ML20214D600
| ML20214D600 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/07/1986 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20214D602 | List: |
| References | |
| TAC-65350, NUDOCS 8611240163 | |
| Download: ML20214D600 (3) | |
See also: IR 05000344/1986023
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
REGION V
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1450 MARI A LANE. SUITE 210
WALNUT CREEK. CALIFORNIA 94596
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NOV 071986
Docket No. 50-344
Portland General Electric Company
121 S.W. Salmon Street
Portland, Oregon 97204
Attention: Mr. Bart D. Withers
Vice President, Nuclear
Gentlemen:
Subject:
NRC Inspection of the Trojan Nuclear Plant
This refers to the special team inspection, conducted by Mr. F. R. Huey and
other members of our staff on August 11 through August 22, 1986.
This
inspection examined your activities as authorized by NRC License No. NPF-1.
Discussion of our findings were held with Mr. Lindblad, yourself and other
members of your staff, at the conclusion of the inspection.
Areas examined during this inspection are described in the enclosed inspection
report. Within these areas, the inspection consisted of selective
examinations of procedures and representative records, interviews with
personnel and observations by the inspectors.
Based on the results of this inspection, it appears that certain of your
activities were not conducted in full compliance with NRC requirements, as set
forth in the Notice of Violation, enclosed herewith as Appendix A.
Your
response to this notice is to be submitted in accordance with the provisions
of 10 CFR 2.201, as stated in the Notice of Violation.
The inspection was based on generic probabilistic risk assessment and focused
on the service water, component cooling water and 125 VDC electrical
distribution systems.
The inspection approach was similar to safety system
functional inspections (SSFI) previously conducted by IE Headquarters staff at
other facilities.
The primary emphasis of this type of inspection is to
conduct a detailed review of the original engineering' basis and the adequacy
of subsequent modifications to the selected systems.
The review covers the
engineering, operations, surveillance, maintenance, testing and quality
assurance aspects of the licensee activities on the selected systems over an
extended period of time.
A concentrated effort is made to evaluate the
ability of the licensee to integrate these activities, over a several year
period, in a manner which assures proper system performance under all
operational and analyzed accident conditions.
Overall Conclusions
The team determined that management control of engineering work at the Trojan
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plant needs improvement and that your engineering organization does not have
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an effective system for maintaining and utilizing the design basis of the
plant. The team also observed weaknesses in your design control process
which: (1) allow errors in design modification activities to go undetected and
(2) fail to ensure that necessary design related parameters are properly
factored into station operating documents.
Specific examples where poor
engineering work and weak management control of the engineering disciplines
were identified by the inspectors and resulted in significant safety issues
being raised included:
1.
Testing of plant safety systems that did not adequately confirm system
design requirements.
Inadequate testing of a system reduces the overall
assurance that the system will perform its' safety function under all
postulated conditions.
2.
Deficiencies and errors in documents associated with modifications of the
Component Cooling WLter system, which led the team to initially que. G n
the operability of the system.
Although the team later independently
determined that many of the errors cancelled each other out or were not
of sufficient significance to affect operability, the team concluded that
the number of engineering errors observed was indicative of weak
management control of engineering work.
3.
Lack of available documentation of the design basis of the Component
Cooling Water system, which resulted in your engineering organization
being unable to adequately address team questions during the inspection
concerning the performance requirements of the CCW system interface
valves and surge tanks.
4.
Plant operating and training procedures which had not been properly
revised to reflect plant design modifications.
In some instances, these
deficiencies involved procedures for responding to emergencies.
During the exit meeting, the team also noted that recent reviews initiated by
your Quality Assurance organization in areas other than those reviewed by the
team have resulted in findings which appear to confirm similar conclusions to
those noted above.
Furthermore, your access to and use of plant design basis
information and your overall engineering performance have been previous topics
of discussion at several recent management meetings between NRC Region V and
Portland General Electric.
Mr. Lindblad acknowledged the team's conclusions
and explained Portland General Electric's program to correct these
deficiencies.
We understand that this program is intended to:
1) review and
update the design basis information and calculations associated with plant
safety systems and bring this information together into an accessible,
controlled format; 2) review the operation, maintenance, surveillance, and
training activities associated with plant safety systems, and confirm these
activities reflect design basis information; 3) review the performance of the
corporate engineering organization by an outside consultant.
The corrective
action program, as explained appears to be a reasonable approach to address
the areas of weakness noted.
Overall, the team findings reinforce the need
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for you to aggressively follow through with these actions. We strongly
encourage you to assign the highest priority possible to your efforts to
improve your performance in this area.
We further request that, in addition
to your response to the enclosed Notice of Violation, you provide a detailed
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written description of your action plan. We anticipate periodically meeting
with you and your staff to discuss the status of your actions.
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.
The responses directed by this letter and the attached Notice are not subject
to the clearance procedures of the Office of Management and Budget as required
by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be glad to
discuss them with you.
Sincerely,.
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.F. Ki sch, Director y
Division of Reactor Safety and Projects
Enclosures:
1.
Appendix A, Notice of Violation
2.
Inspection Report No. 50-344/86-23
cc:
W. S. Orser, PGE
J. W. Durham, Esq., PGE
W. Dixon, DOE
bec w/ enclosures:
RSB/ Document Control Desk (RIDS)
Project Inspector
Resident Inspector
G. Cook
B. Faulkenberry
J. Martin
bec w/o enclosure 2:
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