IR 05000344/1987014

Insp Rept 50-344/87-14 on 870420-0501.No Violations Noted. Major Areas Inspected:Ie Bulletins,Unresolved Enforcement Items,Followup Items & Part 21 Repts

ML20215J301
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/03/1987
From:	Clark C, Jim Melfi, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20215J281	List: IR 05000344/1987014 ML20215J277
References
50-344-87-14, IEB-85-003, IEB-85-3, NUDOCS 8706240393
Download: ML20215J301 (14)

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t U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No: 50-344/87-14 Docket No. 50-344 License No. NPF-1 Licensee: . Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection at: Rainier, Oregon (Trojan Site)

Inspection conducted: April 20 - May 1, 1987 Inspectors: /-- ' M [ J . 8 r/87 p . Melfi' Rfactor Inspector Dra te ' Signed

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/C. A. Clafk,/4eactor Inspector s'jhy/b 7 Date Signed i Approved by: M. M [

S. A..Richards, Chief," Engineering Section f-2 9# 7 Date Signed Sungnary:

Inspection During the Period of April 20 - May 1, 1987 (Report 50-344/87-14)

Areas Inspected: Routine unannounced inspection by regional based i inspectors, of areas covering Inspection and Enforcement (IE) Bulletins, 4 Unresolved, Enforcement items, Followup items and Part 21 Reports. Inspection Procedures 30703, 92700, 92701, and 25573 were covered during this inspectio Results: In the areas inspected, no violations of NRC requirements were identifie ,

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DETAILS

l Persons Contacted l

. Licensee Personnel

• Cockfield, Vice President, Nuclear

• Olmstead, Trojan General Manager

• Jarman, Manager, Nuclear Quality Assurance Department

• Keuter, Manager, Technical Services

• Zimmerman, Nuclear Regulation Branch Manager

• A. Ankrum, Compliance Engineer

• J. Reid, Manager, Plant Services

• G. Kent, IST Plant Test Engineer

• D. Swan, Maintenance Supervisor

• P. Morton, Plant Engineering Branch Manager

• R. Schmitt, Operations and Maintenance Manager

• Guy, Systems Engineer R. Reinhart, System Engineer

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J. Linn, Electrical Engineer E. Graham, MOV Program Coordinator

M. Rothwell, Engineer

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M. Cooksey, NPE Elect. Eng. Supervisor D. Funk, NPE Engineer J. Siebel, Mechanical Engineer

• Attended the Exit Meeting on April 24, 198 The inspectors also held discussions with other licensee and contractor personnel during the course of the inspectio . (0 pen) IEB 85-03, " Motor-Operated Valve Common Mode Failures During Plant Transients due to Improper Switch Settings"

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This NRC Bulletin requested all licensees to develop and implement a program to ensure that switch settings on certain safety-related motor operated valves are selected, set, and maintained correctly to accommodate the maximum differential pressures (DPs) expected on these valves for both normal and abnormal events within the design basi The valves addressed in this bulletin are in the High Pressure Coolant Injection (HPCI) and Auxiliary Feedwater (AFW) System The motor operators on valves can be adjusted to deliver thrusts on the valve and valve stem within a certain range of possible thrust value Valve operators have limit switches which can disconnect power to the motor depending on the amount of stem travel. Torque switches are also installed to disconnect the motor if the valve stem is stuck and the L motor is running. A torque bypass switch is installed to " bypass" the torque switch during initial movements of the stem, since it is possible

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that the torque switch might actuate. By the proper setting of these switches, the valve will operate under the maximum DP across the valve, j_ without damaging the valv u_________________.______________________._________.______ ._ _ _ _ _ . _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _i

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1 The bulletin called for licensees.to review the design basis for the !

valves in the HPCI and AFW systems, that were required to be tested for l operational readiness, in accordance with 10 CFR 50.55a(g). These six ]

requirements were to, (A) review and document the design basis for each l

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valve; (B) establish correct switch. settings from item (A);-(C) change {

'the settings as needed from item (B);~(D) revise procedures to ensure I that the settings are maintained over plant life;'(E) submit a report to )

the NRC within 180 days that informs the NRC on the results of (A) and J the schedule to complete items (B) through (D) and; (F) submit a final 1 report on the completion of the progra I l

