IR 05000344/1985030

Insp Rept 50-344/85-30 on 850909-13 & 23-27.No Noncompliance or Deviations Noted.Major Areas Inspected:Requalification Training Program,Facility Mod Program,Implementation of Audit Program & QC Program Review

ML20133M627
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/08/1985
From:	Dodds R, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20133M623	List: IR 05000344/1985030 ML20133M620
References
50-344-85-30, NUDOCS 8510280159
Download: ML20133M627 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report N /F5-30 Docket N License N NPF-1 Licensee: Portland General Electric. Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection at: Rainier, Oregon Inspection cor. ducted: September 9-13 and September 23-27, 1985 Y

Inspector: I < tali / wiur L0t $l$5 D. B. Pereira, Reactor Inspector Date $1gned Approved By: /C /- ('

R. T. Doddd7 Chief, Reactor Project Section 1 Dat/ $/gned Summary:

Inspection during the period of September 9-13 and September 23-27, 1985 (Report No. 50-344/85-30)

t Areas Inspected: Routine, unannounced inspection of the Requalification Training Program, Facility Modification Program, QA Program - Annual Review, Implementation - Audit Program, Audit Program, and follow-up closure of open items. The inspection involved 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> onsite by one hTC inspector. The inspection modules followed were: Requalification Training Program (41701),

Facility Modification (37701), QA Program-Annual Review (35701),

Implementation-Audit Program (40704), and Audit Program (40702).

Results: No items of noncompliance or deviations were identifie l l

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8510280159 051010 1 l PDR ADOCK 05000344 G PDR

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DETAILS _

Persons Contacted

*R. P. Schmitt, Manager, Operations and Maintenance

• J. D. Reid, Manager, Plant Services

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S. B. Nichols, Training Supervisoe

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D. W. Swan, Maintenance Supervisor

, D. R. Keuter, Manager, Technical Services

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R. E. Sesee, Operations Supervisor

• C. A. Olmstead, Manager, Nuclear Quality Assurance Department

! *J. K. Aldersebaes, Manager, Nuclear Maintenance and Construction

' Neese, Assistant Shift Supervisor Andone, Shift Supervisor Ellis, Instructor, Training Department Scheitzer, Branch Manager, Quality Assurance Engineering G. Zimmerman, Manager, Nuclear Regulation Branch J. Dunlop, Branch Manager, Quality Assurance Operations H. Moomey, Trojan Resident, Oregon Department of Energy

• Denotes attendance at exit interview conducted at Trojan Nuclear Plant on

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September 13, 1985, and at Portland Corporate Headquarters on September 27, 198 . Requalification Training Program The requalification training program was examined for conformance with regulatory requirements, Technical Specifications, and licensee ccomitments. The inspection included a review of records of individual licensed operators who had failed a portion of their annual examinatio The inspector reviewed records for four shift supervisors, five control room operators and three assistant control room operators to ensure that j requalification training was adequately documented. The inspector interviewed two control room operators and one assistant control room operator to verify that their training records reflected the actual training received. The inspector verified chat the licensee instructors have a prepared lecture schedule, lesson plan, and that the instructors have evaluated the result of the most recent examinations and have identified deficient areas to be covered in the lecture series. The control room operators interviewed indicated to the inspector that the individual self-study guides and system checkoffs were beneficial technical aspects of the requalification training program. The operators found it helpful to review the examination after the exam was given, and the requalification training program provides for this review one week

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after the exam has been given. The licensee records for the individual licensed operators were complete and included recent medical

examinations, simulator training evaluations, and latest examinatione needed to maintain licensed capabiiity. Within the scope of this audit, it was determined that, the requalification training program for licensed

operators was being implemente No violations or deviations were identified.

