IR 05000344/1987018

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/87-18

ML20246N886
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/17/1989
From:	Chaffee A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8903280063
Download: ML20246N886 (1)

Text

7 -

,

. .

o ,

o

}.k} -'

.

, _

-c

,

j

.

'

N .

MAR i7 1C39 Docket ~No.'50-344

'

. Portland General Electric Company .' f

'121 SW Salmon' Street .TB-17

' Portland, Oregon .97204 '

.

Attention: Mr. David W. Cockfield- ,

Vice President, Nuclear Gentlemen:

Thank you for your letter dated March 2,:.1989,'in response to our: Notice'of ,

. Violation and Inspection Report No. 50-344/87-18, dated : January 31, 1989, ,.

informing us;of the' steps you have taken to correct the items'which we' '  :)

brought'to your attention. *

Your corrective actions will-be verifled during 'a futuresinspection. ,

.,

Your cooperation with us is appreciated.

• J

? ,

<

Sincerely

',

<

-

,

'

fl ff](k

" 'A. E. Chaffee, Acting Director

'

Division of Reactor Safety

~~

- -

y and Projects bec w/ copy of letter' dated.3/2/89:

Docket File .

'j

.

Resident' Inspector. ,.

Project Inspector G. Cook ,

A. Johns'on '

~

,

l B.' Faulkenberry  ;

J. Martin LFMB State of Oregon

~

j bec w/o: copy of letter dated 3/2/89: '

')

M. Smith l REGION V g J0'Spien/ oan MMencjonca RZimmerman AChaffee. 1 _:

_7 // f/89 /))' /89 .3 //5 /89 J,/d/89'

- # I

,, PY ] REQUEST COPY-]

YES EST

/ NOCOPY 3/YE] gs g/EST NO COPY

] YES / ](~N REQUEST ] YES C(D)/ NO ']-

V "

TO PDR ]

% NO

,

] -l

\\

8903280063 890317 i PDR ADOCK 05000344 l'

O PDC

/ I .)

i

, J L, f:

i

-

_ _ _ _ - - - _ _ _ _ . . _ _ _ _

,

.

.

. .

.

. .

.

-

'

..

-

. .

• 1

< _. . i

.-.~

~

aD [ PortlandGeneralElectricCcarpiny t

David W. Cockfield Vice President, Nuclear March 2, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 l

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555 j

Dear Sir:

Reply to Notice of Violation I

'

Your letter of January 31, 1989 transmitted a Notice of Violation

'

associated with Nuclear Regulatory Commission (NRC) Inspection Report No. 50-344/87-18. Attached is our reply to that Notice i of violation. j

l

Sincerely

.

'

I. ,

y Attachment I c: r. John B. Martin l

Regional Administrator, Region V U.S. Nuclear Regulatory Commission i Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector 8 0 . Ops g ' "n

Trojan Nuclear Plant <

l Affn gg

-

l -;

l

'w ,

' ' 12 Sn Sa nr 5:wt Po1rd. O*e;pn 9'234

_ _ _ _ - _ - _ _ _ _ .

,---x,-- _

. . .

. .

. . l

'

'

' Trojan Nuclear Plcnt D:cument C ntrol Deck

'

Docket 50-344 Attachment

License NPF-1 March 2, 1989 Page 1 of 5 i

REPLY TO A NOTICE OF VIOLATION l

VIOLATION A  !

I Trojan Technical Specification 6.8.1 required that written procedures I shall be established, implemented and maintained covering the applicable activities recommended in Appendix A of Regulatory Guide 1.33, November i 1972. Regulatory Guide 1.33, Appendix A recommends " Procedure Adherence" ]

as a written procedure to be implemented. i In partial implementation of this requirement, Trojan Procedure AO-4-2, Revision 14 "Use of Procedures" in Section 3.11 requires that the proce-deres contained in the Plant Operating Manual shall be followed in the performance of Plant activities. The Plant Operating Manual's Operating Instruction (OI) 5-2, " Safety Injection", Section 3.0, " Sluicing Accumu-lators", required sluicing to be performed using the sample lines.

Contrary to the above, on May 12. 1987 and again on May 23, 1987, borated water was sluiced between the "A" and the "D" sa ^ety injection accumu-lators using a fill line rather than the requirei sample line.

This is a Severity Level IV Violation (Supplemrat 1).

