ML20056B242

Advises That 900712 & 31 Responses to SALP Rept 50-344/90-09 Appropriate.Page 18 of Initial Rept Changed to Relect Effort by Util Engineering Groups in Design of ATWS Mitigation Sys Actuation Circuitry,Per 900615 Board Meeting

ML20056B242
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/15/1990
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cross J PORTLAND GENERAL ELECTRIC CO.
Shared Package
ML20056B243	List: IR 05000344/1990009 ML20056B242
References
NUDOCS 9008230058
Download: ML20056B242 (5)

See also: IR 05000344/1990009

Text

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Docket No. 50-344 AUG 1510M ) Portland General Electric Company , TrojanNuclearPlant 71760 Columbia River Highway Rainier, Oregon 97048 ] Attention: Mr. J. E. Cross Vice President, Nuclear j Gentlemen: j SUBJECT: FINAL REPOR1 ON SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, REPORT NUMBER 50-344/90-09 This refers to the NRC's Systematic Assessment of Licensee Performance (SALP) 50-344/90-09(sprovidedin,yourlettersdatedJuly1990 for your Trojan N i Board Report dated June 1 and to the written commen 12, 1990 and i July 31, 1990. We have reviewed your initial response dated July 12,ded that your overall 1990, as well as your updated response dated July 31, 1990, and have conclu response was appropriate. You addressed various actions to strengthen performance in the functional area of Maintenance / Surveillance. We will !, discuss the progress of your actions during future inspections and management meetings. NRC conc.,usions resulting from our review of your responsas are summarized in Enclosure 1. to this letter. There were no changes made to the SALP report based on your letters of July 12 and 31 1990. However, based on discussions at the SALP board meeting on June 15,19h0,page18oftheinitialSALPreportwaschangedtomoreaccurately ' reflect effort by PGE engineering groups in the design of the ATWS Mitigation i System Actuation Circuitry. The change did not affect the Board's conclusion i for the functional area of Engineering / Technical Support. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures -will be placed in the NRC Public Document Room. Should you have any questions concerning this letter, Appendix I hereto, or the SALP Board's final report, we will W d to discuss them with yoL. Si , , . Martin . Regional Akinistrator Enclosures: 1. Appendix 1, NRC Conclusions 2. SALP Meeting Report No. 50-344/90-22 l l 3. Licensee Response to Initial SALP Report, dated July 12, 1990 l. 4. Licensee Response to Initial SALP Report, dated July 31, 1990 l 5. Final SALP Report jj ?Y I'50* [{ D

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i L o' i o APPENDIX I NRC CONCLUSIONS A. Comments Received from Licensee Portland General Electric's 1990 written responses to the initial SALP Board Report presented no comments which necessitated changing the specific content of the report. However, based on discussions at the SALP board meeting on June 15, 1990, page 18 of the initial SALP report waschangedtomoreaccuratelyreflecteffortbyPGEengineeringgroups in the design of the ATWS Mitigation System Actuation Circuitry. ! B. NRC Conclusions Regarding Acceptability of Licensee's Planned Corrective Actions We feel that your actions to deal with areas needing improvement appear to be responsive. We will review your progress during our on 1 inspection program and as part of future management meetings. going C. Regional Administrator's Conclusions Based on Consideration of Licensee's Response I have concluded that the overall ratings in the affected areas have not changed- , . , &

- - , L '. 1 . REVISION SHEET SALP B0is REPORT REVISION SHEET g LINES 18 27-30 NOW READS On the other hand,.the ATWS/AMSAC design review took over two years to complete as a result of initially providing insufficient information to NRR, and due to insufficient engineering technical support. SHOULD READ that because of the licensee's delay in arriving at a It is noted, however$/AMSAC, Trojan will be among the last to implement AMSA - $ final design for ATW ' an important safety feature. , Basis: The above change is made to accurately reflect NRR's assessment of effort by PGE engineering groups related to the design of ATWS/AMSAC. . 4 $ . - - - , -

__ _ _ . - . _ _ _ _ _ . _ _ _ . _ _ _ _ - _ _ _ _ _ _ _ . _ _ _ , _ i [[ g. UNffe0 STATla 4 .[ NUCLEAR REGULATORY COMMISSION 'g naesta y ! , I ' - WAL T EEK AllF e LA tes ' e...* JUL t 61990 Docket N'o -50-344.- l Portland General Electric Company Trojan Nuclear. Plant 71760 Columbia River Hwy. Rainier, Oregon 97048 Attention: Mr. J. E. Cross Vice President, Nuclear - Gentlemen: SUBJECT: SALP MANAGEMENT MEETING This refers to the management meeting held with Mr. Higgins, yourself, and' i members of your staff at the Trojan Nuclear Plant on June 15, 1990. Subjects- discussed during the meeting are summarized in the enclosed meeting report. In sumary, the meeting focused'on the June 1,1990 Trojan Systematic Assessment of Licensee Performance (SALP) report, which found that overall, activities at Trojan are acceptable and directed toward safe facility operation. . Specific discussion focused on the functional areas reviewed in the SALP report. No response to this letter is required; however, if you have any questions - concerning this report, do not hesitate to contact us. j In accordance with 10.CFR 2.790(a), a copy of this letter and enclosures will be placed in the NRC Public Document Room._ Sincerely. , b i O' R. P. Zimmerman, Director

Division of Reactor Safety and Projects Enclosure: Inspection Report No. 50-344/90-22 ) cc w/ enclosure: D. Stewart-Smith, Administrator, DOE Mr. Scott Bauer, PGE T. D. Walt, PGE , B. Robinson, Trojan Nuclear Plant L. A. Girard, Vice President and General Counsei , 3 . .__...J.-.__,,.,1 . , . . . . _ _ , _ - . . _ . . . , . , . . - , . , _ , , , . . . _ _ , , , . , - - , . , . - -. ... . . . , . - . - .

