ML20030D601
| ML20030D601 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/18/1981 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20030D600 | List: |
| References | |
| NUDOCS 8109010596 | |
| Download: ML20030D601 (3) | |
Text
1 W General MCoiigicsiry
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DonadJ Brochl Assistant Vce Presdent August 18, 1981 Trojan Nuclear Plant Docket 50-344 License NPF-1 1
l Mr. R. II. Engelken, Director U.S. Nuclear Regulatory Commission Region V Suite 202, Walnut Creek Plaza 1990 N. California Boulevard Walnut 9 reek, CA 0'596
Dear Mr. Engelken:
Your letter of July 20, 1981 forwarded results of an inspection conducted June 1-30, 1981 and two notices of violation. Pursuant to the provi-sions of 10 CFR 2.201, attached is our reply to these notices of vio-lation describing the corrective steps which have been taken and the corrective steps which will be taken to avuid reoccurrence.
Should you have further questions, please do not hesite*a to contact me.
Sincerely, DJB/pm Attachment c:
Mr. Lynn Frank, Director a
State of Oregon C2 Department of Energy m
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Mr. L. W. Erickson, Vice Chairman y
y Nuclear Operations Board
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0 121 S W Sal mon Street. Portund Oremn 97204
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RESPONSE TO NOTICE OF VIOLATION 1.
Notice of Violation Technical Specification 6.8, " Procedures", states, in part, that:
" Written procedures shall be established, implemented, and maintained covering the activities referenced below:
a.
The applicable procedures recommended in Appendix "A" of Regu-latory Guide 1.33, November 1972.
Regulatory Guide 1.33, November 3, 1972, Appendix "A", " Typical Proce-dures for Pressurized Water Reactors and Boiling Water Reactors", lists typical safety-related activities which should be covered by written procedures. Paragraph I, " Procedures for Performing Maintenance",
states that, " Maintenance which can affect the performance of safety-related equipment should be properly preplanned and performed in accor-daace with written procedures, documented instructions, or drawings appropriate to the circumstances."
Section 6.8.2 states that, "Each procedure and administrative policy of 6.8.1 above, and changes thereto, shall be reviewed by the PRB and approved by the General Manager prior to implementation.
Contrary to this requirement, on June 4, 1981, modification work requiring a freeze seal on the "C" loop RTD bypass line to install a "T" fitting for the Reactor Vessel Level Indication System,-under Request for Design Change, RDC 80-111, was conducted with a freeze seal procedure not having undergone review by the PRB and the approval of the General Manager.
This is a severity level IV violation.
Response
During the recent NRC Performance Appraisal Branch management inspec-tion, a recommendation was made to look at "' lower-tier' procedures" to see if some of them need to be upgraded to the status of PRB-reviewed, Plant Manager-approved procedures. We are issuing guidance to plant supervisors for their use in this review. This guidance will incorporate the requirements of Regulatory Guide 1.33, Appen-dix "A", November 1972. Our guidance will go beyond the sentence quoted in the violation which states, " Maintenance which can effect the performance of safety related equipment should be properly pre-planned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances." The same paragraph also states that, " Skills normally possessed by qualified maintenance personnel may not require detailed step-by-step delinea-tion in a procedure." In cases such as this, it is appropriate to use documented instructions or drawings, as is permitted in the sen-tence quoted in the violation. Activities such as applying freeze
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seals to small piping in a shutdown, cooled down, depressurized system with two independent means of level indication, by quali-fled craftsmen with adequate work instructions, do not fall into the category requiring PRB-reviewed procedures. Adequate wcrk instructions and precautions were provided to the work group doing the modification on June 4, 1981.
Had these procedures been followed by the personnel performing the task, the freeze seal would not have failed.
2.
Notice of Violation Section 2.C.7 of facility Operating License NPF-1 states:
. all activities to which a quality assurance program is applicable shall, after the date of issue of the license, be conducted in accordance with the Quality Assurance Program for Operation." Quality Assurance Procedure QAP-9, " Control of Special Processes", requires in part that, "Each responsible supervisor shall ensure that personnel per-forming a special process under his direction are adequately trained, tested, and qualified as necessary, prior to performing the special process activities."
Contrary to this requirement, on June 4, 1981 work requiring a freeze seal to be used was done by personnel who were not instructed in the application and cautions of using a freeze seal prior to commencing the work activity.
This is a severity level IV violation.
Response
As referenced in this violation, we do not consider freeze sealing a "special process". A special process as defined in the Nuclear Projects Quality Assurance Program for Operation is one that affects the material such that essential characteristics cannot be determined by inspec-tion, test, or examination.
Because of the interest generated by this occurrence, a formal freeze seal procedure (LTP-20, Liquid Nitrogen Freeze Seals) was prepared, approved, and incorporated into the Work Plan for the subject modifi-cation. Prior to subsequent modification activities using a freeze seal, the personnel assigned to the work were trained in the freeze seal procedure requirements and this training was documented.
To prevent reoccurrence of this violation, planned maintenance and modification activities involving freeze seals will be evaluated to ensure that the freeze seal procedure is adequate and applicable to the activites planned. Additionally, personnel involved in the freeze seal work will be instructed in the application and precau-tions involving a freeze seal prior to commencing work.