IR 05000344/1984023

Insp Rept 50-344/84-23 on 850729-0802.No Noncompliance or Deviation Noted.Major Areas Inspected:Document Control Program,Test & Measurement Equipment Program & Followup of LER

ML20137H917
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/13/1985
From:	Dodds R, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20137H916	List: IR 05000344/1984023 IR 05000344/1985023
References
50-344-85-23, NUDOCS 8508300003
Download: ML20137H917 (6)

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION V

Report N /85-23

- Docket N License N NPF-l' -

Licensee: Portland General Electric Company 121 S. W. Salmon Stree Portland, Oregon 97204-Facility Name: Trojan Nuclear Plant Inspection at: Rainier, Oregon

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Inspection conducted: July 29 thru August 2,' 1985 I

Inspector: /td u 4tter //

D. B. Pereira, Reactor. Inspecto Date Signed Approved By: ~

/.7 Dedl4 R. T. Do46s, Chief, Reactor Projects Section 1 d3!/

Date Signed Summary:

Inspection during the period of July 29 thru August 2, 1985 (Report No. 50-344/85-23)-

Areas Inspected: Routine, unannounced inspection of the document control program, test and measurement equipment program, and followup of a licensee event report. The inspection involved 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> onsite inspection by one NRC inspector. The inspection modules performed are Document Control Program (39702) and Test and Measurement Equipment (61724).

Results: No items'of noncompliance or deviations were identifie PDR ADOCK 05000344 g PM

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DETAILS Persons Contacted

• S. Bauer, Engineer, Nuclear Safety and Regulation Department

• Orser, General Manager

• J. Reid, Manager, Plant Services

• Swan, Supervisor, Maintenance

• Russell, Operations

• Moomey, Oregon Department of Energy

• Keuter, Technical Services, Manager

• L. Bennett, Supervisor, Mechanical Maintenance

• M. Snook, Senior Inspector, Quality Assurance M. Dawson, Technical Services K. Reid, Acting Office Supervisor

• Denotes attendance at exit interview conducted at Trojan Nuclear Plant on August 2, 198 . Document Control Program The document control program was examined for conformance with Technical Specifications, regulatory requirements, and licensee commitment The inspection included a verification that administrative controls have been established for drawings to ensure current as-built drawings, including piping and instrumentation diagrams (P& ids) are provided to the plant site in a timely manner. Administrative Order A0-5-2, " Drawing Document Chan'ges", dated June 26, 1985, Revision 4 provides the necessary controls for obsolete drawings,. ensures that discrepancies found between as-built drawings and as-constructed facility are handled'as design changes, and assigns responsibilities in writin The inspector verified that a master index is maintained for drawings, manuals, Technical Specifications, FSARs, and procedures. Administrative Order A0-4-3, " Responsibilities", dated December 28, 1984 Revision 13 provides the mechanism for this issuance and distribution, and assigns specific responsibilities in writing for the maintenance of the Plant Operating Manual.(POM) and assigns volume responsibility. Administrative Order A0-4-5, " Procedure Reviews", dated March 21, 1984, Revision 10 provides that each POM procedure, checkoff list, instruction and test shall be periodically reviewed no less frequently than every two year This technical review is the-responsibility of the supervisor assigned to the particular volume of the POM as detailed in A0-4-3,

" Responsibilities".

