IR 05000344/1988006

Insp Rept 50-344/88-06 on 880222-26.No Violations or Deviations Noted.Major Areas Inspected:Nonlicensed Staff Training & Followup Items & Followup Items of Noncompliance

ML20148G017
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/09/1988
From:	Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20148G013	List: IR 05000344/1988006 ML20148G008
References
50-344-88-06, 50-344-88-6, NUDOCS 8803290009
Download: ML20148G017 (8)

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,. U. S. NUCLEAR REGULATORY COMMISSION REGION V  :

Report:No: 50-344/88-06 L

Docket N License N NPF-l'  ;

Licensee: Portland General Electric Company l 121 S. W. Salmon Street Portland, Oregon ,97204 Facility Na'me: Trojan Nuclear Plant

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Inspection at: Rainier, Oregon Inspection cond d: F bruary 22-26, 1988 .

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. Inspector: Ad + # f/ N # 7 D. B. Pereira, Reactor Inspector Date Signed Approved by:

• * A .__9 / 7 M 6 M. M. Mendonca, Chief, Date Signed Reactor Project Section 1

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Summary:

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Inspection During the Period of February 22-26 1988 (Report 50-344/88-06) i i

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-Areas Inspected: This routine, unannounced inspection by the Project i Inspector. involved the areas of Non-Licensed Staff Training, followup items, ,

i and followup items of Non-Compliance, f During this inspection, inspection modules 30703, 41400, 92701, and 92702 i

were used as guidanc l

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Results: No violations or deviations were identifie l t

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8803290009 G80311 PDR ADOCK 05000344 O DCD

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The inspector reviewed licensee training records and personnel files of the training staf The review determined that the qualifications of the training staff met regulatory requirements and licensee commitments for the principal and technical staff member During the interview process, the inspector determined that maintenance and non-licensed operations personnel receive training for specific tasks assigned, such as complicated surveillance tests, major equipment repair, and operating procedures during an on-the-job training phase. This phase is conducted by an experienced technician who has completed the job or test many times, and demonstrated proficienc The inspector reviewed the progress of the licensee with respect to accreditation by the Institute of Nuclear Power Operations (INPO).

Presently, the licensee's training program is fully accredited by INP0 and has been since December, 1987. The licensee's training staff appears to be complemented with qualified instructors who have extensive experienc No violations or deviations were identifie . Followup on Open Items e. . Followup Item 87-38-01 (Closed) Valves GS-185 and 186 Have No Heat Tracing Nor Insulation During a previous cold weather inspection, the inspector discovered approximately 6-8 inches of insulation and heat tracing were missing from instrument air lines to valves GS-185 and GS-186, which control CV-2270, the D Steam Line Power Operated Relief (POR), and CV-2250, the C Steam Line POR, respectively. In addition, insulation cans were removed and not reinstalled on valve CV-2230, the B Steam Line PO During this inspection, the inspector verified the heat tracing to be installed or reinstalled. Followup item 87-38-01 is close Enforcement Item 87-09-02 (Closed) Failure to Comply with Trending Procedural Requirements Inspection Report 87-09 identified a Notice of Violation in which the licensee did not note trending information af ter each audit or surveillance. Nuclear Quality Assurance Procedure (NQAP) No. 114 required trending information obtained from Nuclear Quality Assurance Department (NQAD) audits to be entered onto a Trend Analysis Data Form (TADF) on an ongoing basis. When the inspector asked to review the data forms, the inspector was informed that the TADFs were not being completed as requirad. Four audits and one surveillance were completed since implementation of NQAP No. 11 The inspector was informed by the licensee that NQAP No. 114 was deleted in iis entirety and was replaced by the Performance Monitoring / Event Analysis (PM/EA) Department Procedure (PMEAP) 101 Revision 0, entitled "PM/EA Department Procedure Trend Reporting."

