IR 05000344/1987013
| ML20238C771 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/31/1987 |
| From: | Alexander S, Potapovs U Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20238C759 | List: |
| References | |
| 50-344-87-13, IEB-79-01B, IEB-79-1B, IEIN-86-053, IEIN-86-071, IEIN-86-53, IEIN-86-71, TAC-42502, NUDOCS 8709100362 | |
| Download: ML20238C771 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION
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Report No.: 50-344/87-13 Docket No.: 50-344 i
License No.: HPF-1 ,.
Licensee: Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204 3 Facility Name: Trojan Nuclear Plant Inspection'At: Portland General Electric Engineering Offices Portland, Oregon and Trojan Nuclear Plant Box 439, Rainier, Oregon 97048 Inspection Conducted: May 10 through 22, 1987 Inspector:
5. D. A
exander,' 5pecial Projects
[' Date 6[8 Inspection Section (SPIS), VIB i
Also participating in the inspection and contributing to the report were:
E. Merschoff, Acting Chief, Vendor Inspection Branch, DRIS, NRR H. Stromberg, Consultant Engineer, Idaho National Engineering Laboratory J. Stoffel, Consultant Engineer, Idaho National. Engineering Laboratory 11. Jacobus, Member of Technical Staff, Sandia National Laboratories V. Nicolette, Member of Technical. Staff, Sandia National Laboratories J. Burdoin, Reactor Engineer, NRC Region V C. Paulk, Reactor Engineer, NRC Region II Approved by: A2-d?-
U. Potapovs, Chief, SPlb, tendor
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8 -3 / - P7 Date Inspection Branch .
Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation hp DOC M
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INSPECTION SUMMARY:
Inspection on: May 18 through 22, 1987 (Inspection Report No. 50-344/87-13)
Areas Inspected: Special, announced inspection to review Portland General Electric Company's (PGE's) implementation of a program for establishing and maintaining the environmental qualification (EQ) of electrical equipment important to safety at Trojan Nuclear Plant (TNP) in compliance with 10 CFR 50.49. The inspection also included evaluation of implementation of EQ corrective action commitments made by PGE as a result of deficiencies identified in Safety Evaluation Reports (SERs) and Franklin Research Center (FRC) Technical Evaluation Reports (TERs).
Results: The inspectors determined that PGE has implemented a program that meets the requirements of 10 CFR 50.49 at TNP except for certain deficiencies l
identified in this inspection report (Tabulated in Appendix A to this report).
Three of these deficiencies are classified as Potential Enforcement / Unresolved Items and will be referred to the NRC Region V office for further action. They included failure of EQ documentation to establish that functional performance requirements, i.e., accuracies, were met during design basis accident conditions for Minco S8809 resistance temperature detectors (RTDs) used for density compensation in the reactor vessel level indication system (RVLIS), and for Rosemount 176KF RTDs, which provide signals to the subcooling margin monitoring (SMM) system. The third Potential Enforcement / Unresolved Item related to the failure to maintain Limitorque motor-operated valve actuators in containment in a qualified configuration in that gear case grease relief dust / shipping caps had not been remove Seven additional concerns were classified as Open Items, and a future NRC inspection will review your actions concerning them. No deficiencies were
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identified in PGE's implementation of SER/TER corrective action commitment l l
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DISCUSSION j l Persons- Contacted: See Appendix B l
\ Purpose The purpose of this inspection was to review Portland General Electric l l
Company's Trojan Nuclear (PGE's)
Plant imp (lamentation TNP) of the requirements ar.d the implementation of 10action of corrective CFR 50.49 for its commitments made as a result of deficiencies identified in Safety Evaluation Reports (SERs) and Franklin Research Center (FRC) Technical Evaluation Reports l (TEks). l Background Under the provisions of Comission Memorandum and Order CLI-80-21 of May 23, 1980 and based on having operating license (OL) NPF-1, issued November 21, 1975, PGE was required to qualify applicable TNP equipment in accordance with the provisions of Enclosure 4 to IE Bulletin 79-01B, the Division of Operating Reactors (DOR) Guidelines. PGE committed to qualify in accordance with NUREG-0586, Category I, that equipment required to be added in accordance with .
HUREG-0737 and Regulatory Guide 1.9 l The NRC issued an EQ SER, dated 12/17/82, to PGE which forwarded the FRC TER on ,
ThP. PGE submittals of 12/30/82, 1/14/83, 1/21/83 and 3/25/83 forwarded'PGE's i responses to the TER and SER including proposed corrective action for dclicien-cies. PGE's letter of 5/20/83 forwarded their initial response to 10 CFR 50.4 I The hRC held a meeting with PGE on 3/27/84 to discuss remaining open issues regarding EQ for TNP followed by an NRC inspection and EQ file review. Discus-sions included (1) PGE's proposed resolution of the deficiencies identified in the SER of 1E/17/82 and the FRC TER that it forwarded, (2) PGE's general method for ccmpliance with 10 CFR 50.49, and (3) justifications for continued safe operation (JCOs) on equipment for which environmental qualification was not yet completed. A summary of the 3/27/84 meeting, PGE's EQ methodology for TNP and resolutions to outstanding items, JCOs with a request and justification for compliance schedule extension and a revised EQ master equipment list were included in PGE's 5/15/84 and 5/16/84 submittals to the NRC. PGE final resolu-tions to EQ issues and status of corrective actions were forwarded to the NRC in their 6/1/84 submittal. The Final SER on EQ for TNP was issued to PGE on 12/4/8 PGE certified compliance with 10 CFR 50.49 in response to Generic Letter 84-24 for ThP in its letter of 1/28/85. In this submittal, PGE noted that the only exception was an extension past the March 31, 1985 deadline, approved to 'C November 30, 1985 by NRC letter of 8/6/84, for several auxiliary feedwater flou control valve actuators requiring replacement with qualified equipment, ,
because replacement actuators were not expected to be received before September 198 _ _ _ _ _ - _ .
