ML20247D377

Informs That Util Taking Proactive & Aggressive Actions to Improve Performance in All Areas of Plant Operation,Per 890309 Transmittal of SALP Board Evaluation of Safety Performance at Plant for Period Dec 1988 - Dec 1989

ML20247D377
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/15/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8905250393
Download: ML20247D377 (15)

Text

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David W. Cockfield Vice President, Nuclear May 15, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nucicar Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sirs:

1988 Nuclear Regulatory Commission (NRC)

Systematic Assessment of Licensee Performance (SALP)

The NRC SALP Board evaluation of safety performance at the Trojan Plant for the period from December 1, 1987 through December 31, 1988 was provided by your letter dated March 9, 1989. Overall Plant performance during the period was acceptable and found to be directed toward safe operation, with improved performance noted in several functional areas.

However, performance in the functional areas of Security and Safety Assessment / Quality Verification was evaluated as Category 3.

Portland General Corporation has established a goal to achieve sustained superior performance in the area of nucicar operations. To realize this goal, Portland General Electric Company (PGE) is taking proactive and aggressive actions to improve performance in all areas of operation of the Trojan Nuclear Plant. This improvement is being accomplished through '

a commitment of support from Nuclear Division management and the personal involvement of Corporate Management.

8905250393 PDR 890515 ADOCK 05000344 O l

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.' POrtlanci General Electric Coirycs r3r Document Control Desk May 15, 1989 Page 2 The specific concerns identified in the SALP Report and the actions being taken to improve PGE's performance are detailed in Attachment A for the area of Security, and Attac1 ment B for the area of Quality Assurance.

Sincerely, L. 3 Attachments c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident inspector Trojan Nucicar Plant l

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Trojan Nuclear Plant Document Control Desk Docket 50-344 May 15, 1989 License NPF-1 Attachment A Page 1 of 7 NUCLEAR SECURITY DEPARTMENT

1. Concern: A continuing lack of effective management involvement in assuring quality for the Security Program. Security Program operations and support are functioning at a minimum compliance level ,

rather than striving to excel. I l

Improvement Goal: Conduct security operations in a manner that meets and exceeds regulatory requirements.

Improvement Plan:

a. The Nuclear Security Department has been separated from Corporate Security to increase Nuclear Division involvement and to provide increased visibility to Nuclear Division Management (Revision 23, Trojan Security Plan),

b. A new Nuclear Security Department Manager and a new Branch Manager, Security Operations (BMS0) have been appointed. The current department manager's licensing experience provides added sensitivity to regulatory concerns.

c. The Nuclear Security Department Manager has relocated his office from Portland to the Trojan Plant to provide more direct over-view cf Security Program activities and to improve coordination with Plant Manage.l.ent (Revision 26 Trojan Security Plan).

d. The Nuclear Division Managers have committed to increased support for security activities in their 1989 goals and obj ectives.

2. Concern: Poor past performance with security action plans, speci-fically the redefinition and reassignment of responsibility and the failure to meet milestone dates.

Improvement Goal: Formulate effective action plans that have been reviewed and agreed to by support organizations; complete all action items by the scheduled dates.

Improvement Plan:

a. A number of long-term NRC concerns are being completed in 1989:

• The Closed Circuit Television (CCTV) camera installations at the Cooling Tower Cate were completed on schedule, allowing for the removal of a compensatory guard post.

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L Trojan Nuclser Plant Documint Control Dank Docket 50-344 May 15, 1989 License NPF-1 Attachment A j Page 2 of 7

• CCTV upgrades at the Main Cate and Technical Support Center (TSC) Building areas are on schedule; these modifications will allow for the removal of two additional compensatory guard posts.

• CCTV upgrades at the Intake Structure are being designed and are funded for installation this year; this will allow for the removal of one other compensatory guard post.

• Secondary Power Supply System upgrades are scheduled for completion by December 31, 1989.

• A task force was established to address continuing problems with inadequate protected area lighting., Design work is in progress, with installation of new lighting scheduled after the 1989 refueling outage.

