ML20247M957

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/89-01.Response to Violation B.2 Re QA Does Not Appear to Address Supervisor /Mgt Contribution to Event.Amend to Response Requested

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

Text

-1

'

.-

,

,

4.

A

May 23, 1989

)

'

, _

i

Portland General Electric Company

]

'

~

121 SW Salmon Street, TB-17

j

,

Portland, Oregon 97204

]

1

l

Attention: Mr. David W. Cockfield

Vice President, Nuclear

Gentlemen:

'i

1

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.

'

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

!

discuss them with you.

/S/

R. P. Zimmerman, Acting Director

Division of Reactor Safety and Projects

8906050202 890523

h

DR

ADOCK 05000344

PNU

,\\

t;

-

__

_ _ _ _ _ . . _ _ _

s

_

_ - . ._

1

'

.

,

,

,

.

.

1

i

,

.

2

May 23, 1989

,

i

bec w/ copy of letter dated 4/14/89:

Docket File

-]

Resident Inspector

.

Project Inspector

,

G. Cook

j

A. Johnson

i

'

B. Faulkenberry

J. Martin.

LFMB

State of Oregon

bcc w/o copy of letter dated 4/14/89:

M. Smith

i

lI

j

'

'RV/jk

'

A{quESTCOPY

REQUEST

Y

REQUEST CLPY

l

'

'

"

[JES / N0

YES / N0

YES /CE)

V

i

SE ' TO PDR

' _ES / N0

J

MENDONCA Afl

CHAFFEE A ZIMMERMAN S &

5/20/89

5/2889

5/e/89

. _ _ _ - _ _ - _ _

_

. - _

.-

O

.

. .-

j

.

.

g.

-

er

_

,

.

,J[,l!

P

,-

- g

ortlandGeneralElechicCcripeniy

,

David W. Cockfield Vice President, Nuclear

[

p

April 14, 1989

Trojan Nuclear Plant

h

Docket 50-344

g

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 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,

/

> Attachment

c

VNr.JohnB. Martin

]

! ' -

.~ ]

c:

'

Regional Administrator, Region V

./

J'

'

<

h'h

1

U.S. Nuclear Regulatory Commission

t

Mr. William T. Dixon

1

-

.

State of Oregon

j[

,' j

'

Department of Ener6Y

.

,

'

' ' '

'

'

/,-

-

Mr. R. C. Barr

'/'

,

NRC Resident Inspector

Trojan Nuclear Plant

c,

'

,\\

-

6 . Q\\d

u

-

,j

nn

.n

-

l

b

I

t

C

y1

121 SW Samon Sree* Poaana Oregon 9720i

-

_ - _ - _ _ - _ _ - _ _ _ - _ - - - _ _ _ _ _ _ _ _ _ - _ - _ _ - _

__ _ _ _ _ - - - _

-

-

..

• 'Trp5cn vueleer Plcnt

Document C3ntrol Dack

-

.

,,

Dock;t 50-344

Attechment-

.

License NPF-1

April 14, 1989

'

Page 1 of 7

REPLY TO A NOTICE OF VIOLATION

VIOLATION A

1

Title 10 to the Code of Federal Regulations Part 50.9 (10 CFR 50.9)

I

states, in part:

"Information provided to the Commission by . . . a

licensee .

shall be complete and accurate in all

.

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

c.

Safety and Regulation Instruction (NSRI) 900-2Q entitled

I

" 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.

i

--

- _ _ - _ _ - _ _ _ _ _ _ - _ _ - _ - - - _ _ _ _ - - - _ _ . _ _

--

- _ - _ _ _ _ - --

.__

_

_

_

1

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _

_ _ _ _ _ _ _ _ _ _

_

_ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ ,

.

-

,-

$.

.

-

Tro'jan Nur,lo:r Plcnt

D; cum:nt Cantrol D2sk

-

,.~;D ck;t 50 344

Attachment

-

!icense BTPF-1

April 14, 1989

'

Page 2 of 7

I

d.

The importance of ensuring that information provided to the NRC

i

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.

.

_ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ - - -

-_-_-

_ _ _ _ _ _ - -

._ _

>

.

..

' 'Trpjr.n Cue 10 r Pltnt

Document Contral'D30k

- ..

., , , Dock;t 50-344 -

Attcchment

l.

.

l

License NPF-1

April 14, 1989

(

Page 3 of 7

'

1

VIOLATION B

1

1

Title 10 to the Code of Federal Regulations, Part 50 (10 CFR 50), Appen-

l

dix 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."

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

!

'

initially set at five volts, decreased to one volt while recording

applicable bistable actions, and then increased while recording

applicable bistable actions.

I

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,

.

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,

_ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - - _ -

__ ___

_

.

_

-

r

. EU

' '

.

,;

)

'

.

-

,

.

Trajhn Nucicar P1hnt.

Dscument Control D3Ek

"' "

F

d Docket l50-344.

Attachment

!

i

License NPF-1

April'14, 1989

!

.

Page 4.of 7

(h?

'

Revision 26, Section.I. Item 4. states: "The assigned craftsman /

l-

'

technician performs the maintenance prescribed by the MR work

'

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

.

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.

J.

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

,

1989 outage.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ _ _ _ _ _

_

_ _ _ _ - _ - -

_.

. , ,

.

,

Trhjcn Nuclocr Pirnt

• * *

Document Control Desk

-, i Dockbt 50-344

'

Attachment

License NPF-1

April 14, 1989-

,

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:

o

Full compliance has been achieved.

.

- - .

_

. _ _ _ _ _ _ _ _ - _ _ _ _ _

-______-

_ _ _ _ __ ____ _ _ ___-__ _ _ - __

c-

,

. .

4

'

..

.

Trojcn Nuclocr PICnt

D cument Contr31 De:k

<

Docket 50-344

Attachment

-

.

License NPF-1

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-

a.

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.

_ - _ _ _ _ _ - _ _ _ _ - _ _ _

_ - - _ _ -

_

. _ _ _ _ _ - - -

,

.

'

Trajtn Wuclcrr plcnt

Document Contesl De:k

.

'

. . Dr.cket 50-344

Attachment

License NPF-1

April 14, 1989

.

Page 7 of 7

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

~

' necessity.cf being certain that verbal or written J.nstzw+ 4-

.

-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

,

)

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:

,

1

Full compliance has been achieved.

DLN/mr/3008W.0489

1

_-____--____________-__--_-_________________a