ML20043A773

Responds to NRC Re Violations Noted in Insp Rept 50-344/90-06.Corrective Actions:Plant Setpoint Change Procedure Revised to Address Process from Initiation of Calculation to Incorporation Into Device Calibr

ML20043A773
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/17/1990
From:	Walt T PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9005230102
Download: ML20043A773 (8)

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May 17,1990 s

Trojan Nuclear Plant ~

Docket 50-344' License NpF-1 U.S. Nucle'ar Regulatory Commission l

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Document Control Desk.

Washington DC.20555 i

Dear Eirs:

Repiv to's Notice of Violation Your letter of' April 17, 1990 transmittedLNotices of Violation associated' I

with Nuclear Regulatory CommissionI(NRC) Inspection Report' 50-344/90-06. to this letter contains Portland Ceneral: Electric' Company's:

i (PCE's) responses to the violations contained..in th'. inspection report.

e Your' letter also requested that we -includefour assessment of identified) concerns that were-specified:in the body of.the cover: letter:to-the 4

inspection report to assure timely-identification, evaluation, and 4

. correction of day-to-day problems. ~0ur response to'this' request is contained in Attachment 2.

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-Sincerely' 3

T. D. Walt

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Acting Vice President, Nuclear.

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

U.S. Nuclear Regulatory-Commission j

Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant t

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-4 Trojan Nuclear plant Document Control Desk Docket 50-344 May 17, 1990 License NPP-1 page 1 of 4 RFpLY TO A NOTICE OF VIOLATION l

• /lgjetion A Trojan Technical Specification 3.3.2 states, "The Engineered Safety Feature Actuation System (ESFAS) instrumentation channels and interlocks shown in Table 3.3-3 chall be OPERABLE with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4 and with RESPONSE TIMES as shown in Table 3.3-5."

The " ALLOWABLE VALUES" column in Table 3.3-4 for high steam flow in two steam lines specifies "A function defined as follows:

44% of full steam flow between 0% and 20% load and then increasing linearly to 111.5% of full steam flow at full load."

Contrary to the above, from July 17,'1986 to March 20, 1990 Trojan was operated in Modes 1, 2, and 3 with the steam flow trip setpoint function set at 40.87 percent of fu11' steam flow between 0 percent and 20 percent load and then increasing Ilmearly to 112.34 percent of full steam flow at full leed.

This is a Severity Level IV violation.

portland General Electric Company (pCE) acknowledges the violation.

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Reason for ti.e Violation:

r The reason for the violation was personnel error, failure to identify the instrumentation trip setting for Trojan Technical Specification (TIS) Item 1.d. " Steam Flow in Two Steam Lines - High". Table 3.3-4 was not in accordance with calculation TE-113 " Scaling Calculations" f

as was required to be reviewed and corrected from a previous event, 2.

Corrective Steps That Have Been Taken and the Results Achieved, i

The plant was shut down March 19, 1990 as required by TTS.

ESFAS setpoint calculations were reviewed to ensure the present module settings match the calculations for instruments required to be-operable in Modes 4, 5 and 6.

The setpoints were compared to module settings.ss documented in the last calibrations for the modules.

The allowable setpoint band on the instrument calibration data sheet matched those in the calculations and no additional errors in the settings were found.

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m Trojan Nuclear Plant Document Control Desk Docket 50-344 May 17, 1990 License NPF-1 Page 2 of 4 Interim measurec to control incorporation of.new or revised calculations into the Plant setpoint change process were established to ensure proper interdepartment communication.

3.

Corrective Steps That Will Be Taken to Avoid Further Violations.

The Plant Setpoint Change (PSC) procedure will be revised to address the process from initiation of a calculation to its incorporation into the device calibration.

The procedure will define responsibilities for the affected departments, specify the method of transmittal between departments and provide guidance for handling changes that may affect operability or compliance with the TTS or Final Safety Analysis Report l'

(FSAR). This procedure will be issued by December 1,1990.

The personnel error involved with the original lack of identification of the missed setpoint change will be discussed at a Plant Systems Engineering (PSE) group meeting.

This meeting will be held by June 1, 1990.

All calibration records relating to Nuclear Plant Engineering (NPE) instrument accuracy calculations for all instruments shown on Drawing E-3 will be reviewed to ensure that the setpoints have been correctly incorporated into the calibration system.

