IR 05000344/1986002

Insp Rept 50-344/86-02 on 860104-0210.No Violations or Deviations Noted.Major Areas Inspected:Operational Safety Verification,Corrective Action,Maint Surveillance & Facility Organization & Administration

ML20154M506
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/28/1986
From:	Dodds R, Kellund G, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20154M500	List: IR 05000344/1986002 ML20154M497
References
50-344-86-02, 50-344-86-2, NUDOCS 8603140309
Download: ML20154M506 (11)

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U. S. NUCLEAR'REGULATO'Y COMMISSION

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. REGION V

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' Report No. 50-344/86-02

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t Docket No. 50-344 License No.'NPF-1

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Licensee:'

-Portland General Electric Company!

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'121 S. W. Salmon Street'

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Portland, Oregon 97204.

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' Facility Name: Trojan'

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. Inspection at: Rainier, Oregon

, Inspection conducted: January 4 - February' 10, 1986 Inspectors:

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S. A. Richards Dhte Tigned

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Senior Resident Inspector

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G. C. Kellund

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. Resident Inspector

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Approved By:

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R. T. Dodds, Chief Date Sfsned

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' O Reactor Projects Section 1

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Summary:

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Inspection on January 4 - February 10, 1986 (Report 50-344/86-02)

Areas Inspected: Routine inspection of operational safety verification, corrective action, maintenance, surveillance, facility organization.and administration, review of-reactor coolant leak rute deters 1 nation methods, followup on previously identified items,'and inspection-of Narious aspects of plant operation. The inspection involved-199 inspector-heurs by the NRC

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Resident Inspectors.

29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> of inspect 1 n were.during back shift hours.

Inspection procedures 30702, 30703 36700. 40700, 61700,E61726, 61728, 62703,

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71707,,92701, and 93702 were used as guidance during the conduct of the

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inspection,

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Results: No violations or deviations were identified.

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,, DETAILS

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. Yerso'ns' Contacted

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^*W.S.7 rser, Plant, General) Manager f,

'R.P.iSchmitt', Nanager,,0perations and Maintenance

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D.R; Keuter, Manager,< Technical" Services

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i LJ.D..Reid,' Man'ager, PlaniLServices

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L R.E.Susee,Op'erationsSuhervisor

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.D:W.? Swan, Maintenanc'e Supervisor F.7 '

, A'.S.7 Cohlmeyer, Engineering Supervisor

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ZG.L~. Rich,ChemistrySupervis_or4[

T.O. Meek, Radiation Protection Supervisor

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S.BgNichols, Training Supervisor s

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,D.L.

Bennett, Control and Electrical Supervisor

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C.H. Brown, Quality Assurance Operations Branch Manager r

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.e ;t R.W. Ritschard, Security Supervisor

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H.E. Rosenbach, Material Control Supervisor

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'J.K.'Aldersebaes, Manager, Nuclear Maint. and Construction N

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The 'inspe'c, tors also. interviewed and talked with other licensee emp' 9yees during the' course of the inspection.' These included shift supervisors, reactor and auxiliary operators, maintenance personnel, plant technicians

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and engineers,M nd quality assurance personnel.

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• Denotes.those attenYing the exit interview.

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2.

Operatiobif Safety Verification '

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Duringthisinspectida. period,theinspectorsobservedandexamined

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activities-to verify'the operational safety of the licensee's facility.

The obt.ervations.and examinationn ot those activities ~were conducted on a

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_ daily, weekly, or biweekly basis.'

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On'a daily, basis,.the inspectors [ observed control rcos cctivities to

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verify the licensee's adherence to, limiting conditions for operation as prescribed in the facilitystechnical specifications. ' Logs,

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--instrumentation, recorder' traces, and other operational records were examined to obtain information on plant conditions, trends, and'

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,,'C compliance'with regulations. On occasions when a shift turnover was in.

progress, the tu'rnover of information on plant. status was observed to

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determine that.all pertinent information was relayed to the oncoming

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shift.