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. Findings The NRC inspectors examined PGE's program for establishing and maintaining the qualification of TNP equipment within the scope of 10 CFR 50.49. The program was evaluated by examination of PGE's qualification documentation files, review of procedures for controlling EQ efforts, and verification of the adequacy and accuracy of the program for maintaining the qualified status of the applicable equipment at TN Onthebasisoftheinspectionfindings,discussedinmoredeta'ilbelow,the inspection team determined that PGE has implemented a program that meets the requirements of 10 CFR 50.49 for TNP, although some deficiencies were identified (tabulated in Appendix A). No deficiencies were identified in PGE's implementation of SER or TER EQ corrective action commitment .1 Environmental Qualification Program and Procedures Review PGE's " Equipment Environmental Qualification Program" was examined to determine its conformance with requirements of 10 CFR 50.49. PGE's Topical Report PGE-1025, " Environmental Qualification Program Manual," describes the Company's Environmental Qualification (EQ) program on the corporate level. The inspectors examined this principal publication of PGE's EQ program and found that it addresses the following aspects of EQ:
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Regulatory criteria for environmental qualifications
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Equipment reviewed for environ' ental qualifications
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Specifieo environmental conditions and evaluation criteria (temperature / pressure / humidity / chemical effects / radiation / aging)
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Environmental qualification review l
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Environmental qualification documentation Topicc1 Report PGE-1025 adequately addresses PGE's overall equipment EQ program i including the development and maintenance of a qualified equipment master lis I
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4.1.1 EQ Program Implementation The NRC insaectors interviewed personnel of the following groups and examined the applica>1e instructions, procedures and records of these organizations to verify adequate implementation of PGE's EQ program as described in PGE-1025:
4.1.2 Nuclear Plant Engineering and Electrical Branch The inspectors reviewed the following Nuclear Plant Engineering (NPE) and Electrical Engineering Branch (EEB) procedures: j i
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NDP No. 200-21, Rev. 5 dated 6/11/86, " Electrical Equipment Qualification i l Type Qualification Reviews" ;
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NDP No. 200-1, Rev. 6 dated 4/10/87, " Design Change Control"
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EEB Guideline No. 6, dated 7/6/83, " Electrical Equipment Environ.nental Qualification" .
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EEDGuidelineNo.7, dated 9/23/86,"E-2 Drawing,ComponentSummarySheep (CSS)" r The above procedures describe:
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The scope and the method for conducting environmental qualification review, including the documentation used for review, approvals, revision, filing, and control. Procurement and the plant interface for environmental qualification considerations in dealing with such equipmer <
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The processes for the control of design changes for TNP utilizing the Request for Design Change (RDC) process. The RDC provides the basic framework for initiating, evaluating, approving, and implementing design changes to the existing structures, systems and components at TN The specific guidance for coordinating the tasks of drawing control, test report review, and purchasing procedures for completion of equipment l qualification documentatio The spe'cific guidance on preparation and revision of the E-2 drawings to l assure that environmental qualification of electrical components i adequately addressed in plant design change modification work.
l The inspectors concluded that adequate controls have been established in the nuclear engineering department to properly manage the engineering processes associated with the environmental c, qualification of electrical equipmen .1. 3 Procurement The following procurement and related procedures were reviewea by the NRC inspector:
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HDP No. 300-1, Rev. 1, dated 4/21/86, " Procurement Quality Level Classification System"
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NDP ho. 300-2. Rev. O, dated 1/19/86, " Selection of Procurement Sources"
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HDP No. 300-3, Rev. O, dated 2/19/86, " Evaluation of Commcrcial Grade Items"
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NDP No. 300-4, Rev. 0, dated 12/3/86 " Procurement Document Preparation, t Review ano Change Control"
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NDP No. 300-5, Rev. O, " Acceptance of Purchased Items or Services"
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A0-T-25, Rev. 4, dated 9/26/86, " Procurement and Replacement of Environmentally Qualified Electrical Equipment" These procedures establish adequate controls for the procurement, receiving, storing and issuing of environmentally qualified electrical equipmen l l
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4.1.4 Quality Assurance and Control The quality assurance program (QA) as it applies to EQ was reviewed with the QA Manager. The QA Branch conducted an audit of the EQ program in July 1986 and reported the findings in Audit Report CAO-358-86, dated 8/29/8 The inspectors examined this audit in detail to determine the effectiveness of QA's involvement in the EQ progran. The audit delved into the following areas:
training, design control, procurement., procedures, document control, test control, and QA records. Ten deficiency reports in the form of nonconforming activity reports (NCARs) were issued to the responsible organization Ccmpleted corrective actions are required to be reported in writing. The corrective actions had been completed on six of the NCARs with the remaining four NCARs scheduled to be completed by the end of July 1987. Responses to QA 1 findings have resulted in improvements to the EQ progra The inspection revealed that procedures for quality control inspections of the installation of new and replacement EQ equipment at TNP did not clearly ensure i that all replacement and/or modification of qualified equipment would receive !
QA coverage. PGE committed to clarify the appropriate procedures. This issue will be reviewed further during a future NRC inspection and is identified as Open Item 50-344/S7-13-0 ;
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The training program associated with the environmental qualification of electrical equipment was reviewed with the electrical engineering manager who is responsible for EQ training at the corporate offices and the plant training supervisor who is responsible for EQ training at TNP. Training of engineering personnel associated with EQ at the corporate offices is considered adequat Attendance records for EQ instruction conducted at the corporate offices were examined and attendance was found to be good. Some of these training sessions were attended by key plant personnel including lead crafts people. However, training at the plant was found not to be as formalized. Electrical and I&C maintenance personnel had received training in the EQ area, but there were no records to indicate that QC, plant QA and other plant people associated with EQ had received any formal instruction on this subject. During the inspection, PGE committed to expedite implementation of the more formalized EQ site training program they were developing. This area will be reviewed in a future NkC inspection and is identified as Open Item 50-344/87-13-0 .1.6 Operating Experience Review Program (OERP)
c PCE has established Inspection a program and Enforcement forinformation (I&E)) processingnotices and tracking)NRC (formerly (IN and bulletins (IES)
and any action required, including timely responses by PGE of such action This program also includes handling of in-house as well as industry-wide nuclear plant operating experiences, and defects and noncompliance of equip-ment in accordance with 10 CFR 21. This program is described in Topical Report PGE-1044, " Operating Experience Review Program."