NPE will assist PSE to verify that device settlugs comply with the drawing, associated calculation values and any applicable TTS requirements.

This review will be completed prior to entry into Mode 3 following this refueling outage.

4.

The Date When Full Compliance Will Be Achieved.

1 Full compliance will be achieved following the re-calibration of the steam flow instrumentation (PY-505B/6B modules) to the values specified in Calculation TE-113.

This calibration will be completed prior to entry into Mode 3 following this refueling outage.

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Trojan Nuclear Plant Document Control Desk Docket 50-344 May 17, 1990 License NPF-1 Page 3 of 4 Violation B Title 10, of the Code of Federal Regulations, Part 50 ;0 Ch

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Appendix B, Criterion V, states in part:

" Activities tffect', quality shall be prescribed by documented instructions, procei vres *. drawings, of a type appropriate to the circumstances and shall bo x,mplished in accordance with these instructions, procedures, or drawl. s."

The licensee's Nuclear Division Procedure (NDP) 600-0, " corrective Action Program (CAP)," established the methods to identify, evaluate, document, report and correct problems and nonconformances.

NDP 600-0. Section 5.2.B states that for a Corrective Action Request (CAR), supervisors are responsible for the following:

. 2.

Assuring suf ficient information is indicated either on the CAR Form or on attachments so the condition can be accurately dispositioned, corrective actions taken and, where necessary, the item located."

contrary to the above, on March 2, 1990 CAR C90-5007 was issued containing information that Breaker B2245 was replaced, when in fact it had not been replaced.

This is a Severity Level IV violation.

pGE acknowledges this vloistion.

1.

The Reason for the Violation.

The reason for the violation is personnel error, failure to provide accurate information in the CAR as required by procedure.

The information provided by the initiator to the supervisor was misinterpreted and, consequently, misstated on the original CAR.

This information led the organization reviewing the CAR to erroneously believe the problem was resolved.

2.

Corrective Steps That Have Been.Taken and the Results Achieved.

The supervisor and individuals involved in the communication deficiencies and procedural noncompliance associated with CAR C90-5007 were. counseled on the need and.importance of clear and concise transfer of information to ensure the CAR is complete and accurately described.

CAR C90-5007 was reopened March 27, 1990 and properly evaluated with the correct informat. ion and resolved April 3,1990.

Quality Assurance accepted closure of the CAR May 2, 1990.

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Trojan Nuclear Plant Document Control Desk

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Docket.50-344 May 17, 1990-License NPF-1

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The Corrective Steps That Well Be Taken to Avoid Further Violations.

f No further corrective actions are required.'

4.

Date When Full Compliance'W111 Be Achieved.

Full compliance'was achieved April 3, 1990 when CAR C90-5007 was reopened and dispositioned in accordance with NDP 600-0.

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s Trojan Nuclear Plant Document Control Desk l

Docket 50-344 May 17, 1990 Licence NPF-1 i

Page 1 of 3 REPLY TO OTHER NRC ISSUES Corrective Action System Implementation to Assure Timely Evaluation and Correction of Safety-Related Nonconformances The corrective action system used by PGE in the past included l

Nonconforming Activity Reports (NCARs), Nonconformance Reports (NCRs),

and Event Reports (ERs) that often led to duplication, failure to l

consistently identify Plant problems in a timely manner, did not ensure

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verification activities were appropriate, and was not effective in establishing priorities.

To address these deficiencies, PGE has recently implemented a new corrective action program.

Effective corrective action programs at other utilities have been evaluated and attributes which are beneficial to l

Trojan have been incorporated. This program is still in the I

implementation phase. Under the new program, management is involved 6

early in the identification of a problem to help assure timely evaluation and. corrective action. Additional steps have been added to assure prompt operability and reportability determinations.

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As this new system is being implemented, recommendations for improvement are being identified by the users and implemented as necessary.

To facilitate and identify additional. improvements to the program, a t

corrective action project team has been established. This team consists of personnel from Nuclear Plant Engineering, Plant System Engineering, i

Performance Monitoring / Events Analysis, Nuclear Safety and Regulation, and Nuclear Quality Assurance.

