IR 05000344/1981034
| ML20040E744 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/22/1982 |
| From: | Johnson P, Zwetzig G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20040E739 | List: |
| References | |
| 50-344-81-34, NUDOCS 8202050304 | |
| Download: ML20040E744 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No.
50-344/81-34 Docket No.
50-344 License No.
NPF-1 Safeguards Group-Licensee:
Portland General Electric Company-121-S. W. Salmon Street Portland, Oregon 97204 Facility Name:
Trojan Inspection at; Rainier, Oregon
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Inspection conducted:
Dscemben 7-11.and 16,' 1981 Inspector:
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27/ 2-P.H.Jd/nson,ReactorInspector.
D~ ate Signed Approved by: h
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A G.IBIde'tzig,(:hikf, Reactor.OperationsProjects
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Date(figndd Section 1 Summary:
Inspection on November 2-6, 1981 (Report No. 50-344/81-34)
Areas Inspected:
Routine, unannounced inspection of the QA audit program, Nuclear Operations Board activities and IE Circular followup.
Followup inspection was also conducted of certain licensee actions in response to the Perfonnance Appraisal inspection of February-March 1981.
The inspection involved 36 inspector-hours onsite and at PGE corporate offices by one NRC inspector.
Results:
One item initially identified during the February-March,1981, Performance Appraisal inspection was determined to be in noncompliance with Technical Specifications requirements (para. 3 - Severity Level V).
No deviations were identified.
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RV Form 219(2)
8202050304 820122 gDRADOCK05000g
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DETAILS 1.
Persons Contacted PGE Corporate Offices
- B. D. Withers, Vice President - Nuclear
- D.
J. Broehl, Assistant Vice President - Nuclear
- F. C. Gaidos, Manager, Nuclear Projects Quality Assurance W. S. Orser, General Manager, Technical Function; J. L. Dunlop, Quality Assurance Engineering lupervisor, Operations J. D. Schweitzer, Quality Assurance Engineering Supervisor, Projects
- G. A. Zimmerman, Supervisor, Licensing Section R. W. Reid, Senior Engineer Trojan Site
- C. P. Yundt, General Manager <
- C A. Olmstead, Manager, Technical Functions.
- R. P. Barkhurst,' Managsr, Operations and Maintenance
- J. D. Reid, Manager,' Plant' Services
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M. R. Snook, Senior QA/QC Inspector
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The inspector also interviewed other licensee employees during the course of the inspection. These: included corporate licensing
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personnel and plant staff: engineers.
- Present at onsite exit interview on Decemberill,1981.
- Present at corporate exit interview on' December 16, 1981.
2.
Licensee Action on Previous Inspection Findings Followup Item (80-19-01, Open):
Installation of public address and evacuation alarm system improvements. The licensee's letter dated July 20, 1981, stated that installation of the new public address and evacuation alarm system would be completed by the end of 1983, due to " greater sophistication of the new system than originally anticipated." A licensee representative stated that nost of the installation was scheduled to be done in 1982, with the balance to be completed in 1983.
3.
Nuclear r,perations Board (N0B) Activities Inspection of NOB activities included examination of membership and qualifications, meeting schedules covering the past year, items reviewed by the N0B, and recent changes to the N0B charter.
Followup inspection also was conducted in areas identified as
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weaknesses by the NRC's Performance Appraisal (PA) inspection of February-March, 1981.
Inspection findings were as follows:
a.
The NOB Charter had been revised to better define the functions
and responsibilities of NOB members. A Senior engineer had been assigned to the N0B staff function, and NOB Procedure No.100-1 had been issued to define responsibilities of the NOB staff. Methods for handling dissenting opinions and for ensuring that all required reviews are completed had also been included in separate NOB procedures. The charter also addressed NOB review of certain operating records. The licensee did not envision the NOB reviewing all IE Bulletins and Circulars, this being done by other parts of the licensee's organization.
b.
The N0B Chairman, consistent with the licensee's response (letter, Withers to Stello, dated July 31, 1981) to the Performance Appraisal insoection report, stated that a training checklist would be developed for the indoctrination of N0B members. The intent of the checklist would be to ensure that a prospective member understood the responsibilities, regulatory require-ments, and other administrative matters pertaining to board
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membership. This will be reviewed during a future inspection.