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The inspectors examined PGE-1044 and the following Nuclear Disision and Safety ana Regulation Branch procedure (s) which implement the program:
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- NDP No. 100-13. Rev. O dated 4/21/86, " Operating Experience Evaluation" i
- HDP No. 700-1, Rev. 4 dated 1/28/87, " Commitment Control System" l
- NSRP No. 330-2, Rev. 3, dated 5/22/86, " Operating Experience Review l Prograu Administration" , , _ _
PGE's program establishes and describes methods within the company for ensuring that technical information, operating experiences and other lessons learned are 4 implemented in a timely manner to improve the safety and reliability of TNP. A J systematic screening process has been established to review nuclear plant event i
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information, identify and evaluate the important or significant events, and implement appropriate remedial actions. Implementation may include changes to plant procedures, equipment design changes, changes to operator and staff training programs and feedback of significant information to TNP operators and other cognizant personne The major phases of the OERP are (1) input of operating experiences inf ormation,, (2) screening and evaluation of this information, and (3) output of corrective feedback of information. In order to accomplish each major phase of the program, administrative controls are established. These controls include appropriate follow-up and verification, status tracking, and documentation control for records maintenance and closecut. The vehicle for accomplishing these tasks is a serialized, formatted documentation package called an Operational Assessment Review (OAR), in which PGE's actions on an ,
issue are documente l A program coordinator is assigned to the OERP who has the direct responsibility for the day-to-day coordination of the program. Procedure NSRP 330-2 establishes the methods used by the program coordinator for the administration of the OER Procedure NDP 700-1 identifies the system by which PGE's commitments associated )
with TNP are administrative 1y controlled and tracke l The Commitment Tracking List (CTL) is a computer-based document developed to provide a complete listing of these commitments. The OERP Program Coordinator ensures that data pertaining to each operating event assessed in the program is properly entered and followed on the CT .1. Input Phase d The sources of operating experience data for both in-house and industry events are numerous and varied. The OERP interfaces with several organizations to .
ensure the significant events are screened and evaluated by the program. The l following is a listing of operating event information sources from industry !
that are available for input to the operating experience review process:
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INPO significant operating experience and event reports and operations and maintenance reminder
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Nuclear Network Information i
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Supplier /NSSS Vendor Bulletins and Letters
- Safety Defect Reports
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NRC Bulletins and Information Notices
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NRC Generic Letters and Technical Reports Following receipt of operating experience data from the various sources, it is t. hen forwarded to the Program Coordinator within the Nuclear Safety Review Department (NSRD) for the initiation of the screening and evaluation phas .1.6.2 Screening / Evaluation Phase i The screening and evaluation process is coordinated by the Program Coordinator within NSRD. The Program Coordinator screens the information, with assistance frcm appropriate disciplines, to determine applicability and selects the organization with the appropriate expertise to evaluate the operating experience information. Information determined to be particularly significant or time sensitive is distributed to appropriate personnel prior to completion of the evaluation phase. Recommendations for corrective action are developed and used to, define the output phase information. The Program Coordinator utilizes the computerized tracking list for all operating experience information being screened and evaluated as part of the overall assessment proces Procedure NDP 100-13 establishes a uniform method for the evaluation of both industry and TNP-specific operating experience information, including problems, issues, and incident .1.6.3 Output Phase The cutput phase involves the coordination and tracking of the recomended corrective action developed during the screening / evaluation phase through the appropriate implementation / feedback mechanisms within PGE's organizatio These corrective action mechanisms may include design change initiation, procedure revision, training program changes, or information feedback to plant operators and other personnel of the lessons learned from the review of operating experienc Throughout the three major phases, the Program Coordinator is responsible for ensuring that the operating experience information is assessed by the cognizant organizations. The recommended corrective actions are monitored for completion using the CT (
4.1. Information Feedback The monthly Synopsis of Operating Experience" is the primary information feedback method for providing Nuclear Division personnel with a compilation of pertinent operating experience information. The OERP Coordinator is responsible for preparing the monthly report based on information provided by cognizant organizations and, as a result of the information gained, l administrating the OERP. This monthly synopsis is distributed to all licensed I cperators and other appropriate personnel as determined by the Program i Coordinato I l
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The NRC inspectors reviewed the status of actions on EQ-related ins on the CTL computer display and verified implementation _ of PGE's program for processing and tracking NRC bulletins and information notices as~they relate primarily to EQ. Proper functioning of PGE's OERP was further verified by examinating the monthly synopsis reports. These reports included narrative summaries of the evaluations of IEBs,. ins, and other.Significant Operating Events completed during the previous month, referencing the applicable OARS. 0ARs and resultant actions pertaining to selected ins were reviewed in detail and are discussed below: ,,
- IN 66-53, titled Improper Installation of Heat Shrinkable Tubing, and PGE actions regarding it were reviewed in accordance with Temporary Instruc-tion (TI) 2500/17. The review indicated that upon receipt of IN 86-53, {
PGE initiated 0AR 86-61 to evaluate the problem and determine what correc- l tive action would be required. A.three-part action plan was formulated !
including revising procedures,. conducting additional training in splice installation and inspecting installed Raychem splices. As a member of the Nuclear Utility Group on Environmental Qualification (NUGEQ), PGE also participated in a September 1986 Raychem semina Following their action plan, PGE reviewed Raychem technical data appli-cable to TNP. Raychem conducted seminars on splice installation for PGE at the' site and corporate offices. Two training classes.for the crafts were held at the TNP site. The classes were video taped for subsequent use. In preparation for inspecting installations.inside containment, PGE initiated a major program that included a great deal of preliminary work prior to access to the containment scheduled for April 1987. This program included developing inspection procedures and record sheets, identifying and listing affected equipment, reviewing penetrations, researching plant cables for jacket dimensions and qualified substrates, purchasing material reciuired, and researching and obtaining approved cleaning solvent Maintenance Request (MR) 87-1758 was prepared in March 1987 to initiate the inspections and commence the task of replacing the Raychem splices during the refueling outage which started in early April 1987. Twelve teams of one or two electricians and one QC inspector conducted the inspection and replacement. The teams completed detailed inspection record forms for each installation. The records were reviewed by qualified engineering personnel who determined which splices required replacemen The major replacement effort for improper splices included 234 cables at penetrations inside containment covering cable to all e,ualified equipment !