. . - .. - . - . . - _ ..- -. - - l . t . . , ' ~ U. S. NUCLEAR REGULATORY COMMISSION REGION Y ' ' . , Report No. 50-344/90-22 Docket No. 50-344 License No. NPF-1 Licensee Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 i i Facility Name: Trojan Nuclear Power Plant Meeting at: Trojan Nuclear Nwer Plant, Prescott, Oregon Report Prepared by: B. J. Olson i Project Inspector Approved by: SST i .7-Ao-90 '

,*: 5. A Richards, Chief Date Signed Reactor Projects Branch ., . . . , , Meeting Sumary: Meeting on June 15, 1990 (Report No. 50-344/90-22) A management meeting was held to discuss the results of the NRC Systematic ' Assessment of Licensee Performance (SALP) for the Trojan Nuclear Power Plant during the period from January 1,1989 through March 31, 1990, SALP details are documented in SALP Report 50-344/90-09. Details of this management meeting are documented in this report. i T 9 i l y - - ? " 3 : . : .s~ G,) __ . . . . _ _ . . _ . . . . . . _ . - _ , _ _ _ _ . .

.. - - _ - - - - - - . - _ _ - - - . - . - _ . - . . . - . . 'f ' . - - .- DETAILS

, 1. Meeting Attendees a. Licensee Attendees i W. M. Higgins, Senior Vice President T. D. Wa t, Acting Vice President, Nuclear J. E. Cross, Prospective Vice President, Nuclear i W. R. Robinson, General Menager, Trojan Plant C. P. Yundt, Assistant General Manager. Trojan Plant - , - G. D. Hicks, General Manager, Plant Support G. A. Lieuallen, General Manager, Trojan Excellence C. K. Seaman, General Nanger. Quality Assurance ' ! A. R. Ankrum, Manager, Nuclear Security

J. A. Reinhart Acting Manager, Operations > J. F. Whelan, Manager, Maintenance J. M. Anderson, Manager, Materials M. W. Hoffmann, Acting Manager, Nuclear Plant Engineering R. M. Nelson, Manager Nuclear Safety and Regulation Department J. Mody Branch Manager, Plant Systems Engineering G. L. Rich,* Branch. Manager, Radiation Protection , s D. B. Fancher Supervisor, Plant Training W. J. Williams, Compliance Engineer > D. A. Desmarais Public Affairs ~~ .b. NRCAttendee,i ~ ' '"~ ~~ B..H. Faulkenberry, Deputy Regional Administrator - R.' P. Zimmerman, Director, Division of Reactor Safety and Projects l R. J. Pate, Branch Chief, Nuclear Materials Safety and Safeguards R. C. Barr, Senior Resident Inspector ' G. N. Cook, Regional Public Affairs Officer B. J. Olson, Project Inspector ' J. T. Larkins Acting Director, Project Directorate V. NRR

R. B. Bevan, Project Manager, NRR , c. Oregon Department of Energy Attendees ?

H. Moomey, Manager, Reactor Safety A. Bless, Trojan Resident . l- ' L d. Bonneville Power Administration D. L. Williams, Nuclear Engineer 2. Detailed Meeting Minutes Mr. Faulkenberry opened the meeting, indicating that the overall performance at Trojan has been good. Since the last assessment period, there has been improvement in three functional areas and decreased performance in two functional areas. Significant achievements heve been ' _ , _ _ . . . . . . - . ..

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. .- ' noted in the areas of Plant Operations, where no significant transients occurred during the assessment period; Safety Assessment / Quality Ytrification, where there was significant improvement in audits, more technical expertise on staff, and improved management support; and Serwrity, where improvements have been seen in the root cause and 'c0Trtet'ive 'a'ction programs. Areas where there appears to be a need for improvement include Emergency Preparedness, where weaknesses were obserMd7n~ah~eYercise at the early part of the assessment period; and Maintenance / Surveillance, where a number of activities are weak although recent improvements have been seen. Mr. Faulkenberry also noted other achievements at Trojan including: building a new training facility with a good, weckable simulator; moving . the engineering staff onsite where they can be more involved with plant activities;.a new and improved management team; and an active Nuclear Division Improvement Program. In concluding his opening remarks, Mr.

Faulkenberry encouraged an open, candid discussion throughout the meeting. Mr. Zimerman sumarized the results in four functional areas. Mr. Zimmeman noted that the SALP Board deliberated at length in rating Plant 1 Operations as Category 1. Strengths in the area included well managed I day to day activities with. strong supervisors and senior reactor operators; a SALP period generally free of operational events such as transients or significant valve lineup problems; good operator knowledge; and a consistent approach to the resolution of problems. Indicative of this approach were the conservative actions taken to inspect instrument cabinets when loose connections were noted in the OTAT circuits and to shut down the plant when the main steam flow trip setpoints were not properly set'. " Weaknesses observed in the last SALP period, such as procedure compliance, shift turnover, and control room logs, have also improved. The addition of a simulator was noted as an improvement and should ! ~ provide-future benefits; however, current training.was criticized. Mr. , , , Zimeman noted the need to identify operators who repeatedly have i difficulty with training or actual operations such that additional assistance could be provided. He also stated that crew coordination and comunication were problems during the last requalification exam, however , he noted that the crew problems have only been observed in training exercises and have~not been'seen in control room operation. .Mr. Cross i stated that he and Mr. Robinson are currently evaluating crew performance .using the simulator. Problems occurring when Operations and Maintenance groups had to i coordinata activities were pointed out. Coordination problems occurred ' that resulted in overheating of an RHR heat exchanger and calibration of 'i an RHR flow switch at an inappropriate time. Emphasis was placed on the need to work for improved coordination between Operations and other groups. In response to the NRC's coments related to Plant Operations Mr. Walt ! indicated that PGE was pleased with the recognition given, and tht