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3. Facility Modifications The facility modification program was examined for conformance with regulatory requirements, Technical Specifications, and licensee commitments. The inspection included a verification that the modified systems were installed in accordance with the approved design by examining the installation records, reviewing non-destructive examination (NDE) records, and ensuring revised procedures relating to the modification were completed and approve The following two facility modifications were examined in detail:

As-Built Package, RDC-84-106, DCP-2 replaced Laurence Solenoid Valves on Main Steam Isolation Valves (MSIVs) and the MSIV Bypass Valves. This RDC was completed on June 29, 1985. The test records appeared to be complete and the as-built drawings reflected the design chang As-Built Package, RDC-84-104, DCP 1 replaced Auxiliary Feedwater (AFW)

Motor-Actuators. The replacement of 8 AFW flow control valve motor operators was completed on June 27, 1985. Temporary Plant Test-137, dated June 20, 1985, Rev. O verified proper operation of the turbine driven AFW pump upon completion of the modification to the AFW valve

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motor actuators under RDC-84-104. Remote and local operation (open and close) of the AFW flow control valves was verified satisfactor As-built drawings were revised, up-dated and incorporated into the appropriate design and piping and instrumentation drawings prior to system startup.

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The inspector examined the completed test records and verified that the

licensee conducted a review and evaluation of test results, and that the test results were within previously established acceptance criteri Test deviations were resolved and retesting accomplished as necessar It should be noted that the licensee's test did not include simultaneous operation of both feed pumps, the subject of a subsequent licensee event

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report when one pump f ailed to start because of low pump suction pressure. This was corrected by valve adjustment and maintaining condensate storage tank level above 60%.

No violations or deviations were identifie . Quality Assurance Program Annual Review

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The inspector examir.Ad changes to the quality assurance program to i determine whether personnel responsible for development of implementating

procedures were familiar with the changes or revisions. The inspector i

also exasined implementing procedures to determine whether revisions were

! in conformance with the changes described in the docketed Quality Assurance (QA) program, and to determine whether the implemented QA

, program was in conformance with regulatory requirements, commitments, and

industry guides and standards.

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The significance of the specific changes was discussed with cognizant

personnel. The licensee personnel interviewed had full knowledge and understood the significance of any changes. Nuclear Division Procedure

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(NDP) No. 100-5 establishes the requirements for the preparation of

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. 3 cvaluations required by NRC Regulations 10 CFR 50 and Trojan Technical Specifications for changes to the facility and changes to procedure The Safety Evaluation Checklist (Attachment A)'and the Detached. Safety Evaluation (Attachment B) of NDP No. 100-5 were utilized to ensure that Trojan personnel understood the significance of the specific change The QA Program changes were prepared by the QA personnel and these personnel gave training on the QA program changes to their department managers and to QA personne The inspector reviewed the QA program implementation by inspecting the Audit Program and Implementation-Audit Program during this inspection period. Further review of the QA program implementation was conducted in other inspection reports as follows: the Document Control Program in Inspection Report 85-23; the Onsite Review Committee in Inspection Report 85-13; and the Offsite Review Committee and Offsite Support Staff in Inspection Report 85-1 Within the scope of this audit, the licensee's QA program appears to be effectively implemented and was in conformance with regulatory requirements, commitments, and industry guides and standard No violations or deviations were identifie . Audit Program The inspector examined whether the licensee has developed a quality assurance program relating to audits of activities in conformance with regulatory requirements, and commitments in the applicatio Portland General Electric (PGE) Company Topical Report (PGE-8010)

establishes the QA program, and its implementing procedures and instructions. The QA program describes the PGE organizational structure for quality assurance; identifies the functions, duties, and responsibilities of key departments and individuals; describes inter-relationships and inter-faces among internal groups and external organizations; delineates quality program requirements, and prescribes methods of implementatio Nuclear Quality Assurance Department Procedure (NQAP) 110, Rev. 10, entitled " Quality Assurance Audits" establishes requirements and provides guidelines for the selection of audit personnel, preparation of audit checklists, performance of audits, reporting of audit results, follow-up of audit findings, and verification of corrective action for quality

assurance audits performed by the Nuclear QA departmen The inspector verified that the QA department performs the following functions as described in NQAP 110, NQAP 111, Rev. 8, entitled

" Qualifications of Auditors", and NQAP 101, Rev. 7, entitled " Control of the PGE Nuclear QA Program"

Determining qualifications of audit personne *

Determining independence of audit personnel.