inside containment. Splices at 134 pieces of qualified equipment in J containment were replace The hRC inspectors reviewed CAR 86-61, Maintenance Request (MR) 87-1758, and selected inspection and replacement documents including QA record During the walkdown inside containment, the NRC inspectors examined about 30 newly installed splices. The inspectors concluded that PGE's correc-tive action taken in response to IN 86-53, was adequate. However, it was noted that the procedures for QA inspection of the installation process needed clarification with regard to required hold points and PGE agreed to i clarify them and reemphasize with QA inspectors the need to closely refer to the inspection procedures to ensure that attributes required to be
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certified are not missed and possibly covered in subsequent steps--render-ing them unverifiable. This issue will be reviewed in a future NRC inspection and is identified as Open Item 50-344/87-13-0 H 86-03, dealing directly with Unidentified Wire in Limitorque Motorized Valve Actuators prompted an extensive inspection and review project under 0AR C6-14. PGE provided Limitorque with the shop order numbers for all actuators purchased for TNP. On the basis of correspondence from Limitorque, PGE classified actuators with respect to the level of confidence in the documentation of their wiring; i.e., (11 those shop order numbers for which Limitorque certified what wire was actually used, (2) those for which Limitorque certified what wire it was their practice to use at the time of manufacture of actuators under those order numbers <
and (3) those for which Limitorque stated that PVC insulated wire of a type similar to that testec would have been installed by them. PGE then further classified these actuators on the basis of type and severity of accident environment. Their plan was to inspect one in-containment actuator from each of the groups supplied under the various shop order nunbers (a total of six) and to rewire six outside containment which were in high (10 megarad) total integrated dose (TID) radiation fields during the April through June 1986 outag In thes'e inspections, PGE discovered some unidentifiable wiring along with that which agreed with their documentation. The sample was expanded to include all in-containment Limitorque internal wiring and, as a result, i all wiring not identified as either Rockbestos Firewall SIS or Raychem Flametrol was replaced with qualified GE Vulkene Supreme SIS during the 1986 outag The remainingof(Limitorques environments less than 5 (outside megarads containment)
TID) for the were in radiation-only accidents for which they were required to be qualified. Documentation indicated that they l contained polyvinyl chloride (PVC) insulated wiring of type "TW" or "TEW."
They were reviewed for qualification as documented in TNP Nonconformance Report (NCR)86-019 on the basis of 11 years service through the outage to begin in April 1987 and on the basis of minimum, application specific, operating time requirements. PGE concluded that they could be considered i qualified for their applications until rewiring during the 1987 outage l based on their not exceeding known PVC radiation degradation thresholds.
- Qualification for 40 years plus Regulatory Guide 1.97 operating times (to be implemented by the end of the 1987 outage) would require rewiring during that outag Completion of rewiring and several other Limitorque corrective maintenance ;
and modifications were undertaken under a comprehensive Request for Design Change (RDC) pcckage No. RDC-66-033. Under this program, all internal wiring in Limitorques required to be qualified was to M replaceo with qualified GE Vulkene Supreme SIS wire by the end of the 1987 outage (in progress during the NRC inspection). This included qualified Raychem and
< Rockbestos wire not replaced previously. All Limitorques examined
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internally during the NRC inspection walkdown had Vulkene Supreme wire installed. In view of the comprehensive scope of RDC-86-033, its comple-tion will be reviewed in a future NRC inspection and is identified as Open i Item 50-344/87-13-0 __ -
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IN 86-02 deals with magnesium rotors in Limitorque ac motors. PGE l initiated 0AR 86-12 in April 1986 to evaluate the potential magnesium alloy rotor bar problem identified in IN 66-02. This OAR concluded that TNP has two Limitorques with magnesium alloy rotors: M0-2069A and 2069B in environments of concern. These were qualified under Limitorque EQ Report 600198A instead of 600456. The OAR states that the Pressurized Water Reactor (PWR) test parameters used envelope TNP's requirement l Based on this and the additional justification provided in OAR 86-12, the two Limitorques in question were considered qualified for,their applications et TN IN 86-71 identified immediate operational and long-term EQ concerns about energized space heaters in Limitorques. Of immediate operational concern c is the possibility that wiring in contact with or in close proximity to
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the heater elements could be burned, possibly rendering the Limitorques
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inoperable. Also, the resulting elevated ambient temperatures within the motor and limit switch compartments could invalidate Arrhenius qualified life calculations unless the higher ambient temperatures are taken into l accoun TNP personnel had found nine Limitorques in containment with heaters connected. All heaters have now been removed as part of the RDC 86-033 l package'. PGE had not recomputed the qualified life based on the heaters being energized since installation. As a result of concerns raised by the NRC inspectors, these calculations were performed (Bechtel EQG Calculation No. E-1494-1, Rev. 1). The calculation assumed a worst case 11 years of heaters being energized and the results showed that the qualified life of l these Limitorques is now less than the 40-year life without heaters--
although, none had exceeded their qualified lives. EQ files, drawings, and maintenance procedures and replacement schedules will be modified accordingly. Implementation of these measures will be reviewec in a futurc NRC inspection and is identified as Open item 50-344/87-13-0 .
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IN 84-90 concerned qualification problems resulting from the superheated l steam environment created in enclosed spaces outside containment when,
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during a large main steam line break (MSLB), steam generator tubes are
, uncovered by the resulting blowdown producing superheated steam. Upon I
receipt of IN 84-90, PGE initiated OAR 85-12 to evaluate the problem and l Joined the Westinghouse Owners' Group (WOG) Subgroup formed to deal with the issue. The WOG Subgroup contracted with Westinghouse to reanalyze this accident and the resultant mass and energy release data for TNP were received by PGE in October 1985. Bechtel did the calculations for PGE to l convert these data to time-dependent temperature and pressure profiles for
! the affected spaces. These profiles were evaluated by the Nuclear Plant c Engineering (NPE) Electrical Branch for impact on EQ in May 1986.
l The result was that no equipment in the space of principal concern, the main steam support structure (HSSS), needed to be replaced or protected because the MSSS is open to atmospheric pressure at the top and sides, thereby limiting the severity of liSLB conditions such that they were still enveloped by existing qualification parameters for installed qualified equipment. There were, however, five types of equipment whose environments were now judged to be harsh, which were replaced with qualified equipment during a 1965 outage modification package. These included AFW flow control valve and their associated Clark relays
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(replaced with Limitcrques), Rosemount 1153A pressure transmitters (replaced by ITT barton transmitters), Lawrence solenoid operated valves (SOVs) (replaced by ASCO NP-1 type 50Vs) and Barton 288 flow indicating switches (FISs) (replaced by Barton 580 series FISs). The inspector compared the June 1984 and current EQ master equipment lists confirmed these change '
During review of Bechtel's calculations, PGE discovered two significant errors. Assumptions with regard to the strength of barriers to MSLB/High Energy Line Break (HELB) steam entering the Turbine Building enclosed spaces containing safety-relatea equipment turned out to be invalid; e.g.,
rollup steel doors could not witnstand the postulated differential I pressures and would rupture and admit steam to the affected space q Additionally, it appeared that entry paths for steam through the ventilation system were not taken into account. The result was that now these spaces and the TLrbine Building in general would have to be reviewed as harsh environments'as weil as for ability to withstand the structural stresses involved. The reanalysis revealeo that some equipment in the affected spa::es could no longer be considered environmentally qualifie Accordingly, PGE submitted Licensee Event Report (LER) No. 66-10.
