IR 05000344/1990011
| ML20055J352 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/27/1990 |
| From: | Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cross J PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 9008020135 | |
| Download: ML20055J352 (1) | |
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, h-DLL2 7.1990
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Docket No. 50r344
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Portland General Electric-Company.
TrojanNuclearPlant 71760 Columbia River Hwy.
Rainier, Oregon 97048 l
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' Attention:
Mr. J. E. Cross.
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Gentlemen:
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.Thank you for your-letter of July 6,1990;/90-11,-in response to our Notice of
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Violation and Ins 1ection Report No. 50-344
- dated June 7,hich we brought 1990,.
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informing us'of tie steps you have taken to correct.the items w to your attention.
Your corrective; actions..will be verified during-a future
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Yourcooperationwithus(isappreciatede
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Sincerely,
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[kM h$Mosh '
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SFA.RichArdscChief
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ReactorProjects' Branch.
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bec w/ copy of ltr dated'7/6/90:
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Docket File *
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Resident Inspector-
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ProjectInspector;
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'G.
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'B. Faulkenberry
J. Martin
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.bec w/o copy'of Itr dated 7/6/90:.
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M. Smith
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REGION V
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BJ01 son (ED PMorrill-SARichards
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~7/T1/90 7 /f4/90
L (REQUESICOPY
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Q-QUESTCOPYJ-RE ST COPY.
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YES'i / N0 SV /D N0 j YES / NO
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4mmm om PDR ADOCF m60
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en Portland Cwwieral ElectricCuisW
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July 6, 1990-l Trojan = Nuclear Plant, Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Conunission'
Attna Document Control Desk-l Washington DC' 20555.
Dear Sirs -
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Recir to a Motion of Violation-
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i Your. letter of June 7, 1990 transmitted a Notice of Violation (NOV)-
, associated with Nuclear Regulatory. Comuniss1on (NRC) Inspection Report 50-344/90-11'.
Attachment 1 to this~1etter contains Portland General lj[
Electric Company's (POE's) response' to the violation contained in' the
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inspection report. Please note your inspection report Appendix.A; j
references Corrective-Action Request (CAR) C90-3075.. The. correct' CAR number pertaining to the WOV (90-11-02) is CAR C90-3073. We-have'
d incorporated this correction into our !!OV Response, j
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Sincerely
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j T. D. Walt'
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Acting Vice President, Nuclear i
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Mr. John B. Martin
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Regional Administrator Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith
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State of Oregon Department of Energy Mr. R. C. Barr
WRC Resident Inspector Trojan Nuclear Plant g,.__
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Trojan Nuclear Plant LDocument' Control Desk
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Docket 50-344-July 6. 1990
. License WPF-1 Attachment 1-
'Page 1 of 5L FEPLY TO A NOTICE OF VIOLATION-yjolation A Title 10. of-the Code of Federal Regulations, Part 50 (10 CFR 50),
Appendix B, Criterion V,Jstates in part:- " Activities affecting' quality-
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shall be prescrib d by documented instruction, procedures or_ drawings, of-e e type appropriate to the circumstances and shall be accomplished'in accordance with these instructions, procedures, or drawings."
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1. ' Nuclear Division Procedure (WDP) 600-0 Revision 4. " Correct'ive Action Program (CAP)," dated February 23, 1990, Paragraph A.3.3;of-Attachment H states:- "Where.the Evaluating Supervisor disagrees'with MCAC's conclusion that the condition constitutes a nonconfonaance,-
the following actions shall be taken:
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Review the CAR with NCAC and obtain concurrence that a-nonconformance does not exist and..
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Once concurrences have been acbioved, document why the noi conformance does not exist and return the CAR with concurrence from the next-higher level of management to Quality Services.
If-the nonconformance involved hardware, concurrence must also be
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obtained from the Manager,~BPB."
Contrary to the above, on April 14, 1990, the Evaluating supervisor.
i for Corrective Action Request (CAR)-C90-3073 did not perform-Paragraphs A.3.3.A and A.3.3.C of Attachment H to NDP 600-0,
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Revision 4, when he dissgreed with the Management Corrective Action Committee's (MCAC's) conclusion that C90-3073 was a nonconformance.
