ML20127E946

Notice of Violation from Insp on 921027-1207.Violation Noted:Licensees Corrective Actions Not Effective in That,On 921112 & 15,access Doors to Plant Issue Warehouse Not Controlled by Authorized Personnel

ML20127E946
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/08/1993
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20127E920	List: IR 05000344/1992032 ML20127E918 ML20127E946
References
50-344-92-32, NUDOCS 9301200096
Download: ML20127E946 (3)

Text

_ . _ _ _ .. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ ._

NOTICE Of VIOLATION Portland General Electric Company Docket No. 50-344 Trojan Nuclear Plant License No. NPF-1 During an NRC inspection conducted from October 27 through December 7, 1992, four violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:

A. Technical Specification 6.2.2.g. states: " Administrative procedures shall be developed and implemented to limit the working hours of ...

personnel who perform safety-related functions ..., and key maintenance personnel of the unit staff.... Any deviation from the above guidelines must be authorized by the Plant General Manager or, in his absence, Duty Plant Manager, or higher levels of management, in accordance with established procedures...."

Trojan Administrative Order (AO) 3-24, " Fitness for Duty and Work Hours,"

Revision 7, Paragraph 2.1.2.a. states: "The work hour limitations in the procedure shall be applied to those groups indicated by "(shall)" below.

These are groups which fall under the requirements of Trojan Technical Specification (TTS) 6.2.2.g."

1) Contractors ... shall also meet work hour requirements."

Note 4.4.2-1 of A0 3-24 states that " Prior to exceeding the work hour limitations, Attachment I must be approved by the Plant General Manager, Duty Plant Manager or higher levels of management." Attachment 1 is titled " DEVIATION FROM WORKING HOUR LlHITATIONS."

Contrary to the above, during the 1991 Refueling Outage, PGE contractors, specifically B&W personnel conducting the stress relieving of sleeved tubes, which was a safety-related function, exceeded the work hour limitation of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in any seven day period by working 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> in a seven day period, without obtaining management authorization in accord-ance with A0 3-24..

This is a Severity Level IV violation (Supplement 1).

B. 10 CfR 50, Appendix B, Criterion XVI, states in part that Heasures shall be established to assure that conditions adverse to quality ... are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of-the conditions is determined and corrective actions taken to preclude repetition.

Trojan Plant Procedure (TPP) 16-12. "Haterial Storage and In Storage Inspection and Checks," states, "The Materials Manager shall ensure access to Material Services storage facilities ... is controlled.

As a minimum, the following controls shall be applied:

9301200096 930100

-PDR ADOCK 05000344 G PDR ,

a. All access doors to storage facilities shall be locked or controlled by authorized personnel."

Corrective Action Request (CAR) 91-0269 addressed licensee-identified weaknesses in warehouse access control, and was closed by the licensee on July 9,1991 after completion of corrective actions speelfied therein.

Contrary to the above, the licensee's corrective actions were not effec-tive in that, on November 12 and 15, 1992, the access doors to the Trojan issue warehouse were not controlled by authorized personnel. '

This is a Severity Level IV violation (Supplement 1).

C. 10 CFR 50, Appendix B, Criterion XVI, states in part that:

Measures shall be established to assure that conditions adverse to quality ... are promptly identified and corrected, in the case of significant conditions adverse to quality, the measures shall assure that the cause of the conditions is determined and corrective actions taken to preclude repetition.

Contrary to the above, a condition adverse to quality was identified and not promptly corrected in that the investigations of Corrective Action Request CAR 90-3101 and Excellence Response Program review 90-053 deter-mined on May 21, 1990 and January 23, 1991 respectively, that containment airlock equalizing valve door 0-ring seals could become displaced during door operations due to a design deficiency,-but the equalizing valves remained in service in plant modes requiring airlock integrity without corrective actions to address the design deficiency until February 1992.

This is a Severity Level IV violation (Supplement 1).

D. 10 CFR 50.73(b) states that a Licensee Event Report shall contain:

"An assessment of the safety consequences.and implications of an event..." and "A description of any corrective actions planned as a result of the event, including those to reduce the probability of similar events occurring in the future "

Contrary to the above, Licensee Event Report 90-01 addressed the January 8, 1990 discovery that testing had never been performed on the containment airlock inner door equalizing valves, and reported the December 26, 1989 determination that the 93-foot airlock outer door equalizing valve was leaking excessively, but did not provide an assessment of the safety consequences and implications, or describe corrective actions planned in response to the observed deficiencies.

This is a Severity Level IV violation-(Supplement 1). ,

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,-D.C.

20555, with a copy to the Regional Administrator, Region V, and a copy to the NRC Senior. Resident inspector, Trojan Nuclear Plant, within 30 days of the

-_ _ ~___ . _ _ _ _ _ . . _ _ - - _ _ _ _ . _ . _ .

date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for violations A and B above: (1) the reason for the violation,-or, if contested, the basis for disputing the violation, (2) the corrective steps that have been taken and the results achieved (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. In view of the corrective actions you have taken to address violations C and 0 above, as verified by our inspectors, a response to these violations is not required. If an adequate reply for Violations A and B is not received within the time specified in this Notice, the Commission may issue an order or demand for information as to why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken. Where good cause is shown, consideration may be given to extending the response time.

Dated at Walnut Creek, California this P'" day of :ThueAav , 1993

.