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l Temporary modifications to correct the situation included installing steel I reinforcing plates over the rollup doors to the diesel-driven auxiliary l feedwater (AFW) pump room and the Train "A" engineered safety feature (ESF) switchgear room, removing siding from portions of the Turbine Building to provide a vent path for HELB pressure surge, modifying a door to keep steam out of the emergency diesel generator (EDG) air intakes, and installing dampers in or sealing ventilation ducts to AFW pump rooms and l remote shutdown panel C-160 room. A JC0 was prepared for safety-related Turbine Building equipment in open areas showing that such equipment was
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either environmentally qualified, performed its function before exposure !
to HELB conditions, or would neither fail detrimentally to plant safety nor mislead the operato ;
Permanent corrective actions included replacement of main steamline and I turbine first stage pressure transmitters, reinforcing rollup doors and j other barriers, modifying heating, ventilation and air conditioning (HVAC) ;
ducts for affected spaces, and modifying certain Turbine Building siding i
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panels to blow out while still withstanding design wind loads and '
strengthening others. These measures were to be completed by the end of the 1%7 refueling outag )
i Replacement of safety-related main feedwater control equipment and some i i cable for the "A" component cooling water (CCW) makeup pump was deferreo <
until the 1988 refueling outage due primarily to availability of the replacement equipment. P6E had determined this equipment to be operable l and had prepared a JC0 showing that the equipment either could be exempted l from qualification or that it would perform its' safety function prior to ,
failure and that rubsequent failure would neither degrade any safety function nor mislead the operator. Corrective actions not completed by the end of this inspection will be reviewed in a future NRC inspectio This issue is identified as Open Item 50-344/87-13-09,
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IN 87-08 concerns Limitorque actuator motors manufactured by H. K. Porter (now Peerless-Winsmith) between December 1984 and December 1985 fitted with Nomex/Kapton insulated pigtail leads. This wire is not the wire that was tested and reported on in Limitorque Qualification Report 80009. TNP suffered an operational failure of the Limitorque on valve CV-3004D1 which had the wire in question installed. PGE reported this as a defect under 10 CFF,21 on 5/6/86 which was one of the events leading to the issuance of IN 87-08. Examination of the motor leads revealed abrasions, cuts, and tears in the insulation that allcwed the leads to short circuit together and/or to ground. The evaluation concluded that the Nomex/Kapton insulation system is brittle _and relatively fragile, and thus very :
susceptible to damage during field installation or even under normal i (
conditions of vibration and operating environment; to which, in this case, the damage and resulting electrical faults were attributed at TN TNP has eight of the affected type of Limitorques (EQ Record file No. 64),
all of which serve to actuate AFW flow control valves CV-3004A1 through D2 in the MSSS. In a followup to the 10 CFR 21 report, PGE reported in their letter to the NRC of 6/6/66 that four of these and frour spares were sent to Limitorque for repair and replacements were ordered. Upon their return, four appeared to have been repaired adequately, but the other four were in worse condition than when they had left, with frayed motor lead insulation and low insulation resistance (IR) readings. The four of the originally affected actuators not sent to Limitorque were repaired at TNP by covering the leads with RTV-21 covered with Varglas silicone rubber / ;
fiberglass sleeving. Although this system was qualified to the D0R Guide-
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lines, the Limitorques, being replacement equipment installed in 1985, had been qualified to NUREG-0588, Category I. This was justified as an interim measure under 10 CFR 50.49(1), " sound reasons to the contrary," as defined in Regulatory Guide 1.89, Revision 1, " replacement equipment not available to meet installation and operational schedules."
Subsequently, PGE determined that the Nomex/Kapton motor lead insulation system, as well as the new system now being used for replacement by Limitorque, were not the same as that tested and reported on in Limitorque Report B0009. PGE decided not to deal with Limitorque further on this ;
issue and sent all the motors to Farwell & Hendricks to be completely l rewound, releaded and requalified. This project was to be completed (also as part cf RDC-86-033) during the refueling outage in progress during this inspection. Subsequent to the inspection, PGE reported to this office that the rewound Limitorque motors have been reinstalled and successfully operationally tested. The new qualification will be reviewed in a future NRC inspection along with other RDC-86-033 modifications under Open Item 50-344/87-13-0 $
4.2 Maintenance 4.2.1 The following maintenance procedures applicable to EQ were examined:
- Volume 9 Maintenance Procedures; Electrical, and Instrumentation and l Controls
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EE Branch, EQ-1, dated December 1985, "EQ Maintenance and Surveillance l Program Manual"
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- Administrative Order (AO)-3-9, Rev. 23, dated 11/1/86, " Maintenance Requests"
- A0-5-3, Rev. 15 dated 4/4/86, " Spare Parts Equivalency Evaluation Procedures" These procedures and administrative orders describe the methods, responsi-bilities and instructions for the maintenance and surveillance of qualified equipment. They also provide continuity for program implementation between the corporate office where qualification reviews are documented (NPE) and TNP's ,
onsite departments where actual maintenance and surveillance are performe ]
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4.2.2 Valve Cycling Frequency Concern - Limitorque has recommended that their <
actuators, as a general rule, should be cycled at least twice a year for grease '
mixing and part coating. TNP has eight Limitorques that can only be cycled
, .once a year due to operational considerations. These Limitorques are exercised as part of periodic (annual) operating tests (POTS). When the POT is done, the valves are cycled twice for additional grease mixing and part coatin Limitorque has stipulated that the twice yearly guideline was not meant to ,
apply in all circumstances. Furthermore, PGE showed that no degraded perfor- )
mance or failures attributable to infrequent cycling have been identified at TNP. On the. basis of this evidence, the inspector concluded that the estab-lished cycling frequency supports preservation of qualificatio q l
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( 4.2.3 RDC-86-033 - PGE evaluated various NRC ins and other documents identi-fying Limitorque problems. This resulted in the development of a comprehensive 1 Request for Design Change, RDC-86-033. RDC-86-033 included removal of internal !
