ML20006C396
| ML20006C396 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/19/1990 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20006C393 | List: |
| References | |
| RTR-REGGD-01.033, RTR-REGGD-1.033 50-344-89-30, NUDOCS 9002070445 | |
| Download: ML20006C396 (3) | |
Text
.
l i
APPENDIX A i
NOTICE OF VIOLATION Portland General Electric Company Docket No. 50-344 TrojanNuclearGeneratingPlant License No. NPF-1 l
During an inspection conducted on December 18 through 22, 1989, violations of i
NRC requirements were identified.
In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix i
C (1989), the violations are listed below:
i A.
TS 6.8, Procedures and Programs, reads, in part:
6.8.1 Written procedures shall be established, implemented and l
maintained covering the activities referenced below:
j a.
The applicable procedures recommended in Appendix "A" of t
Regulatory Guide (RG) 1.33, November,1972.
RG 1.33 (Safety Guide 33), Appendix A, reads, in part:
A.
Administrative Procedures 4.
Procedure Adherence and Temporary Change Method 1.
rocedures for Performing Maintenance i
5.
General Procedures for the control of maintenence, repair, replacement, and modification work should be prepared before reactor operation is begun.
These procedures should include information on areas such as the following:
I a.
Method for obtaining permission and clearance for l
operations personnel to work and for logging of such Work....
Administrative Order A0 3-9, Maintenance Requests, reads, in part:
l 4.5.3 f.
Immediately bring to the attention of the work group craft supervisor and the Shift Supervisor problems that:
1)
Cannot be corrected without additional work direction.
9002070443 900119 POR ADOCK 05000344 6
Q PDC
,i i
.. ~ ~.
+,g
\\
i k.6.1 Before the end of his shift, the craftsman / technician j
shall take any MRs to the Shift Supervisor or designee for review of post-maintenance testing requirements.
This includes MRs which are ready for clearance release or i
ready to be turned over to operations for use.
l l
k.6.3 The Shift Supervisor or designee shall initial the i
SRO verification block 36 of the MR to document his review.
j
]
]
4.6.7 The individual (s) performing any designated Post-i Maintenance testing shall:
J a.
Document results in block 33 of the MR and sign in l
entry block 34.
Contrary to the above, on September 24, 1989, a maintenance worker installed a Temporary Modification to Train 8 of the Hydrogen Vent System but signed for installing it to Train A, failing to stop work and obtain
-further direction when the direction provided in the Maintenance Request (MR) was inadequate to the work situation.
The Operations-representative-l reviewing the associated MR and the individual performing the post-maintenance test failed to adequately review the MR to identify that work had been requested on Train B but had been signed-off as completed on Train A.
The Operations representative also failed to sign block 36 to document the review.
This is a Severity Level IV violation (Supplement'I).
{
'B.
10 CFR 20.311 reads, in part:
Any generating licensee who transfers radioactive waste to a land disposal facility...shall: (1) Prepare all wastes so that the waste l
is classified according to $61.55.
10 CFR 61.55 reads, in part:
Determination of the classification of radioactive waste involves two considerations.
First, consideration must be given to the concentration of long-lived radionuclides... Second, consideration must be given to the concentration of shorter-lived radionuclides...The concentration of a radionuclide may be determined by indirect methods...if there is reasonable assurance that the indirect methods can be correlated with actual measurements.
The concentration of a radionuclide may be averaged i
i j
4
)
1 over the volume of the waste, or weight of the waste if the units are expressed as nanocuries per gram.
]
Contrary to 20.311, above, radioactive waste shipment 89-90 used the
)
volume of the resin liners in the shipment for determination of radionuclide concentrations rather than the volume of the resin itself.
This resulted in a underestimation of the specific radionuclide concentrations required by $61.55 for waste classification and could have resulted in a misclassification if activities in the resin had been higher.
l This is a severity level IV violation (Supplement IV).
Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company
[
is hereby required to submit a written statement of explanation to the U.S.
Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, letter transmitting and a copy to the NRC Resident Inspector within 30 days of the date of the this Notice.
This rep y should be clearly marked as a " Reply to a Notice of Violation" and should nelude for each violation:
(1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further i
violations, and (4) the date when full compliance will be achieved.
If an l
adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be I
taken.
Consideration may be given to extending the response time for good cause shown.
FOR THE NUCLEAR REGULATO Y COMMISSION s,f us-w fossa.ScaranoDivisionofRadIationSafety Director and Safeguards Dated it Walnut Creek, California this 14 day of TiY)dMM09 g/0 I
ti
,7-.
,- --