ML20128G275

Responds to NRC Re Violations Noted in Insp Rept 50-344/92-32.Corrective Actions:Warehouse Door to Issue Area Will Be Locked Whenever Issue Counter Left Unattended for Reasons Other than to Obtain Part for Issuance

ML20128G275
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/08/1993
From:	Cross J PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9302120226
Download: ML20128G275 (5)

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._ Portland General Electric Company

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James E. Cross

-Vice President and Chief Nuclear Officer d

r February 8,'1993-D Trojan Nuclear Plant Doiket 50-344

j License NPF -

U.S. Nuclear heguintory Commission 4

Attn Document' Control Desk Wasbington, DC 20555 Dear Sir REPLY TO A N_0TICE OF VIOLATION

- Your letter of - January 8,1993 transmitted a Notit,s cf Violation associated -

with Nuclear Regulatory Commission (NRC) Inspection Report 50434:;/9T.-32.

The attachment to this letter contains Portland-General Electric Company's.'-

response to the violation.

Sincerely, u 4.ca,d W. R.-' Robinson:

for. J. ; E. Cross 6

Attachment-ct Mr. John B, Martin-Regional Administrator, Region V.-

U.S. Nuclear'Reguir. tory Commission

.q Mr. David' Stewart-Smith i

State of Oregon 1

Department of Energy Mr. Kenneth Johnston NRC Senior.'ResidentLInspector-Trojan Nuclear Plant-jj i

9302120226 930208

_ Q hj.g ADOCK 0500 gDR.

g-121 SW Salmon Sden Portland, OR 97204 :

50N464-88971

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L TrojanlNuclear Plant' h nument Cont'ol Desk r

G' Docket 50-344 February 8, 1993-

' License NP7-1 Page 1 of 4 REPLY TO A NOTICE OF VIOLATION Violation _A Technical ~ Specification 6.2.2.g statest

" 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 ur.it staf f... Any deviation froo the

-above guidelines must be authorized by the_ Plant General.Manageriar, in his absence, Duty Plant Manager, or higher levels of management, in accordance with established procedures.

Trojan Administrative Order (AO) 3-24, Fitness for Caty and Work llours, Revision 7, Paragraph 2.1.2.a states:

"The work hour limitations in the procedure ahall be applied to those groups t

identified by-'(shall)' below. These are groups which fall under the requirements of Trojaa 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 1 must be approved by the Plant General Manager, Duty Plant-Manager or higher levels of management."

-Attachment 1 is titled'" DEVIATION FROM WORKING HOUR LIMITATIONS".

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Contrary.to.the above, during the 1991 Refueling Outage, PGE concractors, specifically.B&W personnel ~ conducting the stress 3

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-hours in~a seven day period, without obtaining

< management authorization in'accordance with A0 3-24.

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-Portland General Electric-(PGE) acknowledges the violation.

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1. LPeason For.The Violation

'The. reason.for the violation was determined to be a failure of 2

management oversight tol ensure the implementing procedure properly. addressed the requirements-of.TTS 6.2.2.g.-cThe

-Technical Specification requires work hour-lire.itations for-those:

groups or individuals who_ perform safety-related functions.

It-was incorrectly determined by PGE management that the contractors

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E performing the stress. relieving _ activities'did not' require 1 work:

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. hour deviations. _PGE management'should have interpreted the-Technical: Specification-to apply to anyone employed by PGE to.

perform safety-related maintenance work, g

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Trojan. Nuclear. Plant.

Documenk Control'Dsek-J **

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. Docket-50-344 Fshruary 8/1993 License NPF Attachment'l-Page 2 mfL4

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Corrective Steps That'Have Been Taken And-Results Achieved

. c FGE management-determined that*the requir.ements apply-to key-maintenance personnel performing work on safety-related. equipment.

A Licensing Document-Interpretation (LDI)' Request was initiated

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to ensure proper interpretation of TTS 6.2.2.g in the future.

j This LDI will provide additional guidance for recognizing key ~

maintenance personnel, interpreting utilt, s taff application, and determining what constitutes safety-related functions.