training issues will be addressed. Mr. Robinson stated that a Category 1 l i ! I

__ _ _ _ _ _ . _ . _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ L 3 , . .. ' V 1 L' rating was significant, but they do realize that Operations isn't perfect, and problems will be addressed. Each crew will be evaluated ' using the simulator, and consideration will be given to areas where command and control improvements can be made. Mr. Cross stated that communication throughout the organization is important, ano that he will , ' ensure there will be feedback to senior management regarding any of the proposed changes. 2 The next area discussed was Maintenance / Surveillance, Mr. Zimmerman ~ indicated that this functional area was last rated as Category 2 i declining trend, and is now rated as Category 3, improving trend. < Trojan's greatest strengths in this area are perceived as the corrective actions to be implemented by the Nuclear Division Improvement Program, and that Trojan has an understanding of the weaknesses associated with Maintenance / Surveillance. Prioritization of outstanding Maintenance Requests was noted as positive. Implementation of the Work Control Center was addressed as a potential future strength. Recognition was 1 , provided for increasing the supervisory oversight of maintenance and for implementing a well defined training program. < Weaknesses ir< the Maintenance / Surveillance program were then addressed. ., Mr. Zimmerman stated that the majority of operational events were ~rocted in this area, with surveillance of the containment sump being the most significant. It was pointed out that 18 violations were associated with this functional area during the assessment period. There has been difficulty in coordinating activities with other departments, as demonstreted by .viacing the wrong charcoal filter, and by placing the containment hydrogen vent trains in an inoperable status. Longstanding problems have existed related to missed surveillances, poor quality procedures, and corrective actions that were limited in scope. Mr. Zimerman also pointed out that many maintenance jobs have been deferred

during the current outage. Dr. Larkins indicated that < Maintenance / Surveillance is in need of improvement, and that the Work Control Center should be fully implemented. ' Mr. Walt initiated Trejan's response to the Maintenance / Surveillance , a rea. He indicated that he w:: dissatisfied with the overall perfonnance in this functional' area, and that short term, aggressive . actions would be taken. He also stated that Trojan was committed to . improvement in this area. Mr. Robinson stated that he recognizes the weaknesses and problems with Maintenance / Surveillance, and that aggressive actions will be taken to solve the problems. . a Regarding Engineering / Technical Support, Mr. Zimerman indicated that the area was last rated as Category 2 and was rated as Category 2 for tF.is assessment period. He pointed out that the SALP Board noted mixed performance'in this area. Major strengths were identified as: moving the Nuclear Plant Engineering group to the site, which should improve the interface with other plant organizations; performing a good oaality SSFI for the Service Water System; and the Design Basis Document affort, which will improve system understanding. Mr. Zimerman considered that the Design Basis Document program is vitally important, and that the NRC is looking at this effort in a positive light. Trojan is encouraged to continue identifying system problems through this effort. Other examples . .- . - - . - - . .- . - - . - - . . - . . . . . -

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. et i of good engineering work pointed out by Mr. Zimerman were the aggressive actions related to the cracked pressurizer safety valve disc, the strong. i erosion-corrosion program, and the handling of the circumferential cracks in steam generator tubes.. ' Weaknesses, asse'ciated with Engineering / Technical Support were in areas of , inconsistent quality and administrative control of technical work. Mr. ' Zimerman provided examples such as the overheating of an RHR heat exchanger, the incorrect main steam flow setpoint, and the containment sump problems, as illustrative of inconsistent work quality, i Administrative work control problems included drawings that were not

maintained current, updates to the FSAR that were not made, temporary ' modifications that have not been made permanent, and interface problems between design and. system engineering groups. Mr. Zimerman expressed

the need to learn from industry experience and pointed out that Trojan .: should have learned from the industry about problems 4ssociated with ' hydrogen tanks located on the control building roof. Finally, Mr.. Zimmerman discussed attrition of system engineers, with potential problems related to work load and the definition of responsibilities. Dr. Larkins also expressed the need to stabilize the Engineering Department staff. Mr. Walt' stressed the importance placed in the Engineering / Technical Support area and indicated that this is the lead area in the Nuclear Division Improvement Program. He indicated that Trojan is proud of their Design Basis Document and system walkdown effort, and that Trojan is- pleased-with the NRC's recognition of their effort. Regarding staffing, Mr. Walt agreed that there was a high turnover rate in 1989, but no one

has left the group in 1990. Efforts are also underway to secure the position of Manager, Nuclear Plant Engineering. The next' functional area discussed was Safety Assesment/ Quality- Verification. During the last assessment period, this area was rated as Category 3, and for the current assessment period the area was rated as Category 2. Mr. Zimerman stated that Quality Assurance (QA) has now shcwn consistent improvement. The depth and thoroughness of audits along with significant findings were viewed favorably. Mr. Zimerman indicated that PGE should take pride in their self policing actions. The knowledge of the QA staff is consicered to be good, and the implementation of the . Corrective Action Program is viewed as a future strength. A strong, positive attitude by both PGE and Trojan management is recognized. Mr. Zimmerman indicated that Trojan is now taking an industry perspective to problems when in the past there appeared to be self chosen isolation and a reluctance to learn from industry problems. The need for QA to continue playing a strong role in plant affairs was stressed. Weaknesses in the Safety Assessment / Quality Assurance area included the j

role of the Plant Review Board and the Trojan Nuclear Operations Board. ' It is considered that both organizations can be strengthened and can l - become more proactive in their approach to plant problems. Tracking completion of corrective actions can also be improved. The role of the I ! Performance Monitoring / Event Analysis group was viewed as mixed, with a i need stated to improve root cause analysis. Finally, Mr. Zimerman l l . . . . . _ _ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _

