ML20055E024

Responds to NRC Re Violations Noted in Insp Rept 50-344/90-11.Corrective Actions:Generic Issues That Contributed to Violation Will Be Discussed During Mgt Meetings & Quality Insp Supervisor Counseled

ML20055E024
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/06/1990
From:	Walt T PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9007100288
Download: ML20055E024 (6)

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Trojan Nuclear Plant Docket 50-344-g License NPF-1.

- 'i.S. ' Nuclear. Regulatory Commission Attni.' Document Control Desk

-Washin6 on DCL.20555 t

Dear Sirs:

Reply to a Notice of Violation

. Your, letter of' June 7, 1990 transmitted a Notice of Violation'(NOV) associated with Nuclear Regulatory Commission (NRC) Inspection Report 50-344/90-11'.. Attachment I to this letter contains Portland General KlectriciCompany's,(PGE's) response to the-violation contained in the-inspection report.- Please note your: inspection; report Appendix A references' Corrective Action Request.(CAR) C90-3075.-- The correct CAR.

number pertaining to the NOV-(90-11-02) is' CAR C90-3073. We have i

incorporated this correction into our-NOV= Response.-

p-Sincerely, A

4 T. D. Walt Acting'Vice President-' Nuclear

. Attachment c:: Mr. John B. Martin

' Regional Administrator. Region V U.S.E Nuclear' Regulatory Commission Mr. : David Stewart--Smith -

S 4 c of Oregon De;% cment of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant AI)f),qq l

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-,f Trojan Nuclear Plant Document Control Desk Docket 50-344.

July 6, 1990 1

License NPF-1 Page 1 of-5 i

REELY TO A NOTICE OF VIOLATIOk P

H Violation A 2

Title 10, of the Code of Federal Regulations, Part 50 (10 CFR 50),

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- Appendix B, criterion V, states in part:_ " Activities affecting quality shall be prescribed by documented instruction,-procedures or drawings. of.

a type. appropriate to the circumstances and shall be accomplished in

- accordance with these instructions, proceduros, or drawings."

1.

Nuclear Division Procedure (NDP) 600-0 Revision 4. " Corrective-

. Action' Program (CAP),"fdated February 23, 1990 Paragraph A.3.3 of Attachment H states:

"Where the Evaluating Supervisor disagrees with j

MCAC's conclusion-that the condition constitutes a nonconformance,

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the'following actions shall be taken A.

Review the CAR with MCAC and obtain concurrence that a nonconformance does not exist and.

C.

Once concurrences have been achieved, document why the nonconformance does not exist and return'the CkR with concurrence from.the next higher level of management to Quality Services.

If the nonconformance involved hardware, concurrence must also be obtained from the Manager, NPE."

Contrary to the above, on April 14, 1990, the Evaluating Supervisor 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 Revision 4, when he disagreed with the Management Corrective Action-Committee's (MCAC's) conclusion that C90-3073 was a nonconformance.

2.

Administrative Order (AO) 13-1, " Inspection Control", P" vision 6, dated March 5, 1990,~ Paragraph 4.5.1 requires, " Prior to reaching a-step which requires Quality Inspection (QI) inspection, the assigned work group supervisor or desigr.ee shall notify the Mechanical or Electrical QIS or designee."

Contrary to the abcVe, on April 10, 1990, while conducting maintenance per Maintenance Request (MR) 90-0528 on MO-2053A, a-designated work group supervidor did not notify the Electrical Quality Inspection Supervisor (QIS) or designee for the inspection hold point designated for Step 6.b.'

3.

A0-12-4, " Material Issuing and Installation", Revision 27, dated 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 -1990

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License NPF-1 Page 2 of_5 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.

Response for A.1' 6

1.

Reason for the Violationt Root Cause The reason for/the violation is personnel error, failure to follow the detailed steps of NDP 600-0, Revision 4, " Corrective Action

' Program".

- Contributing Cause Ineffective communication between work groups also contributed to this' event.

2.

The Corrective Steps That Have Been Taken and the Results Achieved:

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- CAR C90-3118 was written on April 25, 1990 by the Quality. Inspections

-(QI) Branch to document that' CAR C90-3073 was not processed'in accordance with NDP 600-0, Revision 4 and to properly process the concerns of CAR C90-3073. As a result of the CAR C90-3118 evaluation, the following corrective actions occurred:

l a.

The QI supervisor responsible for not following the procedure requirements of NDP 600-0, Revision 4, Part A.3.3 of Paragraph H was-counseled by the QI_ Branch Manager and General Manager,-

Nuclear Quality Assurance Department (NQAD) on-the importance of.

procedural compliance and management expectations regarding identification and' resolution of Plant. problems and.was also~

disciplined. _This event and the role of the. supervisor in the

' CAR Program was discussed with the NQAD managers =and supervisors at NQAD staff meetings. 'The supervisor responsible for evaluating the CAR was also counseled on the need t6. return to i

MCAC and discuss _any changes required in a CAR'that MCAC has assigned.

'rocedure NDP 600-0, Section A.3.3 was revised April 16, 1990 to b.

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,y change-the sequence'of actions when the CAR evaluating supervisor disagrees with-the'MCAC's conclusion that the condition constitutes a nonconformance.

