IR 05000344/1988030
| ML20235G617 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/31/1989 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8902230311 | |
| Download: ML20235G617 (1) | |
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J MI 3 1 1933 Docket No. 50-344 Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Attention: Mr. David W. Cockfield Vice President, Nuclear Gentlemen:
Thank you for your letter dated January 6,1989, in response to our Notice of Violation and Inspection Report No. 50-344/88-30, dated December 2, 1988, informing us of the steps you have taken to correct the items which we brought to your attention. Your corrective actions will be verified during a future inspection.
Your cooperation with us is appreciated.
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Sincerely, hrM R. P. Zimt6erman, Chie'f
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Reactor Projects Branch ..
bec w/ copy of letter 1/6/89:
docket file State of Oregon A. Johnson G. Cook B. Faulkenberry J. Martin Resident Inspector Project Inspector J. Zollicoffer . -/ . (k n . , qy M. Smith g. [ u gC' 4 Q)
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David W. Cockfield Vice President, Nuclear y 3.o no 40 : 39 99 .
January 6, 1989.
Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sir:
Reply to a Notice of Violation Your letter of December 2,1988 transmitted a Notice of Violation associated with Nuclear Regulatory Commission (NRC) Inspection Report No. 50-344/88-30. Attached is our response to that Notice of Violation.
This response is being submitted late due to the extensive nature of the response and the absence of personnel over the holiday period. This delay was discussed with the Region V staff.
l Your letter also requested comment on other issues identified in Section 4 of the inspection report. As previously discussed with the NRC Region V staff, our comments on those issues will be forwarded by February 3, 1989.
Sincerely,
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Attachment
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c: A r. John B. Martin l Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon l Department of Energy j
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l Mr. R. C. Barr NRC Resident Inspector !
Trojan Nuclear Plant {
l 121 S W Salmon Street, Portland. Oregon 97204
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Trojan Nuclose Plant Document Control Desk I
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License NPF-1 January 6, 1989 )
- . Page 1 of 16 REPLY TO A NOTICE OF VIOLATION VIOLATION A Trojan Technical Specification 4.0.5 states, in part, that " Inservice -
. . . testing of Class 1, 2, and 3 pumps and valves shall be performed in )
accordance with Section XI of the ASME Boiler and Pressure Vessel Code". I 1. Subsection IWP-4140 of the ASME Code requires " Instruments . . .
shall be calibrated either prior to the establishment of reference quantities or on a regular basis as established by the owner".
Contrary to the above: As of October 6, 1987, flow indicators for h service water pump bearing water (FI-3705A, B, C) were not cali- (
brated prior to the performance of any inservice testing of the service water pumps (test procedure POT 7-1). A regular basis had s'
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not been established. >
2. Subsection IWA-5300 requires, in part, that "The record of the a visual examination conducted during a system leakage test . . .
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shall include the procedure documenting the system test condition l and system pressure boundary. Any source of leakage or evidence of structural distress shall be itemized and the location and corree- .
tive action documented".
Contrary to the above: As of September 27, 1988, records had not -
been maintained of post-maintenance testing of service water strainer F-101A after reassembly of the strainer on August 22, 1988.
This is a Severity Level V violation (Supplement I).
Reply to Violation A.1:
Portland General Electric (PGE) Company acknowledges the violation.
1. Reason for Violation:
The reason for this violation is personnel error in that the flow instruments were not included in a calibration program. Since the vendor manual for these instruments indicates that calibration adjustments are not provided, it was concluded that the instruments do not require calibration. The vendor manual stated the instru-ments should be inspected and cleaned periodically to maintain meter accuracy. This requirement, however, had not been included in the Preventive Maintenance Program and, as a result, also had not been performed.
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< Trojan Nuclear Plant Document Control Dask
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2. Corrective Steps Taken and Results Achieved:
The instruments have been scheduled for inspection and cleaning during the next maintenance outage on each train.
