IR 05000344/1987019

Insp Rept 50-344/87-19 on 870427-0501.No Violations Noted. Major Areas Inspected:Routine Maint,Followup & Closure of Previous Insp Findings & IE Bulletin & Generic Ltr Followup

ML20214K150
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	05/11/1987
From:	Mendonca M, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20214K147	List: IR 05000344/1987019 ML20214K144
References
50-344-87-19, GL-86-16, IEIN-86-025, IEIN-86-25, NUDOCS 8705280340
Download: ML20214K150 (8)

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b U. S. NUCLEAR REGULATORY COMISSION

} REGION V

Report No: 50-344/87-19 Docket No. '50-344

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License No. NPF-1 i

i Licensee: Portland General Electric Company 121 S. W. Salmon Street j Portland, Oregon 97204 l Facility Name: Trojan Nuclear Plant

I Inspection at: Rainier, Oregon Inspection con cta : Ap il 7- y 1, 1987 i

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Inspector: I'Idvu . . StMr l

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O. B. Pereira, Reactor Inspector Date Signed l Approved by: #/8 >

l M. M. Mendonca, Chief, Date Signed

{ Reactor Project Section 1

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Summary:  ;

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Inspection During the Period of April 27-May 1,1987 (Report 50-344/87-19)

l Areas Inspected: This routine, unannounced inspection by the Project j Inspector involved the areas of Routine Maintenace, follow-up and closure of previous inspection findings, and IE Bulletin and Generic Letter followup.

j During this inspection, inspection modules 30703, 62700, 92703, and 92701 were

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used.

j Results: No items of noncompliance or deviations were identified.

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j 0705200340 870511 PDR ADOCK 05000344 '

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DETAILS Persons Contacted Licensee Personnel

• D. Cockfield, Vice President, Nuclear C. A. Olmstead, Plant Manager

• R. P. Schmitt, Manager, Operations and Maintenance i * R. C. Jarman, Manager, Quality Assurance Department

• D. Keuter, Manager, Technical Services

• J. D. Reid, Manager, Plant Services

• C. H. Brown, Operations Branch Manager, Quality Assurance i

• A. Ankrum, Supervisor, Nuclear Regulation Branch

• G. A. Zimmerman, Manager, Nuclear Regulation Branch

• M. H. Malmros, Nuclear Engineer i W. L. Kershul, Engineer, Nuclear Safety and Regulation Department D. L. Bennett, Supervisor, Control and Electrical R. Reinart, Supervisor, Instrument and Control

• D. W. Swan, Supervisor, Maintenance R. Russell, Assistance Operations Supervisor, Quality Assurance l U. S. Nuclear Regulatory Commission

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• R. C. Barr Oregon Department of Energy H. Moomey, Oregon Resident Inspector

• Attended the Exit Meeting on May 1, 198 . Maintenance Program Implementation The purposes of this inspection were to determine whether the licensee has developed and implemented a maintenance program that is in conformance with regulatory requirements, determine the effectiveness of

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the maintenace program on important plant equipment, and determine the ability of the maintenance staff to conduct an effective maintenance program.

l The inspector reviewed plant operating history and interviewed plant

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personnel to select several completed maintenance activities from the following categories; safety related (SR) equipment failure leading to a plant shutdown, equipment failure leading to a plant shutdown, equipment

, failure leading to reduced capability of an SR system, and recurring SR

! equipment failur The inspector reviewed several LERs in the above categories and determined that the causes of failures were evaluated and corrective l

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action was taken to reduce the probability of. recurrence. In addition, the procedures specified in the maintenance package were acceptable for the maintenance performed, and that the vendor technical manual for the equipment under repair was controlled and kept up to dat The inspector conducted a record review of associated maintenance activities selected from the above categories and determined that the following requirements were met: Required administrative approvals were obtained before initiating the wor Review of Maintenance Requests (MR)-86-1741, 86-1799,

86-3197, and 87-0924 indicated proper authorization to start work as

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indicated by the shift superviso ; Limiting conditions for operation were met while the component or j system was removed from servic The above noted MRs required plant conditions were specified as well as the technical specification limiting conditions.

} Approved procedures were used where the activity appeared to exceed

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the normal skills possessed by qualified maintenance personnel, and quality control inspections were made and the quality control

records were complet For example, MR-86-1799 described the i procedure required to install 4 new chilled water isolation valves j as per RDC 82-045 DCP The functional testing and calibrations, as necessary, were completed before returning the equipment to service. MRs 86-1741, i 86-3197, and 86-4415 described the functional testing and I calibrations that were necessary to complete the maintenance activit In addition, the shift supervisor signs the MRs that the i work and testing is completed prior to returning the system or component to servic The-licensee had evaluated the system failures and reported them in accordance with 10 CFR 50.73.

