IR 05000344/1989022

Enforcement Conference Rept 50-344/89-22 on 890831.No Violation Noted.Major Areas Inspected:Nrc Concerns Developed as Result of Special Insp Rept 50-344/89-19

ML20247H747
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/31/1989
From:	Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20247H744	List: IR 05000344/1989022 ML20247H740
References
50-344-89-22-EC, NUDOCS 8909200085
Download: ML20247H747 (25)

Text

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,s - U. S. NUCLEAR REGULATORY COMMISSION

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REGION V-

. Report No. . 50-344/89-22

, Docket No. 50-344 License No. NPF-1

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Licensee:: Portland General Electric Company 121 S. W. Salmon Street

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Portland.. Oregon 97204 Facility Name: . Trojan Nuclear Power Plant Meeting at: PGE Corporate Offices, Portland, Oregon

Report Prepared by: J. F. Melfi, Resident Inspecto Approved by: ' *

Me- M*d7 M. M. Mendonca, Chief Date Signed-Reactor Projects Section 1 Meeting Summary:

Meeting on August 24, 1989 (Report No. 50-344/89-22)

~An enforcement conference / management meeting was held in the PGE Corporate

- Office, Portland, Oregon, to discuss NRC concerns developed as a result of a Special Inspection (Report 50-344/89-19), and to discuss licensee corrective actions. For.each area of concern, licensee corrective actions were discussed as outlined in the enclosure to the repor f.[,k92gg,p,{}$[,[,

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. ~ Meeting Attendees

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a.- Licensee Attendees

+ W. J. Lindblad, President D. W. Cockfield, Vice President, Nuc! ear '

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C. P. Yundt, GeneralLManager, Trojan ,

D. W. Swan, Manager, Technical: Services "

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. .~ T. D. Walt, General Manager, Technical Functions

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t C..K.l Seaman, Manager, Nuclear Quality Assurance

'D.'t...Nordstrom. Branch Manager, Quality Operations-

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R. P. Schmitt, Manager, Operations and Maintenance

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R. E.' Susee, Manager, Work Planning and Control A.: NL Roller, Manager, Nuclear Plant Engineer

'J. A. Benjamin, Supervisor, Quality Audits-G. D. Nicks, General Manager, Plant Support

. M. W. Hoffman, Branch Manager, Mechanical Nuclear Plant Engineering

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' R. M. Nelson, Manager,' Nuclear Safety and Regulation Department 1 S.:A. Bauer, Manager, Nuclear Regulation Branch

? J. P.LFischer, Branch Manager, Performance Monitoring / Event Analysis R.;Frankenbach, Public Information Representative'

u J. D. Guberski, Compliance Engineer

.D. L.,Bennett, Maintenance Manager-

' ,NRC' Attendees

J.'B.-Martin, Regional Administrator

'A'.-E. Chaffee, Deputy Director, Division of Reactor Safety and Projects M. M. Mendonca, Project Section 1, Chief R. C. Barr, Senior Resident Inspector, Trojan J. F. Melfi', Resident Inspector, Trojan R. B. Bevan, Project Manager, NRR A. D. Johnson, Enforcement Officer B. Clayton, Section Chief, Regional Office Staff Office of the ED0

. N.-Cook, Senior Region V Public Affairs Officer . State of Oregon Attendees D. V. Yaden, Director, ODOE D.. Stewart-Smith,' Acting Administrator, ODOE H. F.'Moomey, Manager of Reactor Safety, ODOE

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A. Bless,--Resident Inspector, ODOE

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' Bonneville Power Administration D. L. Williams, Nuclear Engineer J

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-_Mr. Martin opened the meeting by stating the purpose of the enforcement L conference was for both PGE and NRC to have a common understanding of the f  :. safety. significance of debris found in, and inadequate design l . implementation of, the containment' sump, and other recent events. He stated that if there.were any disagreements on the NRC's understanding of;

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the_ issues'they should be clarified in the enforcement conferenc ,,

'" Mr. Chaffee then presented the Regional concerns and understanding of the

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issues; surrounding the debris and . inadequate design-implementation .

issues with the containment sump. 'Mr. Chaffee stated that it appeared

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that without.NRC intervention, it is quite possible that the plant would 4' V be.at fu11Jpower operation today with an inoperable emergency sump. This incoerable condition of the sump most likely had existed since initial plant operation. .The sump was noted to be essential to the operability l}

.of. key safety systems to adequately handle severe accidents.

