IR 05000344/1988031
| ML20154F688 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/23/1988 |
| From: | Jim Melfi, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20154F675 | List: |
| References | |
| 50-344-88-31, GL-83-28, NUDOCS 8809200089 | |
| Download: ML20154F688 (10) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION Y Report No.
50-344/88-31 s
Docket No.
50-344 License No.
NPF-1 Licensee:
Portland General Electric Company
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121 S. W. Salmon Street
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Portland, Oregon 97224
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Facility Nane:
Trojan Nuclear Plant Inspection at:
Rainier, Oregon (TrojanSite)
Inspection conducted:
July 18 - July 22,1987 Inspector:
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F. M(1ffFProject Inspector Date signed Approved By:
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A. Ritnafdii, Chibf, Engineering Section D6te Signed Inspection Sumary:_
Inspection During the Period of July 18 - July 22,1988 (Report 50-344/88-31)
Areas Inspected:
A routine, unannounced inspection by a regional based inspector, in the areas of Unresolved, Enforcement, and Followup items.
Inspection procedures 30703, 92700, and 92702 were used.
Results: No violations or deviations were identified.
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DETAILS 1.
Persons Contacted a.
Licensee Personnel
- C. A. Olmstead, Trojan General Manager
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- D. Nordstrom, Compliance Engineer
- J. Reid Plant Services Manager
- M. Swartz, Project Manager, Surveillance and Test
- G. Kent, STE Supervisor Engineer
- J. Lentsch, Personnel Protection Manager
- C. Brown, Quality Operations Branch Manager
- J. Duke, PMEA Engineer
- P. Morton, Plant Engineering Manager B. Monroe, AFW Engineer X. Hakari, IA, CCW Engineer J. Linn, Electrical Engineer b.
USNRC ETarr, Senior Resident Inspector
- G. Suh, Resident Inspector
- Denotes those' attending the final exit meeting on July 22, 1988.
The inspector also contacced licensee operators, engineers, technicians, and other personnel during the course of the inspection.
2.
Enforcement Items (Closed) 87-31-05, "Failure to test AFW Terry Turbine Using Accumulators Only" This violation was issued with the report on December 17, 1988 for the apparent failure to test the steam inlet valves to the AFW steam driven
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turbine using the accumulators as the fail-safe source of energy.
The initial response to the violations in report 87-31 was in a letter dated January 14, 1988 requesting additional time for a response. This letter was followed by the licensee's reply to the violations on January 26, 1988.
The section of the ASME Section XI code cited in this violation was Article IWV-3415. "Fail-Safe Valves", which specifies that "valves with i
fail-safe actuators shall be tested by observing operation of the valves upon loss of actuator power". Th e e air operated valves are required to open to provide steam to the steam driven Auxiliary Feedwater (AFW) pump
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which is used to add water to the steam generators.
The valve uses air as the motive force, with a solenoid valve venting off the air from the actuator top to open and off the actuator bottom to close.
These valves also have class I backup air accumulators to stroke the valve. The solenoid causes the valve to open upon an actuation signal or upon loss of power to the solenoid.
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In the response dated January 26, 1988, the licensee denied this violation. The reason stated was that this particular section of the code does not apply due~ to the fairly unique configuration of the valve.
That is, if there is no accumulator air or instrument air the valve will fail as is. Therefore, on loss of actuator power, the valve fails as is.
Based upon further inspection is this area, the inspector concurs with the licensee's explanation. This violation is rescinded and the item is closed.
3.
Unresolved Items (Closed) 85-22-03, "Review of Tests ind Procedures Required by Generic Letter 83-28. Section 3.2.1 and 3.2.2.
This item is from the NRC inspection at Trojan on Generic Letter (GL) 83-28, "Required Actions Based on Generic Implications of Salem ATWS Events:. As part of this inspection, post-maintenance testing was reviewed for all other safety-related components in the reactor trip system. The response appeared to be deficient with respect to
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post-maintenance testing by the inspector since it did not include an additional review of all safety-related equipment not provided by Westinghouse.
The response was then undergoing review by the office of Nuclear Reactor Regulatien (NRR) to determine the adequacy of the licensee's review.
In a letter dated February 12, 1986, Neighbors to Withers, regarding the licensee's response to GL 83-28, NRR concluded that the review conducted by the licensee was adequate to address the above and other concerns.
This item is closed.
