IR 05000344/1988024

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted Insp Rept 50-344/88-24

ML20151Z264
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/23/1988
From:	Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8808290266
Download: ML20151Z264 (1)

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- Docket No. 50-3!4 8:

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. Portland' General Electric Company

,- 121 S.=' W.- Salmon Street' - '

=~ Portland, Oregen 97204 Attention: 'Mr.-David W. Cockfield Vice President, Nuclear-

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Thank you for your letter of August 12, 1988, in response to our Notice of

- Violation and Inspection. Report No. 50-344/88-24, dated July 13, 1988, ,

j informing us of the steps you have taken to correct the items which we brought to your attention. Your corrective actions will be verified during a future inspection.

Your cooperation with us is appreciated.

Sincerely,

'

h/l R. P. Zimmerman, Chief

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Reactor Projects Branch

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bec w/ copy of letter 8/12/88:

docket file State of Oregon A. Johnson G. Cook 8. Faulkenberry J. Martin ,

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Resident Inspector '

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Project Inspector J. Zollicoffer M. Smith L

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1. U Portland General ElectricCarpy

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" REf' U V 1 e David W. Cockfield Vice President, Nuclear ' O /(/g jS Pg . 0 7 August 12, 1988 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTH: Document Control Desk Washington DC 20555

Dear Sir:

Reply to a Notice of Violation Your letter of July 13, 1988 transmitted a Notice of Violation associated with Nuclear Regulatory Comission Inspection Report 50-344/88-24 Attached is our response to that Notice of Violation.

Sincerely

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l Attachment l

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c: Mr. John B. Martin Regional Administrator. Region V l

U.S. Nuclear Regulatory Comission l

l Mr. Bill Dixon

! State of Oregon I Department of Energy Mr. R. C. Bare NRC Resident Inspector Trojan Nuclear Plant l

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Trojan Nue100r Pltnt Document C:ntrol D:sk Docket 50-34A 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 implamented 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 activitics . . .

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, not 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 authorized 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."

l 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 (Suptlement I).

Response:

Portland General Electric Company (PGE) acknowledges the violation.

1. Reason for Violation:

l 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.

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. ' Trojcn Nuciccr Pltnt Dscumsnt Control Dask Docket 50-344 Attachmont License NPF-1 August 12, 1988 Page 2 of 2 2. Corrective Action Taken and Results Achieved:

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 Fas 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.

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