3. Corrective Steps That Will Be Taken to Avoid Further Violations:
a. The instruments will be inspected and cleaned, and periodic inspection and cleaning requirements will be included in the Preventive Maintenance Program by January 31, 1989.
b. The need for and feasibility of sending these instruments to a vendor for calibration will be evaluated. If practical, the instruments will be calibrated during the next refueling outage in 1989. If calibration is not practical, they will either be replaced with calibrated instruments or, another alternative, such as a code exemption, will be considered. Action to resolve this item will be completed by July 1, 1989.
c. Other instruments of this type used in quality applications will be reviewed to ensure that a similar problem does not exist.
This review will be completed by January 31, 1989.
4. Date When Full Compliance Will Be Achieved:
The Plant will be in full compliance by July 1, 1939 following reso-lution of the calibration and concern described in Item 3.b. above.
Reply to Violation A.2:
PGE acknowledges the violation.
1. Reason for Violation:
The reason for this violation is personnel error. The Maintenance Request (MR) for this work required an observation of the strainer for system leakage following its return to service. The inspection was performed; however, the individuni failed to document it on the MR. This error was compounded by the fact that the MR was not closed following completion of the work duo to the identification of addi-tional work to be done on this component.
Although the required test was performed, the post-maintenance testing requirements did not specify the system test condition or boundary as required by Section II of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. This error resulted from the Maintenance planner not recognizing the repair was a Code repair. Therefore, the MR was not reviewed by the Welding, Repair and Replacement Group who are responsible for ensuring Code requirements are met.
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2. Corrective Steps Taken and Results Achieved:
a. The individual who performed the work was contacted and confirmed that an inspection of the gasket for leakage was performed af ter the strainer had been returned to operation.
This inspection has now been documented on the MR. The res-possibility for properly documenting inspections was emphasized .
to the worker, b. It has been a past Maintenance practice to keep MRs open follow- j ing the completion of the initial work if a new problem is q i
identified. This practice has resulted in the lack of a timely review of the completed work by'the work group supervisor and I the Plant Shift Supervisor. This practice has been stopped. In j this case, a review by these individuals could have identified the failure to properly document inspection results. Mainten-ance work group supervisors and planners have been instructed to close the original MR and issue a new MR to document additional work that is unrelated to the original problem.
c. The reason for the subject repair being a coda repair was reviewed with the Maintenance planning staff. Additionally, the detail required in work instructions was reviewed.
3. Corrective Steps That Will Be Taken to Avoid Further Violations:
The Nuclear Quality Assurance Department will review the issue of MR l closure by February 15, 1989 to ensure that the changes made have been effective.
4. Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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VIOLATION B Technical Specification 6.2.2.g. states, in part,'that:
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" Administrative procedures shall be developed and implemented to limit the working hours of . . . key maintenance personnel of the unit staff . . . during extended periods of shutdown for refueling, major maintenance or major Plant modifications, on a temporary basis, the following guidelines shall be followed: . . . An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven-day period, all excluding shift turnover time . . . Any deviation from the above guidelines must be authorized by the Plant General Manager, or, in his absence, Duty Plant Manager, or higher levels of management, in accordance with established procedures and with documentation of the basis for granting the deviation".
Trojan Administrative Order (AO) 3-1 implements these requirements.
Contrary to the above, during the forced outage that occurred from September 16 through September 23, 1988, management did not review, approve and document planned overtime as follows:
1. Key members of the mechanical maintenance service crew, performing a pressure boundary repair on a safety injection check valve, worked in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, excluding shif t turnover time, in a seven-day period (a journeyman machinist worked up to 82 hours9.490741e-4 days <br />0.0228 hours <br />1.35582e-4 weeks <br />3.1201e-5 months <br /> during September 16-22) and in excess of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, excluding shif t turnover time, in a 48-hour period (a principal mechanic worked up to 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> during September 16-17).
2. Members of the mechanicci maintenance service crew, performing service water flushes of safety grade equipment coolers, worked in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, excluding'shif t turnover time, in a seven-day period (the lead mechanic worked 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> during September 17-23).