• Control Room security door upgrades are scheduled for com-pletion during the 1989 refueling and maintenance outage.

b. A Nuclear' Security Department security officer, qualified as a Security Watch Supervisor, has been assigned to a staff position and given the responsibility of working daily with Operations, Maintenance, and other support personnel to coordinate, monitor, and expedite security-related activities,

c. The Commitment Tracking List (CTL) is being utilized to assure that all open security items are being monitored. Nuclear Division Management will be kept aware of open item status so that appropriate priority and management direction can be established to assure that items are completed on schedule.

d. The following examples provide evidence of improvement in this area:

• When maintenance problems were identified with the explosives detectors at the main entrance to the Plant, procurement was expedited and two now detectors were on site and operational within one month. One hundred percent pat-down searches of all entering personnel during periods when the detectors are not functional was also implemented (Nuclear Security Procedure 600-6, Revision 4).

• When a deficiency was identified in barriers at the Turbine Building, modifications to resolve the deficiencies were installed in three weeks (Safeguard Event Report 89-301-00).

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Tro3cn Nuclear PIEnt Docum:nt Control D3ck Docket 50-344 May 15, 1989 License NPF-1 Attachment A Page 3 of 7

3. Concern.: Violations were identified by regional inspectors that had been identified earlier by the Nuclear Security Inspector but had not been corrected.

Improvement Goal: Utilize the Security Inspector to provide an internal review of the Security Program and take positive and timely action to resolve program deficiencies.

Improvement Plan:

a. A monthly report tracking the status of all open items from the Security Inspector's inspection reports is being issued to the Plant General Manager, General Manager, Technical Functions and the Vice President, Nuclear,

b. Daily meetings are held between the Security Inspector and the Manager, Nuclear Security or the Branch Manager, Security Oper-ations to discuss concerns and identify inspection objectives,

c. The Nuclear Security Inspector now reports directly to the Manager, Nuclear Security in lieu of the Plant General Manager.

This improves communication and allows inspection activities to better focus on areas of concern. The responsibility for an independent overview of the Security Program is maintained by the Quality Assurance Department.

4. Concern: A comprehensive review of security management effective-ness, as committed to in a security action plan, was reduced to a narrow review of a single area.

Improvement Goal: Complete a comprehensive review of Security Program effectiveness and modify the program as required.

Improvement Plan:

a. A comprehensive, independent review of security management effsetiveness was conducted by the Quality Assurance Department in December 1988. A report of the findings and recommendations has been issued. The Security Department has taken appropriate action on recommendations in the report, and a response will be provided to the Quality Assurance Department by June 15, 1989.

b. An internal review of security operations will be completed by December 1989.

Tro'jtn Nuclost plint Docum nt Control D22k Docket 50-344 May 15, 1989 I License NpF-1 Attachment A l Page 4 of 7 i

l S. Concern: Communication problems within the security organization have contributed to past security events.

Improvement Coal: Reduce to zero the number of security events resulting from poor or improper communication.

Improvement Plan:

a. As part of his " striving for excellence" program, the Nuclear Security Department Manager has instituted a policy of more open communications within the department and with outside organi-zations. Emphasis has been placed on assuring that personnel at all levels are familiar with the requirements and expectations, and assume responsibility for their assigned jobs.

b. A program has been established which requires that security managers and other affected plant personnel receive specific training on major modifications to security systems to assure they are familiar with the associated equipment and barriers, as well as any new or revised security program requirements,

c. The Branch Manager, Security Operations assures that knowledge-able security representatives attend pre-job planning meetings and that they'are aware of the responsibility to report and resolve any concerns that arise,

d. Improvements in this area are evident from the excellent coordi-nation that has occurred between Nuclear Plant Engineering, Maintenance, Plant Modifications, Quality Assurance and Security personnel. Examples are resolution of the Turbine Building barrier deficiency (Safeguards Event Report 89-S01-00) and the activities in progress to upgrade barriers at the Intake Structure.

6. Concern: Marginal performance has continued in the area of tech-nical resolution of security issues, with respect to the implemen-tation of compensatory measures.

Improvement Goal: Assure appropriate priority is assigned to resolving security barrier deficiencies. Strive to minimize the total number of compensatory posts.

Improvement Plan:

a. The Nuclear Security Department Manager and Division management are committed to a proactive response in resolving security deficiencies. An example of improvement in this area is the  !

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. implementation of 100 percent pat-down searches when explosives or metal detectors are not functioning prior to the regulatory requirement for doing so.

