ML20151U647

Responds to NRC Re Violations Noted in Insp Rept 50-344/88-24.Corrective Actions:Deviation Form Prepared & Approved to Limit Working Hours of Key Maint Personnel

ML20151U647
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/12/1988
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8808190202
Download: ML20151U647 (3)

Text

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m ammmes David W. Cockfield Vice President, Nuclear August 12, 1988 Trojan Nuclear Plant Docket 50.-344 Licenso NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

Reply to a Notice of Violation Your lotter of July 13, 1988 transmitted a Notico of Violation associated with Nuclear Regulatory Commission Inspection Report 50-344/88-24.

Attached is our responso to ti.at Notice of Violatlon.

Sincoroly, Attachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. Bill Dixon State of Oregon Department of Energy Mr. R. C. Harr NRC Resident Inspector Trojan Nuclear Plant 68061902O2 esoe32 gg(

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+ Trojan Nuc1str P1Ent Docum:nt Control D3sk Docket 50-344 Attachment License NPF-1 August 12, 1988 Page 1 of 2 REPLY TO A NOTICE OF VIOLATION Violation Technical Specification 6.2.2.g states, in part, that:

"Administrative procedures shall be developed and implemented to limit the working hours of . . . key maintenance personnel of the unit staff.

Key maintenance personnel of the unit staff are those personnel who are responsible for the correct performance of maintenance, repair, modifi-cation or calibration of safety-related structures, systems or compo-nents, and who are personnel performing or immediately supervising the performance of such activities . . .

During extended periods of shutdown for refueling, major maintenance or major plant modifications, on a temporary basis, the following guidelines shall be followed: . . .

An individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24-hour period, nor more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period, nor more than 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, all excluding shif t turnover time Any deviation from the above guidelines must be cuthorized by the Plant General Manager or, in his absence, Duty Plant Manager, or higher levels of management, in accordance with established procedures and with docu-mentation of the basis for granting the deviation."

Contrary to the above, members of a vendor site service crew, including welders and their immediate supervisors performing replacement work on the pressurizer surge line worked in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> excluding shift turnover time in the seven-day period of June 11 through June 17, 1988, without an authorized deviation in accordance with established procedures.

This is a Severity Level IV violation (Supplement I),

Response

Portland General Electric Company (PCE) acknowledges the violation.

1. Reason for Violation:

The cause of the violation was personnel error. The responsible personnel were aware of the work hour limitations as specified in the Technical Specifications and Administrative Order (AO) 3-1, "Shift Complement and Work Time", but failed to process the required devi-ation form.

• l Trojen Nuclsar PIEnt Documsnt Control Desk ;

Docket 50-344 Attachment l License NPF-1 August 12, 1988 Page 2 of 2 l

2. Corrective Action Taken and Results Achieved: l l

Once the nonconforming activity was identified, a deviation form was immediately prepared and approved on July 22, 1988. An event evalu-ation was performed and determined the cause of the problem to be personnel error.

3. Corrective Action to Avoid Further Violations:

a. A review of the requirements of A0-3-1 was performed with respon-sible job coordinators and contractor supervisors. Emphasis was placed on ensuring compliance with work-hour limitation requirements.

b. A revision to A0-3-1 has been prepared and submitted for approval.

This proposed revision adds a note explicitly stating the appli-cability of the requirements to outside vendors and contract personnel. This procedural clarification is scheduled to be implemented by October 24, 1988.

4. Date When Full Compliance Will Be Achieved Full compliance was achieved on June 22, 1988 with approval by the Plant General Manager of a deviation from the 72-hour per seven days work limit for those personnel performing replacement work on the pressurizer surge line.

DLN/mr 2508W.888

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