ML20238C663
| ML20238C663 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/23/1987 |
| From: | Chan T Office of Nuclear Reactor Regulation |
| To: | Crutchfield D, Holahan G Office of Nuclear Reactor Regulation |
| References | |
| TAC-66590, NUDOCS 8712310135 | |
| Download: ML20238C663 (11) | |
Text
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NUCLEAR REGULATORY COMMISSION
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December 23, 198/
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Docket No.: 50-344 MEMORANDUM FOR:
Dennis M. Crutchfield, Director Division of Reactor Projects - III, IV, V and Special Projects Cary M. Holahan, Assistant Director for Regions III and V Division of Reactor Projects - III, IV, Y and Special Projects THRU:
George W. Knighton, Director Project Directorate V Division of Reactor Projects - III, IV, V and Special Projects FROM:
Terence L. Chan, Project Manager Project Directorate V Division of Reactor Projects - III, IV, V and Special Projects
SUBJECT:
TROJAN NUCLEAR PLANT - DRAFT SALP REPORT FOR PORTLAND GENERAL ELECTRIC COMPANY (PGE)
Enclosed is the draft NRR input to the SALP Report for Trojan, covering PGE's licensing activities from November I,1986 through November 30, 1987. The report was prepared on the basis of reviewer inputs as well as observations by NRR project management during interactions with PGE personnel. The proposed overall performance of PGE in the functional area of Licensing Activities is Category I.
The rating given in the previous SALP report was Category 2.
Contact:
Terence L. Chan X28997 l
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a December 23, 1987
- George W. Knighton is the SES representative for NRR. 'The NRC SALP Board-meeting for Trojan is scheduled for January 5, 1988. Any comments you may have are requested by December 30, 1987.
original signed by Terence L. Chan, Project Manager Project Directorate V Division of Reactor Projects - III, IV, Y and Special Projects
Enclosure:
T. E. Murley F. J. Miraglia G. W. Knighton C. M. Trammell
, DISTRIBUTION
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Docket No.:
50-344 LICENSEE:
Portland General Electric Company FACILITY:
Trojan Nuclear Plant
SUBJECT:
NRR CONTRIBUTION TO SALP REPORT EVALUATION PEP,IOD: November 1,1986 through November 30, 1067 1.
INTRODUCTION
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A Systematic Assessment of Licensee Perfomance (SALP) is conducted periodically by the USNRC. This report presents the NRR contribution to the overall SALP review for Trojan Nuclear Plant.
It addresses in detail the assessment of the functional area of " Licensing Activities." The other functional areas are also addressed from the NRR point of view for use in the detailed evaluations by Region V, which has responsibility for the final SALP Report for Trojan.
The assessment has been prepared in accordance with the SALP guidance package provided by memorandum from Region V dated December 2,1987. The Region V memorandum incorporates the significant aspects of the NRC Manual Chapter 0516 as attachments.
II. CRITERIA AND
SUMMARY
NRC Manual Chapter 0516 identifies six perfomance criteria with characteristic attributes. Salp performance ratings were provided with the work products prepared by the various NRR reviewers primarily in conjunction with the various licensing actions requested by the licensee. As specified in the Manual Chapter, each of the identified criteria was (Category 1, 2 or 3) based on a subjectively evaluated composite of the characteristic attributes. These work products (mostly safety evaluations) and associated SALP ratings were formally transmitted to the Project Manager (PM) who combined this infomation with his own assessment of licensee performance and, applying judgemental weighting factors, arrived at an overall rating for the licensee.
Most of the licensing amendment requests (License Change Applications -
LCAs) and submittals regarding technical issues which were issued during this evaluation period exhibited an increase in quality and comprehensive-ness, as compared to those which were submitted during the previous SALP period (November 1, 1985 through October 31,1986).
.c Trojan experienced an outage which placed great demands on its management and engineering resources. Five complex technical issues identified during the outage' required resolution prior to restart. Portland General Electric Company (PGE) has demonstrated that it has the potential for producing quality technical products under such circumstances. Although-PGE could improve upon its pursuit to self-initiated the determination of significance, scope and resolution of potential deficiencies,.the NRC recognizes and commends PGE's improvement in this area. Marked.
improvement in management effectiveness and aggressiveness in assuring quality and approach to' resolution of-technical issues, and a renewed.
corporate motivation contributed to this change.
General responsiveness by PGE was high, especially to those issues concern-ing restart. However, timeliness with request to the submission of formal l
documentation on non-restart related issues could be improved.
