ML20247M957
| ML20247M957 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/23/1989 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8906050202 | |
| Download: ML20247M957 (2) | |
See also: IR 05000344/1989001
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May 23, 1989
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Portland General Electric Company
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121 SW Salmon Street, TB-17
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Portland, Oregon 97204
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- Attention: Mr. David W. Cockfield
Vice President, Nuclear
Gentlemen:
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This refers to your letter ofc April 14, 1989, responding to our Notice of
Violation contained in Nuclear Regulatory Commission Inspection Report
50-344/89-01. The report identified two violations with multiple examples,
and you acknowledged the violations.
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Y'our response'to Violation B.2., a Quality-Assurance (QA) failure to
identify and record procedural noncompliance, does not appear to address
the superviscr/ management contribution to this event. This violation
involved a Quality Control Inspector, a new employee, who apparently did not
fully understand management's expectations with regards to procedural-
compliance. .Your. improvement programs, over the past two years and as-
outlined in our May 10, 1989 enforcement conference,. include clarifying
mangement expectations and assuring ' accountability of supervisors. and managers'.
Although your; discussions in the May 10, 1989 enforcement conference
highlighted your actions in this area, your response to this violation does
not address why.~QA supervision and management did not assure that expectations-
were understood.and that the individual was adequately prepared.
Therefore,
please amend'your response to include your evaluation of the adequacy of
management / supervision involvement in scoping and assignment of work
- activities. Also include in your amended response the corrective actions
associated with your findings and your plans for implementing your corrective
' actions. Please provide your response'within 30 days of the date of this
letter.
The response directed by this letter is not subject to the clearance
procedures of the Office of Management and Budget as required by the Paperwork
Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this matter, we will be pleased to
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discuss them with you.
/S/
R. P. Zimmerman, Acting Director
Division of Reactor Safety and Projects
8906050202 890523
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DR
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May 23, 1989
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bec w/ copy of letter dated 4/14/89:
Docket File
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Resident Inspector
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Project Inspector
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G. Cook
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David W. Cockfield Vice President, Nuclear
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April 14, 1989
Trojan Nuclear Plant
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Docket 50-344
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License NPF-1
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U.S. Nuclear Regulatory Commission
ATTN: Document Control Desk
Washington DC 20555
Dear Sir:
Reply to a Notice of Violation
Your letter of Merch 15, 1989 transmitted a Notice of Violation associated
with Nuclear Regulatory Commission Inspection Report 50-344/89-01.
Attached is our response to that Notice of Violation.
Sincerely,
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VNr.JohnB. Martin
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Regional Administrator, Region V
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U.S. Nuclear Regulatory Commission
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Mr. William T. Dixon
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State of Oregon
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Department of Ener6Y
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Mr. R. C. Barr
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NRC Resident Inspector
Trojan Nuclear Plant
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Document C3ntrol Dack
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- Dock;t 50-344
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License NPF-1
April 14, 1989
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Page 1 of 7
REPLY TO A NOTICE OF VIOLATION
VIOLATION A
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Title 10 to the Code of Federal Regulations Part 50.9 (10 CFR 50.9)
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states, in part:
"Information provided to the Commission by . . . a
licensee .
shall be complete and accurate in all
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material respects."
Contrary to the above, on February 2, 1989, the inspectors found that
Plant Operations Test (PDT) Procedure 26-2, Revision 24. " Process
Radiation Monitor Calibration," had not been changed as stated in
Licensee Event Report (LER) 88-49, Revision 0, " Partial Containment
Isolations Result From Signal Spike and Operator Error," dated
January 26, 1989.
This is a Severity Level IV violation (Supplement 1).
REPLY TO VIOLATION A
Portland Ceneral Electric (PCE) Company acknowledges the violation.
1.
Reason for Violation:
The reason for the violation was personnel error. The statement in
LER 88-49 was based upon input provided by the Chemistry Branch
Manager. This input was incorrect due to miscommunication between
.the Chemistry Branch Manager and a'=amhae of his staff and the mann-
p*s failurw to. verify that_the change to 70T-26-2.was complete.
2.
Corrective Steps Taken and Results Achieved:
a.
On February 2,1989, a temporary change to POT-26-2 was immedi-
ately implemented which appropriately revised the procedure as
described in LER 88-49.
b.
On March 23, 1989, Revision 25 to POT-26-2 was approved, which
incorporated the temporary changes.