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. a stated that QA expertise in certain disciplines, such as fire protection and electrical, could be improved. Mr. Walt indicated that Trojan was pleased with the intrusivenest, of the - I QA organization, and that emphasis had been placed in this functional area... He further stated that as QA goes, so goes the Nuclear Division. j Mr. Seaman went on to state that the QA organization will continue to 1 improve. Mr. Higgins indicated that the role of the Trojan Nuclear Operations Board will be reviewed. Mr. Higgins also indicated that 1 working in QA will be a way to get ahead at Trojan. Prior to continuing with the next functional areas, Mr. Faulkenberry took time to stress that Trojan should not get complacent with a Category I rating in Operations, and that efforts should be taken to refocus on a successful startup following the current outage. Mr. Higgins responded by indicating that after noting the decline in the Emergency Preparedness area, they would not allow Operations to slip. Mr. Pate continued with the functional areas of Radiological Controls, j Emergency Preparedness and Security. For Radiological Controls, ' strengths were identified as an increasing management support for the program, improved contamination controls, improved radiological postings 1 and surveys, and a strong erosion-corrosion program. Mr. Pate identified perceived weaknesses in the area of Radiological Controls. ALARA planning, particularly with outage coordination, was noted as weak' The program for transporting radioactive materials, and . the storage of solid waste were also identified as areas in need of ' improvement. Mr. Pate concluded by stating that the Radiological Control area was generally good and stressed the need to work on ALARA controls. ~ Mr. Walt recognized the need for more work in the Radiological Control area, particularly in the area of ALARA. He noted that more ALARA , planning is needed, and the 1991 outage will be improved. Mr. Pate went on to the functional area of Emergency Preparedness. He identified strengths in the area as increased management oversight near the end of the assessment period, with timely and effective response to ide,tified NRC concerns. . Weakiesses identified in Emergency Preparedness were discussed. Mr. Pate j pointed out that the level of management support and oversight of the , , program varied prior to the annual exercise, resulting in fluctuating ' performance. He indicated that there were problems with the annual exercise including weaknesses in dose assessment, a delay in classifying a Site Area Emergency, and poor control of activities in the Technical Support Center. He also indicated that there has been some staffing problems in the Emergency Preparedness area. Mr. Pate concluded his remarks by indicating that consistent support should be provided for Emergency Preparedness programs and for the training and staffing of personnel. Mr. Walt did note that there had been inconsistent management attention in this functional area. Mr. Higgins indicated that efforts are underway to improve the interface between Trojan ano offsite emergency - . . . - - . - - - . - - . . . . .- .- . . _ . - ..

. _ . _ _ _ _ _ . _ . _ _ _ _ _ _ . _ _ _ __ _ __ . . _ . ___ , y g . . $4 , i -< . . . preparedness agencies. He also stated that Trojan has the tools to 1 improve in this area, and th&t those tools need to be applied better. The final functional area to be discussed was Security. Mr. Pate indicated that Trojan has upgraded their protected area with improved 3 lighting and has installed CCTV cameras to reduce the number of security posts. He also stated that organization changes have resulted in improvements in the areas of internal procedures, assignment of responsibilities, comunications, and correction of deficiencies. Security areas where weakness was observed included firearm proficiency by certain on-duty security officers and isolated failures to protect safeguards information. Mr. Pate also stated that there were concerns with the access control facility in that the facility is easily crowded, and there were concerns with backup power sources for the security system. Mr. Pate sumarized his comments stating that management changes have resulted in significant improvements over this evaluation period, but there still are NRC concerns related to Security. Mr. Pate also encouraged Trojan to complete the design and construction of the new access control _ facility. Mr. Walt indicated that emphasis had been placed in the Security area. There will be an evaluation of the backup power supply, and the new ' access control building is scheduled for completion in 1992. Mr. Ankrum stated that there was good support and coordination with Security and ' other onsite groups. He also indicated the need to maintain diligence in this area. Mr. Cross stated that he recognizes the need for a new access , control building. Dr. Larkins noted that, overall, there was an improving trend in Trojan performance toward the end of the assessment period. He indicated that there will be a real challenge for the new management in maintaining the current levels in strong areas while improving weak areas. Mr. Barr indicated that Trojan will face a real challenge in maintaining consistent performance once the goals are established. He also noted that statements made regarding goal setting are promising. Mr. ' Faulkenberry reiterated his opening remarks that overall performance has l been good, and that significant improvements have been made in the areas ' of Plant Operations and Quality Assurance / Safety Assessment. Mr. t - o L Faulkenberry also stated that Trojan has a good operations capability, and that efforts to refocus on operations need to be made so that the L , i startup following this outage is uneventful. Mr. Higgins stated that the L NRC's comments and criticisms are appreciated. He concluded the meeting by indicating that he is proud of the way that Trojan has taken on their problems. . s - p.we <. y , , ,- , ~v... . -.. . . . - . , . - , , . -

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, . . . j i ' M i l g Pbrum1d Genered BedricCorgpqy i , 1 % i. i .g i 1 , 1 ', July 12. 1990 - Trojan Nuclear Plant . Docket 50-344 License NPF-1 - ! t U.S. Nuclear Regulatory Comunission Attn: Document Control Desk Washington DC 20555 . Dear Sirs: , 1989 Nuclear Regulatory Commission (NRC) Systematic Asses - 9t of Licensee Performance (*AfM The NRC SALP Board evaluation of safety perforinance at the Trojan Plant for the period from January 1. 1989 through March 31,>1990 was provided by your letter dated June 1. 1990. ,0verall Plant performance during the period was acceptable and found to be directed toward safe operation, with improved

performance noted-in several functional areas. However, perforiaance in the , = functional area of Maintenance / Surveillance was evaluated as Category 3. ! Portland General Corporation has established a goal-to achieve sustained superior performance in the area of nuclear operations. To realize this - goal, Portland General Electric Company (PCE) is taking proactive and aggressive actions to improve performance in all areas of operation of the