This is a Severity Level IV Violation (Supplement I).
Reply to Violation B:
PGE acknowledges the violation.
1. Reason for Violation: i The reason for this violation is personnel error.
Maintenance Department supervisory personnel did not adequately monitor the overtime of personnel to ensure they did not exceed work-hour limitations as required by the Technical Specifications and Administrative Order (AO)-3-1, " Shift Complement and Work Tine". A contributing cause was that adequate administrative controls were not in place to monitor the overtime, t
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l Additionally, Plant management failed to implement lessons learned from a similar event during the 1988 refueling outage so as to ,
prevent a' recurrence. I l
The earlier event was incorrectly assumed to be an isolated event l
and the corrective action was not applied to all work groups. The evaluation of the earlier event was inadequate, as it did not l identify that other work group overtime controls were inadequate to I prevent excessive overtime.
i 2. Corrective Steps Taken and Results Achieved:
a. This event was reviewed with Maintenance Department Supervisors to clearly emphasize their accountability for ensuring that work-hour limitations are strictly enforced. The Technical Specification limits were also discussed with Maintenance personnel to make sure they are aware of the limits and inform their supervisor if they are likely to exceed them.
b. A system to assist Maintenance supervisors in maintaining con-trol of work hours has been established. Workers will report overtime daily to a clerk who will check to determine if they are at risk of exceeding their work-hour limits. When indivi-duals approach the limits, the supervisors will be alerted in time to avoid further violations, c. Maintenance management has reviewed the hours worked during the last forced outage and determined that work-hour limitations l were followed.
d. The Plant General Manager issued a memorandum directing all managers to review their controls on work-hour limits and to establish measures appropriate for their work functions to ensure limits are not exceeded.
e. The need to address problems as potential generic issues and not isolated events was discussed with division personnel by the Vice President, Nuclear at recent meetings. The accountability of management to ensure that events are properly evaluated and complete corrective action taken to prevent recurrence was emphasized.
3. Corrective Steps That Will Be Taken to Avoid Further Violations:
The Nuclear Quality Assurance Department will perform a review of work-hour limitations to ensure that limits are not being exceeded and that proper administrative controls are in place in each work group to prevent exceeding those limits. This review will be completed by March 31, 1989.
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Document Crntral De k S< l Dicipt. 50-344 - Attcchment-
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.4.> Date of Full Compliance:
Full compliance has been achieved, s-
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Trojan Nuclear Plant Docum:nt Control Dask
' Docket 50-344 Attachmsnt Li' cense NPF-1 January 6, 1989
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Page 7 of 16 VIOLATION C Trojan Technical Specification 6.11 requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.
1. The Trojan Radiation Protection Manual,Section II.B.1.b., Digital Alarming Dosimeters (DADS), states in part, that the DAD is to be returned to the Radiation Protection dosimetry office each time the worker leaves the controlled access area. Radiation Protection Procedure RP109, Personnel Dosimetry Program,Section V, Digital Alarming Dosimeter (DAD), states, in part, " Personnel issued a DAD must return it to the point of issue immediately upon exiting the radiologically controlled area".
Contrary to the above, on September 27 and 30, 1988, and as general practice, personnel did not return their DADS each time they exited the radiologically controlled area.
2. The Trojan Radiation Protection Manual,Section II.D.2.d. , High Radiation Areas, states, in part, " Areas not routinely surveyed require a survey by a Radiation Protection Technician to enter".
Contrary to the above, on October 4, 1988, two reactor operations personnel entered a high radiation area that was not routinely surveyed, without first obtaining the required survey by a Radiation Protection Technician.
This is a Severity Level IV Violation (Supplement IV).
l l Reply to Violation C.1:
PGE acknowledges the violation.