terminsi blocks, connecting field-run control wires directly to limit switch a terminals, splicing power cable to motor leads usir.g Raychem WCSF-N heatshrink sleeving, rewiring internal control wire with GE Vulkene Supreme SIS wire, and installing new stainless steel T-drains in switch compartment covers and motor j housings to replace the carbon steel ones installed under a 1983 RDC which :
addressed the T-drain concern. This large undertaking was scheduled to be I completed during the outage in progress at the time of the NRC inspection and was designed to eliminate all the remaining Limitorque EQ problems identified thus far. This effort will be reviewed in a future NRC inspection and is j identified as Open Item 50-344/87-13-0 .2.4 The inspector concluded that adequate controls of maintenance and sur-veillance of qualified equipment have been established to ensure preservation 4 of qualified statu >
4.3 Environmental Qualification Master List (EQML)
The NRC inspection team reviewed the TNP EQML,' PGE Drawing No. E-2 - Master 1 List Formatted Report, dated 5/8/87, and associated documents discussed below and verified the adequacy of the implementation of PGE's EQML development ano-maintenance procedures for TN .i 4.3.1 1he EQML was based on a review of technical specifications, emergency operating procedures (EOPs), piping and instrumentation diagrams (P& ids),
electrical diagrams and Regulatory Guide 1.97 (Revision 3, Categories 1 and 2). i It was prepared as a joint effort of the PGE Electrical Engineering and huclear !
Safety Branches and TNP Operations personne :
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TNP's EQML is actually a formatted report or printout from the EQ information computer data base. The E-2 database is comprised of individual component EQ l records in the form of computerized drawings (designated "E-2" drawings), I similar in content to system-component evaluation worksheets (SCEWs). The iQML 1 includes all electrical equipment important to safety at ThP identified and/or I sorted by plant ID number, device type or service function, model, EQ record !
file number and a field that indicates which items are exempted from EQ, with l reference to the reasons; such as being in a mild environment, not having a i safety function for the harsh environment to which the equipment.may be !
exposed, etc. The list was confirmed by field verification walkdown ,
l 4.3.2 The procedures listed in paragraph 4.1 above establish procedures and I responsibilities assigned to the Electrical Engineering Branch for maintenance d and control of the EQML. Review of these documents indicated that all types of '
equipment required to be qualified under 10 CFR 50.49 would have been covered.
) 4.3.3 As a validation check on TNP's EQML, the E0Ps were reviewed with TNP j operations ex& rts. The inspector selected 12 items of equipment required to I be used with u ergency Instruction (EI) No. EI-1 [ loss-of-coolant accident i (LOCA)/nain steam line break (MSLD)] and verified that they were all either i
listed in the EQML as qualified or were identified as being exempted for a ;
l valid reason. Records pertaining to exemption from EQ of selected EQML items I were reviewed. No unjustified exemptions were identifie .4 Environn. graal Qualification Documentation Files PGE's TNP EQ o] cementation files are established at PGE offices with duplicate files to be maintained at TNP. The files are caibd "EQ Records" and each is prepared for a given manufacturer and model of qualified component in a parti-l cu'nr environment. Qualification is reviewed for the " worst-case" plant appli-cation of the equipment, i.e. subject to the most severe accident environment
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and most stringent functional performance requirements. The records are i structured areund the appropriate "E-2" sheet identified by plant ID number and consist of four sections and other associated drawings. Section 1 includes EQ
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! test reports, calculations, analyses and supporting documentse Section 2 l contains associated correspondence. Section 3 is for review coments and l resolutions ard Section 4 is comprised of the EQ summary and review checklist Tte associated drawings are E-3 (setpoint accuracies), E-4 (indication accu-racies), and E-6 (maintenance requirements). The files also contain OARS that ptrtain to qualified equipmen The NRC inspectors examined records for 25 selected equipment type In addition to comparing plant service conditions with qualification test conditions and verifying the bases for these conditions, the inspectors selec- d tively reviewed areas such as (1) required postaccident operating time compared to the duration of time the equipment has been demonstrated to be qualified, (2) similarity of tested equipment to that installed in the plant (e.g.,
insulation class, materials of components of the equipment, tested configura-tion compared to installed configuration, and documentation of both), (3)
evaluation of adegJacy of test conditions, (4) acing calculations for qualified life and replacement interval determination, (5) effects of decreases in insulation resistance on equipment performance, (6) adequacy of demonstrated accuracy, (7) evaluation of test anomalies, and (8) applicability of EQ problems reported in NRC IE information notices and bulletins and their resolution ___--_- -
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The EQ record files were found to be generally well organized and auditabl j Specific documentation findings and comments were as iollows: j i
4. EQ Record No. 54 - Minco Type S8809 Resistance Temperature Detectors l
The Minco resistance temperature detectors (RTDs), used for density compensa-tion in the reactor vessel level indication system (kVLIS) were installed as post-accident unitoring equipment and the EQ criterion for them was NUREG-056b, Category Westinghouse Report WCAP-8687, Supplement.2-E42A, Revision 1, cated January 1985, on which the qualification was based, contained no standard temperature reference with which to compare raw data (RTD output)
and verify that RTD accuracy requirements (25.0'F) were met during the LOCA simulation test. The Westinghouse report claimed an accuracy of 1.0'F on the $
basis of their analysis that indicated that this accuracy is assured when the j lead-to-RTD body insulation resistance (IR) is at least 0.5 megohm. All IR i measurements taken during the test were greater than 0.5 megohms. However, only lead-to-body (conouctor-to-ground) irs were measured. No conductor-to-conductor IR or leakage current per se was measured, which may be a likely leakage path not accurately measured by conouctor to ground measurements. The report contained graphs of RTD output and a LOCA chamber thermocouple vs. time which showed that the RTDs remained operable thoughout the test and tracked with the chamber temperature profile. PGE contended that their outputs differed from each other and from the chamber thermocouple output by more than 5.0*F due to (1) their being in different locations within the chamber in which significant transient thermal gradients could exist and (2)
their being attached to water-filled pipe sections (to simulate their installation) causing thermal lag and possibly helping to maintain steady-state tem 3erature gracients. To support the acceptance criterion used, PGE cited a tecinical reference which stated that RTD lead-to-body IR is an acceptable performance acceptance criterion. Until resolved, this issue is identified as I
Potential Enforcement / Unresolved Item 50-364/87-13-0 .4.E EQ Record No. 15 - Rosemount Type 176KF RTDs These R1Ds, which measure reactor coolant system (RCS) loop temperatures and input to the RCS subcooling margin monitor system, arc located insioe contair-ment. As original plant equipment they were to be qualifiec under the DDR {