Reply to Violation _A Portland General Electric (PGE) Company acknowledges the violation.

1. Reason for Vielation:

The reason for this violation is personnel error in not following established Plant procedures. OI 5-2 contains a procedure for transferring water between safety injection accumulators. The percedure calls for the transfer to be done using the sample lines ,

wt2ch interconnect the accumulators. On May 12 and 23, 1987, the f Plant was shut down for the annual refueling outage and the sample j lines were tagged-out for maintenance. Operations personnel needed !

to transfer water between accumulators and determined that an alter- I nate interconnecting path existed through the fill lines. This I alternate path was used on May 12 and 23 to transfer water between the "A" and "D" accumulators without processing a procedure devia-tion or revision, l 2. Corrective Steps Taken and Results Achieved:

The evaluation of the problems experienced with the safety injection accumulator fill line identified several operational areas where improvements were required. These were summarized in an operational

!

j

_ _ _ _ _ _ _ _ J

- _ _ _ _ - - _ _ _ _ - _ ___

. \

. .

. *

.

'

. Trojen Nuc1cir.Plcnt Document.C:ntrol D3ek

./ , Dockel 50-344 Attachment )'

License NPF-1 March 2, 1989 Page 2 of'5 i

I Improvement Plan that was forwarded'to the U.S. Nuclear Regulatory l Commission, Region V on June 16, 1987. As part of the plan, the i need for immediate improvement in procedure compliance was emphasized to Nuclear Division managers in;a-meeting with the Vice President, Nuclear on June 8, 1987. Subsequent meetings with'all ]

division personnel were held between June 9 and June 15, 1987 to discuss procedure compliance and other lessons learned from these events. The focus on procedure compliance has continued, with this area still identified as a key division issue and included in our

" Conduct of Nuclear Plant Operation" guidance provided to emplo-yees. Although subsequent improvements have beenLnoted, continued management attention to this area is provided to ensure full compliance.

3. -Corrective Steps That Will Be Taken to Avoid Further Violations:

Accountability of the workers and their managers and supervisors for

'

procedure compliance continues to be reinforced. This has been.

accomplished through periodic meetings, general employee training, and increased management involvement in day-to-day Plant activities.

4. Date When Full Compliance Will Be Achieved:

The Plant is presently in full compliance.

(9,

_ _ _ _ - _ _ --

, _ , _ , - - - - - _ . _ - _ - _ _ - - - . _ _ - - .

l

. -

- ,

-)

. .

.

!

Document Centrol Disk

'

., * Trojan Nuclair Pitnt l'

'

.. Docket 50-344 Attachment

-

License NPF-1 March 2, 1989~

Page 3 of 5-

!

VIOLATION B l i

Title 10 to the Code of Federal Regulations,'Part 50, Appendix B.:

Section.V, " Instructions, Procedures and Drawings" reads, " Activities affecting quality shall be prescribed by documented instructions, proce- i dures,.or drawings, of a type appropriate to the circumstances and shall i be accomplished in accordance with these instructions, procedures, or drawings."

. - 1

' Portland General Electric Nuclear Division Procedure (NDP) 600-1,

.

l l " Control of Nonconforming Materials,. Parts and Components"..Section 5.4,

"QA Operations Branch Actions", Part C.; stated. " Ensure the nonconforming-

'

!

.

items are identified and controlled to prevent their inadvertent use by use of QC hold tags and/or the necessary danger and caution tags as determined appropriate by the QA Operations' Branch Manager."

contrary to the above, af ter the- rupture of the "A" Safety Injection accumulator fill line on May 12, 1987, adequate controls were not 3 established,in that the fill line was used again-to sluice borated water j from the "A" to the "D" accumulator and a.second rupture of the "A" j accumulator fill line occurred on May 23, 1987.

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

Reply to Violation B j PGE acknowledges the violation.  ;

i 1. Reason fce Violation: l The reason for the violation was personnel error. Following the accumulator fill line failure on May 12, 1987, Nonconformance Report (NCR)87-163 was initiated documenting the failed condition of the I

pipe. At the time of the failure. Quality Control (QC) hold! tags were seldom used for controlling defective. installed. equipment and !

the QA Operations Branch Manager relied on the Plant's use of danger tags. However, no. controls were placed on the release of the danger tags to ensure that the equipment NCR evaluation was complete and the cause of the failure was identified and corrected. As a result, the danger tags were removed When the fill line repair stas comple-ted..even though the NCR was still being evaluated. Subsequently,

'

the fill line was again improperly used'to transfer water between accumulators and a second failure occurred.

