ML20246E819
| ML20246E819 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/07/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907130010 | |
| Download: ML20246E819 (3) | |
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(E!E M COII@If David W. Cockfield Vice President, Nuclear 1
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-i July 7, 1989 Trojan Nuclear Plant 1
Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN:' Document Control Desk Washington DC 20555~
Dear Sir:
Reply to a Notice of Violation Your letter of June 8, 1989 transmitted a Notice of Violation based upon Nuclear Regulatory Commission Inspection Report 50-344//89-14, Appendix A.
Our reply to the Notice of Violation is provided in Attachment I to this letter.
Sincerely, O
Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 8907130010 890707 PDR ADOCK 05000344 g
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.i ThojenNuc1carPlant Documsnt Control Desk Docket 50-344 July 7, 1989 License NPF-1 Page 1 of 2 Response to Notice of Violation Violation Title 10,-Code.of Federal Regulations, Part 50, Appendix B, Criterion V states, in part, " Activities affecting quality shall be prescribed by i
documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings."
Administrative Order, A0-11-5, Revision 3, dated January 15, 1989, entitled
" Lead Shielding Evaluation Procedure" paragraph 2.1 states, in part, "This procedure applies to temporary and permanent lead shielding attached to any safety-related and non-safety-related piping, components, or structures."
Paragraph 6.3 and 6.3.7 provides, in part, that the Lead Shielding Coordinator is responsible for assigning maintenance tags to the specific shielding jobs and logs in the number in the shielding tracking log.
Paragraph 6.4.4.2 requires a maintenance tag to be attached to installed shielding.
Contrary to the above, at the time of inspection, tags had not been assigned or used to identify any of the temporary lead radiation shielding structures installed in the reactor containment building and the auxiliary building.
This is a Severity Level IV violation (Supplement I).
Response
Portland General Electric (PGE) acknowledges the violation, j
1.
Reason for the violation.
The Lead Shielding Coordinator (LSC) disregarded the clearly stated requirement of the procedure. He considered it a minor requirement l
used only for keeping track of individual shielding installations and chose to disregard it since he was aware of every temporary shield j
installed. His error was in disregarding the procedure rather than changing it to ensure it was compatible with the way he believed it should be done.
In addition, the Lead Shielding Project Leader (LSPL), who was responsible for providing supervisory oversight to the LSC, did not catch the error. He focused on field installation aspects of the shielding process rather than conducting a detailed review of the paperwork. His error was inattention to detail in that he did not know the tagging requirement was in the procedure, nor did he question the unfilled blanks on the Lead Shielding Evaluation Form.
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e TrojanLNuciscr Plant Document Control Desk.
Docket 50-344 July 7, 1989
' License NPF-1 Page 2 of 2 2.
Corrective steps.that have been taken and the results achieved.
Since the requirement was clearly stated in the procedure and the LSC chose not to follow it, despite his awareness of it and despite clearly communicated management expectations in this area, positive disciplinary action was administered to the LSC.
In addition, the LSPL received positive disciplinary action along with a list of specific responsibilities for which he will be held accountable.
It should be noted that both of these employees have been exemplary workers-in the past.
The mistakes were errors in judgement. The implications of those errors have been appropriately impressed upon the individuals involved.
3.
Correctivo steps that will be taken to avoid-further violations.
It has been clearly and repeatedly communicated to all plant personnel that they are considered responsible individuals who will be held accountable for their work.
Positive discipline will be applied as necessary for those instances where individuals do not accept the responsibilities of their positions.
4.
The date when full compliance will be achieved.
Maintenance tags were hung immediately on all lead shielding installations as soon as the problem was identified. Positive discipline was performed for the individuals involved within seven days of the incident. The LSPL revised the tagging requirement in the procedure to be more workable from a practical standpoint (i.e.,
changed from maintenance tags to lead shielding tags). Full compliance has been achieved.
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