ML20196E750
| ML20196E750 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/25/1988 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8803010278 | |
| Download: ML20196E750 (8) | |
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m W General ElectncCoir,rsiy David W. Cockfield Vice President, Nuclear February 25, 1988 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Cens.lssion ATTN? Document Control Desk Washington DC 20555
Dear Sir:
En5 neerinr_Parformance Irmrovements i
In our lettet to Mr. John B. Matiin, kesional Administrator, Region V, dkted December 29, 1986, we provided an action plan for improving engineering activities at Portland General Electric Company. Itignificant progress has been made on these action plan items in 1987 with We current status of each item provided in Attachment 1.
In addition, during the 1987 refueling outage, Nuclear Plant Engineering demonstrat;ed a proa<.tive invMvement and resolution to the accumulator fill line failure, main steam line thickness, pipe support design verification, and feedwater restraint failure issues.
The forwarding letter for NRC Inspection Report 87-31 requested our response to certain deficiencies identified by the Inspection Team. The responses to these deficiencies are provided in Attachment 2.
Sincerely, g(M Attachments 1
c:
Mr. John B. Hart in Region d Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William Dixon State of Oregon Department of Energy Mr. R. C. Barr
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NRC Resident Inspector f
Trojan Nu;1 car Plant
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Docket 50-344 February 25, 1988 License UPF-1 i
Page l'of 4 STATUS OF ENGINEERIWC PERFORMANCE IMPRSVEMENT ACTION PLAN Engineering Managemsnt Involvement Increased management attention has been and will continue to be focused on improving cooperation between Design and Plant System Engineers, as well as quality assurance, safety analysis and regulatory compliance personnel.
Increased involvement by the Corporate technical staff has been emphasized and demonstrated during resolution of recent Plant issues such as pipe support 4
design verification and accumulator nozzle f ailures.
Several changes in ensi-nearing management positions were made in 1987 in an effort to improve engineering involvement.
Relocating the Nuclear Division staff from Corporate Headquarters to the Trojan Plant site in 1989 is an important element in this program. Combining the entire Nutlear Division onsite is expected to improve communications and er.gineering involvement in day-to-day activities.
1.
Design Basis Documents (DBDs).
System DBDs have been prepared and are being used for the 13 systems described in the December 29, 1986 letter.
These DBDs are proving to be very useful to both onsite and offsite engineers, particularly in responding to operational questions or issues. This phase of the DBD program is complete with the exception of the DBD open items, and progress has been initiated on the second phase scheduled for completion in 1988.
The DBD open items are reviewed, prioritized, and assigned action (on action plans) corresponding to their significance.
t 2.
Operation, Maintenance, Surveillance, and Training Activities Review, l
4 Reviews of the first phase of DBDs have been completed by the Plant System Engineers and Plcnt Training personnel. Walkdowns of the various cystems by the Plant System Engineers have been completed. The reviews and walkdowns were extremely holpful in identifying discrepancies and e
inconsistencies in Plant drawings and documents. Many open items were i
found. The open items and comments have been factored into revisions of i
the DBDs or assigned to action plans for resolution.
a l
The Quality Assurance Department safety system functional audits planned l
for 1987 have been reschedulod for 1988 due to the timing of completion of the DBDs.
In 1988, the Quality Assurance Department will perform system functional reviews on two of the 13 systems for which DBDs have been prepared to provide an appropriate level of confidence that the problem regarding properly implementing the design and safety analysis into operations is resolved, i
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Trojan Nuclear Plant Document Control Desk Docket 50-344 February 25, 1988 License NPF-1 Page 2 of 4 1
t 3.
Updating Equipment Technical Manuals.
The initial backlog of updating of safety-related vendor technical mar.uals has been completed. The updated technical manuals reflect the actual equipment and components in the Plant, providing better informa-t tion te the maintenance staff, operators, and engineers; and reducing the possibility of making mistakes due to inaccurate information. As equip-ment is replaced or changed, vendor technical manuals will continue to be revised to remain up-to-date and accurate.
4.
Verify and Update Plant Drawings.
The verification and updating of selected Plant safety-related drawings has been completed. All safety-related drawings are updated upon completion of changes to safety-related equipment or systems.
5.
Update other Important Design Documentation.
a.
Valve List - The valve list was reviewed for accuracy and updated in 1987. At the present time, it is being computerized and converted to a controlled document, which is expected to be completed in 1988.
I b.
Piping Material and Fittings List - This list was reviewed for accuracy in 1987 and some deficiencies were f ound. plans are being developed to revise this list in 1988 to reflect the as-built status of the Plant.
c.