2. Corrective Steps Taken and Results Achieved:

After the second failure of the "A" accumulator fill line on May 23, 1987, QC hold tags were used to quarantine the valves and piping in the accumulator fill line. The final QC hold tag was not removed ,

i

!

. _ _ _ - _ _ _

-

, _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. .

.. ,

-

, . .

,

'

• Trojan Nuclear Picnt Documsnt Control Desk

' Docket 50-344 Attachment License NPF-1 March 2, 1989 Page 4 of 5 until after the NCR associated with the two failures war disposi-tioned and the cause of the failures was understood and corrected.

The controls used after the second failure were effective and no further failures occurred.

As follow-up corrective action, Nonconforming Activity Report (NCAR) P87-074 was issued on June 16, 1987. This NCAR identified the failure to properly control the accumulator fill line after the first pipe break. The resolution of the NCAR was a joint effort by Quality Assurance (QA) and Trojan Operations to improve the use of QC hold tags to ensure that adequate evaluations and corrective actions have been completed prior to returning equipment to service. QA took the lead in developin a revision to Nuclear DivitWon Procedure (NDP) 600-1. In th' , QC hold tags were d

"

.

used extensively to control significant equipment and component non-conformances. Examples of where they were used include: temporary covers on steam generator feedwater nozzles, a leaking service water line to cabic spreading room coolers, a cracked seat in the main steam root valve to the turbine-driven auxiliary feedwater pump, bbers and hangers,} the '

a, potential defect;

• k " ^

-

izer surge Ifne. '

• • * '

J f 4 On October 5,1988, Revision 5 to NDP 600-1 was approved, which implemented the use of a new tag specifically designed for NCRs.

Quality Assurance actions relative to the use of these NCR tags are contained in Paragraph 5.4.C of the revised procedure as follows:

'%lensult with the Shif t Supervisor and take action to hang NCR tags on the nonconforming items when deter-mhed appropriate. Additional controls such as use of op,erations tagout/ clearances or safety-related equip-outages may be used in conjune nw NCR tags.

Te8 he tag if continued use i c'c le'and E' .--

n' ry precautions and limit on" dd addi-

rniat81on necessarygo co~

~ -

M r advertent u'se." ,

4 s 2 &.

As a result of this procedure revision, the control of systems with u y A #

.

,

~

J 4 3. Corr ve eps That Will Be Taken to

.

g 4 -

olat ons:

,

-

4 W ..Ah ^

TheI e ac i tut nJuk19 '

en effective sys s ati 196genjor e in e @ o up ;g

-

io .u~ -

i fail fi appropria @ ec'_ .

ations prior p

, to rni he service. F,ollowing Rev n S g NDP 600-1, ' , g the e of R ta in the Plant has become accep ;ed practice.

% *h tw h

. mn :- -

& n c"g y.

v

) *

_

= .

.. . . .

., . .

,,

.

.. ' Trojan Nuclose Plant Documsnt Control Dask

'

,. Docket 50-344 Attachment

.

License NPF-1 March 2, 1989 Page 5 of 5 liowever, as part of an overall effort to improve our corrective action programs, NDP 600-1 has been further improved to more expli-citly describe When an NCR must be initiated and when NCR tags must be used to control the equipment or system until the failure mech-anism has been analyzed and understood.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved, w , . -p .r-GAZ/SAB/DLN/mr 2855W.0289 V-i ...

-

l -

.g

.

-

-

.

, ~

,

3 a ^

r

. b . % ST .. WA g- ,h g

~

A ~ ~

4 $ -

_._ Y

- e e q=e + a em,

+ .a

_

f

.

} -; 'S

- a

~

+

., .-

~

w % :.s e r. - l

. New ":b ? w & si,;n p,o ? M  !

b k1 ~A -- Nk M 4

~

-

_ ,

,

. -

%

• . -. .

" *

7-n=ipap. m J '; ..J1 2 W r~- w w w .- w w # --- ~

'.

p g# A_.# . .x - ~w.ww ,_

- .- -. .- .- - r