In applying and balancing the perfome.nce factors as indicated above, the over&11 performance rating for Portland General Electric Company in the functional area of Licensing Activities is Category 1.
III. PERFORMANCE ANALYSIS Licensing Activities Licensing activities were dominated by two major areas during this SALP period: Significant issues identified and resolved during the 1987 refueling outage; and routine license amendment requests and resolution of technical and generic issues.
Five complex technical issues arose during the Trojan 1987 refueling outage that required resolution prio-to restart:
(1) Accumulator Fill Line Failures-(2) Main Feedwater Restraint Failure (3) Main Steam Line Wall Thickness Deficiency (4) Main Steam Support: Design Deficiency (5) Safety Related Feedwater Pipe Thinning The resolution of all. of the above items was enhanced by considerable management involvement. The degree of management.
involvement was also reflected in the aggressiveness in which the resolutions and root causes were pursued, and in the quality and timeliness of the technical submittals. The resolutions of Items 1, 2 and 5 are particularly noteworthy in that the original submittals.
were technically comprehensive and sound, and required minimal additional information.
~ i The staff four.d FGE's original resolution to Item 3 to be technically
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correct but the approach to the resolution to be fundamentally j
misdirected; the staff did not agree with PGE's " mixed code" approach; j
ie., confomance to their Code of Record (ANSI B31.7 Class 2) is demonstrated by analytic conformance to ASME Section III, Class 1 requirements. However, the technical discussion and analyses associated with that approach was significantly comprehensive to provide a basis for pursuing resolution of this issue concurrent with safe power operation.
The staff found, PGE's efforts in resolving Item 4 to be inconsistent.
While the work effort was recognized to be conscientious, many of 4
PGE's technical assertions considered to be viable, could not be substantiated; conclusions were not soundly supported. Although management involvement and responsiveness to NRC concerns were high, the technical resolution to a deficiency whose scope was not fixed,
,, proved to be elusive. There appeared to be inadequate oversight and guidance of consultant activities.
PGE did not ap3 ear to comand a clear understanding of the issue. However, once tie scope was recognized and defined, a well structured, technically sound, and comprehensive resolution was presented.
Given the circumstances of all five issues demanding nearly simultaneous review, PGE's perfomance toward resolving these issues
. ;is commendable. Although electrical generation capacity was adversely affected by the lengthened outage, PGE demonstrated sound judgement toward maintaining plant and public safety.
With regard to license change applications (LCAs), the preponderance of LCAs contained sound technical discussions and acceptable no significanthazardsconsideration(NSHC) discussions. LCAs 148 and 152 are noteworthy in that the original amendment requests contained sufficient infomation for staff review without the need for addi-I tional infomation. On the other hand, LCAs 145, 150 and 159 were deficient in that they did not contain sufficient bases to support the technical conclusions and the NSHC determination.
(LCA145was submitted at the end of the previous SALP period but was not reviewed atthattime).
In addition to these LCAs, supplemental NSHC discuss-ions were also requested for LCAs 124 and 126 since the original submittals (submitted in 1985) were similarly deficient.
Although PGE's responsiveness to the resolution of issues is generally quite high, the timeliness of fomal documentation could be improved.
For example, supplements to LCAs 124, 126, 142 and 145, and a request for applicable inservice testing system drawings based upon telephone resolutions were outstanding for months.
,4 There appears to be effective communication and interaction between the licensing organization and the engineering organization. However, communication between licensing and the operations organization could be improved. Two issues which should not have excluded direct l
involvement of the licensing organization were: extended low operation, and excessive Emergency Core Cooling System (ECCS) powerleakage that resulted in an unscheduled shutdown. The licensing organization could also be more effective if it took a more inquisitive interest in available operational information as it may relate to licensing bases and comitments.
CONCLUSION The overall SALP performance rating for PGE in the functional area of j
Licensing Activities is Category 1.
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Board Recorrnendations The Board recomends that PGE put more emphasis on providing timely followup documentation, increasing effective interface between plant operations and licensing, and continuing its efforts to identify and resolve past deficiencies.
V.
ASSESSMENT OF OTHER FUNCTIONAL AREAS While the primary thrust of this evaluation is focused on licensing activities and the rating assignment pertains only to this functional area, some NRR observations relating to the other functional areas are included. These observations were gained principally from NRR site visitsandreviewofLicenseeEventReports(LERs).
1.
Plant Operations - A casual attitude towards adherence to plant procedures was noted. A lack of inquisitiveness into anomalies, and numerous procedural inadequacies resulting in LERs were also noted.
2.
Radiological Control - Radiological controls were enhanced following the fuel particle contamination event during the outage. Procedures have been revised and enhanced.