Mr.-Chaffee then mentioned the concern the NRC had with some of the previous missed opportunities to correct this problem including:

U In 1980,'an.RHR pump was inoperable due to a weld rod blockage

.between the pump impeller and casing. Evaluation of this could have, lead to discovery of emergency sump inadequacie The 1986 evaluation of potential . sump blockage considerations. of Generic Letter 85-22 failed to uncover emergency sump inoperability l Concerns.

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The' Design Basis Document-(DBD) review program failed to identify

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the missing screens through walkdown due to a generic program.

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implementation failur ,

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On July 8,'1988, debris was found in the sump including tools that-were likely from the previous outage. QA had made a . recommendation

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to enhance surveillance procedures which was not implemented as

, dispositioned in January 198 ,

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l- Mr. Chaffee then stated.that most of this was old history except the

- issue on DBD inadequate walkdowns, and the July 1988 event which are

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i relatively recent events. This history indicates how business was

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conducted at Trojan, including the recent past. Mr. Chaffee then stated

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that what was even more telling of how Trojan conducts business recently is-Trojan's poor handling of the 1989 sump debris issues and other i l related issues which would be discussed late Mr. Chaffee stated that NRC perceives a continuing resistance in the PGE

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. organization to dig into and evaluate problems fully. He further stated that NRC sees some improvement, but there is still concern based on the l. : -.following events:

U Failure to aggressively correct an inoperable rod deviation alarm after a rod drop event which later contributed to a rod disposition of 24 steps, 12. steps beyond the technical specification limit during startup, in spite of NRC and high level management prompting to correct the original alarm proble l l

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' Failure:to evaluate overheating of the'RHR/CCW heat' exchanger-prior-

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3' to.NRC prompting. ~This eventLoccurred due.to incorrect instructions forLa: heat' soak of the' steam generatorsi and did-result in-exceeding-

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A-the design basis temperature'in the heat exchanger at the time,0f

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e 'w the' event..though subsequent analysis showed that the heat exchanger

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was acceptable 1for continued operation.

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O' - Failure to ensure -that the emergency l sump was operable prior to

entering-mode 4 on July.14, 1989 due=to missed opportunities m -includinsi: failure to ensure complete review

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history;. weak programmatic controlsf and engineering

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weak ,of emergency sump

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involvemen .

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r+ , These events. lead to the impression that there is a continuing need for-NRC involvement to assure aggressive-and thorough' licensee action to' deal-

.with problem Mr; Chaffee th'e n stated-that there is still a major concern with PGE performance ~that demands the licensee's utmost ~ attention. He stated that-the NRC sees three themes to the sump event which are:

(1) The need to enhance the pursuit' and correction of plant problem ,

(2) The'need to enhance engineering involvemen ..

(3): The need to enhance responsiveness to QA concerns.:

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Mr. Mendonca then reemphasized the safety significance of:this event by.

'- . relating the NRC's understanding of the' sump event, as:noted in 2  : Inspection Report 50-344/89-19. The specifics. in;the. discussion of the N $, . event are noted belo '

W; On July 8, the Radioactive Waste Supervisor. noted the debris in the sump and in the_ pipe chase. He then directed. removal, asked for a Quality

,93 Control observation, and informed the Radiation Protection ~ Manager and .

Operations / Maintenance Manager.. The Quality Control observation on the ,

'm removal,was limite A Quality Operations (QO). inspector saw the' debris, and concluded that

.the debris had been in the sump a long time'and was a deportability concer _

His super' visor was informed on July 10. Also on July 10, additiona debris was found and management was informe On July 11, Q0 and Nuclear Safety and Regulation Department personnel

- - -noted that an event report (ER) needed to be written. Also, on July 11,

' the containment' pre-integrity inspections prior to Mode 4 entry were l

. signed off-but not conducted due'to a communication error. No access to '

the sump was made, and there was no specific criteria ~ for inspection of

'the sump:in the procedure. In fact, Mr. Barr the SRI, noted that the

, technical specifications were more descriptive than the actual procedure r .to inspect the sum '~

Mr. Chaffee hoted that no management entry into containment to inspect /

the sump had occurred up through July 11. This appeared to be indicative of a serious lack of management interest. Mr. Barr noted that the ( ,

