ML20138L200

Responds to NRC Re Violations Noted in Insp Rept 50-344/85-36.Corrective Actions:Periodic Instrumentation & Control Test (Pict) 11-1 Revised to Improve Format & Addl Training W/Technicians Underway

ML20138L200
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/06/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20138L153	List: IR 05000344/1985036 ML20138L200
References
NUDOCS 8512190191
Download: ML20138L200 (3)

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% DEC -9 y ;;; gp Ebrt D W4hers Vcc Presdent flEGiGn t sg December 6, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. D. F. Kirsch, Acting Director Division of Reactor Safety and Projects U.S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Kirsch:

Response to NRC Notice of Violation Your letter of November 6,1985 forwarded Inspection Report 85-36 and a Notice of Violation concerning written procedures covering surveillance and test activities of safety-related equipment. Our response to that Notice of Violation is attached.

Sincerely, n

Bart D. Withers Vice President Nuclear Attachment c: Mr. Lynn Frank, Director I State of Oregon  !

Department of Energy 8512190 g 91 851216 gDR ADOCK 05000344 PDR 121 S W Sarnon Stwt, Fbalnt Ov;)cn 97204

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Trojan Nuclear Plant Mr. D. F. Kirsch Docket 50-344 December 6, 1985

. License NPF-l' Attachment Page 1 of 2

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10 CFR 2.201

- -RgSPONSg TO NOTICE OF %IOLATION Violation Section 6.8.1 of the Technical Specifications requires that written procedures shall be established, implemented, and maintained covering survelliance and test activities of. safety-related equipment.

1.'-Periodic Instrumentation and Control Test (PICT)-11-1, Power Range Setpoint Test requires data:to be recorded in PICT 11-1 data sheets.

Step 7.2.3 of the procedure provides for measuring and recording

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Power Range High Volta 8e.

Contrary to the above requirements, Power Range High Voltage was not recorded on several PICT 11-1 data sheets during 1984 and 1985. For example, the voltage reading was not recorded for test of the Power Range Channel No. 44 performed on July 9, 1985, Channel No. 43 per-

. . formed on May 12, 1984 Channel No. 42 performed'on June 20, 1984, and Channel No. 41 performed on October 7, 1984.

2. PICTs 2-1, 2-2, 2-3, 3-1, 3-2, 4-1, 4-2, and 4-3 require the test equipment type and tag number of test instruments used to be recorded in the PICTs data sheets.

. Contrary to the above requirements, test equipment type and tag data

.were not recorded on test data sheets as listed below.

PICT 2-1, dated January 2,'1985; September 3, 1985 PICT 2-2, dated October 3, 1983; January 2 1985; September 3, 1985 PICT 2-3, dated October 3, 1983; January 2, 1985; September 3, 1985 PICT 3-1, dated September 4, 1985 PICT 3-2, dated July 15, 1985; September 5,1985

=PICT 4-1, dated August 28, 1985; September 9, 1985 PICT 4-2, dated August 28, 1985; September 9, 1985 PICT 4-3, dated August 28, 1985; September 9, 1985 This.is's Severity Level IV Violation.

Resoonse

1. Additional PICT 11-1 data were reviewed to ensure the Power Range High Voltage was within Specification on those occasions when the data were not recorded. No deviations from the required voltage were found. In addition, PICT 11-1 is being revised to improve the format and readability of the procedure which we consider to be the cause of the noted deficiencies. The procedure revision will be complete by February 1, 1986. In the interim, maintenance personnel have been advised of the deficiencies and the need to record this specific data point.

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., :r-Trojan Nuclear Plant Mr. D. F. Kirsch Docket 50-344 December 6,1985 License NPF-1 Attachment Page 2 of 2

2. In each of the stated cases where the equipment type and tag data wera not recorded on the data sheets for the ramp generator-used, each of the deficient data sheets have been corrected. This correc-tion was possible because there is only.one ramp generator onsite.

The responsible personnel did not record the ramp generator each time because there could be no question as to which one was used. Addi-tional training has been conducted with the Instrument and Control

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-Technicians to emphasize the need to follow the procedures and for maintaining complete and accurate records.

SAB/kal 0081P.1285 s