1. Reason for the Violation:
The reason for the violation was personnel error in that the Radia-tion Protection (RP) Branch Manager directed RP technicians and dosimetry clerks to allow certain personnel to exit the radio-logically controlled area without returning their DADS. These exceptions generally involved workers required to make frequent entrances and exits due to specific work requirements. The RP Branch Manager allowed these exceptions without processing a deviation to the procedure as required. In addition, the RP technician and clerks did not effectively limit exceptions to specific workers, but rather began to allow the exception to become a general practice for most workers.
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2. ' Corrective Actions Taken and Results Achieved:
.a. The practice of allowing exceptions to this requirement has.been terminated. ' All personnel are required to turn _in their DADS when exiting the radiologically controlled area.
b. ' Signs reminding workers of the requirement to turn in their DADS.
have been prominently posted in the access control area, c. The Radiation Protection Branch Manager has been admonished for his poor judgment in directing that exceptions to a Plant' pro-cedure be allowed without properly changing the procedure.
d. The RP' technicians and dosimetry clerks have been instructed in the need for compliance with this procedural requirement and in
.the reasons.for the requirement. In-addition, the technicians and clerks were' encouraged to challenge instructions which
. appear to conflict with specific procedural requirements and to resolve.these discrepancies prior to proceeding further.
As' a result of corrective actions taken, Plant personnel are.now turning in their DADS when exiting the radiologically controlled area. One isolated' instance was noted on a weekend backshift Where two workers exited without turning in their DADS. In this instance, the workers were required to immediately return their DADS and their supervisors were notified so that appropriate management action could be taken.
3. Corrective Steps That Will Be Taken To Avoid Further Violations:
H a. Computer-transactions will be monitored to determine Which, if any,-individuals are keeping DADS checked into the controlled
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area for extended periods of time. Individuals Who continue to
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violate the requirement will be reported to their supervisors for appropriate disciplinary action.
L j b. In addition, it is recognized that individuals performing cer-E tain specific tasks (e.g., roving 1-hour fire patrol, Auxiliary Building operators) might face time constraints that would prevent them from performing their jobs properly, especially
!. during outage periods when congestion at the entry / exit points 1. nay occur. Plant procedures will be revised to allow specific l; exceptions When absolutely necessary.
l l 4. Date When Full Compliance Will Be Achieved:
Full compliance has been achieved as noted above. The revision to the procedure to allow specific exceptions will be completed by January 15, 1989, l~
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January 6, 1989 Page 9 of 16
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Reply to Violation C.2:
PGE acknowledges the violation.
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1. Reason for the Violation:
The' reason for the violation is personnel error. A licensed operator and an operator trainee entered the seal water heat exchanger room without complying with the posted instructions-to notify Radiation Protection prior to entry.- The operators involved had the proper dosimetry and monitoring equipment and were aware of the notification requirement, but forgot to make the required, notification prior to entry.
'2. Corrective Steps Taken and Results Achieved:
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This event was reviewed with the operators involved and disciplinary action was taken. The Operations Supervisor made a Night' Order entry to remind all Operations personnel of'the need to be aware of and follow Radiation Protection postings. In addition, Plant per-sonnel were reminded that most Radiation Work Permits require the worker to check in with Radiation Protection before going to work.
3.- Corrective Steps That Will Be Taken to Avoid Further Violations:
All corrective action for this violation has been taken.
4. Date'of Full Compliance:
Full compliance has been achieved.
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l VIOLATION D 10 CFR 50, Appendix B, Criterion V and Section 5 of the Trojan Nuclear Quality Assurance Program require, in part, that activities affecting q 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.
1. Administrative Order (AO) 13-5, " Installed Instrumentation Calibra-tion Control Program", states in Section II.C.4.a. that, "When an instrument used to obtain quantitative data for a quality-related ,
test is found to be out-of-calibration, he (the responsible super- l visor) shall ensure an investigation is performed and documented to i determine the validity of previous test results or the acceptability I of previously tested equipment which utilized this instrument during I the interval in question".
l Contrary to the above: On December 5, 1986 and February 15, 1988, river level recorder LR-5521 was found out of calibration, but the required investigations were not performed and documented to deter- ,
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mine the validity of previous test results. Recorder LR-5521 was used in test POI 7-1, " Service Water", to obtain quality related !
quantitative data for use in calculations of differential pressure to establish Service Water pump operability in accordance with 1 Technical Specification 4.7.4.2.
