ML20246M577

Forwards Status of Progress in Achieving Improvement Goals Identified in 890515 SALP Response Re Safety Assessment/ Quality Verification.Addl Resources Applied to Qualify commercial-grade Suppliers

ML20246M577
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/31/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8909070200
Download: ML20246M577 (12)

Text

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.. em PbrtlandGeneralBectricCcivisiy Q David W. Cockfield Vice President, Nuclear August 31 1989 Trojan Nuc1 car Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

1988 Nuclear Regulatory Commission (NRC)

Systematic Assessment of Licensee Performance (SALP)

'By letter dated May 15, 1989 Portland Ceneral Electric Company (PGE) pro-vided a response to the NRC SALP Board' evaluation of safety performance at the Trojan Plant for the period from December 1,1987 through December 31, 1988. The response addressed concerna identified in the SALP report in the functional areas of Security and Safety Assessaent/ Quality Verification.

A number of major changes had just been implentented in the Nuclear Quality Assurance Departitent (NQAD) at the tima this SALP response was submitted.

To demonstrate the results achieved, PGE committed to providing a followup.

report by August 31, 1989.

Attached please find a status of PGE's progress in achieving the improve-ment goals identified in the May 15, 1989 SALP response in the area of Safety Assessment / Quality Verification. The attachment is formatted to provide the' original response, with a status for each item.

Sincerely,

/

MbC p/ - f l, Attachment 4 c: Mr. John B. Martin MO Regional A6ministrator, Region V Q81 U.S. Nuclear Regulatory Commission l OO

$$ Mr. David Stewart-Smith o.g State of Oregon g Departnent of Energy O Cr

[ Mr. R. C. Bare g NRC Resident Inspector [M

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Q, Trojan Nuclear Pla.a.

121 S W Saimon St eet. Pomand. Gregan 97204

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% .'. Trojan Enc 1ccr Pitnt ' Document Centrol' Desk ]

August. 31, 1989 j

. Docket 50-344

' License NW-i Attachment  !

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SAP'ETY ASSESSMENT /0UALITY VERIFICATION

'l. Concern: The quality organizations appeared,to be.insulfleiently involved in the review of evento and Plant problems, and were not providing independent ~ verification that manage:nent policies were being successfully implemented.

Improvement Goal: Quality organizations will actively participate in the review of events and Plant problems and provide independent verification that management policies are implemented.

Improvement Plan:

a. The Performance Monitoring / Events Analysis (PM/EA) group has actively participated in the review of. events in order to verify.

quality of the responses. Nuclear Quality Assurance Department (NQAD) is now participating more actively in the event report process, including attendance at event report critiques, and in the examination of Plant problems. NQAD involvement in recent Plant problems, such as Containment electrical penetrations, has resulted in the identification of additional technical. concerns-which are being evaluated and resolved by the appropriate line organizations.

b. NQAD will review adherence.to management policies and NRC commitments during scheduled audits and surveillance. Senior PGE management expectations are that audits and surveillance will go beyond determining if minimum compliance is being achieved,'and will be a means to ensure that managenent expec-t6tions are carried out in every aspect of Plant operation.

Statos:

a. Ongoing.

NQAD is playing an increased role in the identification and review of Plant problems and concerns. Some recent examples include the identification of debris in the Containment recir--

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culation sump, review of the Containment electrical penetration corrective actions, and the identification of inadequately

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latched reacter trip breakers. Additionally, effective September 1, 1989, the PM/EA group will report to the NQAD General Manager to enhance NQAD's technical capabilities.

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+ Trojan Nue1 Car Plant Document C:ntral Desk Docket 50-344 August 319 1989 Licensa NPF-1 Attachment page 2 of 11

b. Ongoin6 UQAD is reviewing adherence tn management policies and Nuclear Regulatory Commission (NRC) commitments for compliance during inspections, audits and surveillance <. Future inspections,

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audits and surveillance will continue to include these items.

2. Concerrg: A Quality Control (QC) inspector observed a nonconforming maintenance activity and did not document the observation as required by NQAD proceJures. procedural compliance had been a major

oncern in the last EALP. l Improvement Goal: Achieve a clear understanding by all personnel of the management expectations for procedural compliance.

Inmrovement Plan: Specific actions for the QC inspector incident were identified in PGE's response to Notice of Violation dated January 11, 1989. Additional actions include:

a. Procedural compliance expectations were strested by Plant and QA management during the Genere.1 Employee Retraining sessions in 1989.

b. Memoranda to and meetings with NQAD personnel have emphasized that any observed procedural noncompliance will be documented and corrected. Recent Quality Inspection Observation Reports and Nonconforming Activity Reports (NCARs) indicate an increased attention to procedural compliance concerns.

c. Nuclear Division managers and supervisors are bein; held accountable to assure their personnel comply with procedures.