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'" management'walkdown" of containment on July 11 was dclegated to a non-supervisory level, as allowed by procedure. Mr. Martin stated that this. is symptomatic of a lack of a safety consciousnes Mr. Martin further stated that he couldn't think of a more significant safety component, with the possible exception of the Refueling Water Storage Tank (RWST) single line connection to the Emergency Core Cooling System (ECCS). In addition, it was interesting to note that the safety significance of this component is clearly addressed by the licensee's technical specifications and by the radioactive waste supervisor's knowledge of the RHR pump susceptibility to debris which occurred in 198 However, in spite of this: people signed.of f a containment sump inspection I

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that was not done and had previously failed to correct recognized weaknesses in sump inspection procedures in the preceding outage (1988)previously identified by Ouality Assurance

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s , 'Mr. Mendonca continued with the event sequence noting the licensee made

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s a. courtesy ENS call on July 13, and that the licensee's containment inspection was considered complete, by the licensee at this time. He then stated that the NRC's inspection showed little or no engineering ..

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involvement to this time, and that the licensee's inspection of the sump .

consisted only of flashing a light into the sump and not entering. He

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. further stated that there was little or no management involvement or

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understanding of the above activities up to' July 1 ,

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On July 14,'the plant entered Mode 4, and the resident inspector notified; the licensee of his intention to inspect the sump. There was initial resistance on the part of plant management to NRC personnel entering the sump, but access was provided to the inspector, and plant personnel (00 and RP) went along with the inspector. Mr. Martin emphasized that at this time containment had been closed ou Mr.' Melfi stated that the initial response of managenent to the NRC's entering the sump for debris inspection was " Don't you trust us?"

Mr. Lindblad indicated that was not an acceptable response for the plant General Manager to mak Mr. Mendonca continued noting the debris found in the sump on July 14 by the resident inspector (i.e., an unopened bag of 50 30" long tie wraps, weld rod stub, loose tie wrap) and that the licensee was informed of gaps in the sump screens by the resident. At this point, the licensee issued an Event Report, made an ENS phone call, and held a critique. He noted that some of these issues and actions, particularly a critique by the licensee, should have been conducted earlier. In response, to the resident's findings, the licensee cleaned the sump and inspected with a fresh set of eyes, had an independent' cleanliness verification performed, and had an NCAR and an action plan initiate Mr. Barr stated that PGE had recently started the critique process and it needed to mature. He indicated that the RHR pump inoperability issue was overlooked as well as the design issue. He stated that in his opinion people are reluctant to raise problem Mr. Martin noted that the types of items found could easily jam pumps and that this had actually happened at Trojan. He also noted that the engineers should have been involved, and was surprised that these issues were l overlooked by the licensce's critique.

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Mr. Mendonca. continued with the chronology of the ' events, and noted that on' July 17, the licensee performed a multidisiplined inspection of the sump and identified the missing top screen which resulted in an ENS call and a Non-Conformance Report (NCR). He also~noted that on July 19, the NRC inspectors inspected the sump, and identified additional debris in the pipe chase including weld rod stubs, steel wire, and pipe fittings (some of this material was encrusted in boric acid crystals). The NRC also identified additional design problems in that the fine mesh screen was torn at the end of the pipe chase, and gaps were observed in the screen Mr. Mendonca stated that there were two unscreened holes into the pipe chase from the bioshield area noted at this time. Mr. Chaffee stated that these design- flaws had not been previously identified by the licensee as would be expected. Mr. Martin stated that it was significant that the NRC had again identified design problems with the sum Mr. Chaffee then noted that this problem probably went undetected through dozens of startup Mr. Mendonca continued, stating that no work was done by the licensee in the pipe chase. area until July 19. It was also noted that if the company had been on top of these issues earlier, the NRC's concern would have been somewhat diminished.- He noted that the inspectors wanted to obtain a list of debris and its location, and the list provided was not complete, accurate, or indicative.of locatio On July 22, the inspectors toured the sump and did not identify any further discrepancies'in the sump, but did find a loose tie wrap in containment. The licensee then established containment integrity. On July.25, the licensee contacted the resident inspectors for a

.-description of the debris that was found and it's location. On July 27, the resident inspector and~ regional based inspectors found debris on top of the sump screen. This indicated that the PGE walkdowns of containment

'were not thoroug Mr. Yundt made a presentation of PGE's analysis of the issues surrounding