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The corrective and preventive maintenance records were assembled and j stored as part of the maintenance history.

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! The measuring and test equipment (M&TE) used in the maintenance was l identified and in calibration. In addition, parts and materials j used were identified and the material requisitions were a part of the MR.

! The system lineups were processed and verified prior to return to j service.

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The inspector examined several maintenance procedures used to conduct the

work items selected above. The review included areas of mechanical, electrical, and instrument and control, and preventive maintenance procedures. The procedures conformed to the licensee's administrative requirements,' including format, approval, and control. The

! post-maintenance testing is detailed and apppropriate for the repairs

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mad The inspection and quality control hold points are identified in the procedures, and the activity is described in sufficient detai The procedures supplementary reference material such as drawings and technical manuals is adequate and controlled. The precautions and provisions for radiological, temperature, pressure, electrical hazards, fire protection, cleanliness, and housekeeping provisions are adequat The inspector determined that provisions for control of equipment, including lifted leads, jumpers, bypasses, and mechanical blocks are present where necessary. The inspector reviewed the machinery history records for several completed maintenance activities and verified that they are being kept up to date and are properly stored as quality assurance record The inspector reviewed the following procedures and their records:

a. Maintenance Procedure (MP) -2-2 Portable Measuring and Test Equipment b. MP-2-5 Electrical Analog Instrumentation c. MP-1-2 Transformers d. MP-1-5 Reactor Trip and Bypass Breakers e. MP-1-17 Time Delay Devices f. MP-12-4 Valve Air Actuators g. MP-12-5 Valve Motor Operators h. MP-12-6 Quality-Related Pumps The inspector reviewed the Instrumentation and Control (I&C) department's M&TE in the electrical, mechanical, and instrument and control area used to perform the maintenance activities. The inspector verified that the M&TE was in calibration at the time of use, and that the calibration of the M&TE can be traced to nationally recognized standards, is properly stored, controlled, identified with a unique number, and labelled with calibration status. The inspector verified that the error of the M&TE was less than or equal to the instrument being calibrate The inspector reviewed several instrument calibration records for safety-related instruments which were required to be calibrated by the Technical Specifications (TS). The following PICTs 2-1, 2-2, 2-3, 3-1, and 3-2 data sheets were reviewed to verify the following: The instrument calibration history is kept up to dat The calibration of these instruments is traceable to nationally recognized standards and the calibration accuracy ratio is acceptable, The identities of the personnel who calibrated these is clea , Approved procedures were available to perform the calibration The calibration records indicated a review and approval process by supervision. The records also indicated acceptance criteria as necessar The inspector reviewed the preventive maintenance program and verified that a master schedule is available, and that a compilation of late or l

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incomplete preventive maintenance activities is available for management revie The program has preventive maintenance procedures available and are sufficiently detailed to ensure maintenance is performed correctly and properly. In addition, a lubrication schedule is available and kept up to dat The inspector in his review of the preventive maintenance program was informed of a Licensee Quality Assurance Audit on the same subject which was performed during the month of March 1987. This audit discovered two pertinent aspects that this inspector felt should be discussed in this repor The first, Nonconforming Activity Report (NCAR) number P87-041, discovered that the current program lacks procedural requirements for updating and revision in that it does not define interfaces with equipment lists, DCPs, and the Q-list. In addition, there is also no objective evidence that the Trojan Scheduling System Users Manual referenced in MP-3-8 has been reviewed and approved or is being controlled. The second, NCAR number P87-037, stated that the ,

current preventive maintenance program did not specify requirements for ;

the control of computerized records. Both NCARs are to be followed on ,

the open items list and are given open item number 87-19-0 j

l The inspector's review of the maintenance program indicated that the l licensee has developed and implemented a program which controls '

maintenance, which includes lubrication, in conformance with regulatory requirements, commitments in the license, and industry guides and standard ,

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No violations or deviations were identified in this are I l

3. Follow-up on Previous Inspection Findings  !

, \ (Closed) Inspection Follow-up Item 86-48-01 LLRT of Penetration P-10 l

The inspector reviewed follow-up item 86-48-01 which described the need for a local leak rate testing (LLRT) of penetration P-10, which l consists of a line from the discharge of various emergency core

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cooling system rolief valves outside containment through a single l inboard check valve to the pressurizer relief tank inside l containmen After review of the issue, the licensee concluded that 4 l the penetration should be redefined in the USAR as a Type II I penetration, i.e., a fluid line that is connected to a closed system outside the containment and is connected to the reactor coolant system or is open to the containment atmosphere. In addition, the I licensee determined that LLRT of the check valveswas appropriate and '

would include it in the LLRT program. In Revision 14, of Plant Engineering Test (PET) 5-2, penetration P-10 has been added to Data Sheet 4 for LLRT on a periodic basi Based on the inspector's review of revision 14 to PET 5-2, follow-up l item 86-48-01 is close l l (Closed) Enforcement Item 86-20-01 Violation NCR 86-024 No Correct- 1 ive Action

