ML20041G085
| ML20041G085 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/23/1982 |
| From: | Stello V NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20041G086 | List: |
| References | |
| NUDOCS 8203190200 | |
| Download: ML20041G085 (6) | |
See also: IR 05000344/1981002
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Docket No. 50-344
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Portland General Electric Company
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ATTN:
Mr. B. D. Withers
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Vice President, Nuclear
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Portland, Oregon 97705
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Centlemen:
Subject:
Management Inspection 50-344/81-02(PAS)
This refers to the managsment inspection c onducted by Messrs. J. R. Belanger,
L. E. Foster, D. G. Hinckley, D. R. Hunter, and C. R. Oberg of the Performance
Appraisal Section of the Division of Program Development and Appraisal, Office
of Inspection and Enforcement, on February 17-27 and Maech 9-13, 1981, of
activities authorized by the NRC Operating License No. NPF-1, for the Trojan
Nuclear Plant at Rainier, Oregon, and the Portland General Electric Company
corporate office at Portland, Oregon.
This also refers to the significant
observations discussed with you and other members of your staff on February 24,
Februan/ 27, and March 13, 1981, at the Irojan Nuclear Plant and the Portland
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General Electric Company corporate office.
This inspection is one of a series of management appraisal inspections being
conducted by the Performance, Appraisal Section of the Division of Program
Development and Appraisal, Office of Inspection and Enforcement.
The results
of this inspection will be used to evaluate the performance of your management
control systems on a national perspective.
The enclosed appraisal report
includes observations which may be potential enforcement findings.
These
items will be followed by the IE Regional Office.
The enclosed appraisal report
also addresses other observations and the conclusion made by the team for this
inspection.
Section 1 of the report provides further information r.egarding
the observations and how they will be utilized.
Appendix A to this letter is
an Executive Summary of the conclusion drawn for the nine functional areas
inspected.
Of the nine areas inspected and evaluated, five areas were considered average
while four areas, non-licensed training, corrective action systems, quality
assurance, and committee activities were considered below average.
As a result of the significant weaknesses identified in the four areas con-
sidered below average, you are requested to inform this office within 30 days
of receipt of this report of the actions you have taken or plan to take to
improve the management controls in these areas.
Your response to this office
concerning the areas identified as below average will be followed by the IE
Regional Office.
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8203190200 820123
PDR ADOCK 05000344
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Poriland General f.lectric Company
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JUN 2 31981
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In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, your facility security procedures are
exempt from disclosure; therefore, the pertinent section of the Appraisal
Report, Attachment "A", will not be placed in the Public Document Room and
will receive limited distribution.
Attahment "B" to this report is a detailed listing of the persons contacted
and the documents reviewed during the inspection.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this
letter and the enclosed inspection (or investigation) report will be placed in
the NRC's Public Document Room.
If this report contains any information that
you (or your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by talerhone within
ten (10) days from the date of this letter of your intsntion to file a request
for withholding; and (b) submit within twenty-five (25) days from the date of
this letter a written application to this office to withhold such information.
If your receipt of this letter has been delayed so that less than seven (7)
days are availabit ior your review, please notify this office promptly so that
a new due date may be established.
Consistent with section 2.790(b)(1), any
such application must be accompanied by an affidavit executed by the owner of
the information which identifies the document or part sought to be withheld,
and which contains a full statement of the reasons on the basis which it is
claimed that the information should be withheld from public disclosure.
This
section further requires the statement to address with specificity the con-
siderations listed in 10 CFR 2.790(b)(4).
The information sought to be
,
withheld shall be incorporated as far as possible into a separate part of the
'
If we do not hear from you in this regard within the specified
periods noted above, the report will be placed in the Public Occument Room.
If you have any questions concerning this inspection, we will be glad to
discuss them with you.
Sincerely,
,
Sb , Jr.
V
Director
Office of Inspection and Enforcement
Enclosures:
1.
IE Appraisal Report No. 50-344/81-02 (PAS)
2.
Appendix A
3.
Attachment A (Part 2.790(d) Information)
4.
Attachment B
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Portland General Electric Company
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Distribution: (w/ Attachments A* and B)
w/o Attachment A*
Chairman Hendrie
POR
Commissioner Ahearne
LPOR
Commissioner Bradford
NISC
Commissioner Gilinsky
SECY
All Licensees
OCA(3)
E. P. Wilkinson, INPO
W. J. Dircks, EDO
H. R. Denton, NRR
W. Haas, NRR
C. Michelson, AE00
S. Hanauer, 0/0HES
R. A. Erickson, NMMS
H. Boulden, OIA
M. Malmros, Senior Resident Inspector
V. Stello, IE
J. H. Sniezek IE
N. C. Moseley, IE
H. D. Thornburg, IE
J. M. Taylor, IE
NRR Project Manager
PAS Files
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Regional Ofractors
Central Files
- Contains 10 CFR 2.790 Information
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APPENDIX A
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EXECUTIVE SUMMARY
A team of five NRC Inspection Specialists from the Performance Appraisal
Section conducted an announced inspection at the Trojan Nuclear Plant site
and Portland General Electric Company corporate office during February 17-
March 13, 1981.
