IR 05000344/1989003

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Enforcement Conference/Mgt Meeting Rept 50-344/89-03 on 890126.Major Areas Discussed:Nrc Concerns Developed as Result of Insp of Commercial Grade Procurement,Per Insp Rept 50-344/88-46 & Licensee Efforts in Areas of QA Program
ML20235T082
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 02/10/1989
From: Mendonca M, Obrien J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20235T071 List:
References
50-344-89-03-EC, 50-344-89-3-EC, EA-89-016, EA-89-16, NUDOCS 8903080140
Download: ML20235T082 (6)
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D U..; S. NUCLEAR' REGULATORY:: COMMISSION  ;, '; i E 

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   -[j LDocket No. 50'-344
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    . License'e:!Phrtland Genera 1(Electric Company
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Facility:Name:; : Trojan' Nuclear Plant ' > 4~ ~ ' 

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    (Inspection _at:LRegion'V Offices, Walnut Creek.. California             '
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   'iRepo'rt5 Prepared by:

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         < M. M. Mendonca, Chief    _

Date 51gneds , Reactor Projects Section 1 4 ' 

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    . Meeting 1onManuary 26, 1989 (Report No' 50-344/89-03).       .     .
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>    An'enforcementconference/ management'meetingwa'sheldin1the'NRCRegionVw               ,, s office,4 Walnut;CreekTCalifornia',"to:discussiNRCconcerns.developedas.av ,.               ,
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result ofz theifnspection^of; commercial grade girocurement (50-344/88-46) datedi ' i 

    . January 24'11989, andito discuss?tha licensee ls1 efforts?inithe areas of Quality?
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', Assurancei.(Improvement), program,- Event Assessment / Licensee . Event Reporti D 

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V a: ' n.m' ' Enclosure'AI g, , K - DETAILS' 

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DL W. Cockfield Vicel President, Nuclear T. D. Walt, da'na,ger, Nuclear Safety and Regulation 

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L. W. Erickson. Maneger, Nuclear Quality Assurance- 

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a> S. A..Bauer, Manager,; Nuclear Regulation- 

   -J. M. Anderson? Materials Manager J.lLentsch, Manager,3P ersonnel Protection
   ,T7 Meek, Branch Manager, Radiation' Protection
 , ,  <D. L.; Funk. Branch Manager, Electrical Engineerin .' 'M. Hoffmann,? Branch Mariager, Mechanically Engineering t '.A.' H. Miller, Lead Engineer, Electrical-Engineering
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J.tB ,Maftin, Regional! Administrator G.;W.;Knighton,+Directo'r , Project Directorate V, NRR-R.:B. Bevant Project Manager,~NRR A'.E E. Chaffee, Acting Director', Division-of Reactor Safety and 

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_ V R. P-. Zimerman, Projects Branch Chief S. A.'Richards,. Engineering Section Chief M. M. Mendonca,: Project Section 1 Chief 

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G. P. Yuhas, EP&RP Branch Chief 

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   'M. Blume, Regional Attorney G. Cook, Regional Public. Affairs Officer J   R. C.1Barr, Senior Resident-Inspector J. P. O'Brien, Project Inspector W. J. Wagner, Reactor Inspector J. L. Crews, Senior Reactor Inspector
   * A. Johnson, Enforcement' Coordinator State of Oregon Attendees H. F. Moomey, ODOE, Acting Manager of Reactor Safety
  ' Details Mr. Richards opened the enforcement conference. He outlined the findings of the commercial grade procurement inspection conducted August 8-12,
  - October 24-27 and November 28 - December 1,1988 (NRC Inspection Report Nos. 50-344/88-39 dated September 13, 1988 and-50-344/88-46 dated January 24,1989). He:provided the historic dt ta as understood by the NRC with
,   regard to the Main Feedwater (MFKj piping procured to replace eroded _ pipe

' ' in 1987, and outlined the'following concerns: e ___m____.__ 

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i The pipe was procured as' commercial grade from material .

manufacturers and suppliers without evaluated !)uality Assurance-(QA)L program " The pipe was dedicated for use in a safety related application by 

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PGE's engineering staff based solely on the certified material test report (CMTR) which accompanied the pipe. PGE did not verify the 

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CMTR prior to installatio . It appears that several opportunities existed to call out'or correc " these practices, and they were ignored (ie. 1985 Notice of l Violation,1986 PGE QA audit findin s, PGE internal communications' and several NRC information notices . 

' There were indicators that PGE's dedication procedures, in general, have lapsed below an acceptable' level in other areas as wel Mr. Richards'further outlined the goals of the discussion in that, he
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asked:, 

  ~ .Do you agree with o'ur findings?
, ' Provide your thoughts on how PGE got ther . ;How extensive is the procurement problems? What assurances can PGE, provide that the MFW piping is adequate? What;further actions is,PGEl planning?