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During each week, the inspectors c.oured the accessible areas of the

facility to observe the following.'.tems:

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General' plant and equipment cond*tions.

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Maintenance requests and repairs.

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Fire' hazards and fire fighting equipment.

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Ignition sources and flammable material control.

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Conduct of activities ' n accordance with 'the licensee's i

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' administrative. controls and approved procedures.

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Interiors of electrical and control panels.

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. Implementation of the licensee's physical ~ security plan.

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Radiation protection controls.

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.. Plant housekeeping and cleanliness.

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Radioactive' waste systems.

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The licensee's equipment clearance control was examined weekly by the

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inspectors to determine that the' licensee complied with technical

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specification limiting conditions for operation with respect to removal sof'equipmentifrom' service., Active clearances were spot-checked to ensure

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that their issuance was consistent with plant status and maintenance

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During each week, the inspectors' conversed with operators in'the control'

room,'and with other plant personnel. The discussions centered on pertinent topics relating to general plant conditions, procedures,;

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' security, training,.and other t'opics aligned with the work activitie's-involved..

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The inspectors examined.the licensee's nonconfotsance reports'(NCR).to confirm that deficiencies were identified and tracked by the system.

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Identified nonconformances were being tracked and followed to the

. completion of-corrective action. NCRs' reviewed during this inspection

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period included 85-091,85-107,.85-108,' and 85-109. Specific comments-

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concerning NCR 85-091 are contained in paragraph 6 of this report..

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Logs of' jumpers, bypasses, caution, and test tags were examined by the

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inspectors., Implementation of radiation protection controls was verified by' observing portions of area surveys being performed, when possible, and s

by_ examining radiation work. permits currently fn effect to see that

' prescribed clothing and instrumentation were available and used.

f-Radiation protection instruments were also exenned te verify operability-

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and calibration'. status, s

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Th'e inspector's verified;the operability of selected engineered safety

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b fe'a tures'.

This was done by direct visual verification of the correct

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. posit' ion of valves, availability 'of-power, cooling water supply, system

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. integrity and general l condition of equipment, as applicable. ESF systems

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Tverified operable during;this in'spection period included the component s-cooling water ' system, the ' safety :inje'ction system, the emergency boration sys' tem,iand'the emergency diesel generator air start system.

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No ' violations-or 'dev'iatio,ns were. identified.

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Corrective Action l j

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sThe; inspectors performed a general review of the licensee's problem ide'ntification systems to' verify that licensee identified quality related i

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deficiencies are being trackediand, reported to cognizant. management for

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. resolution.. Types of records' examined by the inspectors included Requests for Evaluation, Event Reports, Plant Review Boerd meeting

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minutes,.and Quality Assurance Program Nonconformance Reports. ~The

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inspectors concluded that the licensee's systems were being utilized to correct identified deficien:les. A Plant Review Board meeting was p

att ended by the inspectors on January 15.

The inspectors verified that

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the appropriate committee members were present at the meeting and that

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the meeting was conducted in accordance with the requirements of section 6.5.1 of the facility technical specifications.

No violations or deviations were identified.

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Maintenance During this inspection period, two maintenance activities were witnessed.

The first activity was associated with preventative maintenance of

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' Auxiliary Feedwater flow control valve MOV-3004-D1 on February 4.

During this work, the inspectors verified that the system was declared inoperable by the operators, that the proper procedure was used and that the test equipment was in calibration. The following observations were made:

- The worker apparently tightened electrical connections that were energized and supplied from a 120 VAC vital power supply. The inspector discussed this with the worker. The worker stated that he was knowledgeable of the circuit wiring, however, he had made a mental error in checking those terminations. He stated that he would ensure all power was removed for work on other similar valves.

- The worker adjusted the functioning of the torque switch bypass limit switch, however, the procedure did not provide specific guidance on how tc make this adjustment. The inspectors discussed this concern with plant supervision. Plant supervisico pointed out that the worker was required to view a training film on motor operated valve maintenance and study various technical information prior to perforwing the work, thereby making the task well within the skill of the craft, however, they agreed that formal guidance on-the manner in which to adjust the switch was appropriate. Written guidance was attached to the maintenance request to be used for future valve maintenance.