This procedure was issued on November 1, 1987, and establishes the methods for reporting trends in root cause data accumulated through

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analysis of Nonconformance Reports, Nonconforming Activity Reports, and Event Reports. This inspector _ reviewed the trending of audits and surveillances via the forms of PMEAP 101 and determined that l they are being performed in accordance with PMEAP 101. Enforcement Item 87-09-02 is closed, Unresolved Iter 87-13-01 (Closed) Minco Type S8809 RTD Failure To Meet Functional Performance Requirements j The Hinco resistance temperature detectors (RTDs), used for density compensation in the reactor vessel level indication system (RVLIS),

were installed as post-accident monitoring equipment and the EQ criterion was NUREG-0588, Category I. Westinghouse Report WCAP-8687, Supplement 2-E42A, Revision 1, dated 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 (+/-5.0 F) were met during the LOCA i simulation test. The Westinghouse report clcimed an accuracy of ,

+/-1.0 F on the basis of their analysis that indicated that this l accuracy is assured when the lead-to-RTD body insulation resistance (IR) is at least 0.5 megoh All IR measurements taken during the l test were greater than 0.5 megohm A letter from S. D. Alexander, NRR, to J. Burdoin, Region V, dated January 29, 1988, concluded that the method used to evaluate functional performance of the RTD under accident conditions, i.e.,

I lead-to-body IR, was valid and could be reasonably expected to adequately demonstrate satisfactory RTD performance under accident conditions in the plant applicatio Since the EQ files, as reviewed, did contain the infnrmation as discussed above to support qualification, unresolved item 87-13-01 is considered close Enforcement Item 87-13-02 (Closed) Rosemount Type 176KF RTD Failure to meet Functional Performance Requirements Inspection Report 87-13 determined that Qualification File No. 15 for Rosemount Type 176KF and 176KS resistance temperature detectors (RTDs) did not demonstrate that the plant functional performance requirements for their application were met under the postulated accident condition Even though the Westinghouse test report, WCAP-9157, contained in Qualification File No. 15, provided a portion of the documentation to demonstrate qualification of the Rosemount RTDs to the NRC Division of Operating Reactors (DOR) Guidelines, the Sandia National Laboratory Report, [NUREG-CR/3597 (SAND 84-093) of December 1984),

which provides additional supporting documentation, was not included in the file to demonstrate RTD qualification. An evaluation of the Sandia lab report was completed in order to provide supplemental data to demonstrate that performance requirements were me Westinghouse, being the supplier for the Rosemount RTD sensors, has reaffirmed that the methods used to verify RTD accuracies during high-energy line break (HELB) conditions are sufficient to demonstrate acceptable performance of the RTD This position

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applies to all RTOs (including Rosemount Models 176KF and 176KS).

The licensee has incorporated SAND 84-093 into Qualification File No. 15. The Sandia lab report supports the original qualification methodology used for demonstrating acceptable performance under accident conditions. Enforcement Item 87-13-02 is close e. Enforcement Item 87-13-03 (Closed) Dust Cans On Limitorque Gear Case Grease Relief Valves in Containment Limitorque valve actuators in containment were not maintained in a condition similar to that in which they were tested, in that many of their. gear case grease relief valves have had dust caps installed and qualification files covering these Limitorque valve actuators did not contain any justification for the deviatio Request for Design Change (RDC)86-033 was initiated by the licensee in order to provide a comprehensive inspection, maintenance, and repair program for all environmentally qualified Limitorque valve operators at the Trojan Nuclear Plan This program occurred during the 1987 refueling outag The installation of gear case reliefs where needed was included. However, the work instructions prepared by engineering old not include an explicit requirement for the removal of any dust caps provided by the vendor for shipping and pre-installation handlin Maintenance and construction work group practices were also inconsistent in that these dust caps were removed from most but not all Limitorque valve operators where the installation of a gear case grease relief was require All Limitorque valve operators with gear case reliefs were reinspected for dust caps, and all remaining dust caps were remove This corrective action was initiated immediately after the deficiency was identified and was completed during the 1987 refueling outage. Gear case grease reliefs were installed to accommodate possible grease expansion during accident condition Since the dust caps are soft plastic and are not qualified, the licensee believes that the dust caps would be sufficiently softened and degraded by the accident conditions such that they would not prevent the relief of grease from the casin Thus, had a loss of coolant accident or HELB occurred, the potential impact of this deficiency would have been negligible. Enforcement Item 87-13-03 is close f. Enforcement Item 87-31-06 (Closed) Failure to Perform IST On Various Air Valves Contrary to the licensee's program, valves MS 226 and MS-222 had not been included in the licensee's IST progra Motor-operated valves in the steam supply lines to the turbine-driven AFW pump were replaced with air-operated valves in response to station blackout concerns to ensure an available water supply to the steam generator As part of this modification, backup Seismic Category I air accumulators were added which are in parallel with the Seismic Category 11 normal instrument air supply