Mr. Cockfield began the PGE presentationLby saying, he 'did agree with the findings, and_ explained that:in the past, the procurement process was-doing the minimum to get'by. There was some misunderstanding of th requirements of the code, and there was'too much reliance on consultants to'give answers and interpret the code requirements.- Mr. Martin emphasized the NRC concerns, and questioned PGE's understanding of'their commitments to the NRC's 1985 concerns. He further noted that CMTR's and Certificate of Conformance. (C of C):mean very little unless the Quality Assurance Program does -their job to confirm _their validit Mr. Cockfield agreed that there was some misunderstanding of the 1985 commitments, and subsequent revisions of the procedures confused the issues. He felt that there was too many collateral _ duties for those involved, and management of the procurement program was ineffective. M Cockfield stated that he doesn't want a minimum procurement program and outlined the improvements he has and will mbke: PGE will adopt the EPRI standards for procuremen . PGE will eliminate the six (6) classes of procurement. Items will' be purchased as safety grade or tested to verify application requirement . PGE will put the procedures and instructions in plain language, and provide training, so confusion will be eliminate . PGE has assigned a new procurement manager, and in July 1989 he will report directly to the Vice Presiden {

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Mr. Cockfield then summarized the presentations that ahessed the 

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remaining NRC question ./ 

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G Mr. Walt introduced the PGE staff at the meeting, and outlined d;ji;i ;i:!!\t' ' i ! ' ' p: /' 

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purpose of the presentations and his feelings concerning the NRC 'O!*!n question A discussion was then held regarding the licensee's Quality Assurance (QA) involvement in the procurement area. Both the NRC and the licensee's representatives agreed that QA did not serve the licensee well in that they missed several opportunities to recognize that significant -I deficiencies existed in the procurement are ' Mr. Miller of IMPELL presented the review of PGE's efforts to develop a , safety enalysis addressing the impact of past procurement practices on currtnt-plant operation. He fielded questions from the NRC staff * 

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concerning the safety analysi , Mr. Hoffman made a presentation concerning the MFW piping material 

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testing (see attached), and then fielded questiens from the NRC staf Mr. Martin emphasized the importance to have the chemical and physical 

, test data for all the material used in the MFW piping replacemen Mr. Cockfield agreed, and insured that the remaining testing in progress
..w ould be done, and the results communicated to the NRC staff the next wee '

Mr. Anderson, the new procurement manager, outlined the action plan completed and in progress concerning their safety grade / commercial grade material procurement progra Mr. Cockfield re-emphasized that he wants a good program that is spelled out in simple terms. He stated that, "if it can't be purchased as safety grade, it will be purchased commercial grade and tested before it goes into the facility."

Mr. Anderson answered questions by the NRC staff. Mr. Knighton, NRR, noted that a generic letter concerning the EPRI standards will soon be out for commen Mr. Bauer presented the Quality Programs 'at Trojan and outlined the functions of the different oversight management board Mr. Barr, the Senior Resident Inspector, asked, concerning the Plant Review board (PRB), if the members had a tough time separating their 

 "line function" from their oversite responsibilities. Mr. Bauer agreed, and stated that these kinds of conflict of interest would be addressed by the function of the Trojan Nuclear Operations Board (TN08).

Mr. Cockfield and Mr. Lentsch were able to provide examples where Mr. Barr's concerns were demonstrated, and promptly correcte Mr. Bauer fielded questions from the NRC staff. It was noted by M Chaffee that the Personnel Protection Committee (PPC) did not have any QA personnel involved. Mr. Cockfield agreed that it was a good idea, and he would consider i jjr 

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Mr. Lentsch presented performance trends and improvements concerning the Radiation Protection Program. He led the discussion concerning cyclic performance and how the Radiation Protection program is trying to be more proactive versus reactiv Mr. Walt presented the Licensee Event Report (LER) program, and PGE's attempts to address problems thoroughly, so that the problems don't re-occur, and create a reactive need. He also agreed that they have to make managers more accountable for problems, and felt that the TNOB focus will address this issu " Mr. Chaffee closed the meeting by summarizing the NRC concerns associated with the enforcement' conference: that thorough review and revision of PGE's commercial grade procurement is essentia . that communication of the chemical and physical tests for MFW piping in one week is needed to validate the safety analysi Mr. Chaffee stated PGE efforts in the areas presented appeared promising and generally thorough, and that key elements to their future success should be: continued aggressiveness of the TNOB in probing plant problems and holding all levels accountable; enhancement of quality assurance effectiveness by staffing the QA organization with experienced personnel in all disciplines; consideration should be given to adding a QA individual to the personnel protection committee and other standing bodies as appropriate, to ensure QA involvement in all aspects of plant activities; increased management involvement in day-to-day activitieis, and their visibility in the plant controlled areas; use of a more disciplined effort and formality by the staff to engrain the proper instincts in all personnel; and- timely implementation of your action plans and lessons learned from industry initiatives as well as your ow Mr. Cockfield agreed with Mr. Chaffee, and expressed a need to have our next meeting prior to March 22, 1989, the expected start of the next refueling outag . _ 

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L: , , LEnclosure' , . 

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ITf"'LTO BE INCLUDED IN PGE RESPONSE 

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 : A list of all " safety related. pressure bearing material used and the .

approx.imate quantity used_for the feedwater piping replacement wor l - 

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 ' A . list of- all we,ld rod material used 'for ,the replacement ~ wor , For items, a 'Indl b., identify the.manufact'urer of the material an'd any -

intermediary' supplier ' C - 

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          . Identify whethe'r the manufacturers and suppliers. are now known to have QA program, and whether the program has- been audited / recognized by PGE,.
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otherilicensees,-CASE, ASME,.etc. .' Identify whether any available industry experience' indicates: the ' associated manufacturers'or-suppliers to have quality problem ' 

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f. . For items a. and b., provide copies .of all CMTRs received by PG , Provide copies of all test results' for independent testing performed by PGE to validate the~CMTR Provide a written description of any other testing or-auditing' perfonned-on items-a.~end b. which provide assurance that the MFW piping'is acceptable for safety-related operation until the start of the 1989: outage, Document PGE's safety evaluation of the continued use of.the MFW piping' until the 1989. outag l 

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