2. The Trojan Nuclear plant Administrative Order A0-7-1, " Plant j
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Records", Fm tion II.A. states, in part, that a document becomes a Quality As x.e record When it is completed and approved. Items B and C state, in part, that satellite files of Quality Assurance Records arte maintained in two-hour fire-rated cabinets prior to their transfer to the permanent record storage facility in the Technical Suppe:. Center vault.
Contrary to the above: On September 29, 1988, the licensee main- l tained Waste Gas Decay Tank Discharge parmits Nos. G-32-88 through G-35-88, dated July 1, 5, and 14, and August 30, 1988, respectively, in temporary storage that were not protected from loss
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due to fire in two-hour fire-rated cabinets.
3. Administrative Order A0-4-2, dated August 31, 1988, " Procedural Compliance", states in Section 4.2: "If the POM (Plant Operating Manual) procedure . . . cannot or should not be performed as written j
. . . then the user shall immediately . . . stop the activity
. . . and resolve the problem . . . "
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'Dockst 50-344 Attachment-Licente WPF-1 January 6, 1989 l Page 11 of 16 Contrary to the above: From June 14 1987 to October 1, 1988,'Oper-ating Instruction 01-4-3, " Service Water' System", Section 1.2.4,-
could not be performed as written and the problem was not resolved.
Section 1.2.4 states, " Maintain bearing lube water to the service water pumps at 5 psig and 10 gpm (30-35% by FI-3705A, B, and'C)".
Between-June 14', 1987 (as documented in Maintenance Requests 87-3899, -3900, and -3901) and October 1, 1988 (when observed by an NRC inspector) flow to the Service Water pump bearings was 26% or less.
4. Trojan Administrative Order A0-12-4, " Material' control and Identi- I fication", states: " Periodically, as determined by Storeroom Practice Instructions, the Storekeeper shall perform and document periodic checks to ensure that the quality of' items and their con-tainers is being maintained. These checks will include . . . desic-cants.. . .-shaft turning on rotating equipment . . . insulation resistance checks". Storeroom Practice SP-4, " Physical Inventory and Storeroom Checks", dated June 8, 1987,Section IV requires
"large rotating equipment . . . will be checked every six months ,
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. . . and the rotating elements turned by hand".Section VII requires an annua 1' inspection and energization of the spare Source-Range Drawer.
Contrary to the above: As of October 4, 1988, periodic checks and preventive maintenance, in accordance with A0-12-4, had not been performed for many items in storage 'in the Trojan warehouse, includ-ing the annual energization of the Source-Range Drawer (last performed August 6, 1987).
This is a Severity Level IV Violation (Supplement I)
Repiv to Violation D.1:
PGE acknowledges the violation.
1. Reason for the Violation:
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The reason for the violation is personnel error. The initiation of an out-of-calibration form is the responsibility of the Instrumen-tation and Control (I&C) Supervisor. The initiation is based on his review of the calibration data and a determination of whether the instrument is used to obtain qualitative data for a quality-related test. A list of instruments that are used for Plant test programs is used to make that determination. In reviewing the calibration information for LR-5521 on December 5, 1986 and February 15, 1988 to f determine if an out-of.. calibration investigation was required, the j I&C Supervisor failed to use the list in his review. As a result, a i l
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Page 12 of 16 form was not generated to prompt the required investigation. A subsequent review of the instrument list confirmed that LR-5521 was included on the list.
2. Corrective Steps Taken and Results Achieved.
a. This problem was reviewed with the I&C Supervisor and he was admonished for his inattention to detail in carrying out his responsibilities for this program.
b. A review of recent surveillance test data indicated that Periodic Operating Test (POT)-7-1 has been performed with ;
satisfactory results and with LR-5521 in-calibration since the ;
last out-of-calibration occurred in February of 1988.