Status:

a. Complete.

b. Ongoing.

Attention to procedural compliance by NQAD personnel and by line organization management and supervision has improved. This is ,

evidenced by trending information for the first half of 1989, which shows that an increased number of procedural compliance problems have been identified in the corrective action system.

It is anticipated that the incidence of procedural noncompliance will decrease during upcoming trend periods as management continues to focus on this issue.

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Docket 50-344- August 31 1989 iS  ? y? ' Attachments

.Licenas NPF -Page 3 of'11' j-

c. ongoing.

See b, above.

L 3. Concern: Audits in the' areas of engineering, instrument control, OY . health physice and radiological controls (areas where a lack of experience is perceived) were frequently compliance. based.

Improvement Goal: Develop a performance-based audit and surveil-lance program utilizing experienc6d = personnel.

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improvement Plan: ,

a.~.In February 1989, 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> of Plant-specifi3 training on p performance-based audits and surveillance was provided to NQAD managers, supervisors and auditors.

b. A recent audit,cf Mechanical Maintenance used performance-based concepts; this technique is'being applied to ather areas in 1989.

c. The QA audit procedure is being revised to shif t the focus of audit s from-reviewing documents to reviewing activities impor--

tant to safety.and reliability. This will ensure continued use of performance-based' concepts in future audits,

d. Several staffing changes have been made in VQAD to strengthen

-expertise in engineering, instrument control, health physics and radiological controls. Details are provided in Item 9, below.

Status:

a. Completo,

b. Ongoing.

Performance-based techniques have been used in a number of audits including Plant Systems Engineering (PSE), Health Physics, Training, outage-related refueling activities, and Technical Specifications. Examples include observations of Systems Engineering *s contribution to the solution of Plant problems (PSE audit), observation of fleid sampling techniques for adequacy (Health Physics), and observation of the implemen-DL tation of on-the-job training (Training).

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<8 lL Trojen'uuclear Pltnt= Document C:ntrol Desk Docket 50-344 August 31, 1989 License apF-1 Attachment page 4 of 11

!c. Complete.

The QA audit procedure was issued in March 1989 to reflect the use of performance-based auditing techniques consistent with NUREG/CR-5151, " performance-Based Inspections".

d.- Oncoitag.

See Item 9, below.

4. Concern: Significant deficiencies were identified in the procure-ment program, in that it allowed the use of commercial-grade replacement pipe in the Main Feedwater System without validating the supplier certified Material Test- Reports, and existing procedures for dedicating commercial-grade products for use in safety-related applications were not appropriately implemented. NQAD failed to prevent this, although presented with several' opportunities.

Improvement Goal: . Ensure required levels of quality are applied to materials used in safety-related cervice by use of qualified sup-pliers, receipt inspection, and testing.

' Improvement plan:

a. Responsibility for the procurement procedures was transferred to the' Material Services Manager in December 1988 to allow NQAD to conduct a more independent. assessment of the erogram, instead of directing its implementation.

b. procurement documents are now prepared by a dedicated procure-ment engineering. group. Dedicated personnel have been assigned

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within NQAD to review procurement documents. In-depth NQAD reviews of material engineering evaluations (MEES) are also being performed. MEE reviews include physical verification and documentation of component attributes identified as critical characteristics.

c. Additional resources hnve been applied to qualify commercial-grade suppliers. A review of evaluations approving commercial-grade suppliers, as well as higher quality code suppliera.-is in progress to ensure that all approved vendors meet applicable requirements. Several deficiencies have been identified and corrected.

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. i Trajrn Nucice.r Pl:nt Docum:nt central Desk Docket 50-344' lugust 31, 1989 'j License.NPF-l' Attachment Page 5 of111 d.- [A materials l t'esting program will be initiabed by August 1989 for verification of commercial-grade material. Materials testing activities 'are currently being specified with each procurement, as needed.

Status:

a. ' Complete.

The procurement procedures have been revised to reflect a . change in-responsibility for the Material Services Manager, to include the procurement processes and procedures. This change has allowed NQAD to perform' independent verifications of quality ;

related procurement packages, material engineering' evaluations and spare parts equivalency evaluation reports.

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b. Complete.