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incomplete preventive maintenance activities is available for management revie The program has preventive maintenance procedures available and are sufficiently detailed to ensure maintenance is performed correctly and properly. In addition, a lubrication schedule is available and kept up to dat The inspector in his review of the preventive maintenance program was informed of a Licensee Quality Assurance Audit on the same subject which was performed during the month of March 1987. This audit discovered two pertinent aspects that this inspector felt should be discussed in this repor The first, Nonconforming Activity Report (NCAR) number P87-041, discovered that the current program lacks procedural requirements for updating and revision in that it does not define interfaces with equipment lists, DCPs, and the Q-lis In addition, there is also no objective evidence that the Trojan Scheduling System Users Manual referenced in MP-3-8 has been reviewed and approved or is being controlled. The second, NCAR number P87-037, stated that the current preventive maintenance program did not specify requirements for the control of computerized records. Both NCARs are to be followed on the open items list and are given open item number 87-19-0 The inspector's review of the maintenance program indicated that the licensee has developed and implemented a program which controls maintenance, which includes lubrication, in conformance with regulatory requirements, commitments in the license, and industry guides and standard No violations or deviations were identified in this are . Follow-up on Previous Inspection Findings (Closed) Inspection Follow-up Item 86-48-01 LLRT of Penetration P-10 The inspector reviewed follow-up item 86-48-01 which described the need for a local leak rate testing (LLRT) of penetration P-10, which consists of a line from the discharge of various emergency core cooling system relief valves outside containment through a single inboard check valve to the pressurizer relief tank inside containmen After review of the issue, the licensee concluded that the penetration should be redefined in the USAR as a Type II penetration, i.e., a fluid line that is connected to a closed system outside the containment and is connected to the reactor coolant system or is open to the containment atmosphere. In addition, the licensee determined that LLRT of the check valve was app w .al&te and would include it in the LLRT program. In Revision 14, of Plant Engineering Test (PET) 5-2, penetration P-10 has been added to Data Sheet 4 for LLRT on a periodic basi Based on the inspector's review of revision 14 to PET 5-2, follow-up item 86-48-01 is close (Closed) Enforcement Item 86-20-01 Violation NCR 86-024 No Correct-ive Action

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The inspector reviewed enforcement item 86-20 01 which described for a Non-Conformance Report (NCR)86-024 that the corrective action was not assigned and implemente This NCR documented non-conformances associated with electrical conduit support for the "A" train of the hydrogen recombiner syste The licensee's response and corrective 6ction was as follows: Documentation was provided and subsequently attached to NCR 86-024 to explain why it had been voided. In this explanation, the voiding of NCR 86-024 was accomplished inconsistent with the application of design standards and the National Electric Code specification and for that reason, a new NCR 86-121 was initiated. NCR 86-121 was subsequently evaluated by NPE and dispositioned "use as is" and closed out on July 16, 198 . To avoid further violations, additional steps were take The Quality Assurance Manager discussed the proper methods / reasons for voiding NCRs with the QA/QC specialist, who entered the improper voiding (as corrective action) on NCR 86-024, and the Quality Control Supervisor, who approved the recommended corrective action. The Quality Control Supervisor has counseled all QC staff members responsible for NCR tracking / closing on the correct methods for voiding NCRs. The NPE Electrical Manager addressed this problem and the proper methods and reasons for recommending an NCR be voided at the NPE Electrical Branch staff meeting on July 23, 198 Based upon the above licensee's responses and the consideration that full compliance was achieved with the closing of the NCR 86-121 on July 16, 1986 and the discussions at the NPE Branch staff meeting on July 23, 1986, enforcement item 86-20-01 is close c. (Closed) Enforcement Item 86-19-03 RHR Inoperable in Mode 1 (Closed) Enforcement Item 86-32-02 Inoperable RHR System Flowpath During a resident inspector's tour of the control room on March 31, 1986, while in Mode 1 for one hour and 10 minutes, portions of two ECCS subsystems (the RHR system) were inoperable when M0-8809A was closed. With valve MO-8809A closed, the flow path for both trains of RHR cold leg injection was such that RHR flow to only two of the four Reactor Coolant System cold !egs would have been achieve The licensee's response acknowledges that on March 31, 1986, while in Mode 1, with valve M0-8809A closed, portions of two ECCS subsystems were inoperable for 10 minutes longer than that permitted by Technical Specification LC0 3.0.3. The reason for the violation was determined to be the unavailability of accurate and detailed design basis documents. For that reason, the specific requirements to maintain valves M0-8809A and B open while in Modes 1, 2, and 3 were not being implemented by the appropriate Plant Operating Procedure . _ _ .