Q-List - The original schedule, as stated in the December 29 letter, indicated that we expected to complete a revision to the Q-List by Decerber 1987 that would provide additional detail for the safety-related and quality-related components and equipment installed at the Trojan Nuclear Plant.
Our current efforts have concentrated on completing a revision to the list of safety-related systems and components. This revised Q-List, now identified as the Safety-Related List (3R-List), was made avail-l able for use within the Nuclear Plant Engineering Department in i
December 1987 and will be available for the remainder of the Nuclear Division early in 1988. Use of the list has discovered inconsis-toncies with the Inservice Inspection and Inservice Testing programs for a few components.
It is an excellent teol for determining the proper classification and requirements for safety-related components.
l Upon further evaluation of the need to enhance the Q-List, it was determined that the addition of quality-related items is not cost-j effective and not justified at this time. Work on non-safety-related l
components from the security, environmental monitoring, fire protec-tion, and radiological waste management systems has been deferred in I
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Trojan Nuclear Plant Document Control Desk Docket 50-344 February 25, 1988 License NPF-1 Page 3 of 4 order to complete the additional work on the SR-List. When work on the SR-List is completed, we will reevaluate the effort necessary to enhance the list to include quality-related items, d.
Instrument Data Sheets - A program was initiated in 1987 to prepare an instrument data sheet for each electrical instrument in use at Trojan.
The data sheets will be controlled as engineering documents in accordance with the existing drawing control system, and will be maintained for the life of the Plant. This activity will greatly reduce the possibility of data discrepancies by consolidating engi-neering design information into a single document.
6.
Corporate Engineering Organization Performance Review.
Six of the highest priority issues identified in the independent outside review report of the offsite engineering organization were assigned action in 1987. Action on two of the six items has been completed and recom-mandations are being implemented. The remaining four issues will be completed early in 1988.
Several significant organizational and policy changes have resulted from the corrective action taken in response to these issues. Corrective action is planned to be taken in 1988 for all six of the assigned issues.
7.
Resources.
PGE has continued to evaluate the need for increasing personnel resources and taken steps to do so as appropriate. A total of 75 new full-time positions were created in 1987 and several more have been approved for 1988. Of those 75 new positions, 21 were positions in the Nuclear Plant Engineering Department (Corporate engineering), and 13 were positions in the Technical Services Department at Trojan. These additional positions provide more resources and technical experience in those areas in which improvements are most needed.
8.
Responsibilities and Controls of Specific Functions.
The responsibility and control of American Society of Mechanical Engineers programs, including inservice inspection, inservice testing, and Section II repair and replacement reconciliation, and code welding were consolidated at the Plant in 1987.
Since the Plant is responsible for the performance of this work, it is practical to have all phases and control consolidated at one location at the Plant. A new Branch Manager position directly responsible for these activities and other aspects of surveillance testing is expected to be filled in 1988 providing more management oversight.
These steps are expected to result in improvements to these programs with fewer surveillances being missed, late, or over-due.
Additional specific functions are continuing to be evaluated to
Trojan Nucleer Plant Document Control Desk Docket 50-344 February 25, 1980 License WPF-1 Page 4 of 4 ensure clear assignment of responsibility and that adequate controls are established for their performance.
9.
Improve Specific Engineering Procedures.
Several engineering procedures were revised to incorporate improvements in engineering activities and processes in 1987. The review of engineer-ing procedures will continue to identify and implement improvements as appropriate.
2149W.1237
5 Trojan Nuclear Plant Document Control Desk Docket 50-344 February 25, 1988 License NPF-1 Page 1 of 3 DEFICIENCIES IDENTIFIED IN THE NUCLEAR REGULATORY C0KMISSION (NRC)
LETTER OF DECEMBER 17. 1987 (FOR INSPECTION REPORT 87-31)
Deficiency 1 it appears that your failure to implement comprehensive and esfective trending and root cause identification and correction programs significantly detracts from your ability to apply lessons learned from events at Trojan and identify problem situations before they manifest themselves in plant transients. Due to these weaknesses, increased management attention is needed to ensure more critical evaluations are performed of onsite and offsite events."
Portland General Electric (PCE) Response The following improvements have been or are planned to be made to correct this deficiency.
1.
Lessons learned from industry events are reviewed in the Operating Experience Review Program (OERP). The OERP will be changed by April 1988 to require that all Operational Assessment Reports (OARS) be reviewed by Nuclear Plant Engineering (NPE) (offsite engineering organization) and by senior management.