The Procurement Engineering Branch of the Nuclear Plant Engi-neering (NPE) Department is now performing technical evaluations for all quality-related purchases.and preparing the necessary documentation to assure that critical characteristics of purchased items, as well as material in the warehouse, are verified. NQAD performs in-depth reviews of these procurement-packages,' including physical verification of the material, to ensura procurement document requirements are met and. critical characteristics are verified. This process has been developed to comply with the guidelines specified in Electric Power Research Institute (EPRI) Nuclear Construction Issues Group (NC1G) NP-5652, " Guidelines for the Utilization of Commercial Grade items in Nuclear Safety-Related Applications".

c. Ongoing.

NQAD has initiated an Industrial Grado Suppliers List (IGSL) to document the qualification of commercial-grade suppliers (manufacturers and distributors) with acceptable quality assurance programs. The IGSL was completed by performing approximately 300 commercial-grade surveys at supplier facilities.

l These surveys have identified several suppliers with inadequate L quality assurance programs. A review of part purchase agree-ments placed with these suppliers is underway. No instances of installation of safety-related material procured from these

i. suppliers have been identified thus far. A review of the l- surveys' approving commercial-grade suppliers, as well as other

Trojari Nucler p.Itnt Docum:nt Control Desk Docket 30-344 August 31, 1989 License NpF-1 Attachment .

Page 6 of 11 4

l evaluated quality-related material suppliare, la in progress to ensure that all approved suppliers meet applicable require-ments. This review is scheduled to be completed by December 31, 1989.

d. Ongoing.

The material ens;,ineerins evaluation process identifies the critical characteristics of concercial-grade material. These critical characteristics are verified by performance of document reviews (in the case of suppliers on the IGSL), physical inspection and materials testing. Material testing includes onsite verification of hardness of metals and elastomers on a statistical sampling basis, as well as offsite chemical and physical testing of materials. A program to perform additional onsite testing of commercial-grade items, as well as other gaality-related materials, is being developed. Development of this program will be completed by October 31, 1989, and implementat.lon will begin on or before January 1, 1990.

5. Concern: Inaccurate information was provided to NRC management in a procurement-related presentation.

Improvement Goal: provide accurate information at all times.

Improvement plan: ..

a. Disciplinary action was taken with the individual responsible for conveying unverified information to the NRC. He has since j accepted a position outside of the NQAD.

b. The importance of properly verifying information as well as the consequences of providing inaccurate information to the NRC has been emphasized to all personnel.

Status:

a. Complete.

b. Ongoing.

NQAD has continued to stress the importance of providing complete and accurate information. For example, during the NQAD l staff meeting held on August 28, 1989, it was emphasized that letters to the NRC must not only be accurate, but must also contain information that is important and relevant to the j subject being addressed.

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Page 7'of 11

-6. .Coacern: Until recently, a program to trend' plant events, Non-g ,conturmance Reports.(NCRs) and NCARs did not exist. A program was implemented in January 1989 by NQAD to track and trend various

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L elements of the licensee's corrective action programs.

Improvement Goal: . Effectively use' deficiency trending'to identify

' recurring problems.

, Improvement Plan:

a. ' Programs for trending of NCRs and NCARs have been in existence since 1975. Since past trending methods have not been effective in identifying some recurring problemsg a'new NCAR trending program was' implemented by NQAD in January 1989.

b. This new NCAR-trending program includes a database keyed on subject / topic to supplement the current root cause database and allow more. timely identification of recurring events. j

c. A major revision of the corrective action programs will be completed by December 31, 1989, and will include a common data base to allow identification of problems recurring in the various systems (Event Reports, Nonconforming Activity Reports, Nonconformance Reports, etc.).

d. NCAR/NCR trending information is being'more effectively used to communicate' performance and compliance concerns with line management. The trending,information will continue to have more impact as line management's understanding and use of the infor-mation improves.

Status:

a. Complete.

b. Complete.

c. Ongoing.

A draft of the revised corrective action program procedure is in the review stage. The revision to the procedure is still sene-duled for completion by December 31, 1989,

d. Complete.

NCR/NCAR trending continues to become more effective as a tool for identifying recurring Plant problems t9 line management.

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Trojan . Nuclear. Plant ~ Document Control Desk k % SI <

DocketT50-344 August-31,.1989-pLicense NPF-1 Attachment Page 8 of 11.

L n The first semiannual trend report for the first half of 1984 is

' currently being reviewed. This trend report will present the new trend format and coding in an improved, understandable.

format for management..

7.- Concern: The quality organization's non-conservative approach to problems and inadequate root cause/ problem resolution efforts were a.

major contribution to a decreased performance rating.

Improvement Goal: Meet and exceed regulatory requirements and-

. industry standards for. quality.

