ML20247C143

Forwards Insp Rept 50-344/89-09 on 890522-0609 & 0719-21 & Notice of Violation.Licensee Generally Implemented Committed Programs to Enhance Understanding & Implementation of Plant Design Basis

ML20247C143
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/29/1989
From:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
Shared Package
ML20247C147	List: IR 05000344/1989009 ML20247C143 ML20247C148
References
NUDOCS 8909130259
Download: ML20247C143 (5)

See also: IR 05000344/1989009

Text

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AUG 2 91989

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Docket No' 50-344

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Portland General Electric Company

121 S. W. Salmon Street, TB-17

Portland, Oregon 97204

' Attention: Mr. David W. Cockfield

Vice President, Nuclear

Gentlemen:

SUBJECT: NRC' INSPECTION OF.THE TROJAN NUCLEAR PLANT

This refers to the special' announced inspection conducted by Messrs. Narbut,

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Wagner, Burdoin. Clark and Hon, of this office, and NRC contractors Messrs.

Haller, Houghton, and Jew, on May 22 through June 9 and a followup inspection

by Mr. Narbut on July 19 through 21, 1989. The inspection was related to

activities authorized by NRC License No. NPF-1. At the conclusion of the

inspection, the findings were discussed with you and other members of your  !

staff on June 9 and July 21.-1989.

Overview and Summary

This' inspection was an overview of your own Safety System Functional )

Inspection (SSFI) to determine your effectiveness in identifying and 1

correcting design vulnerabilities. Additionally, the team examined your

progress in the design-basis document program and in related committed ,

programs for. engineering procedure improvements, technical manual updating,

drawing updating and certain specific design documents such as the updating of

thequality-relatedlist(0-List).

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In order for the inspection team to adequately review these prngrams, the team

performed an abbreviated independent SSFI type inspection on systems that had

been previously reviewed by your programs. The SSFI

reviewed included the Control Room Ventilation (riVAC) packages

System that were

and 120 VAC

preferred power system.

In assessing the associated systems and modification packages, the team

focused on the design basis of the systems and the ability of the engineering

staff to evaluate and maintain the design basis, when modifying the systems

and during system operations. The team evaluated the actual implementation of

the design basis through maintenance, surveillance, testing, and plant .

operational aspects associated with the selected systems. '

The team inspection findings and recent events at the Trojan Nuclear Power

Plant indicate that the expectations of PGE management are not being fully

carried through by the licensee's staff and supervisors. Examples identified

by the team include incomplete implementation of design change actions,

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AUG 2 91933

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. unrecognized effects of remote control building doors on control room pressure

and unrecognized problems with ventilation duct s- Torts requiring rework for

operability. Additionally, incomplete evaluation of hydrogen hazards was

identified by an NRC chemistry team, and debris in the containment

recirculation sump and subsequent incomplete cleanliness and. design

verification of the sump was identified by the resident inspectors. The most

disturbing facet of these problems is that PGE management systems are not

identifying these problems. Accordingly, we urge you to give additional

attention to strengthening your management systems to ensure they function

properly and identify and evaluate problems for prompt resolution.

Team Findings

The team found that the licensee had generally implemented the committed

programs to enhance the understanding and implementation of the plant's design

basis. The licensee had developed design basis documents in accordance with

its schedule and had taken other actions (such as having an independent

outside contractor review critical calculations for completeness). The

licensee described additional actions planned to increase the involvement of

engineering personnel in plant activities, including the movement of the

entire engineering staff to the site in August 1989.

The inspection of the systems and modification packages identified a number of

d:fi t :f:: :.d raised significant questions. The team's findings indicate

three areas of weakness which are sumarized as follows:

The engineering and site organizations have been slow to recognize and

deal with problems

Self-revealing problems of control room positive pressure being adversely

affected by remote auxiliary building fire door positions were evident in

event reports in 1987, but were not dealt with until the team inspection.

Likewise,' problems with new inverters causing frequency swings on 120

volt vital AC power buses were identified in 1987, after installation,

but were not thoroughly assessed until the team inspection.

Engineering work has been incomplete

Relatively recent design change work performed by Portland General

Electric (PGE) was found to be incomplete. Examples' include: failure to

account for 480 volt load additions to the vital buses when adding a

supplemental control room ventilation system; failure to assess the

impact of new inverters on the vital DC system; and failure to recognize

and evaluate the possible consequences on the emergency control room

ventilation system of a possible tornadic missile from a roof-mounted

chiller.

Engineering-to-site coordination needs improvement

Essential operating documents have not been consistently provided or l

updated to reflect completed design changes. Examples include failure to

provide a ventilation flow diagram for a supplemental control room

ventilation system, failure to update annunciator response procedures for

120 volt vital AC power, and installed ventilation supports did not match

design drawings.

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AUG 8 91983 i

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l With regard to the conduct of your SSFI program, we are encouragea that you

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have undertaken this initiative. The team noted, h wever, t only one such

SSFI was conducted thus far, and that it was conducted by cuatractors with

little licensee support, due to an unplanned outage. Your contracted SSFI,

though limited in scope, uncovered a number of important findings; which at the

time of our inspection were, largely, still unresolved. Therefore, we

encourage you to aggressively continue your efforts to conduct additional such

inspections and to apply the lessons learned from your first experience. When

properly conducted and followed, we cor. sider this type of effort to be of

value in identifying problem areas, before those problems becoming

self-revealing.

With regard to the development of der,ign bases documents, we are encouraged

that you have undertaken this initiative. Our inspection indicated that your

efforts to date were primarily directed at the reconstitution of existing

design bases information; but, your efforts have not been systematically j

directed toward ensuring that design basis information is complete, sound, and

fully implemented (i.e., that design vulnerabilities and implementation

errors are identified, understood, and appropriately addressed). This was

made clear by the fact that extensive rework was necessary for ventilation

supports, as a result of our review of your original design calculations.

Additionally, we determined that some design basis documents have not been

updated to reflect recent design changes. We understood that maintaining the

design basis documents was intended to be part of your program to ensure

design bases are properly implemented. We encourage you to continue your

development of design basis information, particularly those aspects which will

identify design vulnerabilities and implement corrective or compensatory

measures successfully such as comprehensive walkdowns.

Based on the results of the inspection, it appears that certain 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 stated in the

Notice.

In addition to the response directed by the enclosed Notice, please provide a

written response discussing your management plans regarding your systematic

efforts to identify and resolve design vulnerabilities through future SSFI's

or other processes.

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 enclosed Notices are not subject j

to the clearance procedures of the Office of Management and Budget as required l

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

Should you have any questions concerning this inspection, we will be pleased

to discuss them with you.

Since ely,

'Enk

John B. Martin

Regional Administrator

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AUG 2 9123 -

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[ Enclosures:-

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-I. Appendix A (Notice.of Violation)

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2.; Inspection Report No. 50-344/89-09

cc w/ enclosures:

T. D. Walt, PGE'

C. P. Yundt, PGE-

, L.'A. Girard,.PGE

W. Dixon, DOE-

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Enclosures:

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. 1. Appendix A (Notice of Violation)

2. Inspection Report No. 50-344/89-09

cc w/ enclosures: bec w/ enclosures: bec w/o enclosure 2:

T. D. Walt, PGE Project Inspector J. Martin M. smith

C. P. Yundt, PGE Resident Inspector A. Johnson J. Zollicoffer i

L. A. Girard, PGE docket file N. Western

W. Dixon, DOE R. Nease, NRR l

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