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The licensee's corrective actions were the revising of Plant Operating Manual Procedures to specify appropriate cautions and warnings to ensure that valves M0-8809A and B remain open while operating in Modes 1, 2, and 3. 0ther ECCS subsystems were reviewed to see if there are other valves that could be inadvertently mispositioned and likewise affect the operability of their ECCS subsystems similar to valves M0-8809A and B. This review had been completed and no other valves were determined to be subject to the same mispositioning as valves M0-8809A and The licensee's response appears to be satisfactory and full

compliance with the Trojan Technical Specifications was achieved on March 31, 1986 when valve M0-8809A was reopened. Full compliance was ensured by April 30, 1986, when the appropriate procedures were revised to add precautions. Enforcement items 86-19-03 and 86-32-02 are close d. (Closed) Generic Letter 86-16 Westinghouse ECCS Evaluation Models

, Change in Computer Code Generic Letter 86-16 informed licensees of NRC actions regarding the problems associated with the Westinghouse ECCS Evaluation Model The letter stated that those applicants and licensees who had an ECCS analysis performed with the 1981 Evaluation Model with BART that was under review by the staff when Westinghouse made the changes were required to perform a reanalysis with a corrected version in order to verify compliance with the current licensing basi A revised Westinghouse 1981 ECCS Evaluation Model with BART has been approved by the staff for that purpos For those plants which were analyzed with the 1978 and 1981 versions of the Westinghouse ECCS Evaluation Model, the change to the WREFLOOD code would result in a 6-12 F increase in peak clad temperature. Westinghouse has informed the NRC that the increase would not cause the peak clad temperature (PCT) in current analyses to exceed 2200 F. Trojan Nuclear Plant was analyzed with the 1978 version and therefore would result in a 6-12 F increase in PCT. The revised ECCS evaluation models found that the metal heat model in the earlier analyses was overly conservative, compared with the latest approved model used in the analyses using BART. If a more accurate calculation of the metal heat flow is included in the analyses, the net effect of the above changes is a reduced PCT. It has been concluded that, since the net impact of the changes outlined above is a PCT reduction for all plants analyzed with the 1978 and 1981 versions of the ECCS evaluation model, no further action is required for these plant Based upon the above discussion , Generic Letter 86-16 is close e. (Closed) Information Notice IN-86-25 Traceability and Material Control of Material and Equipment ,Particularly Fasteners Information Notice 86-25 alerted licensees of potential significant problems identified during.NRC Construction Appraisal Team (CAT)

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inspections of material and equipment, particularly fasteners, and to prevent the use of incorrect or defective materials, parts and components. The deficiencies in material traceability and control of fasteners identified at the sites mentioned were attributed to ineffective site inspection programs and vendor surveillance activities by the license Deficiencies were found in fasteners for large vendor-supplied mechanical and electrical equipment and in bolting for battery racks and electrical equipment cabinets at many sites. Supplement 1 provided additional information supplied by the Industrial Fastener Institute (IFI) concerning intentionally mismarked SAE J429K grade 8 bolts. According to IFI, these falsely marked bolts (grade 8.2 for grade 8) could undergo stress relaxation when subjected to temperatures above 500 F, and such relaxation could result in equipment failure and injur The licensee conducted an audit on the control of fasteners during the period of March 3-5, 1987 and is presented in Surveillance

! Report No. P130. The purpose of the surveillance was to evaluate the control of fasteners consisting of nuts, bolts, screws, and washers used at Trojan Nuclear Plant. In addition, the concerns of NRC IE Information Notice 86-25 regarding fasteners were assessed during this audi The inspector reviewed Surveillance Report No. P130 and determined that the licensee's Warehouse traceability is controlled by means of Stores Code Numbers and Purchase Order identification. Issuance of fasteners is documented on Stores Issue / Withdrawal Slips which reference the Purchase Order number. Trojan Maintenance Tool Room traceability relies heavily on Bowman distribution materia markings, which is the primary fastener contractor for the tool roo All fasteners are issued with Tool Room Issue / Return Slips which are retained with the completed Maintenance Request One problem identified during the audit was that the Receipt Inspectors were not verifying the markings on the fasteners. As a result, NCAR P87-034 was issued to the QC group with the recommedations of acquiring specifications and catalogues sufficient to ensure adequate inspection of vendor furnished fasteners; inspect fasteners in a manner to ensure the correct grade is being received in relation to the purchase order requirement and the vendor packing slip; establish a random sampling plan; and write a procedure for the above item Based upon the licensee's response and audit results of IE Information Notice No. 86-25, the inspector determined that the Trojan Nuclear Plant has adequate controls to ensure traceability of fasteners. IN No. 86-25 is closed.

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5. Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 on May 1,1987, and summarized the scope and findings of the inspection activities.