ML20199K879
| ML20199K879 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/01/1986 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| 0401P, 401P, NUDOCS 8604100245 | |
| Download: ML20199K879 (5) | |
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Bad D Whrs Vce Pre 9 dent April 1, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director Office of Inspection and Enforcestent U.S. Nuclear Regulatory Commission Washington DC 20555
Dear Sir:
TROJAN NUCLEAR PLANT Response to Notice of Violation and Proposed Ip osition of Civil Penalty By NRC letter dated March 3, 1986 from Mr. John B. Martin, Portland General j
Electric Company received a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $50,000.
Pursuant to the provisions of 10 CFR 2.201, Attachment 1 is our response to the Notice of Violation.
A check in the amount of $50,000 is also attached for payment of the Civil Penalty.
Sincerely,
^ _-
Bart D. Withers Vice President Nuclear Attachments c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. Lynn Frank, Director State of Oregon Department of Energy SSubscribe?
st day of April 86.
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Trojan Nuclear Plant Director, Office of Docket 50-344 Inspection Enforcement License NPF-1 April 1, 1986 Page 1 of 4 10 CFR 2.201 - RESPONSE TO NOTICE OF VIOLATION I.
VIOLATION ASSESSED A CIVIL PENALTY 10 CFR Part 50, Appendix B, Criterion X reads, "A pro' gram for inspec-tion of activities affecting quality shall be established and executed by or for the organization performing the activity to verify confor-mance with the documented instructions, procedures, and drawings for accomplishing the activity. Such inspection shall be performed by individuals other than those Who perform the activity being inspected.
The Trojan Quality Assurance (QA) Program, Section 2.2 references Section 3.2 of the Trojan Nuclear Plant Updated Final Safety Analysis Report (FSAR) for guidelines to be used for determining that systems are safety-related and governed by 10 CFR Part 50, Appendix B.
Sec-tion 3.2 of the FSAR lists the Auxiliary Feedwater System (AFW) and the diesel generators as being safety-related.
Administrative Order 3-9 states that when the Trojan maintenance organization authorizes work, the assigned work group supervisor is responsible for determining the need for QA/QC review of work instructions and for providing for appropriate installation checks to ensure that the equipment functions properly when returned to service.
Trojan QA Procedure 10-2 requires a sign-off by signature or a con-tec11ed stamp showing evidence of satisfactory completion and verifi-cation of the inspection by an inspector who has been qualified in accordance with ANSI N45.2.6 or SNT-TC-1A-1968 as appropriate.
1 Contrary to the above requirements, certain aspects of your Quality Assurance Program were not implemented, in that during 1984 and 1985 i
to the date of the inspection (December 13, 1985) maintenance work requests and accompanying instructions prepared by onsite maintenance supervisors did not provide for appropriate quality control (QC) j inspections except as specifically required by an applicable code or in those instances Where the maintenance work involved a splica in Ray-Chem electrical cables. Examples of maintenance performed with-out appropriate QC inspection include:
(1) The inspection of the west emergency diesel generator following the installation of a new turbocharger, idler gear and brackets, completed on August 2, 1984, under MR-84-0564.
In this instance, inspection was performed by the
Trojan Nuclear Plant Director, Office of Docket 50-344 Inspection Enforcement License NPF-1 April 1, 1986 Page 2 of 4 same individual who performed the maintenance activity; and (2) the satisfactory completion and verification inspection in September 1985 under MR-85-4389 of four time delay relays in the control circuitry for the diesel-driven AFW pumps was not performed by an inspector who had been qualified in accordance with QA Procedure 10-2.
This is a Severity Level III violation (Supplement I).
(Civil Penalty - $50,000) i PGE Response:
For the two instances cited, PGE acknowledges the Violation.
The same person who did the work for the west emergency diesel generator modifications performed the installation inspection and, in the case of the installation of the time delay relays in the control circuitry for the diesel-driven AFW pumps, the inspector had not been qualified in accordance with QA Procedure 10-2.