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Ensuring corrective actions will be taken for deficiencies 4 identified during audits, i i l Issuing audit reports to managemen *

Periodic review of QA audit program to determine its status and adequac ,

Preparation 6f long-range audit plans or schedule *

l' Audited. organization will be-required to respond in writing to audit I finding Checklists or. procedures will be used in the performance of audit It appears that the licensee has developed an ef fective QA program relating to audits of activitie No violations or deviations were identifie . Implementation, Audit Program The inspector examined whether the licensee has qualified personnel i

conduct routine audits, ensuring that activities were in conformance with

regulatory requirements, licensee commitments, and industry guides and

standards. The inspector examined / reviewed fourteen audits conducted by the QA Department during the 1984 and 1985 time period. The inspector's j review of the audits verified that the following inspection requirements

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i 4 QA personnel involved in the audit met the minimum education,

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experience, and qualification requirements for the audited activity.

The content of the audit report clearly defines the scope of the l audit and the results.

l The audits were conducted by trained personnel not having direct

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responsibility in the area being audited.

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Appropriate follow-up action via Nonconformance Activity Reports

, (NCAR) had been taken.

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j The audited organization's response to the audit findings was in

! writing, was timely, and adequately addressed the findings and recommendation The inspector reviewed the licensee's long range audit schedules and

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i sampled audit reports to verify that the frequency of audits was in

{ conformance with the Technical Specifications and the approved QA l program. The sampled audit reports were in the areas of operations, j maintenance, plant engineering, corrective actions, requalification

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training, administration, and modifications / material control during the l 1984 and 1985 time period. These areas were in accordance with the l Technical Specifications and the approved QA program audit schedul _. _,_ _ _.,__,_-- ,_ _____._ _ _ _ _._ _ ,_,.._ __.__,_. _ ,_ __..~_ _,,_ _ _ ,_

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j No violations or deviations were identified.

! Follow-up on Previous Inspection Findings I (Follow-up Item 85-11-01; Closed) Plant Review Board Evaluation

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After Revision 28 of A0-7-6 Issued and PRB Engineer Onsite I

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Due to the heavy administrative requirements put on the Plant Review Board (PRB) Chairman; a PRB engineer was added in March 1985 to the plant staff in order to administrative 1y help the PRB Chairman. The

! PRB engir.cer's functions were to coordinate PRB meetings, maintain I

{ status of PRB action items, status follow-up on active LERs, and l write LERs. The PRB engineer's action relieves the Nuclear ,

Engineer, the PRB Chairman, and the Office Supervisor of a large ,

amount of their administrative work.

Revision 28 to Administrative Order (AO)-7-6, issued August 2, 1985,

presents a new event report form which will clarify and expand the PRB's role in plant events reportable or not and prevent

! reoccurrence of events and improve plant operational efficienc The inspector reviewed A0-7-6, Revision 28, and the PRB engineer functions and concludes that the PRB Chairman has been relieved of a l large portion of his administrative duties and that A0-7-6, Revision 28 expands the PRB's role in plant events reportable or no Follow-up item 85-11-01 is closed.

! (Follow-up Item 84-04-01; Closed) Consider Observations Regarding

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Operator Requalification Program i The inspector verified that'the operator requalification program was being performed in accordance with the licensee commitments.

Specifically, the proctors and licensed candidates have been given i instructions for appropriate action to be taken during the

examinations. The examination material from brief notes to finished j type written exam was being kept under lock and key. The security

of examinations material appeared to be satisfactory. The annual

- evaluations of operators was being evaluated by management and steps taken to ensure substantive and~ meaningful material has been included. Oral examinations of operators were conducted by a

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licensed SRO. The content of the oral exams included all requirements, and -an assessment of weaknesses for followup, j Followup Item 84-04-01 is closed.

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! (Followup Item 84-05-05; Closed) Adequacy of Corrective Actions

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to Audit Findings i

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A previous inspectors review disclosed that the licensee's audits j had identified similar weaknesses and that the underlying causes for

these weaknesses had not been adequately evaluated and corrected as

prescribed by Criterion XIII of 10 CFR 50, Appendix It was

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l j further emphasized that the licensee needed to evaluate the adequacy

, of existing procedures, with respect to assuring responses to audits f

have been reviewed and followed up in an effective and timely

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The licensee's QA manager informed the previous inspector that an i evaluation would be performed and that policies would be established that will be consistent with the regulatory requirements.

