ML20042G544

Forwards Rev to Commitment Dates Re Notice of Violations Associated W/Insp Rept 50-344/89-09,per NRC & LER Submitted on 900208.Changes Recommended to Mgt Sys Used to Assign & Track Commitments

ML20042G544
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/09/1990
From:	Walt T PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9005150059
Download: ML20042G544 (4)

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.h May 9, 1990 i

t Trojan Nuclear Plant t!

Docket.50-344' f

License NPF-1 l

i U.S.' Nuclear-Regulatory Commission E

f, Attn:

Document Control Desk

. Washington DC '20555

Dear Sirs:

Chnnges to Commitment Dates i

lYour letter of' August ~29,.19891 transmitted Notices of Violation (NOVs)

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iassociated with Nuclear Regulatory. Commission Inspection ReportiS0-344/89-09. Our' response to three of the NOVs. initially provided.

completion-dates of December 31, 1989' for these correctivt actions.

Also, in'a' Licensee ~ Event' Report submitted-on February'8, 1990 commitments were s

mede ts complete certain corrective actions by March 20, 1990. This letter >

is to-inform you these commitments were not completed as scheduled, to.

explain the: delays in being able tc-meet our original commitment due dates,

_and to establish new dates for the commitments. There is no safety'

! significance for any of the five missed commitments.

On March 29,'1990 a. critique was held'to discuss'these commitments.

It was determined that.the cause of the missed commitments was a lack of accountability on the part of the action parties, their managers, and the.

engincors assigned'to track completion of the commitments. 'Some changes were recommended to the management systems used to assign and track the

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commitments.

The responsible managers acknowledged their accountability for tha commitments and confirmed to devote sufficient management attention

'l to ensure no further. commitments were missed. While commitment completion-will remain the responsibility of the assigned action' parties and the managers, commitment tracking will now be performed by a single individual in the Nuclear Safety and Regulation Department to ensure no further corsnitments are missed.

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l Portland General Electric l

Document-Control Desk May 9, 1990

-Page 2 This management breakdown is not consistent with our goals for excellence in the operation of the Trojan Nucicar Plant.

In previous correspondence 1

we have informed you of actions in progress as part of our Nuclear Division l

-I Improvement Plan.which will further address the issue of meeting commitments. These actions include evaluations of the roles of. supervisors and managers and of the overall system for commitment management. We are resolute in our pursuit of excellent performance at Trojan. -

t Sincerely, I

T. D. Walt Acting Vice President, Nuclear i

Attachment c:

Mr. John B. Martin Regional Administrator, Region V l

U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith i

State of Oregon Department of Energy Mr.'R. C. Barr NRC Resident Inspector

. Trojan Nuclear Plant

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Trojan Nuclear Plant-Document Control Desk 1'

Docket 50-344 May 9, 1990-License'NPF-1 Attachment Page 1 of 2 Revision to Commitment Dates 5

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1PGE Letter of December 31, 1989,

-Response to Notice of Vio_lation Violation B.1 Portland General Electric Company (PGE) received a violation'for not including sufficient detail for assumptions _ used in support of a calculation,~which was contrary to the requirements of Nuclear Division.

Procedure (NDP) 200-4, " Quality-Related Calculations". _As a corrective step to be taken to avoid further violations, PGE committed to provide training sessions to: Engineering to reinforce the requirements of the NDP. 'These training sessions were to be completed by December 31, 1989.

This commitment was not met by the. scheduled date. _ Nuclear Plant Engineering (NPE)~has. revised the commitment date for performing the training to July 1, 1990.

Violation B.3 PGE received a violation for.using'an analyses on the impact of the dc

' electrical system that was based upon the use of an unverified, incorrect assumption of the inverter performance characteristics that was made in<a a

previously used calculation.

The use of the calculation without checking for applicability, assumptions, and mathematical accuracy was contrary to the requirement of NDP 200-4.

In addition to the training review for NDP 200-4, PGE also committsd to review the requirements of Nuclear Plant Engineering Procedure (NPEP) 200-11. " Verification of Design", and.NDP 200-1,." Design Change.

control", by December 31, 1990. These reviews,were not completed by the i

scheduled date. These will be completed by July 1, 1990.

Y violation D As part of our corrective steps that would be taken to avoid further violations, PGE committed to review and revise NDP 200-1, " Design Change control", te ensure the responsibility and authority of individuals in the configuration management process are understood.

This was to be accomplished by December 31, 1989.

L PGE is still revising the design change procedures to accomplish this commitment. The implementation of the Design Basic Document (DBD)

Program in conjunction with the extended outage in 1989 contributed to the delay in having the new procedures ready as scheduled.

The now design change procedures are currently scheduled for implementation by July 1, 1990.

The subject reviews will be completed by September 30 j,

1990.

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.TrojanL Nuclear plant Document Control Desk Docket 50-344 May 9, 1990 License NPF-1 Attachment page 2 of 2

Licensee Event Report 90-02 In LER 90-02, " Low Temperature Overpressure Protection System (LTOPS)

Evaluation Limits Violated During plant Operation Due to Procedural-Inadoquacies", dated February 8,1990, PGE committed to develop approprinto precautionsand guidance and to reviso applicable operatins procedures to ensure compliance with the LTOPS analysos by March 20, 1990. With the l

exception of General Operating Instruction (GOI) 1-1, " Plant Heatup - Cold

- r Shutdown to Hot Shutdown", all, applicable procedures.have been revised.

A-revision to the Low Temperaturo O'Jerprossuro Analysis is in progress to determino if a change to COI 1-1 is required.

COI 1-1 will.1mm revised, if necessary, by the end-of the 1990 refueling outage since this 1s the next time the procedure will be used.

WJW/bsh 4402W.0490 I

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