ML20247C280

Responds to NRC Re Violations Noted in Insp Rept 50-344/89-18.Corrective Action:Reevaluation of OAR 87-29, Involving Mods to Hydrogen Gas Supply Sys Implemented as Part of 1989 Refueling Outage

ML20247C280
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	09/08/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8909130302
Download: ML20247C280 (4)

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Portland General BectricGnipiny David W. Cockfield Vice President, Nuclear September.8, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission

. ATTN:, Document Control Desk

~ Washington DC 20555 Deac Sir:

1 Reply to a Notice of Violation Your letter of August 3, 1989 transmitted a Notice of Violation associated with' Nuclear Regulatory Commission Inspection Report 50-344/89-18.

Attached is our reply to that Notice of Violation.

Sincerely, O

EV Attachment c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant l 8909130302 890906 [EC'/

PDR ADOCK 05000344 Q FDC fg 121 S W Caiman Sveet. Portrarvi Oregon 97204

'b Trojin Nucle r_ Plent Docum:nt Control D:sk

. Docket 50-344' September 8, 1989 License NPF-1 Attachment Page 1 of 3 REPLY TO A NOTICE OF VIOLATION Violation

. Title 10 to the Code of Federal Regulations, Part 50 (10 CFR 50),

Appendix B, Criterion XVI, " Corrective Action", provides in part that:

"Heasures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, defi-ciencies, deviations, defective material, aad equipment and nonconformances are promptly identified and corrected . . ."

Contrary to the above, as of April 21, 1989, corrective actions had not been taken to evaluate and correct design deficiencies in the hydrogen gas supply system which were identified and documented on an Operational Assessment Review (OAR) Form (OAR-87-29), dated May 3, 1987, in response to Nuclear Regulatory Commission (NRC) Information Notice No. 87-20,

" Hydrogen Leak in Auxiliary Building".

This is a Severity Level IV violation.

Response

Portland General Electric (PGE) acknowledges the violation.

1. Reason for the Violation:

The unacceptable delay in evaluating NRC Information Wotice 87-20 and providing appropriate corrective actions was caused by weaknesses in the Operating Experience Review Program (OERP). The identified weaknesses are:

a. The OERP does not address tracking of OARS and resolving management comments made on evaluations during the approval process, so as to resolve any comments and continue the approval process.

b. The OERP does not procedurally require timely evaluations

(<90 days).

c. The OERP does not provide for direct management involvement in ensuring Prompt evaluation and incorporation of industry operating experience.

Management comments on the initial evaluation of NRC Information Notice 87-20 were not resolved in a manner that would allow timely approval and implementation of corrective actions. The reevaluation I _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ _ -

.s Trajcn Euclear Plcnt Document Control Dask Docket 50-344 September 8,'1989 License NPF-1 Attachment Page 2 of 3 of OAR 87-29 was assigned to a department other than the original evaluation department in order to resolve management comments.on the proposed corrective actions. Once assigned for re-evaluation in December 1987, the OAR was given a low priority and was not completed until March 1989. Inadequate management attention was given to the i: completion of the overdue action to complete the evaluation.

2. Corrective Steps Taken and Results Achieved:

The specific corrective actions of reevaluated CAR 87-29, Which involved modifications to the hydrogen gas supply system, were implemented as part of the 1989 refueling outage.

0AR 87-29 was reopened. The new evaluation included NRC Information Notice 89-44, " Hydrogen Storsge on the Roof of the Control Room". The evaluation is complete and is in the management approval process.

PGE previously recognized the need to improve the timeliness of evaluating operating experience feedback and implementing corrective actions. Prior to receiving this. Notice of Violation PGE had implemented the following changes to the OERP and process to improve the timeliness in evaluating and correcting deficiencies:

a. The OERP Coordinator maintains a status record of open OARS and is now issuing a monthly report of those OARS which have been in evaluation for greater than 180 days.

b. 0AR evaluations and corrective actions are tracked by the Commitment Tracking List (CTL), Which is administered and controlled by the Nuclear Safety and Regulation Department (NSRD). Evaluations or corrective actions for all CTL items, including those associated with OARS, Which exceed the due dates are shown as overdue on the CTL. Management receives monthly printouts highlighting overdue items.

These actions are adequate to prevent recurrence of the identified violation.

3. Additional Corrective Steps That Will Be Taken to Avoid Further Violations:

The OAR 87-29 corrective action to revise Topical Report PGE-1012,

" Fire Protection Plan", to address hydrogen leakage in the Auxiliary Building, will be completed in the next amendment to PGE-1012 which is scheduled to be issued by December 29, 1989.

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Trojcn Nucleer Plant Docum:nt Control Dank L Docket 50-344 September 8, 1989 License NPF-1 Attachment Page 3 of 3 PGE Topical Report PGE-1044, " Operating Experience Review Program",

and Nuclear Division Procedure (NDP)-100-13. " Operating Experience Evaluation", will be revised. These revisions will include changes to address the following:

a. A method will be developed and specified to address management comments on an evaluation in the approval process. This change will ensure management comments are resolved and incorporated into the evaluation so that the evaluation and corrective actions can be approved and implemented without delay.

b. The time to complete OARS will be specified as 90 days. Eval-uations that cannot be completed within 90 days will require approval from the cognizant General Manager.

c. Monthly feedback on overdue OARS and those approaching evaluation deadlines will be provided to management.

There revisions will be completed by December 29, 1989.

A review of the effectiveness of the OERP will be conducted by the Quality Assurance (QA) Department. The completion of this review is scheduled for March 31, 1990. The criteria delineated in INPO 89-005,

" Guidelines for the Use of Operating Experience", will be utilized for this review.

4. Date When Full Compliance Will Be Achieved:

Full compliance will be achieved with regard to OAR 87-29 following completion of the corrective action to amend PGE-1012 and completion of management review of the reopened OAR. PCE-1012 will be revised and issued by December 29, 1989. Management review of the reopened OAR will be completed by October 31, 1989. PCE-1044 and NDP-100-13 will be revised and issued by December 29, 1989.

RMN/DRS/KLB/bsh 3530W.0889 I

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