The procedure providing guidance for writing LERs, Nuclear
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Safety and Regulation Instruction (NSRI) 900-2Q entitled
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" Licensee Event Report Preparation and Review," was changed on
February 11, 1989 to specifically require obtaining the proce-
dure revision number and date when making statements in an LER
that a procedure has been changed.
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Tro'jan Nur,lo:r Plcnt
D; cum:nt Cantrol D2sk
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!icense BTPF-1
April 14, 1989
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Page 2 of 7
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d.
The importance of ensuring that information provided to the NRC
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be complete and accurate was reemphasized with the appropriate
personnel involved. In addition, a February 15, 1989 memorandum
was issued by the Vice President Nuclear to all managers and
supervisors stressing the importance of ensuring that
information be verified as accurate and complete.
3.
Corrective Steps That Will be Taken to Avoid Further. Violations:
.All cerrective steps have been completed. Continued management
attention will be provided to ensure that these corrective steps are
effective.
4.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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Attcchment
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License NPF-1
April 14, 1989
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Page 3 of 7
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VIOLATION B
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Title 10 to the Code of Federal Regulations, Part 50 (10 CFR 50), Appen-
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dix B, Criterion V, states, in part:
" Activities affecting quality shall be prescribed by
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documented instructions, procedures, or drawings of a
type appropriate to the circumstances and shall be
accomplished in accordance with these instructions,
procedures, or drawings."
1.
Periodic Instrument and Control Test (PICT)-5-2, " Steam Generator
Level, Protection Set II," Revision 12, approved August 26, 1988,
requires, in part, the use of multiple photocells associated with
the comparator logic tester and the use of a simulated test signal
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initially set at five volts, decreased to one volt while recording
applicable bistable actions, and then increased while recording
applicable bistable actions.
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Contrary to the above, on February 2,1989, test personnel performed
the test in a manner inconsistent with the procedure, in that only
one photocell associated with the comparator logic tester was used
and the simulated test signal was ramped down and up in a staggered
fashion to obtain data for each bistable action until the signal was
decreased to one volt.
1his is a Severity Level V violation (Supplement I).
2.
Licensee Quality Inspection Procedure (QIP) IS, "QI observations of
I&C Calibration Activities," Revision 0, approved January 4, 1989,
specifies in part, that the quality control inspector shall note
Whether work -was Performed in accordance .with spps _d instzw+ 4 ans,
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procedures, and/or technical manuals to assure that Plant proce-
dures, work package instructions, and installation standards are
followed.
Contrary to the above, on February 2, 1989, a quality control
inspector failed to note and document failures to follow approved
procedures during the performance of channel functional testing of
steam generator water level instrumentation per licensee procedure
PICT-5-2.
This is a Severity Level IV violation (Supplement I).
3.
Licensee Plant Safety Procedure (PS) 3-30. Revision 17,Section IV
Item E. states:
"It is the responsibility of the person accepting
the equipment clearance to check the equipment clearance and assure
himself that the equipment is satisfactorily tagged and the equip-
ment is deenergized and cleared fnr work before starting work."
Further, licensee procedure Administrative Order (AO) 3-9,
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Trajhn Nucicar P1hnt.
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Attachment
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License NPF-1
April'14, 1989
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Page 4.of 7
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Revision 26, Section.I. Item 4. states: "The assigned craftsman /
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technician performs the maintenance prescribed by the MR work
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instructions and documents itsl completion in the work performed
section of the MR."
Contrary to the above, on February 12,-1988, a Maintenance craftsman
replaced;the charcoal'adsorber in the "B" Train of.the containment
Hydrogen Vent System that was not tagged out or cleared for work,
and failed to replace the charcos1 adsorber of'the
"A" Containment
Hydrogen Vent System specified in KR werk instructions.
This is a Severity Level IV violation (Supplement I).
REPLY TO VIOLATION B.1
PGE acknowledges the violation.
1. . Reason for: the Violation:
The reason for this violation is personnel error. Personnel failed
to follow the procedure exactly as written, and assumed that actions
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that were technically equivalent to the steps in the procedure could
be' substituted without making a procedure revision or deviation.
Subsequent review found that the problem of not connecting the
comparator photocell to the light specified in the procedure was
common to other procedures.
In addition, the practice of raising.
and lowering the test signal When all photocells were not operable
was a common past practice.