. Trojan Nuclear Plant. This improvement is being accomplished through a 3 l commitment of support from Wuclear Division Management and the personal involvement of Corporate Management. L L ! s h f W 2 ) - m , $ ? . - - t I w v gw 3 r

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. . .* .. . The specific doncerns identified in the SALP Report and the actions being { taken to improve PGE's performance are detailed in Attachment A. '1 Sincerely, 1 If - . J. E. Cross Vice President. Nuclear Attachments j j . 1 c: Mr. John B.. Martin Regional Administrator, Region V U.S., , Nuclear, Regulatory , Commission ' ' Mr. David Stewart-saith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector.. .. . , . - Trojan Nuclear Plant . ,. . . - - ... a... ... .a . . . . . . . - -

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. .:: t : . . t . r - { ' ,. ,. . . . . .. i .C !"~ MAINTENANCE /SURVEIff "CE RESPONSE . . Board Recommendation Licensee management should continue to focus on improving the control of plant work activities. Specifically, the licensee should continue to implement the Work Control Center concept!, improve planning and scheduling, and improve the quality of maintenance and surveillance procedures. The licensee should also define clear axpectations for middle management to the first line supervisor with respect to quality performance and individual responsibilities. Portland General Electric Company (PGE) Rosconse PCs is committed to fully implementing the Work control Center concept and is making progress towards that end. We have recently established a centralized Planning and Control organization. We have hired a new ! , permanent Manager of planning and Control who will rwport at the end of July. The new manager holds a current Senior Reactor Operator (SRO) license on a Westinghouse four-loop pressurized water reactor (pWR) and , is a degreed engineer. A training program for work planners and schedulers is currently being developed for future implementation. ' The Work Control Center concept is being utilized during the current outage. We are working from a three day schedule which is prepared by Outage Management, reviewed by qualified SROs at the Work Control Center, and concu.e d with by the work group managers. This methodology will ! continue through startup and power operation until a computerized schedule is developed which will allow planning and scheduling of work activities on a 12 to 13 week cycle. This computarized schedule will alicw coordinating all work activities (i.e., maintenance requests, . preventative maintenance, and surveillances) thus minimizing equipment out-of-service times, helping prevent safety-related equipment train violations, and relieving the Shift Supervisor of unnecessary j administrative duties. - , PCs recognizes the need for more comprehensive outace planning and has l already issued the 1991 Preoutage Milestones. These milestones clearly i 3 define the outage planning schedule and responsibilities to ensure timely I work planning and material availability. Management oversight and personnsi accountability will be utilized to assure these milestones are accompl3shed. I i s

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' .- f , ' s >g. a Trojan Nuclear plant Document Control-Desk- Docket 50-344 July 12, 1990 License WpF-1 Attachment A page 2 of;3 j

. . . ' The Maintenance Depar_tment;,ha_s b_een, making _ steady progress in

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a implementing the Maintenance Improvement Plan.- One result has been increased staffing at all levels of management and supervision. Additional _ personnel are in place to improve preventative maintenance and surveillance activities. gach craft group now has a designated position for.a specialist.Lo improve the. quality of procadures. A computerized trending system for. equipment. failures became operational in May 1990. j' With.new management d1rection.and a strong focus on pricrities.ithe foundation for further improvement is in. place. - .. u ' The key . element in our plan to improve performance in tN maintenance area is the effective;use of. supervisors. Supervisors 6.+ attending i i Frontline Leadership training which teaches communication, leadership, and supervisory skills. The Maintenance Manager has established clear guidance fog, supe,rvispry,,ov,ersight , of, work in the plant. The established s ' . goal la ,for first line supervisors to spend a minimum of 50 percent'of- 1 I their time in the field. Management; oversight and holding pe:ple j accountable N performance will improve the quality of work, reduce . mistakes; strengthen proctew wi ::ompliance, and upgrado work-site j material. condition. In a:ahd he manner, Maintenance Department' upper j level supervisors:and managea are required to make frequent in-depth -observations of plant activities. 1 i#anagement expectations t.be been defined in the procedural compliance area and people will be held, accountable to cc:nply with these expectations.... Actions to improve procedural compliance include effective- use of the new proceduct -specialist assigned to each craf t group. prompt j . resolution of procedural probleas'by the specialist will encourage craft l workers to stop work in.-the face of uncertainty. The procedure specialist will also improve the overall adequacy of maintenance work . procedures. Improved procedures will lead to improved compliance. An H additional part of the improvement plan is the development ofinew procedures for calibration of all Magan instrument loops and Plant ,- instruments which provide inputs for reactor trip or Engineered Safety Features (ESP) actuations. A dedicated team was established in February 1990 to accomplish this task. i , ? POE's plan to improve root cause analysis, understanding of technical issues, and implementation of correction actions is based on management attention and effective use of supervisors. The new Maintenanco i Equipment Tracking System (METS) provides an additional tool for analyzing equipment failures. The new procedure specialists are available to assist the craft supervisors in investigating and evaluating problems. As established in the Maintenance Improvement program, the Maintenance Manager is holding ongoing discussions with supervisors to evaluate Plant events and corrective actions. , I .. ~ -

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. . . .c ,; -.- . ... ' .- ,. .( Trojan Nuclear Plant Docket 50-344' Document Control Desk License WPF-1 July.12, 1990

Attachment A - Page 3 of 3 " r ' . . . As shown by.the NRC.noted improvement PCE has established increased- . management oversight to ensure timely and proper. response to Wuclear . !> i Regulatory Cossaission (WRC) concerns. Improved commitment. control and h ' prioritization. programs, which are. currently being developed, will . provide additional improvement in this area. - 3 2 . . um; .,