In the interim, these additional reviews have been implemented. These additional reviews will ensure more management attention and engineering involvement in the operational experience from outside industry.
2.
Lessons learned from events at Trojan are evaluated by Event Reports. Revisions made in 1987 to the Event Report system have shown that they are an excellent tool to evaluate events, particu-larly events that have been repeated.
The threshold for initiating an Event Report was lowered in 1987. This change has resulted in an increase in the number of Event Reports in 1987.
In addition, in 1988, to ensure that corrective actions identified in the evaluation of Event Reports are accurate, correct, and proper and are being performed in a timely manner, the following measures have been taken:
Reviews of evaluations by the Performance Monitoring / Event a.
Analysis (PM/EA) Department, concurrent with evaluations by the assigned work group, have been implemented when an event has been determined to be reportable or when requested by Plant management.
b.
More attention has been directed to the root cause and contributing cause determination of the Event Reports in an effort to prevent the recurrences of events.
Trojan Nuclear Plant Document Control Desk Docket 50-344 February 25, 1988 License NPF-1 Page 2 of 3 PM/EA has been assigned the task to trend causes of Event Reports c.
on a semiannual basis and issue the appropriate reports to the Nuclear Division management.
d.
PM/EA is improving the quality of their recommendations to be more relevant to the cause of the occurrence and more meaningful to Plant management.
Increased emphasis will be. directed to accomplish corrective e.
actions on Event Roports in a more timely manner.
f.
PM/EA will continue to perform periodic evaluations to determine the effectiveness of corrective actions.
g.
In addition, the quality and meaningfulness of the commitment tracking list will be improved in order to permit better direction and allocation of resources for ensuring that corrective actions are completed on time, h.
The Plant Review Board (PRB) is continuing to work to imprave evaluations of the Event Reports by attempting to focus on major issues and becoming less defensive.
3.
Nonconformance Reports (NCRs)/ Nonconforming Activity Reports (NCARs) are used to evaluate lessons learned from events at Trojan. There has been an increase in the number of NCRs and NCARs by a factor of 1.5 over 1986. This is indicative that Nuclear Division personnel are attempting to look for problems and bring them to management's attention for resolution.
PGE appreciates the significance of evaluating and applying lessons learned and operational experience to day-to-day activities.
PGE will continue to take steps to improve the activities in this area.
Deficiency 2 "Design engineering personnel did not appear to have open communication nor adequate interface with the Plant staff."
PGE Response PGE is taking several steps to improve the communications between the offsite engineering organization and the onsite operating staff.
In that regard, PGE has taken, or will take, the following steps:
1.
There are daily phone calls between the Plant Duty Manager and the General Manager Technical Functions, informing him of Plant status, issues and problems, and determining which issues and problems need assistance from Technical Functions.
Trojan Nuclear Plant Document Control Desk Docket 50-344 February 25, 1988 License NPF-1 Page 3 of 3 2.
Several memoranda have been written from the Plant management to their appropriate staffs directing them to involve the Technical Function organizations offsite in resolving issues and problems identified onsite, 3.
The Plant System Engineers are directed to communicate directly with the NPE Design Engineers in the Corporate offices.
4.
Although NPE is n design modification organization, they have been directed to provide assistance on Plant problems.
5.
There is an onsite NPE organization which provides immediate and daily interface with the Plant organizations via the morning / daily meetings and increased awareness of Plant problems and issues.
6.
To further improve communications between NPE and Plant staffs, the entire Nuclear Division will be moved onsite in late 1989. Not only is this expected to improve communications, but when the move occurs, there will be a redefinition of responsibilities between the various engineering organizations to ensure that resources are properly directed to correct the necessary deficiencies.
In general, NPE involvement in onsite engineering activities has improved in the last year.
Specific examples of NPE involvement are the Barton transmitter issue, several events from the 1987 refueling outage, and the motor-operated valve actuation testing program.
PCE recoe,nizes the need to continue to improve communications within the Nuclear Division and will continue to take measures directed at accomplishing this task.
Deficiency 3 "Your improvement program in these areas should include a realistic appraisal of the effectiveness of your present programs and increased involvement by your corporate engineering in the improvement to these programs."
EGE Response In addition to the above, steps PGE has taken in an attempt to perform a more realistic appraisal of the effectiveness of our programs include the independent CE task force study performed in late 1986, the self-appraisals periodically performed by Nuclear Division management, and the fact that several management changes have been made in 1987.
PCE has endeavored to involve System Engineers more specifically in design modi-fications. PGE feels that continuing efforts are needed and will be taken to continually assess our present programs and to provide increased management awareness and engineering involvement as necessary.
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