3.
Maintenance - Ability to maintain the Contr.a Room Envelope's positive pressure requirement from the HVAC stand >oint is variable. This appears to be caused primarily by a lac c of attention to detail.
4.
Surveillance - No observations.
5.
Fire Protection - A lack of understanding regarding the effects of of fire barrter integrity due to modification was apparent.
Housekeeping practices, however, were generally good.
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Emergency Preparedness - No observations.
7.
Security - The plant security system appeared to be functioning as, designed.
8.
Outages - Outege activities appeared to be well planned and organized.
9.
Quality Programs and Administrative Controls Affecting Safety The conclusions reached in 10 CFR 50.59 evaluations which concluded that prior NRC approval was not required tended to be appropriate.
However, the evaluations themselves (checklists) generally contained insufficient explanation and detail for the PM to conclude that the review was anything more than superficial. The procedures governing 10 CFR 50.59 evaluations and the evaluation requirements themselves need to be upgraded.
- 10., Engineering - A significant effort-to improve the quality of engineering products has been observed. The development and use of Design Basis Documents and improved technical analyses are testaments to this effort.
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VI. SIGNIFICANT OCCURRENCES l
f NRR/ Licensee Meetings, Inspections and Audits - The licensee's a.
presentations were well structured; technical content was appropriate. The licensee was well prepared for these meetings and fared well in the face of questioning. -
A list of all NRR/ licensee meetings is shown below:
l Date Purpose April 8, 1987 Steam Generator Tube Plugging (F*)
Criteria, Bethesda, MD May 18-22, 1987 Environmental Qualification Inspection and Check-Valves l
Inspection, Licensing Actions, Trojan Nuclear Plant and Portland, OR June 16, 1987 Technical Restart Issues, Bethesda, MD July 15, 1987 Main Steam Support Design Verification and Main Feedwater Erosion / Corrosion,Bethesda,MD July 21-23, 1987 Support Design Verification Audit.
San Francisco, CA July 21-23, 1987 Pipe Thinning Task Force, Trojan Nuclear Plant August 20, 1987 Support Design Verification, Betlesda, MD November 12, 1987 Main Steam Wall Thickness Requirements, Seismic Qualifications Program, Component Cooling Water System Requirements, Bethesda, MD November 18, 1987 10 CFR 50.59 Evaluations and License Amendment Applications.
Trojan Nuclear Plant b.
Comission Meetings - None c.
Schedular Extensions Granted - None
e-,a d.
Reliefs Granted May 18, 1987 Inservice Inspection, Nozzle tor Vessel Weld Examination August 25, 1987 Inservice Inspection, Feedwater Piping Hydrostatic Test -
Requirements, e.
Exemptions Granted November 12, 1987 Fire Protection, 10 CFR 50, Appendix R Requirements f.
Orders Issued - None g.
Emergency Technical Specification Issued - None-h.
License Amendments Issued Amendment Number LCA Description 122 113 Revises Reactor Coolant Loop requirements in Mode 3; Control Rod Mechanism surveillance requirements, December 16, 1986 123 141 Revises Emergency Core Cooling System Pump Surveillance Require-ments, slanuary 7,1987 124 127 Revises actuation logic for Component Cooling Water to Reactor Coolant Pump Valves, March 6,1987 125 146 Redefines Limit for Shutdown Rod and Control Rod Insertion Limits, March 20, 1987 126 135 Provides editorial corrections and permits administrative control of valve MD-059, April 2, 1987 127 147 Revises pressure-temperature limits and reactor vessel material irradiation surveillance schedule, April 9, 1987 128 130 Revises " Administrative Controls" regarding PRB responsibilities,
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- Amendment Number LCA Description 129 144 Eliminates containment isolation valve stroke testing mode limit-ations, April 22, 1987 130 134 Revises Condensate Storage Tank minimum volume requirement, April 22, 1987 131 117 Revises reactor trip system and engineered safety features actuation system instrumentation requirements, April 22, 1987
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132 128 Revises Onsite Power Distribution System requirements, July 30, 1987 133 152 Revises steam plugging (F*) generator tube
- criteria, August 7, 1987 134 148 Increases the setpoint tolerance for the pressurizer and main steam safety valves September 1, 1987 135 156 Revises " Administrative Controls" regarding temporary changes.
October 2, 1987 136 155 Provides editorial changes to
" Solid Radioactive Waste".
November 9, 1987 1.
Issues Pending - At the end of this SALP period, there were 10 amendments and 23 other licensing issues under review by NRR.
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