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.. ,[" PtweendGeneralBeatiocorgeny l Jarnes E. Cross Vice President. Nuclear t ' , 6 , + l , , , July 31, 1990 $ ', Trojan Muslear plant Doaket 30-344 ! Lleanse Npp-1 j U.S. Wuolear Regulatory commission Atta: Document Control Desk . Washington DC 20535 ' . , , Dear sirst , 1 1989 Nuclear Regulatory Commission (NBC) sva+ - kin Amman 4 of Llammaam Perfe=ran f ear s) t ) C4 WRC SALp loard e, valuation of safety performance at the Trojan plant for the period from January 1, 1989.through March 31, 1990 letter dated June 1.-1990. Overe11 Plant performance during the period wasw . steeptable and found to be directed.toward safe operation, with improved portormance noted-in several functional areas. However, performance . in - the : functional' area of Maintenance / Surveillance was avsluated as Category 3. i i Our initial response addressing the Maintenance / Surveillance area was provided,in a.1etter dated July it. 1990. in Attachment A.= An updated response is provided - , . Sincerely, j [ , Attachments M 0M L es Mr. John 5. Martin Regional Administrator, Region Y . U.S. Buclear Regulatory commission , . , , , h Mr. David stowert-8mith , , - State of Oregon Department of Energy , ( Nr. R. C. Barr i- ! NRC Resident Inspector Trojan Wuolear plant .. , - - - r y v o o v > .> 3 =l f) 121 SW Salmon St. Portland, OR 97204 503/464 8897 i k ;.a 4,ett esst'te*se ysst scs tes t-swa won ! k _ , _ _ - - - - ~ - - * ^ ^ - " - . - - - - - g

._ _ _ . _ _ _ _ _ _ . . . . _ _ . .~. _ ._ . . _ _ _ _ __ _ ._ _ _ _ __ _ _ _ __ ^% ... .. .a , .. , k s Trojan Wuolest plant . Docket 30-3a4 DocumentCbntrolDesk ' License NPF-1 July 31, 1990 . Attachment A Paio 1 of 4 , ' s MAtarfewAucgjgggygff.v.aaseg ;;;;.weg named Rea-- -.dation t,1censee management should continue te focus on improving the control o work activities. Specifies 11y. the licensee should continue to implement the Work Control Center concept, improve planning and scheduling. and improve 1 quality of maintenance imd surveillance procedures. ' The licensee should also. , with respect to quality performance and individual respon - i [ portland Canacal Rientria e = anw (EGM e :Or.ma t making progress towards that end.PCs is committed to fully implementi L planning and Control organisation. We have recently established a centralised Control, who reported July 'We have hired a new Manger, planning and Reestor Operator (820) license on a Westinghouse four-loop pr ' - reactor.(pWR) and is a: degreed engineer. We have recently completed an independent study.of our work' control process, both outage and nonoutage

-1 are revising our estion plan to incorporate the results of this study. revision will be~ complete by August 31, 1990. This 'l As enumerated below, we are making incremental improvements in the work control process in parallei with the overall upgrade effort and are establishing performance indicators to determine success rate. teamwork across department boundaries in' daily work activities, the foll To assure , actions have been taken: 1. The plan of the Day'(p00) is reviewed and approved daily by not-only the Work Control Center and Duty Generel; Manager, but also by the work gr management responsible for the work sativities. performance indicators have been established and posted to show Maintenance Requests (NRs) j 1 completed versus NRs scheduled, surveillances' completed versus L surveillancss scheduled, and' clearances hung versus clearances requested. 2. problems are identified and tracked to compistion. Currently, The 7 a.m. meeting consists of the plant staff dopsetment representatives and is led by the Shitt supervisor. This meeting covers adivities and plant problems from the day's upcoming work activities.the previous two shifts which are e attended and is led by the planning and control Department.Ino 12 noon 1 is designed to cover current Plant status, status of problems identifiedThis meet et the 7 a.m. meeting, status of ourcent work activities, and work ' . 2 '* d 26,11 0661'10'89 ~ u .m . - -- - - - - - - - - ~ ~ - . . - - - -- ' -

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License NPF-1. July 31, 1990 ' ' Attachment'A page 2 of e scheduled for the following day. . documented and followed'to closecut. Action items from these meetings are This meeting schedule and content; , ' may very dependent upon assessment of effectiveness, Plant status, or scheduled work load. 3. A planned revision to our work control procedure will; incorporate the following philosophy. Work packages for estivities on the 700 will be ', reviewed by the cognisant work groups the afternoon prior to the scheduled date.. The work packages will then be delivered to the control room along with the necessary alearances. The shif t Supervisor on the 11 p.m. - 11 a.m. shitt will review and authorise the work packages, ensure tha clearances are hung, and' deliver the work packages back to the work groups , prior to 7 a.m.. This will allow the work groups to start work l inmediately upon reporting to work.-reduce the work load for the Supervisor.. help minimise safety equipment out of service times,. day shift lf and- minimise traffic in the control room. This proposed-procedural revision I will be added to our Werk Control Center Action Plan by August 31, 1990. L l In addition, the plant General Manager has provided guidance to the ' operating crews that requires. work to continue to completion for activities that require entry into a Technical specification action ' (' statement of 72 hours or less or for which a special Report would be coquired if not completed. perfomance indicators will be established for safety-related equipment out-of-service . times by' August -31,1990. % ,. 4 To aid in preventing safety related equipment train violations, a ' ' procedure revision is planned to require the Work contr:1 Center to instituto designated train-related weekly scheduling. Croes train scheduling will be thoroughly reviewed and minimised. This proposed ' procedural revision will be added to our Work Control conter Action Plan by August 31, 1990. In addition, a scheduling system is being developed to integrate-surveillances, preventive maintenance tasks, and MRs. This integrated scheduling tool is targeted for completion by November 30, 1990. This will not only help in preventing safety-related equipment ! train violations but will also aid in minimising safety-related squipment '" out-of-service times, evaluating preventive to-corrective maintenance ratios, and assessing manpower requirements. perfomance inlicators established in the area include corrective maintenance backlog (total) and corrective maintenance backlog trend by length of time open. Other indicators will be established to trend preventive maintenance items- ., '" scheduled versus' preventive maintenance items complete, number of Proventive maintenance items overdue, and number of cross-train comp. . onents- scheduled during train-related weeks. These indicators are planned to be 3 in place by August 31, 1990. - A training program for the Planning and Scheduling personnel is currently being developed. Tentative curriculum guidelines are complete. Implementation of this training program will be in accordance with our Maintenance Improvement Plan. This training program is designed to improve implementation of and assure consistency in our work planning process and . 6e e,iii essi te se .