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the sump. Mr. Yundt stated that they realized that they needed to do a better job and that they recognized the safety significance of the sum Mr. Johnson asked if PGE had any exceptions to the report and Mr. Yundt said he did not, but would recharacterize some of the statements. In particular, Mr. Yundt stated that when the inspectors found the debris on July 19, licensee's inspection of the sump was not complete. Mr. Martin stated that he realized that PGE was not finished with their inspection at that tim PGE presented their analysis of NRC Inspection Report 50-344/89-1 Mr. Yundt stated that they had performance problems, and that inspection of other areas was not adequate. He also stated that there were personnel errors on the part of management, the procedures were too <

general in nature and that the qualifications of inspectors had not been j defined. He also stated that personnel performance also includes management oversigh )

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. As corrective actions, Mr. .Yundt noted that there was inadequate

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personnel performance and that this would be dealt with. Mr. Cockfield l stated that the debris in the sump was probably due to inadequate work L control and tool contro Mr.:Yundt stated that the' licensee was going to include the Trojan f: . Technical: Specification (TTS) related surveillance in Periodic

, Engineering Tests (PET) or In-Service Inspections (ISI), as appropriat .He also indicated'that the licensee was looking at all Administrative

, . Orders (A0's)'to remove surveillance from these orders, and relocate the

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. surveillance. requirements in more appropriate procedures to assure they

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were appropriately conducte ,, Mr. Barr stated that QA had recommended that emergency sump TTS requirements

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-be inclu~ded in the ISI program, end the A0 was determined to be adequate

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by non QA plant staff. He further stated that A0's generally have-similar problems'in. implementing TTS requirements which was also a topic i

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Mr. 'Yundt' continued with the corrective actions stating that the sump had been seal wire closed and danger tagged; a foreign material and tool control program will be initiated for the sump; and the installation of a solid plate on top of the sump will be evaluate Mr. Yundt stated that the 'cause of the missing screen was the apparent failure to complete construction of the sump. He also stated that the sump inspection procedure was not specific and the DBD walkdowns were not properly implemented. He stated that there was no formal program in place as to what was expected. Mr. Cockfield stated that the management oversight on the DBD program was not adequate. Mr. Martin stated that this was surprising on the DBD effort, since the DBD effort was a major effort on PGE's par Mr. Cockfield said that the licensee planned to redo the DBD walkdowns and revamp how they do it. Further, he indicated that PGE plans to take a team approach with QA, design and system engineering participation, and make the instructions more specifi Mr. Martin indicated that the problem with formal instructions was not the root of the problem, but the fact that people were not doing their job was the real problem. Mr. Cockfield stated that the program lacked specificity. Mr. Martin replied that people seem to have lost contact with what they are suppcsed to do. Mr. Cockfield stated that there has been a disconnec Mr. Chaffee wanted to know if the system engineers knew what was expected of them and did they have enough time to do the job. Mr. Lindblad replied that they needed to review the DBDs to see if the engineers get all the information they need, that the current description might not be adequate. Mr. Martin indicated that to think that revising the document was going to correct the problem is not correct, and that it should be burned into everybody's brain as to what these systems do, so people can recognize when things are wron *

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L, Mr. Cockfkeld thought the Containment Spray (CS) DBD, which is one of the pN ,

systems that utilizes the sump, did not have enough detail. He indicatedi

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that'the Fina'l Safety Analysis Report (FSAR)-and the training manual were

\,3L r more descriptive than the DBD. Mr. Yundt indicated in light of this

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..b V T , lack of detail, there were missed opportunities to correct the sump

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e problems, in that the system engineer DBD walkdown should have identified

.the missing screens. He also indicated that another missed opportunity

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s ' was~.when material was found in the sump in 1988, in that actions taken

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were inadequate to ensure thorough cleaning, adequate inspection, and

.- : f identification' of root causes of sump deficiencies.

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v Mr. Yundt' related other issues brought up as a result of the sump issue, (f *.

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N<^ inc10 ding: that the adequacy of the foreign material exclusion program I N ,, ^

for compo,n'ents important to safety, needed to be evaluated; and that the . .

. quarantine program needed to be improved, s- .