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c. A review of the information used to make out-of-calibration ,
investigation determinations was performed. This review . l
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determined that the instrument list being used was compiled by Plant Engineering in 1986 and is not formally controlled or ,
maintained current. Since the instrument list is not controlled j or routinely updated, its use has been terminated. Instead, the l I&C Supervisor will prepare an out-of-calibration form for all quality-related instruments that are found to be out-of calibra-tion. These will be forwarded to the system engineering group for an out-of-calibration evaluation, as appropriate.
d. I: expectations to aggressively identify and correct problems were discussed with Nuclear Division managers and supervisors as part of the Trojan Excellence Program and during recent expectation meetings with the Vice President,-Nuclear. These expectations were further reinforced with Maintenance Department supervisors during a subsequent meeting with the Vice President.
3. Further Corrective Action:
The method for determining the need for out-of-calibration investi-gations will be further evaluated. Any changes to the program will be implemented by June 30, 1989. l
! 4 Date of Full Compliance:
Full compliance has been achieved.
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Page 13 of 16 Reply to Violation D.2 PGE acknowledges the violation.
1. Reason for the Violation:
The reason for the violation is personnel error. The Effluent Analyst responsible for the' Waste Gas Decay Tank discharge permits was not adhering to the requirement in Administrative Order (AO)-7-1 to transfer completed Quality Assurance (QA) records to the Technical Support Center (TSC) vault within 60 days of completion. Thus, the permits were maintained in temporary storage that did not meet the 2-hour fire rating beyond the 60-day period allowed by the procedures.
Long-term storage of QA records in satellite files was discontinued in 1984, and all files kept in such storage were transferred to the j TSC vault. In the intervening years, the Sffluent Analyst had becomo complacent in his compliance with the A0-7-1 requirements, and allowed records to be kept at his workstation for periods greater than permitted by the procedure. His supervisor, the Chemistry Branch Manager, had not reinforced the requirements for the proper storage of records, nor audited the Chemistry Department for compliance in this area. The Chemistry Branch Manager was unaware of the improper storage of the completed records.
2. Corrective Steps Taken and Results Achieved:
a. Appropriate disciplinary action was taken with the individual Who failed to adhere to procedural requirements.
b. The specific violation war discussed with the Chemistry Depart-ment staff in morning meetings in October 1988 and again on Decerber 20, 1988. All Chemistry personnel were reminded of the requirements for the proper storage of QA records (as found in '
l A0-7-1), and all completed QA records were transferred to the TSC vault. The Effluent Analyst was directed by the Chemistry Branch Manager to copy necessary logs and forms, and not to keep original QA records for more than 60 days after completion.
c. A check of Chemistry Department files was performed on December 20, 1988 which verified that QA records were no longer being improperly stored.
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Trojtn Nuc1Str Picnt Document C:ntrol D Ik
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3. Corrective Steps That Will Be Taken To Avoid Further Violations:
A task force will be formed to look at the generic issue of handling QA, records throughout the Nuclear Division. This group will recom-mend corrective actions.(if needed) to prevent potential loss.of irretrievable data. The task force will make its recommendations by January 20, 1989. The recommendations will then be evaluated by management. A schedule for implementation of the approved actions will be developed and tracked on the Commitment Tracking List.
4. Date When Full Compliance Will Be Achieved:
Full compliance has been achieved. I Reply to Violation D.3 PGE acknowledges the violation.
1. Reason for the Violation:
The reason for the violation is lack of adequate management over- !
sight to ensure that Plant problems and discrepancies are resolved.
In this instance, evidence of problems with low-bearing lube water flow to the service water pumps had been identified several times in the past. Maintenance Requests (MRs) had been issued on August 13, 1986 and June 14, 1987 identifying the need to correct low-flow conditions. While some corrective work was performed under each HR, the action was ineffective and the long-term implications were not considered. Plant Engineering was aware of the situation; however, a formal request for evaluation was not issued. The MRs from 1987 were held open for further resolution, but neither the status of corrective action or its priority were followed. As a result, the problem recurred several times.