The licensee's initial response to the NRC was in a letter (Withers to l Martin, May 8, 1986) which stated that the basis for the differential l pressure was from Westinghouse Owners Group (WOG) recommendation The licensee was still documenting the design basis for the valves and stated that the report would be provided by July 15, 198 The licensee submitted a complete report on the design basis on July 15, 1986. .The ,

licensee's submittal was appropriat '

The licensee has elected not to perform pressure testing of valves in these systems to determine if the valves will lift against the maximum D This is due to problems with bringing the systems-up to pressur The licensee.is relying on analytical means to verify that the valves will operate under the assumed maximum DP. condition The inspector reviewed with the licensee a calculation (MOV-8806), typical for resetting a valve' torque switch. The analytical method is conservative and consistent with industry practic l The inspector reviewed the completed packages and observed the work on d the following valves: j

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MOV-8801A, SMB-0, Boron Injection Tank Discharge MOV-8801B, SMB-0, Boron Injection Tank Discharge I

MOV-8813, SMB-00, SI Pump Mini Flow MOV-8814, SMB-00, SI Pump Mini Flow t

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MOV-8806, SMB-0, SI Pump Suction Valve from RWST These packages contained the as-found and as-left MOV testing data ;

reports, the as-found and as-left switch settings, the engineering torque and thrust settings, and any problems noted with the valv The packages ,

seemed complete and discrepancies noted by the inspector were also '

identified by the license The following procedures were used in conjunction with MOV testing:

MP 12-5, " Valve Motor Operators".

MR 87-1759, " Generic Procedure for Testing of Motor Operated Valves using the M0 VATS 2100/2150 Signature Analysis System with MCC Baseline Signatures".

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, The instructions were followed by the MOV testing group. All instructions were reviewed by responsible licensee personnel. Quality '

Control (QC) involvement in the setting of the switches was noted by the inspector. The torque switches were set with the valve in mid-stroke and the belleville spring in a relaxed conditio The licensee used the Motor Operated Valve Analytis and Testing System (M0 VATS) or their own )

electronic equipment in the setting of limit and/or torque switch '

settings. The settings are based on stem movement. If the stem movement differed from the corresponding disc movement, this would be identified in either trac The bulletin requested that the correct switch settings be established and maintained for the MOVs. The licensee maintains hard cards with the correct switch settings on them in the electrical maintenance supervisors offic These hard cards are xeroxed and used as data sheets when performing valve maintenanc !

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The inspector's review of the bulletin response did not include an audit l of the design differential pressures used to set the valve switche This will be performed by NRR staff personnel. The inspector did review the licensee's program for implementation of the bulletin. The review indicated that the personnel were adequately trained, the schedular commitment was being met, and the implementation of the program was acceptabl This bulletin will remain open only pending the NRC audit of the design pressures used in setting the switche . Unresolved Items Unresolved Item 86-23-04, (0 pen) " Review of Plant Modifications on 8attery Sizing Calculation TE-009" This was an unresolved item from the last Trojan team inspection (August, 1986). The modifications to the 125 volt de batteries changed the load profile to the batteries from the original load 1 study performed in 1975, as reported in the Final Safety Analysis !

Report (FSAR). The load profile was used as input into the sizing calculation TE-009. The load profile had not been updated in spite !

of changes to the de system which could affect the capability of the battery to supply its safety related load The licensee maintained that the emergency loads remained within the profile, even though no documentation had been found that it had been reviewed by Engineerin The batteries must have the capacity to maintain a voltage above 105 volts dc (1.81 volts per cell on a 58 cell battery) to maintain the r design assumptions on circuitry fed by the battery. The original j design assumptions were noted in the original calculatio The

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licensee performed a new calculation (TE-119) for the design loads on the battery, which supersedes calculation TE-00 )

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In.this new calculation, the licensee makes several changes to the load profile and correction factors for temperature and aging. The de light load (120 Amperes) has been transferred from the A train i

battery to the B train batter The length of time for the A train profile has been increased to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from 30. minutes. The B train has had the computer load (135 Amperes) taken off and 15 amperes added for contingency. The loads on the B train then remain i approximately the same. The ficensee notes that the battery could not meet the old criteria (50 F, 80% degradation for aging) for capacity. The licensee has reviewed historicg1 data, and raised the minimum temperature in the battery room to 60 F. This change reduces the temperature correction factor. The new factor for aging is 95%. In the design sizing standard, IEEE 450-1980, the factor for aging is 80%. Since the inverse of the aging factor is used far testing the load profile, both of these changes reduce the amperage that the battery has to deliver during the service test (though above aesign suods).