Guidelines. Westinghouse Test Report WCAP-9157 indicated that narrow range j 176KF RTDs were tested. The wide range RTDs (176LS), used in the same appli-cation, and also covered by WCAP-9157, are identical except for a slightly longer length. No LOCA test RTD performance data were given in the report I other than pre- and post-test calibration data. No IR values were given and j the report did not state that any were recorded during the tes The concern that testing had not demonstrated that the manufacturer's accuracy specifications were met was raised in the FRC TER (TER Item ho. ES). In their post-meeting submittal to the NRC, dated 6/1/84, PGE contended that the manu-facturer's accuracy specification was for normal operation only and not en appropriate acceptance criterion for accident performance. They further asserted thbt the testing demonstrated sufficent RTD accuracy to meet TNP's specific accident functional performance requirements. This resolution was accepted generally along with all the others in the Final SER on EQ for TNP issued to PGE on 12/4/84. However, the EQ record file as reviewed during this inspection did not contain documented performance data to support PGE's post-meeting submittal assertion. Thus, meeting of accuracy requirements could not be verified based on WCAP-9157 alon '
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In response to this identified deficiency. PGE researched their files and found a Sandia National Laboratories report (NUREG-CR/3597 (SAND 84-093) of 12/84)
that reported satisfactory performance (with respect to test criteria) for these RTDs under conditions generally applicable to pressurized water reactor LOCAs. PGE committed to review this report formally for qualification applica-bility to the TNP environment as well as for appropriateness of the reported performance data to the specific TNP application;;. They were to incorporate this information in the EQ file as supplemental cata to demonstrate that perfor-mance requirements were met. Subsequent to the inspection PGE, reported that this had been done. However, the EQ file as reviewed failed to establish that functional performance requirements werr met under accident conditions, and PGE had not conducted or documented the required review of the Sandia report for TNP environmental and functional applicability. Therefore, this is identified (
as Potential Enforcement / Unresolved Item 50-344/67-13-02.
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4.4.3 EQ Record No. 76 - Weed RTD The qualification criterion for this file is NUREG-0588, Category The file contained National Testing Service Report 548-8854-2 of October 1982. The file lacked conclusive evidence that the installed RTDs were similar to the tested
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ones. A certification letter of conformance from the vendor indicating that I the above test report was appropriate for qualification of the installed RTDs was included in the file, but contained insufficient detail for the reader to make an independent judgement of similarity. It was not clear that the file established any accuracy requirements for these RTDs nor did the file show that RTD accuracy had been demonstrated during the LOCA test. PGE presented evidence identifying the installed RTD (used to measure containment temperature) as being similar to the tested ones and they showed that this Regulatory Guide 1.97 post-accident monitoring parameter had no accuracy requirements specified. PGE also stated that the RTD was not required to be used specifically in carrying out emergency operating procedure .5 Plant Walkdown Inspection The inspectors conducted a physical inspection of 10 selected aieces of equip-
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ment and field wiring outside containment. Equipment was chec<ed for nameplate data or other identifying marking, mounting location and orientation, material condition and pr o ervation, installation interfaces, normal service ambient environmental and functional conditions and any special features or attributes to verify that all conditions were consistent with the requirements identified in the EQ documentation files, including evidence, where applicable, that required EQ-related maintenance had been performed. The inspectors also examined Limitorque valve actuator internal wiring in accordance with NRC Temporary Instruction (TI) 2515/75 to assess the existing conditions and PGE actions relative to IE Information Notice 86-03. The results of the walkdown inspection are discussed below:
4.5.1 Field Wiring Identification i
During the plant walkdown, field wiring identification tag numbers were recorded and a check was conducted to verify that identification matched the numbers on plant wiring diagrams. The inspectors reviewed TNP's system of
! cable traceability and found it should be generally adequate. However, PGE l personnel, using this system could not produce, within the time allowed by the inspection, all the archived records necessary to trace selected component and
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. i cable numbers to a particular manufacturer, type, lot etc., of cable. The I readily available records, principally the computerize " Circuit Schedule," i could trace from a component or cable number to a cable specification number called the " Cable Code" (similar to a " mark number"). These were traceable to EQ documentation via the E-2 number suffix which included the Cable Cod However, not all cable with the same code is necessarily from the same manufac- l turer, nor is it necessarily qualified. PGE was not able to retrieve all j installation, QA, and procurement records in the time available needed to show ;
exactly which cable was which type, but could produce procurement documents for l qualified cable for the Cable Codes of the selected cables. Some of these were l able to be matched with those cables of the sample which were visually identi- l fied. No Cable Codes on E-2s were found to lack procurement documents for q qualified cable and no instances were noted of discrepancies between installed i cables anc EQ documentation. Review of the system and review of EQ procurement i and material handling QA controls provided some assurance that only the quali- )
fied cable of a given Cable Code would be installed in applications required to be qualified. PGE was to identify the location for retrieval of all pertinent records required to confirm traceability of the selected cables to EQ documen-tation, which will be reviewed in a future NRC inspection. This is identified as Open Item 50-344/87-13-1 .5.2 Dust' Caps on Limitorque Gear Case Grease Reliefs in Containment j isin gear case grease reliefs were installed on qualified !tmitorques examined in containment. However, Limitorques on valves M0-2069B - Residual Heat i Removal Sumr Recirculation Isolation, M0-3296 - Component Cooling Water (CCW) i to Reactor Coolant Pump Lube Oil Cooler / letdown Heat Exchanger Isolation, MO-3300 - CCW from RCP lube oil cooler / letdown heat exchanger isolation, MV-6703 - RHR Hot Leg Injection Isolation and M0-3320 - CCW to RCP lube oil coole"/ letdown heat exchanger isolation had dust caps still installed on the reliefs. PGE committed to inspect of all Limitorques and to remove any grease relief dust covers inside and outside of containment. These Limitorques were not maintained in a condition similar to tnat in which they were tested (with reliefs uncapped) and the EQ file contained no justification for this deviation. This is identified as Potential Enforcement / Unresolved Item l 50-344/87-13-03.