Management controls in nine areas were evaluated.
Five
areas were considered average and four areas were considered below average.
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The following information is a summary of the inspection results.
Training:
(Section 2),
a.
Licensed:
Average.
A program for licensed training was established and
implementad. Additional management attention is required regarding
updating of the training lesson plans.
b.
Non-licensed:
Below Average.
A comprehensive program for non-licensed
training for all personnel was not established.
The effectiveness of the
non-licensed training program which had been implement (d was not adequately
evaluated b3 wanagement.
Individual employee's training needs had not been
adequately determined and established by management.
Additionally, there
were weaknesses in Quality Assurance training of the plant and corporate
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staffs as demonstrated by a lack of understanding of the QA Program.
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Desion Chances and Modifications:
Average (Section 3).
The system of manage-
ment controls in the area of design changes and modifications was adequately
established and implemented; however, management control weaknesses were iden-
tified involving the Plant Review Board's (PR8) failure to review final Design
Change Packages, implementing procedures, and proposed setpoint changes.
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Mainten'ance:
Averace (Section 4).
The established program for the control of
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maintenance activities conducted by the licensee was adequate.
However, manage-
ment control weaknesses were identified involving the review of lower-tier
procedures which were used to control safety-related activities, accomplishing
maintenance activities using uncontrolled vendor manuals, and the processing of
temporary modifications resulting from the placement of jumpers and lifting of
Review of Licensed Activities (Operations):
Averace (Section 5).
An effective
operating organization was estaclished; newever, a comprehensive independent
verification program for controlling safety-related activities was not estab-
lished.
Corrective Action Systems:
Below Averace (Section 6).
A nrogram was
establisned for the control of corrective action activities; however, the
lack of understanding of the corrective action system by personnel due to
marginal indoctrination and training resultad in the failure to identify
and document a number of conditions adverse to quality as required by
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Appendix A (Continued)
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program procedures.
The failure to document adverse conditions limited the
data provided to plant and corporate management and independent review groups,
severely hampering the effectiveness of the corrective action program as a
viable management tool.
Furthermore, the corrective action program, as
implemented, appeared to concentrate primarily on the determination of
reportability to the NRC instead of requiring the identification of all
conditions adverse to quality and allowing a management evaluation to
decide the reporting requirements.
Thus the use of the program as one
of the measures of the effectiveness of the QA Program and ensuring
management awareness of conditions adverse to quality was limited.
Procurement:
Average (Section 7).
An effective organization existed and
adequate procedures for procurement activities were established; however,
some weaknesses existed in the area of material' storage.
Committee Activities:
Below Average (Section 8).
The Plant Review Board
(PRB) and Nuclear Operations Board (NOB) included capable individuals
who were active in their review responsibilities.
There were, however,
significant weaknesses in the scope of the PRB and NOB review activities.
There was a lack of formalized training for the PRB and NOB members.
Furthe r-
more, t5e review of procedure and design change safety evaluations by the
NOB was M timely.
Quality Assurance Audits:
Below Average (Section 9).
The program for
performing quality-related audit activities was established; however, the
program procedures lacked adequate detail to ensure the performance of all
program commitments, to require the use of audit and surveillance personnel
with specific technical expertise in the a:eas audited, to ensure adequate
handling of audit findings, and to provide a comprehensive method for eval-
uating the effectiveness of the QA Program.
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Physical Protection:
Average (Section 10).
A program for the phys-
ical protection of vital equipment had been established and implemented.
Additional management attention was required in the areas of communications
between site and corporate security management and vital area access controls.
Summary
Weaknesses in the existing management controls and the 13ck of program implement-
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ation were noted in the areas reviewed during this inspection.
While the weak-
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nesses in some areas could be attributed to deficiencies in written procedures,
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others appeared to be derived from shortcomings in training personnel to under-
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stand and implement management policy as reflected in the procedures.
In addi-
tion, the management control system did not appear to be fully effective in all
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areas in overseeing program implementation and requiring strict adherence.
Addi-
tional attention to the weaknesses made in this report should improve the Trojan
Nuclear Plant's system of management control over nuclear operations,
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Appendix A (Continued)
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During the inspection the team was favorably impressed with~the knowledge. -
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and experience..of the Operations Department personnel at the site.
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strength, along'with the implementation of the operating assessment program,,
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indicates the potential for an effective management control systee in the
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Operations Department.
Had the issue of lack of independent verification of
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system lineups and valve positioning not been identified, this area would
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have been considered above average.
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