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Administrative Order'(AO) 13-1, " Inspection Control", Revision 6, dated March 5,1990. Paragraph 4.5.1 requires, " Prior to reaching a step which requires Quality Inspection (QI) inspection,'the asu1gned work group-supervisor or designee shall notify the Mechanical-or Electrical QIB;or designee."'
contrary to the above, on April 10, 1990, while conducting maintanance per Maintenance Request (MR) 90-0528 on MO-2053A, a designated work group supervisor did not notify the Electrical Quality Inspection Supervisor (QIs)-or designee' for the inspection hold point designated.for Step 6.b.
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A0-12-4, " Material Issuing and Installation", Revision 27, dated
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March 6, 1990. Paragraph 4.1.3.a requires. "If the identification for an item becomes lost or illegible:
the item'shall be documented and controlled as specified in NDP 600-0 (Reference 5.2.8)."
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Trojan Nuclear Plant Document Control Desk Docket 50-344 July 6,e1990-q 1.icense NPy-1=
Attachment 1; Page:2 of.5
'I Contrary to the above, on April-10, 1990, the identification of the torque switch for MO-2053A was not legible and was not controlled per NDP 600-0, i.e., CAR tag attached.-
Bosponse forJ__.l, 1.
Reason for the Violation.
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Root Cause-
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The reason for the' violation is personnel. error, failure to-follow
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the detailed steps of NDP 600-0,= Revision 4. " Corrective Action
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Program".
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.Contributina Cause
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Ineffective comununication between work groups also contributed to this event.
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The Corrective Steps That Have Been Taken and thE Results Achieved:
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CAR C90-3118 was written on Apr11 25, 1990 by the-Quality Inspections
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(QI) Branch to document that CAR C90-3073.was not processed in
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accordance with NDP 600-0 Revision.4 and to properly process'the
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concerns of CAR'C90-3073. As a result of the CAR C90-31181
' evaluation, the following corrective actions occurred:~
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The QI supervisor responsible for not following-the procedure
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requirements of NDP 600-0 Revision 4, Part A.3.3 of Paragraph H
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was counseled by the QI Branch Manager and General Manager, Nuclear Quality Assurance Department -(NQ&D) on the importance of
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procedural compliance and management expectations regarding identificatlan and resolution of Plant problems and was also discipline.a. This event and the role of the supervisor in the CiG Frogram was discussed with the NQAD mana6ers and supervisors at NQAD staff meetings. The supervisor responsible for evaluating the CAR was also counseled.on the need to return to MCAC and discuss any changes required in a CAR that MCAC has assigned, b.
procedure NDP 600-0, Section A.3.3 was revised Apell-16, 1990 to change the sequence of actions when the CAR evaluating supervisor disagrees with the NCAC's conclusion that'the condition constitutes a nonconformance. This change ensures the.
disagreement with the CAR assigned by MCAC is discussed with the initiator or the initiator's-supervisor prior to going back to MCAC for discussion of the disagreement.
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Trojan Nuclear Plant Documen't Control' Desk DockeL~$0-344 July 6,:1990.
License NPF-1 Attachment 1 Page 3 of 5-c.
The_ importance of bringing problems to management attention 'when one employee _has a disagreement with.the next level of management'
on a concern affecting the reliability or safety.of; Trojan was addressed in' a Lessons Learned Susunary April 24. 1990 by the Trojan Plant General Manager and sent to all' Buclear Division; personnel It was'emphasised that~this type of problem is the
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responsibility of management and supervisory personnel to resolve.
3.. Corrective Steps That Will be Taken to Avoid Further Violations:-
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The-generic issues that contributed to this violation will.be discussed periodically during management meetings conducted over
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the next-quarter to emphasize supervisory responsibilities with respect to the CAR Program, b.
Lessons Learned from this event will'be incorporated ~1nto'the
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Frontline Leadership training ' module on cosaunications, c.
PGE will. monitor the CAR /Rucellence Response Programs for the next six months to ensure CARS are properly addressed by Managers--
and-Supervisors.
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Date When Full Compliance Will Be Achieved:
Pull compliance was echieved when the supervisors responsible for not
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complying with the requirements of EDP 600-0 were counseled and the CAR was properly dispositioned in accordance with the procedure.
Response for A.2 1.
Reason'for the Violation:
Root Cause The reason for the violation is personnel error, failure to correctly follow the instructions of A0-13-1, " Inspection Control".