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The inspector verified that the effective revision master lists are reviewed quarterly and POM binders are reviewed annuall The inspector selected several procedures and drawings from the site master file, control room copies, and the Technical Support Center (TSC)

copies for verification with the master revision index. The inspection included a review of the following procedures and diagrams as listed by file location:

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. 2 Site Master Control Room Tech. Support File Copy Center Copy Administrative Procedure 89 89 89 Operating Instructions 0 52 52 General Operating Instructions 8 8 8 Off-Normal Instructions 60 0 60 Emergency Instructions 23 23 23 Functional Restoration Ins Periodic Operating Tests 37 0 37 Periodic I&C Tests 45 45 45 Maintenance Procedures 43 0 43 Quality Assurance Procedures 0 21 21 Plant Safety 29 29 29 Piping and Instrument Diagrams 0 68 68 The inspection results of the Trojan document control program were as follows: Administrative Order 8-13 Revision 3, Pages 1 and 2 were misfiled into A0-8-3, Revisio 14, Pages 1 and 2 in the Shift Supervisor's Copy. The inspector contacted the Office Supervisor and she immediately corrected the misfiling. The inspector verified that the control rooms cc py was correct. No other misfiling was noted in any controlled documents or drawings in the Site Master File, Control Room Copy, or the Technical Support Center Cop The inspector review of the Technical Support Center and the Site Master File docume'nts verified that the copies were consistent (same revision) with the master revision inde No violations or deviations were identifie . Tist and Measurement Equipment Program The test and measurement equipment program was examined for conformance with Technical Specifications, regulatory requirements, and licensee commitment The inspection included a verification that administrative controls for '

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test and measurement equipment calibration / adjustment frequency have been established. Maintenance Procedure MP-2-2, " Portable Measuring and Test Equipment", dated March 27, 1985, Revision 3 provides a procedure for ensuring that portable measuring and test equipment (M&TE) are properly controlled and calibrated at specific periods to maintain accuracy within prescribed limits. Table 1 of MP-2-2 provides an equipment inventory list which identifies the following: All test and measurement equipment which will be used on safety-related structures, systems, or component The. calibration / functional check interval for each piece of equipmen .__ _ _ _ _ . _ _ . _ _ - _ _ . _ - _ _ , , .- _ _ _

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shall be identified. The validity of these calibrations and tests should be determined, and if necessary, the tests and calibrations should be repeated using properly calibrated equipment. This procedure conducts an investigation or evaluation of the cause of out-of-calibratio The inspector verified that a formal system have been established to assure that new M&TE will be added to the inventory list and calibrated prior to being placed in service. Procedure MP-2-2 Paragraph 6-1, procurement and acceptance of M&TE, describes the procurement process of M&TE as initiated by the plant supervisor for new purchases and replacement purchases for worn out or missing M&T The inspector performed a review of Trojan Nuclear Plant's i Measurement standards calibration data as maintained by the I&C Department. The ten measurement standards reviewed were satisfactory in that the M&TE was maintained, calibrated, and issued in accordance with MP-2- No violations or deviations were identified.

Licensee Event Report Review Licensee Event Report (LER) 85-08 describes an inadvertent safety injection that occurred on June 30,1985, at 11

45 PDT while performing surveillance testing on the ' reactor protection system in accordance with periodic instrument and control test (PICT) 10-1, " Reactor Projection Systems". The two out of three logic criteria for a low pressurizer l pressure safety injection (SI) were established due to a procedural l deficiency.

i Action was taken in accordance with the licensee's emergency instructions l and the SI was reset without blocking the low pressurizer pressure signal j due to a procedural deficiency in the emergency instructions and the SI reinitiated at 11:57 PDT. The licensee is taking action to revise PICT 10-1 and the emergency instruction EI-0.3, "SI Termination Following Spurious SI" and is evaluating the administrative control of instrument

and control (I&C) system testing.

, The licensee's cause of occurrence was~ partially attributed to deficient

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procedures, in particular, PICT 10-1 did not specify which reactor trip inputs would have to be removed when shutdown in order to operate the reactor trip breakers. The maintenance and operations personnel incorrectly determined that the pressurizer pressure signal would have to be simulated because they did not recognize that this trip is blocked below 10 percent reactor powe PICT 10-1 was written to be performed while the plant is operatin Procedure El-0.3 was deficient in that it did not require the operator to ensure the signal which caused the inadvertent SI was blocked or removed as necessary before resetting the SI circuitr The inspector interviewed management, maintenance, and operational personnel regarding the significance of this event with regard to _