1 Improvement Plan:

r-Principles and standards of NQAD operation have been promulgated

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a.

to NQAD personnel, including avoidance of minimum compliance approaches.

b. NQAD personnel are taking a more rigorous and conservative approach in evaluation of root causes and corrective actions.

This is'particularly evident in NQAD involvement with the NCR/NCAR process. Incomplete evaluations and/or corrective

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actions are being rejected by NQAD and returned for rework.

Status;

a. Complete.

b. Ongoing.

NQAD management involvement in the NCAR and NCR Program will continue to ensure prompt identification of problems, root causes and implementation of corrective actions,

8. Concern: The NQAD and Plant management have had only limited success in dealing with major recurring Plant problems.

Improvement Goal: Prevent recurring problems.

Improvement Plan:

a. The NQAD staff has implemented action to involve higher levels-of management in cases of inadequate corrective actions and in providing more timely resolution of deficiencies, c

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b. 'The'NQADI. staff performs real time' trending-of deficiencies and; informs responsible management-of developing trends for each

, . deficiency-so that corrective action can be taken,

c. NQAD has become more assertive in reviewing the. adequacy of problem evaluations and corrective actions to ensure that all.

causes have been identified and that generic implications have

-been~ adequately addressed.

Status:

.a, b, c. Ongoing.

Real-t'ime trending, combined with semiannual trend reports, i provide a valuable management tool for the identification of plant problems. Improved communication between NQAD and Plant staff and management has also resulted in a better understanding and~ increased awareness of problem areas. In. addition, begin-ning in the third-quarter of 1989, NQAD will prepare for line

-organizations and the Trojan Nuclear Operations Board a quar-terly report which identifies emerging or unresolved issues.

9. Concern: The licensee should thoroughly examine the NQAD and strengthen weaknesses. The experience level of the QA organization requires strengthening.

-Improvement Goal: Assess the functions, staffing, and, experience of the NQAD and make necessary changes. Improve the experience level of the department through the selection of personnel experienced in areas other than'QA,-and provide training to current personnel.

Improvement Plan:

a. In April 1989, a number of staffing changes were implemented:

(1) An individual with experience in licensing and compliance was appointed the Branch Manager for Quality Assurance Operations and also the Acting Quality Assurance Manager.

(2) An experienced Trojan manager with Quality Assurance back-ground was appointed as Quality Support Branch Manager.

g Docum:nt Contral D3ck Trajcn Nucl33r Pltnt Docket 50-344 August 31, 1989

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License NPF-1 Attachment

.Page 10 of 11 (3) The Performance Monitoring / Event Analysis Manager has been transferred.into NQAD for a two-month period (prior to a one-year assignment to INPO). He will be the acting Quality Operations Branch Manager.

(4) A Nuclear Engineer with experience in safety analysis.and regulatory issues was appointed as Audit Supervisor.

(5) An Electrical Engineer, Hechanical Engineer and Radiation Protection Engineer were added to the Audit staff.

(6) An experienced Instrumentation and Control (I&C) technician was contracted for I&C field observations.

In addition, other staffing changes are currently in the process of being implemented to further supplement the experience level of the NQAD.

b. To ensure that the NQAD develops into an engineering and technical-based organization, existing and new NQAD engineers, specialists and supervisors will be enrolled in the accredited Technical Staff Training Program.

c. NQAD will continue to supplement audit teams with appropriate technical personnel from outside the department.

Status:

a. Ongoing.

(1) A new NQAD General Manager has been hired with previous experience in quality assurance, engineering and regulatory issues.

(2) Quality Operations Branch has added a new mechanical engi-neer with extensive maintenance and reactor engineering experience to serve as the Quality Operations Rover,

b. Complete.

Existing and new NQAD engineers, specialists and supervisors have been enrolled in the accredited Technical Staff Training Program.

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Trajen Eucle:r Plent Document Control Dask Docket 50-344' August 31, 1989 License NPF Attachment Page 11 of 11

c. Ongoing.

Ten technical experts have been used to date on eight audits.

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Audits using technical advisors include: Technical Specifica-tions, Health Physics, Training, Chemistry, Corrective Action, Security and Plant System Engineering audits. The remaining 1989 audit schedule also contains provisions for technical experts in the areas of Maintenance [ Electrical and Instrument and Control (I&C)], Fitness-for-Duty and Nuclear Safety and Regulation- NQAD will continue to use technical experts in appropriate audits and is currently evaluating the use of tech-nical experts in the surveillance, inspection and observation programs.

RMN/SAB/PGN/mr 3525W.0889 1

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