Furthermore, PGE acknowledges that independent inspections of electrical maintenance and modifica-tion activities had not been implemented at a level required and expected by our Quality Assurance Program.
In some cases, inspec-tions were performed, but were not documented; in others, an independent or qualified inspector was not used.
The reasons for these violations can be attributed to personnel The personnel involved failed to follow implementing proce-error.
dures and failed to exercise good judgment in requiring appropriate 1
independent inspections of maintenance activities.
In several instances where independent inspections appeared to be inadequate, proper work packages and instructions were prepc 'ed, identifying verification and inspection points, but the independent inspections were not appropriate.
corrective actions to resolve this situation are both immediate and long-term. The immediate corrective actions involved the establish-ment of a QC Observation Program in which QC inspectors are, on a daily basis, assigned to observe and monitor the maintenance activities that have been scheduled to assure that procedures are followed and qualified workers are performing the activity as directed. Quality Assurance Department personnel are involved on a daily basis in planning for modifiestions and maintenance activities and in the preparation of work instructions to ensure that adequate inspection points are identified to the workers.
Independent inspectors are directed to sign or initial at the appropriate steps in the work package to indicate their review of the maintenance activity which they are observing.
In addition, a consultant has 4
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Trojan Nuclear Plant Director, Office of Docket 50-344 Inspection Enforcement License NPF-1 April 1, 1986 Page 3 of 4 been retained to develop quality control electrical inspection proce-dures and a training program to qualify electrical inspectors, to the level specified in our Quality Assurance Program.
QC and maintenance procedures are being revised to specify requirements for independent inspections and the insertion of QC observation inspections or other hold points during both scheduled and unscheduled maintenance activities (corrective maintenance es well as modifications). As long-term corrective action, permanent independent inspection hold points will be added to existing maintenance procedures and periodic surveillance procedures.
PGE feels that full compliance with the Nuclear Quality Assurance Program has been achieved. The existing Plant procedures will be revised to include independent inspection hold points and inspections by December 31, 1986. The development of a new maintenance procedure concerning independent inspections and hold points for corrective maintenance will be implemented by April 24, 1986.
Development of QC inspection procedures to control the independent inspections will be completed by April 24, 1986. Training and qualification of selected electrical inspectors will be completed by April' 24, 1986, with the complete training program implemented by December 31, 1986.
II.
VIOLATION NOT ASSESSED A CIVIL PENALTY 10 CFR Part 50, Appendix B, Criterion D - Instructions, Procedures, and Drawings - states in part that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Contrary to the above, on December 10, 1985, the tagging of AFW flow indicating switches was not sucomplished in accordance with drawings in that identification numbers placed on the switches did not match those shown on Piping and Instrumentation Drawing M-213, Sheet 2 Revision 6.
This is a Severity Level IV violation (Supplement I).
PCE Response:
PGE acknowledges that tags on the AFW flow indicating switches were not consistent with the identification numbers on P&ID Drawing M-213, Sheet 2, Revision 6.
The reason for this violation is the result of personnel error. Upon the receipt of the flow indicating switches, the tag numbers were not verified on each of the switches, work instructions were not written to require the worker to verify which
i Trojan Nuclear Plant Director, Office of Docket 50-344 Inspection Enforcement License NPF-1 April 1,'1986 Page 4 of 4 switch was to be installed in which location, and, when the work was performed, the worker did not verify the installation of each switch in its proper location. The immediate corrective action performed was to remove the tags from the flow indicating switches and replace them with accurate tags, consistent with P&ID M-213, Sheet 2 Revi-sion 6.
In addition, the appropriate supervisors held discussions and meetings with the individuals preparing work packages and the workers installing equipment and/or instrumentation and emphasized the need to verify equipment is installed in its proper location.
Receipt inspections of equipment will include the verification as to whether or not the equipment received has specific identification numbers. This corrective action has been completed, and compliance with our Nuclear Quality Assurance Program has been achieved.
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