Revision 6.
The Maintenance personnel involved with-this' event were
, aware of the requirements of A0-13-l~, but incorrectly interpreted the-instructions to MR 90-0528 and did not contact QI at the intended circle Q hold point.
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Contributina Cause a.- Poorly organized work instructions contributed to the personnel error. Step 6.b "Detennine as found displacement of torque switch to be replaced using calibration tool as follows.
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Trojan ~ Nuclear Plant Document-Control Desk Docket-50-344 July,6,o1990 License NPF-1 Attachment 1 page 4 of 5
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(i.e., l'n the ' Test' Stand')" contained the' required Circle Q hold-
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point, but was listed prior to the torque switch removal-(Step 6.b.1).
Had the provisions of Step 6.b.1 beenLrepositioned in the work instructionc to precede the' " Determine as-found displacement of.the torque! switch",Lthe possibility of missing
'the Circle Q hold point could 1. eve been reducad; b.
MP 12-5.03, Revision 0, " Motor-Operated' Valves preventative
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Maintenance procedure 3-Year Inspection"., was incorrectly referenced as the procedure to use.under Maintenance Request (MR)90-528.
MP 12-5404, " Motor-operated Valves Switch Inspection. Overhaul, Replacement', and; Adjustment of Limitorque-
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- Size SMB-000 Through SMB-5".. Revision;0, was the appropriate procedure fcr this MR, 2.
The Corrective Steps That Have Been Taken and the Results Achieved:
a.
The electrical craftsmen involved with not-complying with the requirement of A0-13-1 were' counseled, May 10, 1990.
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The requirements of A0-13-1 regarding the need to notify QI l
before commencing a step with~a Circle.Q hold point:was communicated to the Electrical Maintenance Branch during shop l
meetings April 23, 1990 and again on May 3, 1990.
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A0-13-1 was revised Apr11.20, 1990Jto more clearly state when QI L
is to be-notified regarding a Circle Q hold point.- Although this concern did not contribute directly to this event, the revision to A0-13-1 that was made should eliminate any misinterpretation of the requirement.
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Corcective Steps That Will Bo Taken to Avoid Further_ Violations:
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MP 12-5.04, Revision 0, " Motor-operated Valves Switch Inspection, Overhaul, Replacement, and Adjustment for.Limitorque size SMB-000 through SMB-5", will be revised prior to performing this work
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again, i
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The Mechanical and' Instrumentation and control (I&C) Branches of-Q the Maintenance Department wil1 ~ be instructed on the revision to
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LL A0-13-1 addressing the actions to be taken concerning when'to
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L notify a QI inspector for a.QI hold point by July 31, 1990, c.
The violation associated with this inspection report will be reviewed with the Maintenance Department and plant Modifications
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Department as part of Lessons Learned Training by July 31, 1990.
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t Trojan Nuclear Plant Document' Control Desk Docket 50-344 July 6, 1990~
License NPF-1 Attachment 1
~Page $ of 5
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Date When Full Compliance Will Be Achieved:
Full compliance was achieved following the counseling of the individuals involved.with 'the misinterpretation-of A0-13-1.
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Response for A.3:
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Reason for Violation!"
The reason for the-violation is procedural inadequacy.
The provisions of Procedure A0-12-4, "Naterial Issuing and Installation",
Revision 27 were-inadequate regarding the. removal of quality-related
components from the field.
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The torque ewitch involved in this; event was' to be tested to obtain
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g an optimum setting value for the new torque-switch being installed.
This value would have been used only if the as found setting was
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within acceptable values. No as found setting was used and the torque switch-was discarded,
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Corrective Steps That Have Been Taken and the Results achieved,
A0-12-4 was revised July 6.,1990 to include provisions for -
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components removed from the field.
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Corrective-Steps That Will Be Taken to Avoid Further Violations:
The Maintenance Department will review this ovent as a Lessons l
Learned and will emphasize the need for maintaining traceability and i
control of quality-related parts and components ~during removal from the field, as well as, during installation from the warehouse.
This review will include tho'rovision to A0-12-4 and will be completed by July 31, 1990.
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Date When Full Comp 11erce Will Be Achieved:
Full compliance will be achieved following the issuance and training review of the revision' to procedure AO-12-4 for maintaining control and traceability of quality-related components removed from the field.
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