05000344/LER-1988-049, Responds to NRC Re Violations Noted in Insp Rept 50-344/89-01.Corrective Actions:Temporary Change to Plant Operation Test Procedure 26-2 Implemented Which Appropriately Revised Procedure as Described in LER 88-049

Responds to NRC Re Violations Noted in Insp Rept 50-344/89-01.Corrective Actions:Temporary Change to Plant Operation Test Procedure 26-2 Implemented Which Appropriately Revised Procedure as Described in LER 88-049

ML20244C646
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	04/14/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8904200319
Download: ML20244C646 (8)

LER-2088-049, Responds to NRC Re Violations Noted in Insp Rept 50-344/89-01.Corrective Actions:Temporary Change to Plant Operation Test Procedure 26-2 Implemented Which Appropriately Revised Procedure as Described in LER 88-049

Event date:
Report date:
3442088049R00 - NRC Website

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Ptx lland Gex1eral Electric Coiriptsiy L

{ .m.E David W. Cockfield Vice President, Nuclear April 14,'1989 Trojan Nuclur Plant Docket 50-344 License NPF-1 l U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

Reply to c Notice of Violation Your letter of March 15, 1989 transmitted a Notice of Violation associated with Nuclear Regulatory Commission Inspection Report 50-344/89-01.

Attached is our response to that Notice of Violation.

Sincerely, W

Attachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T Dixon State of Oredon Department of Energy Mr. R. C. Bace NRC Resident Inspector Trojan Nuclear Plant 8904200319 890414 PDR ADOCK 05000344

% I i Q PDC g g 121 S W Salmon St'eet Port and. Oregon 97204

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Trojtn Nuclasr Plcnt Docum2nt Control Dack' boeket 50-344 Attachment License NPF-1 April 14, 1989 Page 1 of 7 REPLY TO A NOTICE OF VIOLATION VIOLATION A Title 10 to the Code of Federal Regulations, Part 50.9 (10 CFR 50.9) states, in part:

"Information provided to the Commission by . . .a licensee . . . shall be complete and accurate in all material respects."

Contrary to the above, on February 2,1989, the inspectors found that Plant Operations Test (POT) Procedure 26-2, Revision 24, " Process Radiation Monitor Calibration," had not been changed as stated in Licensee Event Report (LER) 88-49, Revision 0, " Partial Containment Isolations Result From Signal Spike and Operator Error," dated January 26, 1989.

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

REPLY TO VIOLATION A Portland General Electric (PGE) Company acknowledges the tiointion.

1. Reason for Violation:

The reason for the violation was personnel error. The statement in LER 88-49 was based upon input provided by the Chemistry Branch Manager. This input was incorrect due to miscommunication between the Chemistry Branch Manager and a member of his staff and the mana-ger's failure to verify that the change to POT-26-2 was complete.

2. Corrective Steps Taken and Results Achieved:

a. On February 2,1989, a temporary change to POT-26-2 was immedi-ately implemented which appropriately revised the procedure as described in LER 88-49.

b. On March 23, 1989, Revision 25 to POT-26-2 was approved, which incorporated the temporary changes.

c. The procedure providing guidance for writing LERs, Nuclear Safety and Regulation Instruction (NSRI) 900-2Q entitled "Licenseo Event Report Preparation and Review," was changed on February 11, 1989 to specifically require obtaining the proco-dure revision number and date when making statements in an LER that a procedure has been changed.

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d. .The importance of ensuring that-information! Provided to tts NRC be complete 'and ~ accurate .was: reemphasized with. the' appropriate l personnel involved. In' addition,-'a February 15, 1989 memorandum'-

was issued by.the Vice President, Nuclear to all managers and

l. . supervisors stressing the importan'ce of ensuring that' information be verified'as accurate-and complote,

3. . Corrective Steps ThatlWill be Taken to' Avoid Further Violations:

E All' corrective' steps have been completed. . Continued : n:anagement attention will be provided'to ensure thatlthese' corrective steps.are-effective.

'4. Date When. Full Compliance Will Be Achieved:

-FullL compliance has been. achieved.

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' Trojan Nuclear Plent Docum:nt Control'Dask Docket 50-344 Attachment License NPF-1 April 14. 1989 Page 3 of 7 VIOLATION B Title 10 to the Code of Federal Regulations, Part 50 (10 CFR 50), Appen-dix 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 accomplished in accordance with these instructions, procedures, or drawings."

1. Periodic Instrument and Control Test (PICT)-5-2, " Steam Generator Level, Protection Set II," Revision 12, approved August 26, 1988, requires, in part, the use of multiple photocolls associated with the comparator logic tester and the use of a simulated test signal initially set at five volts, decreased to one volt while recording 1 applicable bistable actions, and then increased while recording applicable bistable actions.

Contrary to the above, on February 2,1989, test personnel performed the test in a manner inconsistent with the procedure, in that only ,

one photocell associated with the comparator logic tester was used and the siniulated test signal was ramped down and up in a staggered fashion to obtain data for each bistable action until the signal was decreased to one volt.

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

2. Licensee Quality Inspection Procedure (QIP) 15, "QI observations of I&C Calibration Activities," Revision 0, approved January 4, 1989, specifies in part, that the quality control inspector shall note whether work was performed in accordance with approved instructions, procedures, and/or technical manuals to assure that Plant proce-dures, work package instructions, and installation standards are followed. 1 Contrary to the above, on February 2,1989, a quality control l inspector failed to note and document failures to follow approved procedures during the performance of channel functional testing of steam generator water level instrumentation per licensee procedure PICT-5-2.