- The worker did not originally document that the limit switch was adjusted. The general topic of the need to accurately document maintenance for equipment history records was discussed with the plant general manager.

The inspectors also checked the wiring terminations of the motor operator. No discrepancies with the wiring were noted.

While none of the above observations appears to be a violation of regulatory requirements,' the inspectors coucluded that the observations supported a general concern expressed in the most recent NRC EALP report that the licensee should strive to ensure that work instructions are sufficiently detailed and all work performed is well documented.

The second maintenance activity observed was associated with inspection of the

'B' component cooling water pump motor bearings on January 13.

-The inspectors noted that this work was conducted in accordance with

. approved procedures and properly documented.

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No violations 'or' deviations were identified.

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Surveillance '

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The surveillance testing of safety-related systems was witnessed by the inspectors,. Observations by~the inspectors included verification that proper procedures were used, test instrumentation was calibrated and that

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.the system or component being tested was properly. removed from service if

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required by the test procedure. Following completion of the surveillance tests, the inspectors verified that the test results met.the acceptance criteria of'the technical spesifications and were reviewed by cognizant licensee personnel.' No corrective action was' required due.to the test re,sults. The.sy's)ess.were returned to an operable status consistent with

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4the; technical specification requirements following the completion of'the

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Ta 't'est'.

Surveillance tests witnessed during the inspection period were n

C, associated,with!atjpower measurement of the moderator. temperature

>}$[ coefficient,on; January 1,7,andsu'veillancetestingofthereactorcoolant r

isystes delta-temperature'and average temperature protection instruments

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No violations 1or deviations we're identified.

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s 6.

. Reactor' Coolant System (RCS) Valve Replacement

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'In~ July, 1985, at the conclusion of_the annual refueling outage, the licensee determined that s 2Einch RTD bypass loop manual isolation valve,

designated as valve 8063A',-required replacement. The work was accomplished under maintenance request.(MR) 84-1800, following which the.

' plant recovered from the outage and returned to power operation.

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October, licensee' engineering personnel recognized from reviewing documentation of the job, that an ASME Class 2 valve had been mistakenly installed, instead of the required ASME Class I component. The licensee

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documented -the non-conforming condition with nonconformance report :(NCR)

i m-85-091.

The licensee contacted the valve manufacturer and determined that the valve used could be. upgraded to a Class I component-without physically altering the valve. The licensee then initiated action to contract the manufacturer to perform this service.

The~ inspectors reviewed the circumstances surrounding the event and made the following-observations:

- The work documentation for the job was poor. The NR originally was written to repair the valve ~and after repair efforts failed, it was revised to replace the valve. This change in the work instructions resulted in difficulty in ensuring that the proper ~ reviews were conducted prior to starting the work of replacing the valve.

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.The Plant Review Board (PRB) had not reviewed the event.

In that the valve is being upgraded to ASME Class I without physical altering, the facility technical specifications were not violatej ted a PRB review was therefore not specifically required. The inspeccors concluded, however,~ that an error made in the repair of the RCS pressure boundary-should be of sufficient significance to warrant a PRB review. The PRB c

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considered'this event on February 12, 1986, and found it to be not

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reportable.

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- The' licensee's action to upgrade the valve was not well coordinated.

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When the inspectors; questioned the status.of this effort,-licensee representatives were uncertain as to the group responsible 'for ensuring

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completion of the NCR corrective action.

A^ review by the licensee then

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. determined that the effort was stalled because the information on.the purchase order to obtain contractor services was< incomplete. The

' licensee has since resolved the problems with the purchase order and

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-verified:the valve manufacturer's ability to upgrade the valve.

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- The inspectors reviewed the quality control (QC) inspections that.

accompanied the work and determined that two QC inspectors performed

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inspections for weld preparation, fit-up, completed weld visual, and

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T liquid penetrant. Additionally, three separate welders worked the job.