This change' ensures the disacreement with the CAR assigned by MCAC is discussed with the initiator or the ' initiator's supervisor prior to going back to 1MCAC for discussion of the disagreement.

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Trojan Nuclear Plant Document Control Desk Docket 50-344' July 6, 1990 License NPF-1 Page 3 of 5

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c. The importance of bringing problems to management attention when one employee has a disagreement with the.next level of. management i

on a concern affecting the reliability or safety of Trojan was addressed in a Lessons Learned Summary April 24, 1990 by the Trojan Plant General Manager and_sent to all Nuclear Division personnel.

It was emphasized'that this type of problem is the responsibility of management and supervisory personnel to resolve.

3.

Corrective Steps That Will be Taken to Avoid Further Violations:

a.

The generic issues that contributed to this violation will be

.I discussed periodically during management meetings conducted over-the next quarter to emphasize supervisory responsibilities with respect to the CAR Program.

b.

Lessons Learned from this event will be incorporated into the Frontline Leadership training module on communications.

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PGE will monitor the CAR / Excellence Response Programs'for the next six months to ensure CARS are properly addressed by Managers and Supervisors.

4.

Date When' Full Compliance Will Be Achieved:.

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- Full compliance was achieved when the supervisors responsible for not-

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complying with the requirements of NDP 600-0 were counseled and the j

C() yqs properly'dispositioned;in accordance with the procedure.

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Response for A.2 l '. Reason for the Violation:

Root Cause

~1 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 "i, p aware of the requirements of A0-13-1, but-incorrectly interpreted the j

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instructions to MR 90-0528 and did not contact QI at the intended

[g Circle Q hold point.

1 Contributing Cause

a. -Poorly organized work instructions contributed to the personnel error.

Step 6.b " Determine 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, 1990 License NPF-1 J

j Page 4 of 5

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n (i.e., in the ' Test Stand')" contained the required Circle Q hold l

point, but was listed prior to the torque switch removal

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(Step 6.b.1).

Had the provisions of Step 6.b.1 been repositioned

'in-the work instructions to precede the " Determine as found

' displacement of the torque switch"; the po.1sibility of missing

-the Circle Q hold point could have been reduced.-

b. 'MP 12-5.03, Revision 0, " Motor-Operated Valves Preventative'

. Maintenance Procedure 3-Year Inspection", was incorrectly j

referenced as the procedure to use under Maintenance Request (MR):90-528.

MP 12-5.04, " Motor-operated Valves Switch Inspection Overhaul, Replacement, and Adjustment'of Limitorque Size SMB-000-Through SMB-5", Revision 0, was the' appropriate procedure-for this MR.

~2.

The Corrective Steps That Have Been Taken and the Results-Achieved:

a.

The electrical craftsmen involved with not complying with the 1

requirement of A0-13-1 were counseled, May 10, 1990.

.b.

The requirements of A0-13-1 regarding'the need to notify QI-

-before commencing a step with a Circle Q hold point was

-communicated'to.the Electrical Maintenance 3 ranch during shop:

meetings April. 23, 1990 and:again on May 3, 1990, c.

A0-13-l'was revised April'20,'1990?to'more clearly state when: QI is to be notified regarding a-Circle Q hold point.. Although this a

concern did not contribute directly to this event, the' revision i

to A0-13-1 that was-made should eliminate any misinterpretation of the requirement.

3.

Corrective Steps That Will Be Taken.to Avoid Further Violat'lons:

-I a.

MP'12-5.04,. Revision 0, " Motor-Operated Valves Switch Inspection, j

overhaul, Replacementi and Adjustment for Limitorque-size SMB-000

-l through SMB-5". will be-revised prior to performing this work again.

b.

The Mechanical and Instrumentation and Control (I&C) Branches of.

the-Maintenance Department will be instructed on the revision'to r

A0-13-1 addressing the actions to be taken concerning when to 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 Departmont and Plant Modifications Department as part-of Lessons Learned Training by July 31, 1990.

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Trojan Nuclear Plant Document Control' Desk Docket 50-344-July 6, 1990 License NPF-1 -

Page 5 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.

Response for A'.3 '

1'. Reason for Violation:

The reason for the violation is procedural inadequacy. The provisions.of: Procedure A0-12-4, " Material Issuing and Installation",

Revision 27 were' inadequate regarding the removal of quality-related components from the field.

s The torque switch involved in this event was to be tested to obtalp an optimum setting value for the new torque switch being installed.

This value would have.been used only if the.as found setting was within acceptable. values.

No as found' setting was used and the torque switch was discarded.

~2.

Corrective' Steps That Have Been Taken and the Results achieved.

45" AO-12-4.was: revised July. 6,11990 -to-include provisions for controlling and maintaining traceability of quality-related components removed from the: field.

'3.

Corrective Steps That Will Be Taken to Avoid'Further. Violations:

The Maintenance Department will review this event as a-Lessons Learned and=will emphasize the need for maintaining traceability and control of quality-related parts and components'duritig removal'from the field, as well as, during installation from the warehouse. This review will include the revision to A0-12-4 and will be completed by July 31, 1990.

4.

Date When Full Compliance Will Be Achieved:-

Full compliance will be achieved following the issuance and training review of the revision to procedure A0-12-4 for maintaining control and traceability of' quality-related components removed from the field.

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