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

3. Licensee Plant Safety Procedure (PS) 3-30, Revision 17,Section IV Item E. states: "It is the responsibility of the person accepting the equipment clearance to check the equipment clearance and assure himself that the equipment is satisfactorily tagged and the equip-ment is deenergized and cleared for work before starting work."

Further, licenseo procedure Administrative Order (AO) 3-9,

E Trojen Nuclear Plant Docum:nt Control Dack Docket 50-344 Attachment License NPF-1 April 14, 1989 Page 4 of 7 Revision 26,Section I, Item 4. states: "The assigned craftsman /

technician performs the maintenance prescribed by the MR work instructions and documents its completion in the work performed section of the MR."

Contrary to the above, on February 12, 1988, a Maintenance craftsman replaced the charcoal adsorber in the "B" Train of the containment Hydrogen Vent System that was not tagged out or cleared for work, and failed to replace the charcoal adsorber of the "A" Containment Hydrogen Vent System specified in MR work instructions.

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

TUPLY TO VIOLATION B.1 DE acknowledges the violation.

1. Reason for the Violation:

The reason for this violation is personnel error. Personnel failed to follow the procedure exactly as written, and assumed that actions that were technically equivalent to the steps in the procedure could be substituted without making a procedure revision or deviation.

Subsequent review found that the problem of not connecting the comparator photocell to the light specified in the procedura was common to other procedures. In addition, the practice of raising and lowering the test signal when all photocells were not operable was a common past practice.

2. Corrective Steps Taken and Results Achieved:

All PICTs were reviewed to determine where a similar problem existed. A procedure deviation was made to all applicable proco-dures to correct the photocell location and to permit the test signal to either ramp continuously up and down, or to be stepped at the discretion of the technician performing the test. This action was completed on February 27, 1989.

Management expectations for limitations on procedure flexibility were discussed with Maintenance electrical and instrumentation and control (I&C) personnel and their supervisors. Personnel were advised that technical or electrical equivalency is not sufficient justification for not following the procedure as written. If an equivalent method is to be used, the procedure or work instruction must be changed to reflect it. This was also discussed with temporary Maintenance employees that are being used for the .

1989 nutage.

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

The lessons learned from this event will be incorporated into the Periodic Maintenance Retraining Program. This will be completed before the next session scheduled to begin in September 1989.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

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' boeket 50-344 Attachment License NPF-1 April 14, 1989 Page 6 of 7 REPLY TO VIOLATION B.2 PGE acknowledges the violation,

1. Reason for the Violation:

The reason for this violation is personnel error. The quality control inspector failed to recognize the procedural noncompliance because he had not adequately reviewed the PICT-5-2 procedure ahead of time and did not have a copy of the procedure with him while observing the channel functional testing. The inspector was notified of his assignment to perform the observation only a few j minutes before the testing was to begin.

2. Corrective Steps Taken and Results Achieved:

a. Management expectations of the role of quality control inspec-tions in verifying procedural compliance were discussed with all inspectors. It was emphasized that verification of procedural compliance requires that the inspector be familiar with the procedure and have a copy with him during the observation.

Subsequent PICT observations performed by quality control inspectors have been observed by nmnagement to ensure that expectations are implemented,

b. Scheduling of PICT observations has been improved. Inspectors are now assigned to specific PICT observations well in advance, allowing adequate preparation time.

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

a. Electrical quality control inspectors will participate in the classroom training sessions of the I&C technician quarterly training program to improve the inspectors' knowledge of I&C  !

activities. Participation in this training is scheduled to begin in September 1989.

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b. All electrical quality control inspectors will attend formal )

observation training by August 1, 1989.  !

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved. l l

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Docket 50-344 Attachment h License NPF-1 April 14, 1989 Page 7 of 7 REPLY TO VIOLATION B.3 PGE acknowledges the violation.

1. Reason for the Violation:

The reason for this violation is personnel error. The replacement of the charcoal adsorber for the "A" Containment Hydrogen Vent System was to have been performed under a clearance accepted.by the system engineer. The system engineer had verified that the equip-ment was tagged, deenergized, and cleared for work. However, miscommunication between the system engineer and the maintenance craftsman resulted in the craftsman replacing the "B" charcoal adsorber. In addition, the craftsman did not have a copy of the Maintenance Request (MR) with him When performing the work, and relied solely on verbal instructions from the system engineer.

2. Corrective Steps Taken and Results Achieved:

a. Upon discovery on February 23, 1988 that the "B" charcoal adsorber had been replaced, the "B" Containment Hydrogen Vent System was placed in an inoperable status. On July 1, 1988, during the annual refueling outage, the required operability testing was performed on the "B" charcoal adsorber with satisfactory results. The system was returned to operable status.

b. The craftsman received additional instruction on the need to carefully read and follow instructions when performing work l

under an MR. The engineer received additional training on the necessity of being certain that verbal or written instructions are clear, complete and, where required, reference specific component identification numbers.

c. Maintenance personnel have received training on AD 3-9,

" Maintenance Requests," specifically relating to verbal instruc-tions. Emphasis was placed on properly documenting verbal instructions,

d. Maintenance personnel are now required to have a " field copy" of the MR at the worksite to assure that the procedures are followed and there is no confusion as to the instructions, procedures or intent of the MR.

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

All corrective steps have been completed.

4. Date When Full Compliance Will Be Achieved:

Full compliance has been achieved.

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