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Trojan Nuclear plant Docket 30 344 Document Control Desk , License NPF-1 July'31, 1990=

Attachment A page 3 of.4 4 l w111' include such areas as parts procurement, safety-related determination. E femat of work instructions, and unifomity of post-maintenance testing. ' Training is-tentatively scheduled to begin by January 1, 1991. In response to a corrective Action Roquest (CAR corrective action and in an effort to uygrade our surveillance program, we a)re revising our surveillance , administrttive procedure. This revision will provide more definitive guidance for organisational responsibility within the surveillance program. The surveillance administrative procedure is currently scheduled to be revised by september l', 1990. In addiklen, by November 1, 1993 we will evaluate a. long-term program for procedural upgrade of the te6 aical content of surveillance procedures. 4 pSg recognises the need for nota comprehensive outage planning W has already issued the 1991 preoutage Milestones. These milestones alearly define the outage planning schedule and responsibilities to ensure timely work planning and material availability. Management oversight and personnel accountability will be utilised to assure these milestones are accomplished. Trojan's Leadership Team, consisting of the genior Vice president - Generating ' Division, the Vice president - Nuclear Division, and the Diviolon General Manants, has selected the Corrective Action Program (which includes event inve=Jigation) as one of eight items on the Leadership Team agenda. pos's> goal for the Corrective Action progree is that it promptly identifies problems, efficiently correets them, and effectively prevents them from i recurring. A number of actior.s have been completed in support of the goal, several more are planned, and it is recogniced that others will be required as necessary adjustaants are identified. The Wuelear Division has recently.Laplemented revised procedures to address corrective actions (including event reviews).- The revised corrective action procedures are designed to eliminate duplication and confusion, shorten the processing time for corrective action documents, increase the use of trending, and capture corrective action / event report information in a single data base to enhance trending.. ,. An ongoing self-assessment plan,is in place to identify additional areas for improvement in the Corrective Action program. These include, meetings with managers, supervisors, and employees to obtain feedback,-biweekly surveillances of the program (this frequency may be adjusted depending on results), and the establishment of a 13 umber of performance indicators to assist in detemining if measurable expectations are met. . The Maintenance Departmout has been making steady progress in laplementing the Maintenance Improvement plan. One result has been increased staffing'at all 1' levels of management and supervision. Addit".onal personnel are in place to improve preventive maintenance and surveillance activities. Each craft group now has a designated position for a specialist to laprove the quality of . 4 ' 'd 66: 1I e661 1e'ee _ e s c c e c s . t e c ..f -"I - W d - - - - - - - ,

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. r -' - Trojan Nuclear plant , . Dooket 50-344 Document Control Desk " License NpF-1- July 31, 1990 Attachment A page 4 of 4 proc 4dures. A.computerised trending system for equipment failures became ". operational in May 1990. With new management direction and a strong fe m on priorities, the foundation for furthee improvement is in place. i The key element in our plan to improve performance in the maintenance area is ' the effective use of supervisors. Supervisors are attending Frontline Leadership training which teaches communication, leadership, and supervisory skills. The Maintenance Monager has established clear guidance for ' supervisory oversight of work in the plant. The established goal is for first-line supervisort ta spend a minimum of 50 percent of their tima in the field. A performanoe~ indicator is being established to track performance with respect to this geel. This' indicator will be in place by August 31, 1990. - - Management oversight r.nd holding people accountable for performance will improve the quality of work, reduce mistakes, strengthen procedural . compliance, and upgra.e work-site material condition. In a similar manner, Maintenance Department upper level supervisors and managers are required to make frequent in-depth observations of plant activities. Management expoetations have'been defined in the procedursi compliance area ! and people are being held accountable to comply with these. expectations. In addition Quality Assurance surveillonoss are tsing utilised to assure compliance with management expectations. Actions to improve procedural- sempliance include effective use of the new procedure specialist assigned to each craft group. prompt resolution of procedural problems by the specialist- , will reinforse requirements to stop work in the face of uncertainty. The procedure specialist will also improva the overall adequacy of maintenance work procedures. An additions 1 part of the improvement plan is the _, development of new procedures for oslibration of all Hagan instrument loops , and plant instaments which provide inputs for reactor' trip or angineered Safety Features actuations. A dedicated team was, established in February 1990 _ to accomplish this task with completion expected by September 30, 1990. s p03's plan to improve root cause analysis, understanding of technical issues. and implementation of correction actions is based on management attention and . effective use of supervisors. The new'Neintenance squipment Tracking System (MgT8) provides an additional. tool for analysing equipment failures. The new procedure specialists are available to assist ther craft supervisors in investigating'and evaluating problems. As established in the Maiptenance Improvement program, the Maini.enance Manager is holding ongoing discussions with supervisors to evaluate plant events and corrective actions. As shown by the NRC noted improvement, PCs has established increased y l management oversight to ensure timely and proper response to NRC concerns. Improved oo "Vment control and prioritisation programs, which are currently ' bein5 deve19,, 4 will provide additional improvement in this area. These two 4, programs are -noduled to be in place by December 1, 1990.