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Corrective Steps That Will Be Tnken To Avoid Further Violations l

Since the event took place, A0 3-24 was converted'to' Trojan Plant L

Procedure (TPP) 13-15. - The TPP w.{11 be revised' to' f aclude the r

LDI guidance on the' application of.TTS 6.2.2.g related to the interpretation of key r.alntenance personnel of the unit staff, This procedure will be revised by April 1,:1993.

Should PGE employ co. tractors to perform safety-related ftmetions.

as key maintenance personnel in'the futu'e,,the provisions of r

TTS 6.2.2.g. will be applied.-

4.

Date When Fu1*L Compliance Will Be Achieved 5

91 PGE is in full compliance with the requiremen'.n of TIS 6.'2.2.g.

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..;Tro'jan Nuclear; Plant Document C$ntroit Desk; fa' f Docket 50-344 February 8,=1993

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License NPF-1

. At tachn ent 'l Pago 3 of.4 Einlation_B l

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:

j corrective action taken to preclude repetition.

TPP 16-12, Material Storage and in Storage Inspection:and: Checks,-

states, "The Materini Manager shall ensure access to Material Services storage facilities.

is controlled.- As a minimum, the.fo11owin6-controls shall be applied:

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A11 access doors to storage ft tilities 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-en' July 9, 1991 after completion of corrective acticas specified therein.

Contrary to_the above, the licensee's corrective actions were notJ effective in that, on November 12 and 15, 1992, the access doors to-the Trojan issue warehouse were not_ controlled by authorized _ personnel.

9 B_emponse to Vlclatinn_B Portland General Electric (PGE) acknowledges the violation.-

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Reason For The Violation

'In June 1991 PGs completed corrective actions-for warehouse access control weaknesses which we're-documented intCARi91-0269.

The corrective. actions associated with the CAR included'_(1) a procedure revision to clarify and' rest'rictfaccess control,0(2)-a-reduction-in the number of-individuals granted unescorted access,-

and (3) training of warehouse personnel on the requirementsLof'

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C access control.

In mid 1991 the three main-' warehouse entrance 1 doors and the issue. counter' door were' posted," UNAUTHORIZED l'ERSONNEL KEEP OUT".

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Ine reason for.the violation was determined'to be a failure on1

- the par t of., the storeroom : personnel to follow the procedure. -. -The pr6cedurefrequires that access 1 doors he locked or controlled by; F-authorized _ personnel. The event for theicited violation cccurred fin November:1992'when an Oregon Department'of EnergyE(ODOE)

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inspector.vas able to compromise physical and posted barriers by_

reaching ~over the issueLeounter door and. unlocking the' door with d key which-had beenLieft in the door.

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T jan

Nuclear: Plant

. Document Control;DesV-o

' i -Docket 50-344

February 8.-1993:

' License HPF-1.

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- Page 4 of 4-2.

Corrective Steps ThaLLHave Been Taken And'Results Achieved-As a result of the event evaluation, the,following: controls were-3 implemented to ensure warehouse access controle-

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The issue counter door is maintained in a locked condition Dj and.the kef is now stored in a location-that.is unaccessible 3'

.from outside the issue' counter.

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The warehouse door to the issue area is. locked whenever.the.

lasue counter is lef t unattended for reasons otherEthan-to-y obtain a part for issuance.- If obtaining a part will _ require an extended period of time, the issue' area entrance' door is-locked.

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Warehouse personnel were trained regarding the need for-procedural. compliance to maintain warehouse access control.

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Corrective Steps.That Will Be Taken To Avoid; Further Violations Based on the corrective steps takan, no additional corrective-steps'are required.

4.: Date When Full' Compliance Will Be Achieved Comp 1funce with 10 CFR-50 Appendix B Criterion XVI was achieved-on. February 4.1992 when the additional-controls implemented to -

ensure warehouse access control were completed.

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