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Corzwet.ive<. steps 2aken 6Jiasult.s Aahad:
All PICTs were reviewed to determine where a similar problem
existed. A procedure deviation was made to all applicable proce-
dures to correct the photocell location and to permit the test
signal to either ramp continuously up and down, or to be stepped.at'
the discretion of the technician performing the test. This action
was completed on February 27, 1989.
Management expectations for limitations on procedure flexibill,ty
were discussed with Maintenance electrical and instrumentation and
control (I&C) personnel and their supervisors. Personac1 were
advised that technical or electrical equivalency is not sufficient
justification for not following the procedure as written.
If an
equivalent method is to be used, the procedure or work instruction
must be changed to reflect it.
This was also discussed with
temporary Maintenance employees that are being used for the
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1989 outage.
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License NPF-1
April 14, 1989-
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Page 5 of 7
3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
The lessons learned from this event will be incorporated into the
Periodic Maintenance Retraining Program. This will be completed
before the next session scheduled to begin in September 1989.
4.
Date We Full Compliance Will Be Achieved:
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Full compliance has been achieved.
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Docket 50-344
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April 14, 1989
page 6 of 7
REPLY TO VIOLATION B.2
PGE acknowledges the violation.
1.
Reason for the Violation:
The reason for this violation is personnel error. The quality
control inspector failed to recognize the procedural noncompliance
because he had not adequately reviewed the PICT-5-2 procedure ahead
of time and did not have a copy of the procedure with him while
observing the channel functional testing. The inspector was
notified of his assignment to perform the observation only a few
minutes before the testing was to begin.
2.
Corrective Steps Taken and Results Achieved:
Management expectations of the role of quality control inspec-
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tions in verifying procedural compliance were discussed with all
inspectors.
It was emphasized that verification of procedural
compliance requires that the inspector be familiar with the
procedure and have a copy with him during the observation.
Subsequent PICT observations performed by quality control
inspectors have been observed by management to enmare that
expectations are implemented,
b.
Scheduling of PICT observations has been improved.
Inspectors
are now assigned to specific PICT observations well in advance,
allowing adequate preparation time.
3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
me 41ectrical quality control inspectors-will Participate in :the
classroom training sessions of the I&C technician quarterly
training program to improve the inspectors' knowledge of I&C
activities. Participation in this training is scheduled to
begin in September 1989.
b,
All electrical quality control inspectors will attend formal
observation training by August 1, 1989.
4.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
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Attachment
License NPF-1
April 14, 1989
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REPLY TO VIOLATION B.3
PGE acknowledges the violation.
1.
Reason for the Violation:
The reason for this violation is personnel error. The replacement
of the charcoal adsorber for the
"A" Containment Hydrogen Vent
System was to have been performed under a clearance accepted by the
system engineer. The system engineer had verified that the equip-
ment was tagged, deenergized, and cleared for work. However,
miscommunication between the system engineer and the maintenance
craftsman resulted in the craftsman replacing the "B" charcoal
adsorber.
In addition, the craftsman did not have a copy of the
Maintenance Request (MR) with him when performing the work, and
relied solely on verbal instructions from the system engineer.
2.
Corrective Steps Taken and Results Achieved:
a.
Upon discovery on February 23, 1988 that the "B" charcoal
adsorber had been replaced, the
"B" Containment Hydrogen Vent
System was placed in an inoperable status. On July 1, 1988,
during the annual refueling outage, the required operability
testing was performed on the
"B" charcoal adsorber with
satisfactory results. The system was returned to operable
status.
b.
The craftsman received additional instruction on the need to
carefully read and follow instructions when performing work
under an MR.
The engineer received additional training on the
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' necessity.cf being certain that verbal or written J.nstzw+ 4-
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-3re c.ltar, templete and, Where requittni, .nference irpecific
component identification numbers.
c.
Maintenance personnel have received training on AD 3-9,
" Maintenance Requests," specifically relating to verbal instruc-
tions.
Emphasis was placed on properly documenting verbal
instructions.
d.
Maintenance personnel are now required to have a " field copy" of
the MR at the worksite to assure that the procedures are
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followed and there is no confusion as to the instructions,
procedures or intent of the MR.
3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
All corrective steps have been completed.
4.
Date When Full Compliance Will Be Achieved:
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Full compliance has been achieved.
DLN/mr/3008W.0489
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