or equipment fail to meet acceptance criteria and instructing operators to sign their comment. The special order also directed that if a Maintenance Request (MR) is issued,-the MR number should be included.

3.

Corrective Action to Avoid Further Violations:

The Surveillance and Test Group and the System Engineering Group which review and trend the information recorded on the test data sheets are now verifying the comments section of the data sheets describe and document problems encountered.

4. Date When Full Compliance Will Be Achieved:

Full compliance han toen achieved.

TDW/SAB/DLN/mr/2799P 788

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