The inspector has been informed that the computer is not a safety-related loa Therefore, removing the computer from the station battery should not involve a safety issu Based on the review of historical data, the change in temperature factor is acceptable. The reduction in the margin has been discussed with the licensee The battery is due to be replaced in the next refueling outage in 1988. Therefore the reduction in the aging factor (which was meant for end of battery life) is acceptabl At the time of the inspection, the licensee had performed the test j on the B trai The battery did maintain the design amperage and i did not drop battery voltage below 105 volts. The battery passed the new design load profile with the new correction factor This item remains open pending a review of the results on the A train batter l 1 (0 pen) Unresolved Item No. 50-344/85-20-01: IST Program Procedure !

Findings  !

(1) The ASME Code,Section XI and Periodic Engineering Test -

PET-9-4 - require the full range of instruments used for IST, to be no more than three times the reference values measure '

During the initial inspection, the inspectors identified gauges l that exceed these limits (Item 3.a.).

On December 13, 1985 the licensee issued a request for Design Change (RDC) 85-05 to replace the existing identified gauges, that exceeded the above limits. A set of gauges with the correct ranges, are scheduled to be installed per the RDC during the current .ipril/May 1987 refueling outag The licensee has taken appropriate actions on the identified concer __-_. - _______-__- ______-___________-- __ - -

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i (2)Section XI and PET 9-4 require pump tests to be performed by 1

' setting either flow or differential pressure at a reference value and'then determining the other parameters. During the ,

11aitialiinspection, the inspectors identified that some I procedures did not pre-establish either flow or differential pressure.to a reference value (Item 3.b.).

The licensee has issued procedural. changes to correct this ,

situation. The inspector reviewed applicable portions of Periodic Operating Tests - POT-4-1 (Containment Spray) Revision j)

'17, POT-8-1 (Component Cooling Water) Revision 8, POT-16-1

.(Residual Heat Removal) Revision 13 and thel Trojan Nuclear Plant Intervice Testing Program for. Pumps and Valves Second 10-Year-Interval (PGE-1048), Revision 0. These documents now

. address pre-establishment of-either flow or differential pressure (DP) or in the case of the component cooling water

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pumps, the use of a manufacturer's pump curve where it appears .

a set or sets of reference values cannot be established for l eitherL flow or D The licensee has taken appropriate action on.the identified'

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(3)f During the initial inspection the inspectors found valve SF 51

, listed in the first Inservice Testing Program (PGE-1022),

. Amendment 3 of November 1985, as a category ' A' valve requiring leak testing. A review of the 1984 outage test data for containment local leak rate test results,; revealed this valve 3

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was not tested (Item.3.c.').

The licensee reviewed the classification for this valve and deleted it from the IST program. The licensee stated, that since no credit was taken for this valve in mitigating the consequences of an accident or in shutting down the reactor to cold shutdown conditions, that it could be deleted from the IST j p progra ;

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3, l subject, this concern has been resolve !

(4) In 1983 the licensee committed to recategorizing accumulator

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l t discharge cileck valves 8956 A through' D as "AC" and to perform applicable code testing. During the initial inspection the inspectors found that per POT-2-4, these valves were only leak tested if the first check valves from the RCS leaked, and since i these first valves had not leaked, valves 8956 A-D had not been l

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leak tested (Item 3.d.). I A review of PET-9-4 (Revision 6), PET-9-8 (Revision 0) and POT-2-4 (Revision 12), revealed that the licensee has taken appropriate actions to test these valve (5) The initial inspection revealed Pressurizer power operated

. relief valves PCV-455A, 456 and Main Steam system air operated :

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relief valves CV-2210, 2230, 2250 and 2270 pressure set points were not tested per IWV-3510 (Item 3e).

The licensee recategorized the subject valves from BC to B type valves. The licensee has taken the position that testing these Copes-Vulcan air-operated / electronically actuated valves every three months increases the normal number of times these valves have to op' against a differential pressure, thus deteriorating the valve seat and increasing the likelihood of

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causing leakag Relief requests were submitted and approved to test valves during cold shutdown. A review of POT-1-5 (Revision 6) and POT-14 (Revision 0) identified these valves are now scheduled to be full-stroked exercised during cold shutdow The licensee has taken appropriate actions to test these !

valve (6) During the initial inspection several problems were noted regarding safety and relief valve test procedures (Item 3.f.).