DpC/5301W e4 esitt essi'le'ee "CC *** *** '~"* " " > . _ .- _

. - . _ .._ _ _ ~ _ __ . _ . _ _ _ _ _ _ , &, W _ _, kk g UNITaD STATss' i - NUCLEAR REGULATORY COMMISSION a- . , naOION V ~ ' . L - WAL UT cetEEK AL o i esses j . - ....* JUN L 1990 1 ' Docket No'.'50-34a ~ \\ - Portland General-Electric Company ! 121 SW Salmon Street Portland, Oregon 97204

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- Attention: Mr. T. D. Walt Acting Vice President, Nuclear H . Gentlemen: . - u SUBJECT: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, REPORT-NUMBER 50-344/90-09 . . The NRC: Systematic- Assessment of Licensee Performance (SALP) Board has completed the periodic evaluation of Portland General Electric Company's (PGE)~ performance at the Trojan Nuclear Power Plant for the period January 1,1989 through March 31, 1990. ~ The~ performance of Trojan was evaluated in the functional areas of plant l operations, radiological controls, maintenance / surveillance, emergency- preparedr:ess,ication.y, engineering / technical support, and safety assessment / securit

quality verif

The criteria used in conducting this assessment and the 1 , > SALP Board's evaluation of PGE's' performance in these functional areas are contained in the enclosed SALP report. q _ e- - Overall the SALP BonM found the performance of licensed activities at Trojan to be acceptable and directed toward safe facility operation. The Board noted Oin particular the absence of any significant operations events during the fifteen month SALP period, and weighed this aspect of. performance heavily in concluding that a SALP Category I rating is appropriate in the plant operations functional area. .In considering the overall PGE performance et < Trojan, the Board recognized the actions' taken during the last half of the < W

assessment' period to strengthin the Trojan management team and to improve

g p(erformance in. specific areas through the Nuclear Division Improvement PlanT - NDIP). functional area in the enclosed SALP report, however in general the Board 1 concluded that PGE should continue to implement the actions outlined.in the . -Nuclear Division Imarovement Plan. Furthermore the Board recommended that ..PGE ensure that mecianir,ms are in place to provide prompt feedback on the

o

. effectiveness of actions implemented under the NDIP. s The Board's most prominent concern was in the functional area of 5 Maintenance / Surveillance. Performance in this area was considered to have declined to a Category 3, from a Category 2 following the previous SALP < assessment. Specifically the Board considered the planning, scheduling and oversight of maintenance /s,urveillance work activities to be weak, and the . quality of associated procedures and work instructions to be in need of s T b $[? D 'l $ f , - . , 66 . , _ - _ . - . - , , . .- . . . . - ,. _ , - - , -

. . - . . - - - . . .. . - , 2 .. ' + . ' . improvement. Illustrative of these concerns were the deficiencies identified - with the containment sump midway through the SALP period, and the work planning and scheduling problems which occurred while preparing for the 1990 refueling outage. Although the Board observed an improving trend at the very end of the peried, this area clearly. warrants close future scrutiny by PGE management. , In the functional area of engineering / technical sup that overall performance was at a Category 2 level. port, the Board concluded However, the Board noted that there were a number of specific examples of both particularly good i technical work and notably weak technical work. A recent example of weak performance in this area was the failure of the engineering organization to recognize that'the main steam line flow engineered safety features setpoints were in violation of the Technical Specification requirements. This error was subsequently identified by the operations Shif t Supervisor. The Board recommended that high priority be assigned to permanently filling the position of Manager, Nuclear Plant Engineering (NPE), and that actions be considered to both with NPE personnel and with System provide for staff stability, Board furthermore considered it important that the Engineering personnel. The . ! actions being taken to promote consistent, high quality technical work,llowed and to ! com)1ete the Design Basis Document program, be continued and closely fo by >GE management. The Board considered the performance of Quality Assurance (QA) audits during thisassessmentperiodtobeamajorimprovementoverpastQAaudits. This conclusion contributed significantly to the Board rating the Safety - Assessment / Quality Verification functional area as a Category 2. You are encouraged to continue to demand that QA critically, and independently assess rformance at Trojan.- The Plant Review Board and the Trojan Nuclear rations Board continue to be considered in need of improvement in i ntifying programmatic deficiencies at Trojan. A management meeting-to discuss the results of the SALP Board's assessment has 'been scheduled for June 15, 1990, attheTrojansite. Arrangements for the management meeting will be discussed further with your staff in the near futn In that your performance was evaluated as Category 3 in the maintenance / surveillance functional area, you are requested to provide a L, written response within 30 days after our forthcoming meeting, which I. addresses your plans to improve performance in this functional area. Comments ! on other portions of the SALP report may be provided as appropriate. !.. A summary of the SALP Board's assessment is prr.vided in Section II of the ' enclosed report. Perceived strengths and weatnesses and Board recommendations are discussed in Section IV, Performance Analysis. In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations,s Public Document Room, as well as anya SALP report will be placed in the NRC comments you may wish to submit to the NRC regaroing the content of the SALP . , report. . - - - .. -. . .- -.

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t - , ' t ) v, . . . . m 3 1 .. - I , +

-The NRC!s Office of Analysis and Evaluation of Opera'.icnal- Data performed an-

. , assessment of licensee event reports. This assessment was provided.as input

- r. * to the:SALP process; a copy is, therefore, provided as Attachment I to the . enclosed report. i, - The response requested by this letter is not subject to the clearance . < procedures of the Office of Management and Budget as required by the Paperwork =

o L Reduction Act of 1980, PL 96-511. ' Should you have any questions concerning the SALP report, we will be pleased - 4 to discuss them with you. 9 9 ' < .. J. B. Martin - Regional Administrator ' n

Enclosures-

" SALP Report Nos. 50-344/90-09 Attachment ~1 Enclosed in SALP Report

, i - cc w/ enclosures: S. Bauer, PGE C. P., Yundt, PGE L. A. Girard, PGE t _ D., Stewart-Smith, DOE , .c i . . '.:

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