(81-34-01)
c.
The licensee's July 31, 1981, letter identified plans to review 10 CFR 50.59 safety evaluations on a quarterly basis, although the N0B Charter still specified an annual review.
The N0B Chairman stated that, although the NOB still planned to do the review quarterly, the charter would be revised to soecify a semiannual review, consistent with the N08 meeting frequency and review requirements in the Technical Specifications (TS).
(81-34-02)
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d.
A N08 procedure covering procurement of services by the N0B was still under development.
(81-34-03)
e.
The assignment of N0B reviews to subcommittees or individuals i
was discussed.
Such assignments are made by the licensee to i
screen, summarize, or otherwise facilitate the comoletion of required reviews. The inspector stated that reports to the NOB from designated reviewers or subcommittees should present
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sufficient information to permit the N0B to fulfill its TS review responsibilities.
Individuals or subcomittees were being used to perform reviews of 10 CFR 50.59 safety evaluations for the N0B. The NOB Chairman stated that their reports to the NOB would include a brief description of each 50.59 change and a summary of its safety evaluation.
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L f.
Onsite and offsite licensee groups were, drafting internal
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guidance to govern NOB and Plant Review Board reviews of violations of TS and other regulatory requirements. An initial draft of a definition of " Technical-Specifications violation" did not include violation of procedures required. by TS 6.8.1 or TS 6.11 to be implemented or adhered to. The inspector cited the IE position that violation of such a procedure does constitute a violation of TS 6.8.1 or 6.11 if the procedure -
violation has an adverse effect on nuclear or radiological safety.
g.
The PA report observed that the N0B had not been reviewing NRC inspection reports prior to the February-March,1981, PA inspection, and therafore had not been fulfilling its TS requirement to review TS violations. The licensee had incorporated into the N0B charter a requirement for the NOB to review NRC findings of noncompliance and the licensee's responses to them.
This item was determined to represent noncompliance with TS requirements.
Corrective actions were taken by the licensee following the PA inspection, however, and a response identifying further corrective actions is not required.
4.
QA Audit Program The licensee's audit program was examined against the requirements of the Technical Specifications (TS), the Nuclear Projects Quality Assurance Program for Operations (NPQAP/0), and pertinent industry standards.
Followup. inspection was also conducted of weaknesses identified during the Perfomance Appraisal (PA) inspection of February-Ma rch, 1981. The following inspection findings resulted:
a.
The NPQAP/0 assigns responsibility for the licensee's internal and external audit programs to the QA department.
Schedules of onsite and offsite audits had been issued for 1981. A matrix listing all TS requirements had also been prepared for use in scheduling and monitoring the completion of audits of
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TS required activities. A similar document did not exist to define the scope of other portions of the audit program or to serve as a basis for preparing and following the status of audit schedules.
For example, an audit of the maintenance program was scheduled semiannually, but there was no definition (other than records of previous audits) of what activities in the maintenance area should be audited.
It also was not clear that the audit program was covering all quality-related activities.
During the exit interview on December 16, licensee management stated that~the need for a clearer definition of audit program scope would be evaluated.
(81-34-04)
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The PA inspection discussed the licensee's periodic review of the " status and adequacy of the quality assurance program," as required by 10 CFR 50, Appendix B, Criterion II.
While the licensee was found to have been conducting this review, several quality-related activities were not included.
The licensee's response (letter, Withers to Stello, dated July 31, 1981) to the PA inspection report stated that " Revisions to established Plant and Corporate procedures and instructions will be made in order to provide... a comprehensive method for evaluating the effectiveness of the QA program." The NPQAP/0 presently assigns responsibility for this review to the NOB.
The licensee was considering a change which would have the QA Board perform the overall evaluation, with input from N0B review included.
The role of the QA Board regarding the QA program for operations is not defined in the UPQAP/0.
Procedures or instructions defining how and by whom the evaluation would be performed had not yet been developed.,-(81-34-05)
c.