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.b. A status of the number of compensatory posts currently.in place at the Plant is included in the monthly Nuclear Performance Report for the Trojan Nuclear Plant. The status identifies the l number of posts relative to previous months and provides an L indication of progress made toward eliminating compensatory posts,

c. To' ensure that compensatory actions are not terminated prema-turely, Security Department procedures have been revised to require preparation of a modification or maintenance acceptance checklist with sufficient lead time to allow review before the work is completed (Nuclear Security Procedure 300-2, Revision 2).

7. Concern: .The proposed barrier criteria document failed to adequately consider all of the design threat parameters of 10 CFR 73.1.

Improvement Goal: Formulate a barrier critoria document that is practical, cost-effective, and in compliance with regulatory requirements.

Improvement Plan:

a. The existing barrier criteria document has been reviewed with respect to the applicable regulatory requirements,

b. .An action plan is being prepared to detail the appropriate analysis and testing required to resolve open issues in the criteria. The action plan will be issued by June 30, 1989.

8. Concern: Certain security violations Which were identified during the SALP period have been the subject of previous enforcement action or discussed in NRC information notices. The previous SALP Report recommended that corrective actions implemented as a result of past problems and NRC notices be periodically reevaluated for applicability.

Improvement Goal: Determine the root cause of security problems and initiate effective corrective action such that the number of repeat offenses is minimized.

Improvement Plan;

a. The Security Inspector will review two previous prob;2m areas each month to assess the impact of the corrective actions to address those problems. The items and findings will be specifically addressed in the Security Inspection Reports.

. '.. iTrojen Nuclear Plant Docum:nt Control Dsak Docket 50-344 May 15, 1989 License NPF-1 Attachment A Page 6 of 7

b. A' preventive maintenance program'for appropriate security equip-ment will be. formulated and implemented by December 1989- .

c. All Safeguarda Event Reports will include descriptions of previous similar events. This provides another mechanism for evaluating the effectiveness of previous corrective actions.

9. Concern: Security organization statements of responsibility and authority appear to overlap.

Improvement Goal: Assure that the Nuclear Security Department-organizational structure is well defined and understood by personnel both within and outside the department.

Improvement Plan;

a. The reorganization Which separated the Nuclear Security Depart-ment from the Corporate Security organization (Revision 23, Security Plan), and the relocation of the Nuclear Security Department Manager to Trojan (Revision 26, Trojan Security Plan) has streamlined the organization.

b. The Security Inspector now reports to the Manager, Nuclear Security Department in lieu of the Plant. General Manager.

10. Concern: Tbc Trojan Fitness for Duty program is considered weak becauss it lacks a requirement for random testing after' employment.

Improvement Goal: Develop a random drug-testing program to be implemented once'the NRC issues a Final Rule on the Fitness-for-Duty Program.

Improvement Plan:

a, PGE will proceed with development of a random drug testing program following publication of the Fitness-for-Duty Rule, anticipated by.the end of May, 1989. An action plan is being developed detailing responsible parties and required action for a random drug testing program for Nuclear Division and other employees badged for unescorted access to the Trojan Nuclear Plant.

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- Trojen Nuclear Plant Document Control D2sk Docket 50-344 May 15, 1989 f License NPF-1 Attachment A {

Page 7 of 7 j l

1 The annual audit of the Security Program by Quality Assurance is sche-duled for August 1989. Tho scope of the audit will include review of security procedures and practices (including proper handling and storage /

of Safeguards Information), an evaluation of the physical protection system effectiveness, review of the physical Security System Maintenance 1 and Testing Program, and a review of the commitments for response established by local law enforcement authorities. This audit will allow management to assess the improvements discussed above and maintain their overall commitment to the Security Program.

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. " . . Trojan Nuclear Plant. Documsnt Control Dask Docket 50-344 May 15, 1989 License NPF-1 Attachment B Page 1 of 6 SAFETY ASSESSMENT /0UALITY VERIFICATION Portland General Electric Company (PGE) acknowledges the weaknesses in the Nuclear Quality Assurance Department (NQAD), and is committed to major changes and improvements in this area. This commitment has the full support of the Chief Executive Officer, the President of the Generating Division, and the Vice President, Nuclear, who are giving l

their personal attention to correcting these weaknesses.