These problems were reviewed during this inspection, and their status is identified belo The initial inspection identified that procedure MP-5-1 ,

for pressurizer safety valves was not clear as to what constituted an unacceptable test, who determines the ultimate corrective action and what action was required (testing additional valves). A review of MP-5-1 revision 13, identified that while some additional clarification information has been added, there still is not a sign off in this procedure that the test results observed were acceptable or unacceptable. When this procedure has been completed for a valve and applicable enclosures filled in and signatures recorded, it should be clear what the acceptance criteria was and that the test results were acceptable or unacceptabl Also if an unacceptable test is observed, what additional actions are required or who has to be notified (see paragraph III C of MP-12-15 Revision 7, for an example of additional actions required).

This procedure still needs additional work in the above area On the subject of what additional actions are required if a valve fails a lift test, a review of PET-9-4 data sheet PET-9-4-DBS (page 1 of 1) identified this sheet for safety / relief valve action / evaluation did not have a

"close out follow" section as did data sheets PET-9-4-DBP and PET-9-4-DBV. The licensee stated it would be a good idea to add a "close out follow" section to data sheet PET-9-4-DBS to identify what corrective action was taken for a failed valve test, i

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b. The initial inspection identified that as found lift tests were not required to be performed on valves being repaired. To date the licensee has followed the position that if a valve required repair for other than unacceptable lift performance, then an as found lift test is not require Paragraph II.A.14 of procedure MP-5-1 Revision 13 states pre-maintenance testing may be performed for IST credit if desired, but this type of testing is not required under the current code (1980) or the 1983 code. After repair work is completed, acceptable lift testing is require The purpose of Section XI testing is to verify operational readiness of relief and safety valves, or identify potential problems that may affect safe operation of the plan If the operational readiness of a valve is questionable, then the conservative approach to this question is to test that valve and similar values if the first one is found unacceptabl The question on whether an as found lift test of relief and safety valves scheduled for repairs, for other than unacceptable lift testing results, will be subject to NRC technical staff evaluatio The licensee will be notified of the results of that evaluatio c. The initial inspection identified that procedures MP-5-1 and MP-12-15 allowed averaging of lift test values to determine acceptabilit A review of MP-5-1 identified that while paragraph III.A.3.f stated "the acceptable set pressure for all lifts is 2485 psig i 25 psig", enclosure I.B.5 records a lift pressure average, without a clarification about acceptance tolerance on each lift and the average record valu !

A review of MP-12-15 revision 7 identified that while .

enclosure I.B.4 provides setpoints and tolerances for I applicable valves, enclosure I.B.3 records a lift pressure that appears to be an average value, without any clarification that each lift pressure (and therefore the average) has to be within the acceptance toleranc Each above procedure could use additional clarification information, so that there is no misunderstanding that when the final procedural sign offs are made in enclosures, that it is clear that test data was acceptable or unacceptabl An inspector will review the procedures identified above, during a future inspection to verify that these areas on averaging values and acceptance tolerances have been resolve I

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The licensee has resolved the questions on procedure .j findings (1) through (5) identified above, but this item l will remain open until the concerns / questions on procedure {

' finding (6) has been resolved by the licensee and l applicable documents review by an inspecto '

4. Enforcement Items (0 pen) Enforcement Item No. 50-344/86-23-14: Failure to Test Valves in Accordance with ASME XI Requirements  !

The initial inspection identified that several valves were not included in the licensee's IST Program and there was no evidence the NRC had granted relief from testing these valves. The valves identified in this initial review are listed below:

1"-GBD-26CK(2) N2 supply to component cooling water (CCW) surge tank Class I/II interface valve /2"-HBD-65CK(2) N2 bottle supply to CCW surge tank check valve /4-HBD-31(32) Containment air cooler vent / check valve /4-HBD-32(32) Containment air cooler vent / check valve The licensee acknowledge the concerns raised regarding the normal and backup nitrogen supply valves and added them to the new second 3 10 year interval IST Program (PGE-1048). A review of PGE-1048 verified the valves had been added. Per a January 15, 1987 licensee ,

memorandum (GJK-001-087) these valves will be tested on a cold i shutdown interval, instead of the quarterly exercise listed in PGE-1048, as of the date of this inspection. The licensee has taken appropriate' action on this portion of the ite In regards to the 32 containment air cooler vint/ check valves, the licensee disagreed that these should be incluced in the IST Progra The licensee position will be subject to NRC technical staff evaluatio This item will. remain open pending completion of the NRC technical evaluation of the containment air cooler vent / check valve (Closed) Enforcement Item No. 50-344/86-23-17: Procedural Weakness for Component Cooling Water System (1) The initial inspection identified that Operating Instruction 01-4-2, " Component Cooling Water" (CCW), Revision 10, and Off-Normal Instruction ONI-14, " Loss of Component Cooling Water," Revision 0, were not properly maintained to be consistent with the plant design basi In particular, the ,

procedures permitted a maximum CCW heat exchanger outlet 1 temperature of 140 F, whereas, the containment pressure