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syste The accumulators are separated from the instrument air system by two series check valves. This portion of the system was originally shown as Quality Group 48 on Sheet 1 of FSAR Figure 10.2-3, "Main Steam System," which exempted it from testing in the IST Program. The current FSAR figure shows this portion of the system as Quality Group 2, no longer exempt, as noted in the Notice of Violation. During 1987, check valves MS 222, and MS 226 were identified as an open item for addition to the IST Progra The change in FSAR figures was discovered by an independent contractor who had been secured to perform a detailed review of Trojan's IST Progra These valves have been included in a marked-up copy of Topical Report PGE-1048, "Inservice Testing of Pumps and Valves, Second 10 year Interval." Testing of this system will be modified to meet ASME Section XI Code requirements for these check valves. Revision 1 to Topical Report PGE-1048 is currently under review and approval for submittal to the NRC by February 15, 1988. The check valves MS 222 and MS-226 are included in POT 5-1 and will be tested during the shut down sequence in early April 198 Enforcement item 87-31-06 is close g. Enforcement Item 87-31-08 Failure to Follow Drawing Installation Of Pipe Support H-834 Contrary to the licensee's Nuclear Plant drawing number HBD-80-50 which delineated the installation of support H 834 on the safety related portion of the instrument air supply line, support H 834 was not reattached to the air supply line following performance of a modification. This violation was discovered by one of the inspectors during a walkdown on the instrument air syste Pipe support H 831 was removed as part of work on a design change made in the area during the 1987 refueling outage. The modification involved the installation of new deck gratin The design change package recognized the possibility of hanger interferences, but did not specifically identify the need for removal of Support H 83 During installation of the modification, the job coordinator did not recognize H 834 as a seismic support on a safety-related system and failed to provide written instructions, as required, to ensure the support was properly reinstalle Following installation of the deck grating, the final closeout inspection failed to identify the disconnected pipe suppor The pipe support was immediately reinstalled, and the job coordinator was instructed on the required actions regarding removal and reinstallation of pipe support Affected work groups have been instructed that they not perform work outside the scope of specific work instructions. In addition, an investigation determined that the responsible job coordinator was not assigned any other jobs involving pipe supports during the 1987 refueling outag Enforcement Item 87-31-08 is close .

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h. Enforcement Item 87-31-12 (Closed) Failure to Perform 10 CFR 50.59 Evaluation for Reduced EDG Air Pressure Setting Trojan's UFSAR Figure 9.5-10 requires the Emergency Diesel Generator (EDG) Air Start System pressure regulators to be set such that downstream pressure is 200 psig. Contrary to this, the eight EDG Air Start System pressure regulators downstream pressure setpoints were 180 to 190 psig. The setpoint had been changed without documenting the performance of a safety evaluatio Figure 9.5-10 of the Trojan FSAR, a schematic of the EDG Air Start System, identifies the subject regulating valves as follows:

"Pressure Reducing Valve 300 to 200 PSIG," wSich was interpreted as descriptive of the type of component rather than prescriptive of a required downstream pressure setting. The pressure regulators were set at 180 to 190 psig to ensure adequate diesel start capability yet minimize wear on the air start motor An engineering review and safety evaluation of the setpoints of the pressure regulator were performed by the system engineer. The review determined that the EDGs p?rform their design function at the more limiting setting of 165 psi The manufacturer indicated that the system could perform its function at a system pressure as low as 120 to 125 psig. Low pressure, below 160, +/-5psig is annunciated in the control room and corrective action is taken when require In addition, a 200 psig +/-10 percent tolerance for the setting of these pressure regulators is considered acceptable based on engineering judgement and Trojan Plant experience. The setting assures the EDG will start in 10 seconds or less and coordinates to prevent spurious annunciation during EDG start A revision to Administrative Order (AO) 5-4, "Plant Setpoint Changes," has been prepared and has Deen submitted for approva This change provides specific guidance on the need for a safety evaluation when changing a pressure regulator's settin Enforcement Item 87-31-12 is close i. Enforcement Item 87-31-13 (Closed) Failure to Follow Drawing Installation of EDG Air Lubricators Relay Air Valves and Pressure Gages Bruce GM Diesel Inc. Drawing A071F07001, Revision 9-Schematic Diagram-Air Start System for Tandem Engine Unit, requires the EDG Air Start System lubricators to be installed upstream of the relay air valves; does not indicate installation of a pressure gauge on the EDG Air Start System Relay air valves, and requires EDG Air r Start System pressure gauges downstream of the pressure reducing valves to be 0-300 psig gauge Contrary to the above, all eight lubricators of the EDG Air Start System were downstream of the relay air valves; one of eight relay -