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Although'the weld instruction and the weld ecord form clearly.

indicated'that the work was to be performed under ASME Section III'

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~ Class I requirements, none'of the above individuals noted that the component being welded into.the system was the wrong class.

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.The licensee determined that the wrong valve was-withdrawn from the

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. warehouse for the job because the. supervisor who requested the valve did

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-not have an accurate understanding of class requirements. The. licensee

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has reduced the list of perronnel authorized to withdraw material from the' warehouse while considering long term action to ensure correct material identification prior to drawing out ' parts. The inspectors

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discussed the.above observations with the plant manager. They noted.that while no violation of technical specification requirements had occurred, they were concerned that a number.of weaknesses were noted with a job as

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significant as the replacement of a RCS pressure boundary component.

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No deviations or violations were identified.

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Reactor Coolant System Leak Rate Determination i'

The inspectors utilized a personal computer (PC) program to independently l

determine the reactor coolant system (RCS) leak rate. The PC program

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.used is titled RCSLK9, and is described in NUREG 1107. The program is supplied by the.NRC Division ofLEmergency Preparedness and Engineering

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' Response.i Prior to using th'e' program, the inspectors verified that the

,. - ^ plant.' parameters as'sumed by the program were consistent with the actual 7plantconditions. [Several leak' rates were calculated, and in all cases,

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(the5resultswerewithintechnicalspecificationlimits.

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The inspectErs also reviewed the licensee's leak rate procedure, Periodic Operating Test (POT) 1-3, " Leakage Evaluation." The licensee has under

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< 1certain conditions had limited success with repeatability of results.with

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~ the' procedure. fFor example,,on February 6, the licensee determined the

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RCS leak rate'three times with'the unidentified leak rate results being

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0.95, 0.71, and 0.27 gallon's per minute. The inspectors noted several

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apparent deficienciessinithe licensee's procedure which could' account for

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the relatively wide variation in leak rate results. The most significant

factor' is the determinatiV>n of pressurizer level change effect on the

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leak rate calculation. The' total RCS leakage is referenced to water at approximately 100 degrees F'and atmospheric pressure, however, changes in

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pressurizer level have'apparently not been corrected by the procedure to this reference. A one. percent change in level over the nominal four hour duration of the test,would result in approximately a 0.25 gpm error in

,. leak rate 'results! :Under normal'pl' ant conditions, the pressurizer level remains 1.basicallyfconstant thereby eliminating this potential error.

'However,,wh,en increased purification' letdown flow is valved in, as was

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,the case for the firstitwo tests on February 6, the plant experiences difficul'ty injmaintaining*a constant level.

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r The second ' potential error exists in that the RCS water volume change due to changes in'the average coolant'. temperature is not corrected to the

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reference temp'erature and pressure'. The RCS temperature normally remains constant during the test so tha't-this error would not normally be significant, although the potential for noticeably effecting the test results under unusual conditions remains. The third apparent error concerns determining the volume change in the reactor coolant drain tank (RCDT). The licensee's procedure presently assumes that the volume change over the range of the tank level indication is linear, however, because the tank is a horizontal cylinder, a linear conversion does not provide an accurate determination of volume change. With nominal leakage into the tank, this potential error is relatively small, approximately 0.03 gpm. Under abnormal conditions, the error could be large enough to be significant.

The inspectors discussed the above concerns with licensee representatives. The licensee agreed to ensure that only one letdown orifice is in service during leak rate calculations, thereby eliminating errors due to pressurizer level chsages, until they revise the procedure.

Corporate engineering has been reviewing the accuracy of various tank level measurements and will consider the RCDT in this effort. The inspectors noted that all completed leak rate calculations they reviewed remained within technical specification limits when corrected for the above discussed errors. This area is considered an unresolved item (344/86-02-01) and will be further reviewed after the licensee has considered the inspectors' concerns.

8.

Organization and Administration The inspectors reviewed the licensee's organizational structure to verify that the onsite organization was functioning as described in the administrative controls section of the facility technical specifications.