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analysis limited CCW heat exchanger outlet temperature to a maximum of:120 ]

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A review of'01-4-2 (Revision 12) and ONI-14 (Revision 6) during f this inspection verified that these procedures had been revised i as of those revisions to provide instructions not to allow the l

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CCW heat exchanger outlet temperature to exceed 120*F (CCW temperature).

(2) The initial inspection idertified that 01-4-2 had not been properly maintained, since it was not consistent with the plant design basis, as defined in the plant instrument inde It was x

identified that 0I-4-2 specified a 90 psig and a 100 psig setting for the two CCW surge tank backup nitrogen system

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regulators to'be set at 95 psi During this inspection, a review of OI-4-2 (Revision 12)

identified that the specific setting for the two CCW regulators

'had been removed from the procedures. Per discussion with the licensee, the setting provided in the earlier revisions of 01-4-2 were never used to set the CCW regulators, instead a maintenance request was issued each time.they required

, calibration and adjustment. Therefore, the-subject regulator setpointt were removed from the procedur The-licensee has taken appropriate action on this item.

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This item is close (Closed) Enforcement Item No. 50-344/85-20-02: IST-Failure to Perform Additional Valve Testing as Required by ASME Section XI (IWV-3513)

ASME Section XI, Subsection IWV-3513, " Additional Tests," states in part, "When any valve in a system fails.to function properly during a regular test, additional valves in the system shall be tested."

During the initial inspection, the inspectors found where some valves in a system failed, and additional valves were not teste A violation was issue During this inspection, the licensee provided documentation that additional valves in the applicable systems had been tested or were scheduled for testing during the April /May 1987 outage. Also procedure PET-9-4, Revision 6, has been updated to ensure additional valves will be tested in accordance with Section XI requirement In the case of component cooling water (CCW) system valves PSV-3323A i and 3323B, the licensee is aware that these types of valves appear ;

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to fail their initial tests each time, and have stated that they will take an additional look'at these valves to improve their operational readiness. A September 1985 review of the IST Program has added two new valves (PSV-3285A and 3285B) to the test group containing valves PSV-3323A and 3323B, and testing of these similar valves will be followed closely by the license .

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The licensee has taken appropriate action on the identified j violatio i This item is close . Followup Items j (Closed) 86-23-02, Adequacy of Motor Overcurrent Protection and Horsepower Rating

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In the last team inspection at Trojan, the adequacy of motor !

overcurrent protection for Component Cooling Water (CCW) valve M0 J 3294 could not be verified. An inspection data sheet indicated that i the valve had a 1.3 horsepower (hp) motor, but the new replacement motor test data indicated that the motor was only a 0.70 hp moto The inspector was informed that the original documentation for the i motor was incorrect when it specified a 1.3 hp motor. The motor i that was replaced was a 0.70 hp motor. Also, there was a concern J about the adequacy of the overload protection, so that the overloads 1 on the motor would not trip prematurel j

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The inspector noted that the nameplate rating of the motor in containment was 0.70 h The licensee is performing a walkdown on systems to verify that the motor overloade are correctly size This is being tracked on the Trojan Commitment Tracking List (CTL)

under number 1159 Based on the licensee's actions, this item is close l (Closed) 86-23-08, Improper Use of Plant Configuration Change when Modifying PAMI Panels This item concerns the use of a Plant Configuration Change (PCC)

which is used to make minor changes to non-safety-related equipmen The PCC index was reviewed during the last team inspection and PCC E 85-511 was questioned because two non-safety related fans were ,

allowed to be installed on the Post Accident Monitoring Information (PAMI) panel The PAMI panels are safety-related and contain reactor vessel level indication and subcooling margin instrumentation. This item also stated that the operation of these instruments depended on the cooling provided by the fans and that-the performance records for the PAMI instruments indicated a higher failure rate after they were installe This item was addressed in inspection report 50-344/87-08. The item was closed out except for the following concern. The licensee was intending to replace the subcooling margin monitor during the 1987 )

outage. This had not been performed at the time of that inspection, i The inspector verified that the licensee was installing the new monitors in the PAMI cabinets under RDC 84-40. This item is therefore close .