air valves was equipped with a pressure gauge; and one of eight pressure reducing valves downstream pressure gauges was a 0-200 psig gaug . -- - . - _ . - _ . .

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DETAILS Persons Contacted Licensee Personnel

• C. A. Olmstead, General Manager R. P. Schmitt, Manager, Operations and Maintenance J. D. Reid, Manager, Plant Services

• P. Morton, Branch Manager, Engineering

• C. Nordstrom, Engineer, Nuclear Safety and Regulation Department R. Reinart, Supervisor, Instrument and Control U. S. Nuclear Regulatory Commission R. Barr

• G. Y. Suh Oregon Department of Energy

• H. Moomey, Oregon Resident Inspector

• Attended the Exit Meeting on February 26, 198 . Non-Licensed Staff Training The purpose of this inspection was to evaluate the effectiveness of the licensee's training programs for the non-licensed staf The inspector conducted interviews with several new, several experienced, and two temporary non-licensed employees concerning their general knowledge in administrative controls, radiological health and safety, industrial safety, controlled access and security, the emergency plan, and quality assurance. The General Employee Training (GET) program provides training in the above subject areas for all non-licensed employees. The inspector also was involved with his annual retraining during this inspectio In general, the personnel interviewed were pleased with the GET training program and had only one comment that it was rather length It takes two days of classroom training to complete the qualification and badging proces The inspector reviewed plant operating history to select several abnormal events or unusual occurrences that might have been caused by deficient trainin For the events / activities reviewed, it was evident that the classroom training and the on-the-job training received were sufficient to have either prevented the occurrence or mitigated its effects by recognition and proper operator action The inspector determined that past history was factored into the training program, s

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The licensee agreed that the installation of the lubricators did not comply with the vendor's schematic drawing; however, the installation does comply with the vendor's detailed description of the installation and function of the lubricator in section 14 of Technical Manual M16-90 (Pages 14-1 and 14-5). The licensee contacted the vendor, who advised them that the installation is prope The drawing was as-built by the vendor in December 197 The drawing has been revised to reflect the proper installation of the lubricator The licensee agreed that a 0-600 psi gauge was installed in the air start system on East Engine B K106A2 on the north side, and a pulsation dampener is installed in tubing to the governor air boost on the south side of the West Engine K10681, neither of which is identified on the vendor's drawing or other design documents. The reason for the installation had not yet been determined, however since the gauge had a tag denoting temporary installation, it could be possible that this equipment was installed during startup. An evaluation was conducted via Nonconformance Report (NCR)88-013, which determined the gauge was not necessary and was removed. The pulsation dampener is being evaluated via NCR 88-013, and is being adequately resolve The licensee agreed that West Engine A K106Al on the south side has a 0-200 psi gauge installed on the regulator instead of the required 0-300 psi gauge. The licensee's review of plant records revealed that on May 15, 1981, the installed 0-300 psi gauge failed a preventive maintenance check and was replaced with a 0-200 psi gauge. The ircorrect installation may have been due to an older (1972) revision of the vendor drawing, contained in the technical manual, which indicated a 0-200 psi gauge. A new 0-300 psi gauge has been installed. A 300 psi gauge is preferable because this local gauge is used to indicate a normal line pressure of about 200 psi Based on the above licensee actions, Enforcement Item 87-31-13 is close . Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 on February 26, 19F,8, and summarized the scope and findings of the inspection activitie >