The lack of a trending program for maintenance history, and an inadequate system for monitoring and tracking open MRs contributed to this violation.
2. Corrective Steps Taken and Results Achieved:
a. The cyclone separators, the source of the lube water flow to the l service water pump bearings, were cleaned and the flows increased to above 10 gallons per minute (gpm).
b. An evaluation of required lube water flow to the pump bearings has determined that a wider range of flows is acceptable to ensure adequate cooling for the bearings. As a result, a devi-ation to Operating Instruction 01-4-3 has been implemented which revises minimum required lube water flow to 5 gpm.
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c. Expectations to aggressively identify and correct problems were discussed with Nuclear Division managers and supervisors as part of the Trojan Excellence Program and during recent expectation meetings with the Vice President, Nuclear. These expectations were subsequently reinforced with both Maintenance and Opera- l tions supervisors. In particular, Operations was instructed to l make procedure revisions when operating parameters are outside of prescribed limits for extended periods and appropriate evaluations indicate that continued operation under those conditions is acceptable.
3. Corrective Steps That Will Be Taken to Avoid Further Violations:
a. Periodic cleaning of the separators will be added to the Preven-tive Maintenance Program by January 31, 1989.
b. A formal revision to OI-4-3 will be implemented by January 31, 1989.
c. A long-term program to improve maintenance history and trending is scheduled to begin in March 1989. As historical data is accumulated under this program, we expect to improve our ability to identify and correct recurring maintenance problems.
d. An improved system for tracking and monitoring the status of open MRs is being developed and will be in use by February 15, 1989.
4. Date of Full Compliance:
Full compliance has been achieved.
Reply to Violation D.4 PGE acknowledges the violation.
1. Reason for the Violation:
The reason for the violation was personnel error in that warehouse personnel failed to comply with the requirements of Administrative Order (AO)-12-4 and lower-tier procedures. Contributing to this procedural compliance deficiency were two f actors:
a. Lower-tier procedures established in 1987 are cumbersome and difficult to understand, b. No formal support program was developed to ensure that compli-ance was achieved, such as a preventive maintenance scheduling system.
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Trojtn NucicCr Plcnt' Document Contr21 Dehk Docket S0-344 Attcchment j
,Li*tenke NPF-1 January 6, 1989
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I In addition, the need for an improved preventive maintenance program was recognized by Material Management Department supervisors and included in a long-term improvement action plan for completion by 1990. However, the responsible supervisors failed to take appro- ;
priate interim measures to correct the noncompliance that existed.
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k 2. Corrective Steps Taken and Results Achieved: I a. All materials requiring desiccants have been-inspected and where necessary, desiccants were replaced. This was completed on October 6, 1988.
b. Shaft rotation maintenance has been performed on all equipruent and material requiring such preventive maintenance. This action was completed on October 6, 1988.
c. Electrical energization of materials requiring such preventive ;
maintenance'was completed November 8, 1988.
d. Meggering of motoring requiring such preventive maintenance was completed October 18, 1988, e. Examination of inventory items for shelf-life was completed by December 31, 1988.
f. A review of the Trojan Materials Management Department improve-ment action plan was performed to identify any other programs Which are not receiving the correct priorities. No other problems were identified.
3. Corrective Steps That Will Be Taken to Avoid Further Violations:
a. Procedures for a comprehensive preventive maintenance program will be developed and fully implemented by January 16, 1989.
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Thess will include lower-tier procedures Which will provide clear direction for warehouse personnel. Training will be provided for warehouse personnel prior to implementing the procedures.
b. The Preventive Maintenance Program will utilize a computerized )
system to track preventive maintenance actions required to maintain material. This program will provide a formalized notification process to alert maintenance crews and warehouse management when action is required.
4. Date When Full Compliance Will Be Achieved:
Full compliance has been achieved. l l
DLN/mr/2739W.1288
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