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... (0 pen) 85-23-13, Discrepancies, Lack of Program and Procedure'for Safety Grade Classification of Instruments-This. item was identified in the last team inspection. The inspectors noted that the documentation for determining the safety classification at Trojan was weak. The Q-List was used as the principal document for determining classifications, but was very general. .The licensee was then using other documents to determine the safety classifications, which lead to errors found by the team for the safety classifications. The lack of a program to track and the method for determining the safety classifications, were weaknesses identifie The licensee, in response to this item, is submitting a single document, the Safety-Related Equipment Lis The program to implement this list was noted by the inspector in a letter, T. Walt to C. Yundt, dated 4/17/8 The. licensee is intending to issue this-list no later than 9/30/8 The inspector performed a sample. review of the draft: list and the program to implement the list, and did not identify any concerns in the areas reviewed. This item will remain open pending the issuance of revision O'of the Safety-Related Equipment list, and a review by an inspecto (Closed) Followup Item No. 50-344/86-10-01: Cycling of Manual Valves per IST Program (1) The initial inspection identified that the licensee did not periodically cycle all manual valves that may be used under abnormal operating conditions. Valves which are required to reposition to prevent or mitigate the consequences of an accident are required to be cycled periodically. The inspector identified that the Service Water System contained several manual valves, which the licensee agreed appeared prudent to periodically cycl During this inspection, a review of PET-15-1, Revision 0 (issued March 13, 1987), identified that the licensee has issued this procedure to cycle the applicable manual valves in each train of the Service Water System and other associated systems by performing a test on each train every second consecutive refueling outages. The licensee has taken appropriate action on this ite This item is close . Part 21 Reports (Closed), 86-14-P, " Auto Sprinkler Model C Deluge Valves Failed to Open" This part 21 report was issued by Automatic Sprinkler Corporation when several six inch model "C" valves failed to operate under high pressur These valves operate automatically for fire protection of equipment.

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When the temperature rises,.the valve opens and water is dumped out of t

the valve. Under pressure for extended periods of time, 2 mating-surfaces may stick together, causing the valve not to open. Automatic 1 Sprinkler issued a procedure for. testing these valves and smaller (2 ,]

c inch) valve ;

Trojan has been fully testing these valves and has not experience any problems with them. The licensee is aware of this problem and is taking

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appropriate corrective action to preclude any problem l This item is close (Closed), 86-29-P, "ITT Air Operated Diaphragm Valves Natural Frequency less than 33 Hertz" This Part 21 report has also been discussed in inspection report 50-344/86-48. Information Notice 87-02 has been issued by the'NRC discussing this-problem. This Part-21 report was issued when it was analyzed that some valves with extended structures had natural frequencies less than 33 Hertz (Hz). The implication is that the valve would have a response amplification with these low frequencies which could render it inoperabl The licensee issued an Operational Assessment Review (0AR) for the 1 Seismic Class I ITT Grinnell valves that they have (OAR 86-102). These valves were predominantly in the gaseous radwaste system. In the initial assessment, the. licensee said that these valves do not appear to be a problem due to the supports the valves have. 'The licensee contacted Bechtel to do an engineering analysis on these' valves. Bechtel' informed

'the licensee (memo JMS-13-87) to modify some supports due to' exceeding code requirements. The licensee issued Non Conformance Reports (NCRs) to address these concerns (NCR 87-036, NCR 87-037, NCR 87-082). The licensee'has taken appropriate action and was working on these NCRs at !

the time of the inspectio l This item is close . Licensee's Methods for Documenting Actions Taken in Response to Inspector Identified Concerns During this inspection, the inspectors identified that the licensee did not always document all the corrective actions taken in response to.an inspector identified concer Licensee personnel appeared to take appropriate actions, but did not document this corrective action in all case The licensee agreed that their personnel needed to do a better job of documenting all their corrective actions and stated they would reinstruct their personnel on this subjec The licensee agreed that improved documentation of corrective actions taken, would aid in auditing the licensee's response to identified concern E ,

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! Exit Meeting  ;

i The inspectors met with the licensee representatives denoted in paragraph 1 on April 24, 1987. The scope of the inspection, observations and findings as noted in this report were discusse j l

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