The inspector reviewed Nuclear Quality Assurance Department i Procedure (NQAP)-107, Revision 8 entitled, " Control of Conditions Adverse to Quality and Corrective Action" and in which section 5.4,

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Corrective Action Status requires on a monthly basis the cognizant

Organization Supervisors or Managers to identify changes to NCAR 1 corrective action completion date In addition, the QA Department

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personnel review the NCAR status log on a monthly basis to assure j that it was complete and that NCARs were being resolved in an

adequate and timely manne Procedure NQAP-110, Revision 10 entitled, " Quality Assurance Audits"

, Section 5.8 " Audit Reports" requires the audited organization to define the corrective action taken to prevent recurrence, the root cause, and a scheduled date for the corrective action in the event

, that required corrective action cannot be completed within the j allotted time.

j Followup item 84-05-05 is considered closed.

j j (Generic Letter 85-05; Closed) Inadvertent Boron Dilution Events Generic letter 85-05 informs the licensee of operating pressurized

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water reactors of the staff position resulting from the evaluation

! of Generic Issue 22, " Inadvertent Boron Dilution Events" regarding

! the need for upgrading the instrumentation for detection of boron

! dilution events in operating reactor In summary, while the NRC did not require operating plant backfits for boron dilution events

] at this time, the staf f would regard an unmitigated boron dilution

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event as a serious breakdown in the licensee's ability to control l its plant, and strongly urged each licensee to assure itself that

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adequate protection against boron dilution events exist in its j plants.

In memorandum JWL-201-85m, dated April 17, 1985 from J. W. Lentsch, i Manager of NSRD, to W. J. Orser, Plant Manager, the Nuclear Safety l and Regulation Department's (NSRD) evaluation of Trojan's designs

and controls that minimize the likelihood of an inadvertent boron t

dilution event prompted the following recommendations:

(i) Re-emphasize the potential for, and mitigation of, inadvertent boron dilution events in retraining. Training for Trojan i

Operations personnel should address the causes, indications,

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and corrective actions for inadvertent boron dilution events,

! both at power and shutdown.

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' (ii) Operations and Maintenance personnel retraining should address

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maintenance practices similar to those outlined in MP-11-2,

" Decontamination of Steam Generator Channel Heads", that have

the potential for boron dilutio !

j Additionally, this memo stated, plant simulator exercises performed 3 annually, may include CVCS malfunctions at power. The licensee's

{ response appears to be adequate and effectively protects the plant

against boron dilution event Generic Letter 85-05 is considered closed.

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} (Other PJ-01-20; Closed) Inspect Fire Protection Modifications i- per Zwetzig Memo of January 15, 1982

(Other PJ-01-20; Closed) Items in SER Section 3.1 Complete

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i (Other PJ-01-20; Closed) Complete Except Memo Para 2

l The NRC's Fire Protection Safety Evaluation Report (SER) dated j March 9, 1978, identified a number of modifications to plant

I programs, administrative controls, and equipment which were to be implemented by the licensee. Items in Section 3.1 entitled j " Modifications" of the SER were required by a licensee condition

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(inserted by Amendment 22) to be installed by the end of the second l refueling outage. Completion of the Section 3.1 items was verified

, by the Senior Resident Inspector, as documented in Inspection j Report 80-21. Section 3.2 entitled, " Incomplete Items" of the SER,

as amplified by an SER supplement dated March 25, 1980, identified seven other items to be implemented as part of the fire protection j program. Examination of pertinent records, interviews with licensee

personnel, and inspector observations confirmed that the items in j Section 3.2 had been complete '

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The above items PJ-01-20 are considered close :

{ (Unresolved Item 85-23-02, Closed) LER 85-08 Cause of Occurrence j and Corrective Action by Licensee 1.

The inspector reviewed LER 85-08 with licensee personnel and i

discussed the licensee's actions concerning personnel error as a

! contributing cause to the LER. The' licensee agreed that it was also

, personnel error and that the term " inadequate administrative i control" meant personnel erro ;

i j Unresolved item 85-23-02 is considered closed.

' (LER 85-08 Reportable Occur, Closed) Inadvertent Safety Injection i

j The inspector reviewed LER 85-08 with licensee personnel as

discussed in the above unresolved item, and determined that the

licensee had reported the LER factually, determined the corrective actions necessary to prevent another occurrence, and implemented the

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LE8t 85 08 is considered closed.

i i Exit Interview

j- The inspector met with the licensee representatives denoted in

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paragraph 1 on September 13 and 27,1985, and summarized the scope and

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findings of the inspection activitie ,

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