The licensee has made one change in the past year which is not yet reflected in figure 6.2-2 of the technical specifications. As of January 1, 1986, the onsite quality assurance group was divided into two separate groups consisting of quality control and quality assurance. These groups report to the corporate quality assurance manager, whereas the previous onsite quality assurance group reported to the plant manager. The licensee submitted license change application (LCA) 129, dated September 13, 1985,- to the NRC to reflect this organizational change in the technical specifications.

At the conclusion of the inspection, discussions with the NRC licensing project manager indicated that the LCA would be shortly approved. The change strengthens the quality assurance

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organization in that'the onsite personnel are now independent of the plant staff and the activities of the onsite and offsite quality assurance personnel are better coordinated.

Section 6.3 of the technical specifications requires the facility staff to meet or exceed the minimum qualifications of ANSI N18.1 -_1971 for comparable positions. The Trojan Office Supervisor maintains a master volume of all plant positions and job descriptions. Review of the job descriptions is controlled by Administrative Order A0-1-9, " Personnel Qualifications Periodic Reviews." The inspectors reviewed selected position qualification requirements as listed in the licensee's master volume against the ANSI requirements for comparable positions.

In all cases, the licensee's requirements met or exceeded that required by the ANSI standard.

The licensee's control of deviations froa work overtime guidelines is described by A0-3-1, " Shift Complement and Work Time."

As allowed by technical specifications, personnel may work hours beyond the guidelines stated in the technical specifications, provided the plant manager approves the deviation in advance. The inspectors reviewed the individual work time records for mechanical maintenance workers and selected ten instances where individuals had work hours beyond the guidelines.

In all cases, the deviation had been approved by the plant manager and was filed in the facility records vault.

In reviewing the approved deviations on file, the inspectors noted that deviations had been approved for the performance of steam generator eddy current testing during the 1985 refueling outage. The work-involved approximately 50 personnel. Discussions with a supervisor involved with the job indicated that many of the personnel concerned did not work hours beyond the guidelines, however,.the deviation had been approved as a contingency.

The inspectors felt that a closer control of individual overtime would have been more appropriate. This concern was discussed with the plant manager.

The inspectors also observed that the forms used to document overtime deviations did not' require that the period of time for which the deviation applied be stated on L the form. The inspectors discussed this with plant management, who agreed to revise the form.

No deviations or violation's were. identified.

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General Employee Training

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During this reporting period, the licensee conducted annual general employee training for their personnel. This training reviews plant requirements in' areas such as security, fire protection, industrial safety, and quality. assurance. Senior company management also utilized these sessions _astan opportunity to discuss plant performance and company goals directly with plant employees. The company President, Vice

' President-Nuclear, Plant General Manager, Manager-Quality Assurance, and Quality Assurance Operations Branch Manager, all perticipated in these sessions. The inspectors attended their presentations to one ;;roup of employees and concluded that management's participation in general employee training is an effective means for company expectations and

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priorities to~be directly presented to the plant employees. Of particular note, the company's increased emphasis in formal quality assurance activities was discussed by several of the speakers.

i-No violations or deviations were identified.

10.

Followup On Steam Generator Snubber Inoperability As reported in Licensee Event Report (LER) 85-13, the licensee found the steam generator hydraulic snubbers to be in a degraded state during surveillance testing conducted in conjunction with the 1985 refueling outage. The licensee analyzed the worst case stresses that would result on the reactor coolant system (RCS) if the snubbers all locked up and determined that the 'B' RCS hot leg would experience the highest stress.

This stress would be in excess of the yield stress for the material, however, additional plastic analysis indicated that the strain that would be experienced would be within code allowable limits. Although the design and physical layout of the steam generator snubbers appear to make the probability of their locking up very remote, unusual movement by the pressurizer surge line tends to indicate that the 'B' hot leg may have experienced some unexpected stress due to the snubber problems.

While the licensee's analysis indicates that the worst case situation would remain within code allowable limits, the inspectors questioned the licensee concerning what physical inspections would be conducted to I

verify that no unacceptable conditions resulted from the degraded snubbers.

Licensee representatives stated that while they were confident that no unacceptable condition had resulted, their intention was to-inspect the steam generator support column bolts during the 1986 outage.

