ML20238C760

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Forwards Insp Rept 50-344/87-31 on 870921-1002 & Notices of Violation & Deviation.Util Has Not Consistently Applied Lessons Learned from Industry Experience & Other Plant Events.Increased Mgt Attention Required
ML20238C760
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 12/17/1987
From: Kirsch D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Cockfield D
PORTLAND GENERAL ELECTRIC CO.
Shared Package
ML20238C763 List:
References
NUDOCS 8712310202
Download: ML20238C760 (4)


See also: IR 05000344/1987031

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DEC 171987

Docket No. 50-344

Portland General Electric Company

121 S. W. Salmon Street

Portland, Oregon 97204

Attention: Mr. Duke Cockfield

Vice President, Nuclear

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Gent'emen:

Subject: NRC Inspection of the Trojan Nuclear Plant

This refers to the special team inspection, conducted by Mr. W. .P.

Ang and

other members of our staff on September 21 - October 2, 1987. 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.

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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 and Notice of Deviation, enclosed herewith as

Appendices A and B.

Your response to these notices are to be submitted in

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accordance with the provisions stated in the Notice of Violation and Notice of

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Deviation.

The primary objective of the inspection was to assess the ability of the

Trojan Nuclear Plant to safely respond to a postulated event (s) of a type

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actually experienced at similar facilities.

Inherent in this evaluation, is a

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determination as to how aggressively your staff pursuest industry experience,

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problems, and lessons learned to preclude similar-type occurrences at Trojan.

The secondary objective was to assess the effectiveness of your organization

in the identification, resolution, and prevention of onsite safety significant

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technical problems and deficiencies in plant systems and operations.

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The Instrument Air (IA), Emergency Diesel Generator (EDG) Air Start System and

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the Main Feedwater System were selected as the sample systems for the

inspection. The team used industry experiences with air systems that were

compiled in the USNRC AE0D case study report C701 as a basis for evaluation of

the Trojan air systems. The inspection plan also included a review of

engineering work and design basis documents related to the selected systeras.

The results from the 1986 team inspection was used as a reference for this

inspection.

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The NRC inspection team found that, although, you have a system for evaluating

events from other plants, your staff has not consistently applied the lessons

learned from industry experience and event from other plants to the Trojan

plant systems. Weakness in instrument air system testing and operation

described in the industry literature was not identified by your staff's

evaluations when similar weaknesses existed at Trojan; i.e. gradual loss of

air test and planned routine system blowdowns. Also it appears that your

failure to implement a comprehensive and effect trending program and root

cause program significantly detracts from your ability to aoply lessons

learned from events at Trojan and identify problem situations before they

manifest themselves in plant transients.

Increased management attention is

needed to ensure more critical evaluations are performed of onsite and offsite

events.

Our 1986 Safety System Functional Inspection Team identified examples of poor

engineering work and weak management control of the engineering disciplines in

the inspection of the Component Cooling Water and Service Water Systems. This

team inspection identified the following similar findings for the IA and EDS

air start systems:

1.

Testing of plant safety systems did not adequately confirm system design

requirements.

2.

Deficiencies and errors were observed in documents associated with

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modifications of the IA System and EDG Air Start System.

3.

Lack of available documentation of the IA and EDG Air Start System design

basis resulted in your engineering organization being unable to

adequately address team questions, such as the adequacy of the sizing of

the accumulators for the AFW Terry turbine steam admission valves.

In light of the weakness identified above, the inspection team concluded that

PGE does not fully understand the design of the Instrument Air and the EDG Air

Start Systems at Trojan. Design engineering personnel did not appear to have

open communication nor adequate interface with the plant staff. Several areas

were noted where engineering involvement in modifications to the Instrument

Air system was poor. The above deficiencies taken together (lack of

understanding the design, poor communications and lack of involvement)

indicates that there is a need to improve the " pride of ownership" of.the

Engineering Department for the design of assigned plant systems.

During the exit meeting on October 2,1987, you and your staff reemphasized

that you had an on-going program to define and maintain the design base for

the Trojan plant. The team's findings again reinforces the need for you to

pursue this program. Also, proper attention should be given to consistently

applying lessons learned from your own experience and from the experience of

others. As discussed in our management meeting on December 1, 1987, your

aggressive pursuit of corrective actions to 13 prove your performance in

establishing and maintaining the design basis for the plant is an important

part of your engineering improvement program. Also, the management meeting

and the team inspection findings reinforced that a viable corrective action

program is highly dependent on your organization's ability to be self

critical. Your improvement _ program in these areas should include a realistic

appraisal of the effectiveness of your present programs and increased

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involvement by your corporate engineering in the improvement to these

programs.

In addition to your response to the enclosed Notices of Violation and

Deviation, we request you provide a detailed written description of your

action plan to address the deficiencies described above and include the

necessary improvements to that plan to ensure successful implementation.

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

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by the Paperwork Reduction Act of 1980, PL 96-511.

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Should you have ar.y questions concerning this inspection, we will be glad to

discuss them with you.

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Sincerely

Yh{

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O.F.Kfrsch, Director

Division of Reactor Safety and Projects

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Enclosures:

1.

Appendix A - Notice of Violation

2.

Appendix B - Notice of Deviation

3.

Inspection Report No. 50-344/87-31

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cc w/ enclosures:

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C. A. Olmstead, PGE

J. W. Durham, Esq., PGE

W. Dixon, DOE

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Resident Inspector

Project Inspector

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J. Martin

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