ML20011D897
| ML20011D897 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/18/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9001020268 | |
| Download: ML20011D897 (5) | |
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December 18, 1989 David W. Cockfield Vice President, Nudear l
Trojan Nuclear Plant i
Docket 50-344 License NPF-1 i
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington DC 20555
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Dear Sir:
i Reply to a Notice of Violation l
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Your letter of November 16, 1989 transmitted Notices of Violation associated with Nuclear Regulatory Commission (NRC) Inspection i
Report 50-344/89-27. Attachment 1 is our response to the violations i
contained in that report.
The trans'nittal letter also requested PGE to respond to the inspection concerns of weaknesses in administering and controlling maintenance at Troj an.
It has been recognized the overall work control practices at Trojan are in need of improvement.
Several actions have been taken or are in progress to identify and implement the necessary improvements.
i A special task group headed by the Manager, Planning and Control, is l
developing improved work control practices. The actions of this task group are delineated and tracked in the Trojan Work Control System Action Plan (AP 89-052).
This plan focuses on evaluating and incorporating good practices used at other nuclear power plants.
In addition PGE has assigned a qualified Senior Reactor Operator to the planning and Control Department to assist in proper identification and control of work activities. The task group will revise the work control procedures to incorporate improved practices prior to the 1990 refueling outage.
Sincerely, Attachment.
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Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear plant 9001020260 891218 PDR ADOCK ODOOO344 g of G
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- 21 SW Satmon StreetJWh:1 Orepn 97204 I (
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Trojan Nucicar plant Document Control Desk Docket 50-344 December 18, 1989 License NpF-1 Page 1 of 4 REPLY TO A NOTICE OF VIOLATION Violation A Trojan Administrative Order (AO)-3-9, " Maintenance Requests", Revision 32 August 1,1989, Section 4.4.1.b states "The Cognizant Initiating Supervisor or designee shall enter the applicable Technical Specification section, and the nuniber of any Limiting Conditions imposed in Entry Block 9 of the Maintenance Request".
Contrary to the above, on September 6,1989, the Cognizant Initiating Supervisar did not enter the applicable Limiting Conditions imposed in Entry Block 9 of MR 89-8419.
Consequently, a residual heat removal (RHR) pump was rendered inoperable and Limiting condition for Operation 3.5.2.d was unknow-ingly entered when a flow switch, FIS-611, was removed from service for maintenance.
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This is a Severity Level IV violation.
Response
portland General Electric Company (pGE) acknowledges the violation.
1.
Reason for the Violation:
The reason for the violation is personnel error. The Cognizant Shift Supervisor believed the requirement for the Limiting Condition for Operation (LCO) entry on the Maintenance Request (MR) was fulfilled when Section 3.5.2 was delineated as the applicable Technical Specification section and the LCO.
2.
Corrective Steps That Have Been Taken and the Results Achieved:
Trojan Operations issued a memoranduta to all. Shift Supervisors to a.
reemphasize the applicable Technical Specification and LCO must be entered on MRs as specified in Administrative Order (AO) 3-9,
" Maintenance Requests", Revision 32, Section 4.4.1(b).
b.
The Event Report (ER 89-154) for this event was reviewed in operator training.
The cognizant Shift Supervisor was removed from watch standing c.
duties.
3.
Corrective Steps That Will Be Taken to Avoid further Violations:
Based upon the Task Force review of Trojan's work control process, a.
i MR Forms will be revised to remove the initial operability I
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-l Trejan Nuclear Plant Document Control Desk-Docket 50-344 December 18, 1989 j
License NPF-1 Page-2 of 4 determination from the Shlft Supervisor responsibility.
Recommendations from the Task Force will be evaluated and 1
implemented to provide the Shift Supervisor with enough detailed information (i.e., TTS, LCO, Clearance Requests, affected train, 1
etc.) to make-the correct verification regarding Plant operability.
.b.
A0 3-9 will be revised to reflect changes to the MR Form'affected by the revision of Trojan Work Control practices.
These actions w!,11 be completed prior _ to the 1990 Refueling Outage.
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The Date When Full Compliance Will be Achieved:
I Full compliance was achieved folluwitts issuance of the Operations 1
memorandum to the Shift Supervisors reemphasizing the requirement to enter the applicable Technical Specifications and Limiting condition for Operation in Block 9 of the MR Form'..
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Trojan Nucicar plant Document Control Desk Docket 50-344 December 18, 1989 License NPF-1 i
page 3 of 4 Violation B Trojan Administrative Order (AO)-3-14 " Control c. Safety-Related Equipment i
Outages" Revision 22, dated June 21, 1989, states in part in Section 4.4.3.c, "The Shift Supervisor shall sign and dato the Worksheet on-
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Line 7 indicating-approval of the outage."
1 Contrary to the above, on September 8, 1989, the Shift Supervisor did not sign and date the Worksheet indicating approval of the outage to work on the flow switch, FIS-611, associated with the RHR pump; however, he-authorized the FIS-611 outage.
This is a Severity Level IV violation (Supplement I).
Response
pCE acknowledges the violation.
1.
Reason for the Violation:
a.
The reason for the violation is personnel error.
The Shift Supervisor did not recognize that work on the flow switch, FIS-611, could render the RHR pump inoperable. As a result of the decision not to declare the RHR pump inoperable,.the safety-related equipment outage worksheet was not completed, b.
procedure A0-3-14 contributed to the cause of the violation as it did not contain-specific instructions for the Shif t' Supervisor to take should the Shift Supervisor disagree with'the planning group regarding the operability of the affected-train.
2.
Corrective Steps that have been Taken and the Results.'.chieved:
The operator training cycle following the September 8, 1989 event a.
included a review of this event and reamphasized the importance of accurate and conservative equipment operability determinations, b.
Appropriate disciplinary actior. was~taken with tho Operations perso nel involved in making the decision not to declare the RHR pump a. operable, An entry was made in the Operations Supervisor Special Orders c.
Notebook on December A, 1989' requesting Shift Supervisors to treat the'stfety-related outage worksheets as a Quality record upon receipt and to complete.the worksheets as required by A0-3-14.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 December 18, 1989
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License NPF-1 Attachment.1
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All train-related work must now be specifically l'dentified and E
scheduled on the Plan of the Day (POD). thereby ensuring upcoming work receives a detailed review for operability prior to the work being authorized by the Shift Supervisor. Work on separate trains of safety-related equipment sinmitaneously'is generally prohibited.
Exceptions to this. rule must receive the. prior approval of the Duty Plant General Manager on a' case-by-case basis..
A' licensed Senior Reactor Operator has been assigned to the-Planning e.
and control Department to provide an independent review of proposed work to assist in operability determinations prior to the review required by the Shift Supervisor.
'1 3.
Corrective Steps that will be Taken to Avoid Further Violations:
i A0-3-14 will be revised to include instructions for the Shif t Supervisor to disposition the iafety-related outage worksheets should he not agree that the work'vequested-requires removing L
safety-related equipment (or systems) from service.
This revision will be completed by January 12, '1990.
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Dated when Full Compliance will be Achieved:
l Full compliance was achieved on December'8, 1989 when the entry was made in the Operations Supervisor Special Order Notebook requiring safety-related outage worksheets be completed whenever they are included in the work package and forwarded to the Technical Support l
Center vault in accordance-with Procedure A0-3-14.
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