The PA report presented coments regarding the scheduling and documentation of audits by the Plant-QA grouo.
In response, a document had been preoared which outlined the scope of audits conducted by the Plant QA group (in addition to those performed by the corporate QA Department).
An audit / surveillance schedule was also being issued monthly. Audits were being documented in accordance with Section II.D.3 of QAP-18-2.
In addition, the "QA Staff Instruction for Trend Analysis Report Preparation" was revised in September 1981 to require a review of Plant Staff Audit and Surveillance Reports for deficiencies noted and corrected during the audit or surveillance (i.e.,
not documented on a Quality Noticc).
Significant conditions adverse to quality were also required to be documented as a Possible Reportable Occurrence.
d.
Plant QAP's had been revised to provide for distribution of plant audit and surveillance reports to the N0B (QAP 18-1, Revision 9; and QA! 18-2, Revision 2; both dated 9/28/81).
e.
The indeoendent safety assessment program described in the licensee's July 31, 1981, letter was scheduled for funding and development beginning in January, 1982, f.
A Joint Utility Management Audit was conducted during the week of December 7-11, 1981. The results of this audit were expected to be a significant input to the review of QA nrogram adequacy discussed in paragraph 4.b above.
g.
No findings resulted from examination of other activities associated with the audit program. These included auditor qualifications; assignment of responsibilities for overall
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management of the program; and'the establishment of methods for identifying audit findings, responses, and corrective actions.
5.
IE Circular Followup The inspection included followup on licensee' actions in response to recent IE Circulcrs. The circulars had been fo'rwarded to and reviewed by cognizaor members of the licensee's organization.
Inspection findings were as follows:
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IE Circular 80-05, Emergency. Diesel Generator Lubricating Oil (Closed):
Provision for the addition of lubricating oil during engine operation had been included in RDC 80-052 (scheduled for installation during the 1982 'refuelfn'g outage).
The onsite stock of lubricating oil had also been increased to 13' barrels to provide for operating both diesel generator units continuously for one week.
IE Circular 81-03, Seismic Monitoring Instrumentation (Closed):
An internal memorandum dated 4/28/81 noted that many of the problems listed in the circular pertained to Trojan, although fewer failures had been experienced in the previous 12-18 /
months.
Surveillance requirements in the TS were reflected in the licensee's surveillance testing program. The performance of seismic monitoring instruments is also reviewed periodically by tha resident inspectors.
IE Circular 81-02, Performance of NRC Licensed Individuals (Closed): Administrative Order 3-8 had been revised to incorporate the provisions of the circular. All operators had also reviewed the circular; IE Information Notice.79-20, Revision 1; and Regulatory Guide 1.114.
IE Circular 81-10, Steam Voiding in the Reactor Coolant System (0 pen):
Facility. procedures GOI-4 and ONI-6 had been revised to incorporate concerns expressed in the circular.
Licensee resnonse to action items 2 and 3 as recommended in the circular will be examined during a future inspection.
6.
Exit Interview The inspector (and Senior Residant Inspector) met with licensee management (denoted in paragrapn 1) on December 11 at the Trojan site and on December 16 at the PGE corporate offices. The inspection findings of paragraphs 2 through 5 were discussed. One finding of
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the February-March,1981 Performance Appraisal inspection was identified as a noncompliance item for which the licensee's cor-rective actions had been complete.
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The definition of " Technical Specifications violation" was discussed.
A definition being prepared by the licensee had not considered procedure violations to be TS violations. The inspector expressed the NRC's position that violation of a procedure required by TS 6.8.1 or 6.11 to be implemented or adhered to represents a violation of TS 6.8.1 or 6.11 if the procedure violation has an adverse effect on nuclear or radiological safety (paragraph 3.f).
Licensee representatives made the following responses regarding certain other matters discussed during the December 16 interview:
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Stated that methods for performing a periodic review of QA program adequacy and the role of the QA Board in the Quality Assurance Program for operations would be defined (paragraph 4.b).
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Stated that a clearer definition of QA audit program scope wo'ild be evaluated (paragraph 4.a).
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