Their analysis indicates that had unusual stresses occurred, the bolting material would have been physically affected, thereby making inspections of these bolts a good physical indicator of an actual high stress condition.

The licensee has not finalized their plans for performing inspections, however, licensee representatives stated that the NRC resident inspectors would be informed when actual inspections to be conducted are finalized.

The inspectors reemphasized their concern that the licensee's analysis should be validated by physical inspections. This event will continue to be followed as part of the inspectors' review of LERs.

No violations or deviations were identified.

11.

Followup On Previously Identified Items Licensee Event Report (LER) 85-09 (Closed): Reactor trip due to unit auxiliary transformer cooling fan fault. The licensee repaired the immediate problems with the cooling fans. The selective tripping scheme for the cooling fans is being considered by the licensee as a long term item. Corrective action taken associated with operational problems with, the auxiliary feedwater (AFW) pumps was closely followed by the inspectors. A meeting between the licensee and NRC Region V was held on August 8, 1985, to' discuss in detail the past performance of the AFW l

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pumps and the licensee's actions to improve their reliability. Details of this meeting are provided in meeting report 85-26.

LER 85-10 (Closed): Reactor trip due to heat tracing short in conjunction with periodic surveillance testing. The licensee has increased efforts to rehedule maintenance activities such that equipment affected by the maintenance are associated with'only one vital power supply at^any1given time. This scheduling will minimize the possibility for this type of trip recurring.

LER 85-11 (Closed):

Pressure instruments incorrectly calibrated. The licensee corrected the pressurizer pressure instruments to reflect the static head of water on the instruments. The setpoints for the AFW pump low suction pressureLtrips were. corrected to compensate for the static

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head of water on those pumps. s The adequacy of the licensee's technical s

reviews was, discussed;with the licensee at a special meeting on December

.13,' 1985. This' meeting' was de' scribed in inspection report 85-39.

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Followup Iten 85-21-02 (Closed): Adequacy of the licensee. engineering technical reviews'..

As described in inspection report 85-39, the licensee and NRC Region V met,ori December 13, 1985, to discuss this issue. The licensee, presented various actions being implemented to improve their performance in this area..The inspectors will continue to be sensitive tolthe~ adequacy of technical reviews.

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. Followup Item 85-34-03 (Closed)i' Residual heat removal (RHR) pump recirculation flow diversion not considered. The licensee contracted the Westinghouse Corporation to review the effect an RHR pump recirculation valve failing open on the emergency core cooling system analysis. The Plant Review Board reviewed the results of this analysis on January 29.

The analysis concluded that a 2 degree increase in peak clad temperature (PCT) would result. This increase is not significant in light of the fact that the plant has an approximately 100 degree margin to the PCT limit of 2200 degrees.

Performance Appraisal Item PA-81-08 (Closed): Nuclear Operations Board (NOB) required to verify corrective action. The inspectors reviewed Nuclear Division Procedure 500-1, which specifies N0B responsibilities.

Paragraph 5.2.0 requires the NOB to identify followup actions to ensure the effectiveness of corrective actions.

Special Report SR-83-01 (Open): Release of noble gas from the south boric acid storage tank (BAST). The licensee took action to reduce the gas pressure in the BASTS, however, discussions with licensee personnel indicate that minor releases have recurred due to losing the loop seal on the vent line. As a final corrective action, the licensee is planning on increasing the vertical length of the loop seal by 11 feet, thus increasing the tank pressure needed to blow out the Isop seal. This design change is scheduled for implementation af ter the 1986 outage.

12.

Miscellaneous Observations During routine tours of the plant, the inspectors noted the door to panel C160 open. Upon request, operations personnel closed the door and

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the' door not fully closed could. compromise their seismic qualification.

The inspectors discussed this' concern with plant' management who' agreed to

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take action to ensure the door remained closed.,

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During'the-inspection period, the inspectors observed increased quality

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.No violations or deviations.were identified.

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the inspectors summarized the scope and findings of the inspection.

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