Significant changes have already been made and are achieving the desired result of transforming NQAD into a proactive and performance-oriented organization, Changes have been made in three of the top four management positions within NQAD. The individuals placed into these management positions are top performers from the line organization Who were selected because of their. demonstrated ability to be intrusive, to ask hard questions and to surface root causes to problems. Additionally, technical experts have been added to NQAD in the areas of electrical engineering, mechanical engineering, radiation protection and instru-mentation and control. These changes were made to ensure NQAD has the capability to review the technical details and adequacy of work activities.

There actions are just the beginning stages of a major transformation of the NQAD. NQAD will become a problem-finding, performance-measuring organization, which will serve to be a catalyst for higher Nuclear Division performance standards. This is our commitment. To demonstrate the results achieved, we will provide you a followup report by August 31, 1989.

The specific concerns identified in the SALP Report are addressed below:

1. Concern: The quality organizations appeared to be insufficiently involved in the review of events and Plant problens, and were not providing independent verification that management 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 group has actively participated in the review of events in order to verify quality of the responses. 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.

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,- '.* . Trojan Nu: lose Plant Documint Control D2sk Docket 50-344 May 15, 1989' License NPF-1 Attachment B Page 2 of 6 b .- NQAD will review adherence to management policies and NRC l 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 management expec-tations are carried out in every aspect of Plant operation.

2. Concern: A Quality Control (QC) inspector observed a nonconforming maintenance activity and did not document the observation as required by NQAD procedures. Procedural compliance had been a major concern in the last SALP.

Improvement Goal: Achieve a clear understanding by all personnel of i the management expectations for procedural compliance.

Improvement 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 stressed by Plant and QA management during the General 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 being held accountable to assure their personnel comply with procedures.

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3. Concern: Audits in the areas of engineering, instrument control, health physics 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 experienced personnel.

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-specific training on performance-based audits and surveillance was provided to NQAD managers, supervisors and auditors,

b. A recent audit of Mechanical Maintenance used performance-based concepts; this technique is being applied to other areas in 1989. i l

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. !. Tr'sjen Nuclear plant Docum nt Control D2rk-Docket 50-344 May 15, 1989 License NPF-1 Attachment B page 3 of 6

c. The QA audit procedure is being revised to shift the focus of audits from reviewing documents to reviewing activities impor-tant to safety and reliability. This will ensure continued use of performance-based concepts in future audite.

d. Several staffing changes have been made in NQAD to strengthen expertise in engineering, instrument control, health physics and radiological controls. Details are provided in 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 service by use of qualified suppliers,' 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 program, instead of directing its implementation.

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

c. Additional resources have been applied to qualify commercial-grede suppliers. A review of evaluations approving commercial-grade suppliers, as well as higher quality code suppliers, is in ,

progress to ensure that all approved vendors meet applicable requirements. Several deficiencies have be.. identified and corrected.

d. A materials testing program will be initiated by August 1989 for verification of commercial-grade material. Materials testing activities are currently being specified with each procurement, as needed.

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, .. . 'Trbjcn Nucisar Plcnt Docum2nt Control Dask Docket 50-344 May 15, 1989 License NPF-1 Attachment B Page 4 of.6 l S. Concern: Inaccurate information was provided to NRC management in a H procurement-related presentation.

Improvement Goal: Provide accurate information at all times.

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a. Disciplinary action was taken with the individual responsible for conveying unverified information to the NRC. He has since 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 NHC has been emphasized to all personnel.

6. Concern: Until recently, a program to trend plant events, Noncon- ,

formance Reports (NCRs) and NCARs did not exist. A program was I implemented in January 1989 by NQAD to track and trend various 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 problems, 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.

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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' understanding and use of the infor-mation improves.

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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 i i

industry standards for quality, Improvement Plan:

a. Principles and standards of NQAD operation have been promulgated 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 actions are being rejected by NQAD and returned for rework.

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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.

b. The NQAD 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.

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.

. . " , Td3jin Nuclear Plant Document' Control D ck Docket 50-344 May 15, 1989 License NPF-1 Attachment B Page 6 of 6 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 background was appointed as Quality' Support Branch Manager.

(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, Mechanical 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.

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