'Mr. Mend 6nca indicated that DBD and engineering problems were also reenforced by recent NRC SSFI team findings and asked what is going to

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be done in the DBD review. Mr. Walt said that PGE will review the DBD's

, a'nd will define what to do with the involvement of design engineering, OA'and an SRO. He stated that he will look at the design basis, important calculations, maintenance and surveillance' procedures, and perform comprehensive system walkdowns. Mr. Walt said that they would get this program defined in Septembe Mr. Martin stated that he thought their recognition of problems was unacceptable. The examples he noted were problems identified with the rod deviation alarm, boiling in the CCW/RHR heat exchanger, Reactor Trip Breaker (RTB) latching problems, and instrumentation being pulled resulting in the RTBs openin Mr. Chaffee questioned the aggressiveness of lower level supervision. He thought that there should have been self-initiated critiques. Mr. Martin said that he agreed, and that the Radioactive Waste supervisor, who raised the sump issue, ran into a hostile receptio Mr. Yundt continued and stated that another management issue was of timely reporting. Mr. Cockfield stated that the issue of sump debris was reported to a high enough level in PGE, that more appropriate corrective actions should have been initiate Mr. Yundt continued and stated that there were key management issues with this event: untimely critiques, ineffective and untimely corrective actions, and lack of management accountabilit Mr. Mendonca wanted to know which specific management problems were most significant to the license Mr. Cockfield replied that lack of a timely critique of this event was a problem with this issue. Mr. Cockfield also related that they have been working on how to recognize problems, and that he had met with electrical and I&C maintenance, knowing that there were problems in this are Mr. Martin stated that he thought accountability should have been on top of the list. ,

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Mr. Yundt stated that their was no significance in the order of the issues. ,Mr. Martin stated that he thought it showed PGE's attitud Mr..Cockfield disagreed,' stating that he wanted to put accountability last, to be the summary issu The issue of I&C and 0A interface came up. Mr. Cockfield stated that 0A interface with other groups is still a problem, and other groups are not totally on board yet. He was trying to deal with the' issu Mr. Walt replied that they cannot keep on having event after event at Trojan. He stated that he intends to ramp up fast to address the management problems. Mr. Lindblad replied that he would like positive actions taken to improve performance as well as negative actions to improve performanc . , .

Mr. Nordstrom stated that 0A had issued NCARs on this issue. Mr. Walt ,

< also stated that as opposed to previous years. 0A was pushing management '

on this event. . Mr. Swan stated that 0A had a tenacity that was not

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, , previously show Mr. Yundt concluded the presentation noting that the corrective actions di'scussed will ensure the sump will remain operable and that similar

.i t events will not occur. He said that further evaluations will identify j. *

other areas requiring action and this will result in improved operation

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of the plan Mr. Barr brought up the subject of his perception of wishful thinking on the part of PGE management. He noted that PGE management was guilty of

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wishful thinking that the DBD effort was properly implemented; i.e the engineers believed that they hao a good idea of what they needed to do, but this'was not what management expected them to do. Also, on the seismic latching of the reactor trip breakers (RTBs), Mr. Barr indicated that the licensee still did not know the purpose of the latc Another example of wishful thinking that Mr. Barr noted, was problems with a response to NRC concerns on procedural compliance related to Inspection Report 89-14. Mr. Barr pointed out that in the licensee's response, the licensee stated that the trend was down for procedural noncompliance as evidenced by PM/EA's finding that the percentage of total noncompliance due to procedure noncompliance wa: trending dow However, the fact that the total number of procedure noncompliance had stayed about the same or gone up was not addressed. Further, the 1989 data had not been evaluated in the response. The NRC has also issued more procedural related violations this year than last year. Mr. Barr said the licensee's response was wishful thinking, in that the facts did l not support the conclusions.

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Mr. Martin stated that the sump issue is of great concern to the NRC, but noted that PGE has done good things in the last few years (e.g.,

obtaining a simulator, moving people to the site, spending money for fixe's). Mr. Martin said he perceives that the people associated with Trojan have a tendency to avoid problems and don't want to hear the (For example: rod deviation alarm issue, boiling in the CCW/RHR heat exchanger, RTBs seismic latch discrepancies, and the RTBs opening which were aggravated by weak management action). Mr. Martin emphasized that these problems are similar to those that have occurred over the last six year I l

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.Mr'.L' Johnson,-then: related the specifics of the new enforcement policy, including escalation and mitigation factor . IMr.,Clayton stated that a representative from the ED0's office only -

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q' comes outlfor enforcement conferences when the issue is.significant. He Z , . related that he saw~a lot of similarities to plants in Region I which '

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.were 'on the' troubled plant list (e.g. Peach Bottom, Pilgrim, Calvert Cliffs.]qd Indian Point).

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Some of these common attributes include.:

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t hostility to problims by management, lack of management / supervisor involvement, lack.of procedure compliance, and a stagnant organizatio He encouraged the' licensee to take these problems seriousl Mr. Martin concluded that in past management meetings, he has made some allowance for problems being the result of actions of past management, but that current problems at PGE fall squarely on present managemen ,

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