As discussed during the May 10, 1990 management. meeting at the Trojan i

Nuclear Facility, PGE will continue to monitor the corrective action program's development and implementation carefully.

In areas where performanco does not meet pre-established expectations, adjustments will be identified and implemented.

Supervisor / Management Oversight of Maintenance Activities Oversight of maintenance by managers and supervisors has been recognized i

as a performance area that has needed improvement at Trojan.

The Maintenance Department Manager has established a goal for first line supervisors to spend at least 50 percent of their time in the field in r

direct supervision of work activities, t

Expectations of supervisory / management involvement in the oversight of-work activities was further clarified by a memorandum to all Maintenance Department Supervisors and Unit Supervisors. Additional guidance has been provided to supervisors concerning expectations for pre job -

briefings. The amount of time spent at each work site and the determination of what work will be observed is left to the discretion i

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Trojan Nuclear plant Document Control Desk Docket 50-344 May 17, 1990 License NpF-1 E

page 2 of 3 i

i of each unit supervisor. The Maintenance Manager reviews the results of l

problems in the maintenance area and supervisory involvement on a weekly basis and coaches individual supervisors on the standards expected to be consistantly applied. These coaching sessions provide routine effective l

feedback on an individual's performance and will continue unless other 1

l action is appropriate or it is no longer considered beneficial.

Maintenance will continue to monitor the pesults of supervisory oversight l

in day-to-day activities and take prompt corrective actions to ensure the desired end result of work being. performed in a safe and quality manner j

is achieved.

Ovscsight of Non-Routine Evolutions pCE recognizes non-routine plant activities require greater management oversight due to an increased likelihood of encountering unexpected problems. The key to success in this area lies in management's alertness to non-routine evolutions such that additional involvement and oversight by supervisory personnel can be provided.

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To improve management performance in this area, specific oversight functions are being addressed in the Nuclear Division Improvement Plan (NDIp) under the key item " Role and Style of the Manager / Supervisor."

l An action plan is being developed for this key issue.

In the interim, a recent plant Manager memorandum communicated the concern of management involvement in non-routine evolutions to all supervisors and managers.

Expectations of. management actions were defined in the memorandum.

Additionally, this issuo has been discussed with all supervisors / managers at a weekly management meeting.

L Expectations of manager and supervisor involvement have been provided to all levels of supervision. pCE will continue to monitor the progress of its improvement program and provide additional guidance or corrective action where needed, l

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Larne Backlot of Overdue Commitments l

pGE recognizes that our current Commitment Management program does not-have the capabilities to allow us to effectively manage our commitments.

Lack of tools for prioritization, scheduling and requesting work l

internally, coupled with a June 1989 policy that Commitment Tracking List l

(CTL) due dates could not be changed, has resulted in too many I

commitments being made without the resources to meet them, schedules not being met, work and due date assignments being made without prior agreement by the responsible department, and a large backlog of overdue CTL items.

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Trojan Nuclear Plant Document Control' Desk l

Docket 50-344 May 17, 1990 License NPF-1 Page 3 of 3 I

A critique was held with Trojan management on March 29, 1990 to address missed external commitments. On May 9, 1990,.a letter was submitted-providing a revised schedule for the five NRC commitments that were overdue.

One individual in the Nuclear Safety and Regulation Department has now been assigned the responsibility for tracking all external firm date commitments.

On April 18, 1990, a Project Manager and Project Engineer were assigned I

to develop a Commitment Management Program that would provide a high level of confidence' on the part of management and external agencies that PGE commitments are responded to in a timely manner, implemented, tracked, and implementation maintained.

A Project Plan is currently being formulated.

The policy that CTL due dutes could not be changed was rescinded on May 16, 1990 by issuance of a deviation to the Commitment Control System procedure that al)ote CTL due date changes with proper management

. approval. A revision to this procedure is also in progress that will instituto departmental CTL coordinators, which will facilitate information flow cnd provide management with timely and up-to-date information to assist in commitment management.

In addillon, the CTL computer program is being modified to add a field for completion date and provide more flexible reporting capabilities.

These short-term enhancements,'in conjunction with the Project plan under development, constitute the framework for a living Commitment Management Program that will be continually followed up, evaluated, and adjusted to ensure that the desired result of effective commitment management is-achieved.

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