l 4.5.3 Limitorque Serial Number Discrepancies Several Limitorques inspected had different serial numbers from those listed on the E-2 Drawing. Examples of valves whose Limitorques had discrepant numbers were:
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MOV-2069B, Residual Heat Removal Sump Recirculation Isolation (in containment) -
! The serial number on the nameplate was 170580, but listed on the E-2 drawing as l 179579.
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f10-3296, Compontrt Cooling Water (CCW) to Reactor Coolant Pump Lube Oil Cooler /
Letdown Heat Exchanger Isolution (in containment) - The serial number on the nameplate was 166774 and on the E-2 drawing was 165744.
l M0-3320, CCW to RCP lube oil cooler / letdown heat exchanger isolation (in con-tainment) - The nameplate serial number was 166773, listed as 166743 on E- .-_ -
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J M0-10006 - The serial number on the E-2 record for th( Reliance motor was B7106275N-RJ-2. The serial number on the motor nameple te was B7106275M-RJ- PGE showed that serial number verification and document correction was in progress under the comprehensive Limitorque EQ-related maintenance project, RDC 86-033. PGE also showed that this did not affect qualification since the Limitorques were identified for EQ purposes by shop order number and traceable through installation records to plant ID numbe '~
4.5.4 NO-10006 - Grease Reliefs with Fittings A grease fitting was installed in the threaded hole at the grease relief exit port. This nipple had grease on it, implying that someone had tried to inject c grease into it. This condition was also identified on the adjacent valv These units are located in the electrical penetration room outside containment and do not require a grease relief since high temperatures will not be experi-enced in this area. PGE committed to inspect all Limitorque grease reliefs and to remove any grease nipples as well as the dust caps discussed in paragraph 4.5.2 above. It was also noted that the local mechanical position indicator was broken (dial hand and glass cover missing). The mechanical indicator is not EQ related and this was pointed out as a maintenance item. PGE had already documented t.his condition, and the indicator is to be installed when the new part is available from Limitorque. PGE will confirm that the broken indicator does not affect the operability of the valve.
l 4.5.5 CV-3004A1 - AFW Flow Control Valve (MSSS)
l There was a section of unlagged steam pipe adjacent to the actuator. PGE showed that the lagging had been removed to facilitate removal of the actuator motor housing for rewinding and that their controls would ensure that it would be replaced. With the lagging reinstalled, the temperature at the Limitorque .
is less than that assumed in qualified life calculations, thus, concerns over I the shortening of qualified life are alleviate {
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APPENDIX A TABLE OF FINDINGS Inspection on: May 18 through 22, 1987 (Inspection Report No. 50-344/87-13)
Report Item Paragraph Item Nun.by Potential Enforcement / Unresolved Items: Failure to establish that Minco 4. /87-13-01 ;
Type S8809 RTDs met functional performance requirements l
l Failure to establish that Rosemount 4. /87-13-02 Type 176KF R1Ds met functional i
performance requirements 1 Dust caps on Limitorque gear 4. /87-13-03 case gr, ease relief valves in containment Open Items: Raychem Sleeve Installation 4.1. /87-13-04 Hold Points (IN 86-53) Limitorque Space Heater Effects 4.1. /87-13-05 (IN 86-71) Limitorque EQ-Related Maint+oance 4.1. /87-13-06 and Modifications (RDC-86 ,.s) and 4. . Quality Control Coverage of 4. /87-13-07 Ocalified Equipment Maintenance ; Site EQ Training Formalization 4. /87-13-08 High Energy Line Break Deficiencies 4.1. /a7-13-09 in Turbine Building (IN 84-50)
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10. Traceability of Field-run Cable 4. /87-13-10 d
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APPENDI'( B Persons Contacted B.1' Portland General Electric' Company (PGE)
- D. W. Cockfield, VP Nuclear '--
C. A. Olmstead, Plant General Manager
- E. L. Davis, Branch Manager, Electrical Engineering
- J. C. Perry, Electrical. Engineering Supervisor 4
- G. A. Zimmerman, Manager,. Nuclear Regulation Branch'
- A.~R. Ankrum, Nuclear Engineer, NRB
, 'C. H. Brown, Operations Quality Assurance Manager D. D. Wheeler, Quality Control Supervisor H. E. Rosenbach, Materials Control Supervisor
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S. B. Nichols, Trojan Training Supervisor R. L. Bennett, Control and Electrical Supervisor D. B. Roberts, head Storekeeper D. L. Thompson, Lead Materials Receiving QC Inspector R. P. Wolford, Level 3 Electrical QC Inspector M. H. Malmros, Nuclear Safety and Regulation' Branch
- H. A. Peeny, Supervising Engineer, NPE
- D. R. Swanson, Manager, Nuclear Safety Branch
- A. N. Roller, Manager.. Nuclear Plant Engr. Dep *J. L. Dunlop, Branch Manager, QA Engineering & Support
- T. D. Walt, Manager, Nuclear Safety & Regulation M. N. Islam, Engineer
- C. P. Yundt, Genera 1' Manager, Technical Functions
- R. P. Schmitt, Manager, Trojan Operations & Maintenance
- R. P. Sheppard, QA Engineer
- C. J. Piluso, Supervising Engineer
- R. C. Jarman, Manager, NQAD B.2 Consultants to PGE B. K. Dilodare, Engineering Supervisor, Bechtel E.3 Observers
- H. F. Moomey, Trojan Resident, Oregon Department of Energy B.4 NRC t
- 6. Y. Suh, NRC Resident Inspector, TNP
- T. Chan, hRC/NRR/PD35 Licensing Preject Manager
- Denotes those present at the exit meeting at the PGE Portland offices'on I May 22, 198 > B-1 1