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c. The serial number and Trojan number for each piece of equipmen The inspector verified that formal requirements exist for marking the latest inspection / calibration date on each piece of equipmen Procedure MP-2-2, Paragraph 6.4.8 calibration stickers and tags, requires: calibration stickers' be pla'ced on equipment calibrated by the Trojan I&C calibration laboratory. This label denotes that the instrument was fully and completely calibrated and meets the approved specifications. The calibration sticker is white with black print and indicates date calibrated, date calibration due, and initial of person performing calibratio The inspector verified that a system has been provided for assuring that each piece of equipment is calibrated and adjusted on or before the date required. Accordingly, Procedure MP-2-2 paragraph 6. calibration schedule and interval, requires that the Instrument and Control (I&C) Department maintain a schedule for the M&TE covering both calibrations and functional check In general, M&TE is on a periodic calibration schedule, which is scheduled monthly by use of a computer system that Trojan realizes has been a prrblem for some time. PGE's quality assurance program has an outstanding program audit finding; nama y Loop-1136, which identified discrepancies betwee the completed I&C Test Instrument Calibration Data Sheets and the completed monthly computer schedules. This item will remain open pending implementation of the new computer maintenance scheduling system scheduled for the end of August 1985 (Follow-up item 85-23-01).

, The inspector verified that a written requirement is established I

! which prohibits the use of test and measuring equipment which has not been calibrated within the prescribed frequency and describes controls to prevent inadvertent use of such equipmen Procedure MP-2-2, Paragraph 2, responsibility, provides the responsibility of the users of M&TE to ensure that a piece of M&TE is not used after l its calibration due date and to ensure that any malfunctions or i suspected malfunctions are reported to the I&C test equipment technician promptly so that the equipment can be removed from service and repaired. The procedure MP-2-2 also describes that it is each supervisor's responsibility to ensure that each M&TE is made

available for calibration prior to its due date. These controls ensure that M&TE is calibrated prior to use or puts the equipment into the calibration program if out of calibratio The inspector verified that out-of-calibration ccatrols are established which require when a piece of equipment is found to be out-of-calibration, the acceptability of items previously tested or

measured will be evaluated and documente Inaddition,pn evaluation of the cause of out-of-calibration will be pet forme Procedure MP-2-2, Paragraph 6.4.9.8, test equipment out-of-calibration investigation, describes that an investigation shall be performed whenever M&TE is found to exceed required calibration tolerance or that has been subjected to possible damage,

, or to be non-functional. This action could be the result of an

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offsite calibration, onsite calibration, or other event. All i equipment tested or calibrated using that M&TE since its calibration l

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personnel erro This inspector felt that since PICT 10-1 did not give specific guidance in order to operate the trip breakers but rather a general NOTE in which it was stated that it may be necessary to remove reactor trip inputs in order to operate the trip breakers; a procedural deviation should have been generated. Administrative Order (AO) 4-2,

"Use of Procedures" provides for deviations in which they are temporary and "on-the-spot" changes to or departures from approved plant operating manual procedures that do not change the intent of the procedure. This deviation from (Attachment A of A0-4-2) would have allowed the maintenance ind operations personnel to have had another authority check the operation for resetting the trip breakers. Without this additional check, the operations and maintenance personnel incorrectly determined that they needed pressurizer pressure signal to be simulate The inspector realizes that FICT 10-1 and EI-0.3 were in error and that the LERs corrective action concerning those issues will help prevent reoccurrence of the event. The inspector will leave this item as an unresolved item and will review the licensee's actions concerning personnel error at a later inspectica (85-23-02).

5. Unresolved Items An unresolved item is a matter about which more information is required in order to ascettain whether it is an acceptable item, an open item, a (*viation, or a violatio . Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 on August 2,1985, and summarized the scope and findings of the inspection activities.

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