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(Closed) 86-23-01, "Undocumented Engineering Judgement used in Place of Dy 1gn Analysis" This item was open during a Safety System Functional Inspection (SSFI)
team inspection at Trojan in 1986. The team reviewed calculation number TM-051, "CCW System Loss of Inventory Following a Seismic Event" Rev 0,
from the licensee's calculation file.
The calculation file concluded l
that the CCW system was not adequately protected from a seismic event
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because the seismic class I/ll interface valve would not close fast eliough. Loss of the CCW system could inhibit the ability of the plant to i
reach a cold shutdown condition.
The licensee indicated that the calculation was too conservative for various reasons. The most significant reason was the calculations
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assumption that the seismic ev"nt was a complete double ended guillotine rupture of the seismic class Il pipe.
The licensee stated that only a moderate energy crack need to be postulated. The amount of water lost from the guillotine break is much larger than the moderate energy crack.
Bechtel did an analysis of the CCW system (BP-12672, dated 12/6,b6) which stated that the design was reasonable if a full guillotine break was not
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considered. A review of this letter indicates that the design assumptions were adequate for a moo'erate energy crack.
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Another issue remained about which break had to be assumed. The office of Nuclear Reactor Regulation (NRR) was requested to review the seismic design basis for the failure mode of moderate energy systems.
Discussions between NRR and the licensee resulted in a letter from NRR dated 12/15/87 that a double ended guillotine break had to be assumed for the CCW system.
The licensee stated that they were going to upgrade the CCW system to seismic class I requirements in a letter dated 3/25/88, and submitted a license change amendment dated 2/21/88 to run the CCW system with the interface valve closed. The licensee is currently running in a split train configuration, with one valve closed.
The licensee's program for upgrading the system is proceeding to qualify the system to resolve this concern.
Based on the licensee's action plan and the progress made to date, this item is closed.
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(Closed) 86-23-04, "Review of Plant Modifications on Battery Sizing Calculation TE009" This item was open during a Safety System Functional Inspection (SSFI) at Trojan. The modifications to the 125 volt DC batteries changed the load profile to the batteries from the original load profile study performed in 1975, as reported in the Final Safety Analysis keport (FSAR). The load profile had not been updated in spite of changes to the DC system which could affect the capability of the battery to supply its safety-related loads. The licensee maintained that the loads remained within the profile.
During a design basis accident, 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 design assumptions on circuitry fed by the battery. The original design assumptions were noted in the original calculation. The licensee performed a new calculation. (TE-119) for the design loads on the battery, which supersedes calculation TE-009.
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For this new loading situation, the licensee performed a test on both
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trains of the battery to show that the battery would still perform its safety function with the load profile as per design. These tests are i
done in accordance with IEEE 450-1980. This IEEE standard takes into account aging and ten'perature factors, and runs the test at higher than l
service loads.
This item was reviewed in inspection report 87-14, in which the inspector noted that the B train battery had passed its load profile with the voltage maintained above 105 volts.
The A train test had not been done at the t'.me of that inspection.
The inspector reviewed the results of the A train battery test.
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battery maintained the design voltage for the duration of the test, but
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a tha battery did not pass by much. Based on the results of the battary tests, the licensee decided to replace both batteries. This was performedunderEngineeringChangeNotice(ECN)87-007,DesignChange Package (DCP) 1 and 2.
The licensee has completed their installation.
This item is closed.
-(Closed) 86-23-15, "Review of CCW Makeup Pumps for ASME Section XI Reouirements" This item was opened during a Safety System Functional Inspection (SSFI)
at Trojan. The inspector noted that the Component Cooling Water (CCW)
makeup pumps were not in the Inservice Testing (IST) program. These Seismic Class I pumps were installed to provide makeup water to the CCW system as necessary to provide for cooling capability. The need for such makeup may arise from existing system leakage or leakage across isolation valves installed between Seismic Class I and Class II systems.
The item was discussed with the licensee during that inspection, who stated that the pumps were not required.to bring the reactor to a cold shut down condition or mitigate the consequences of an accident.
The inspector was informed that the leakage out of the system due to break across the Seismic Class I/II interface would remove so much water out of that train that the makeup pumps would not matter.
For smaller leakages the pumps would help, but the system could be protected without
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the pumps.
The licensee has put these makeup pumps on the IST program to increase system reliability.
Based on discussions with the licensee, and the inclusion of these pumps in the IST program, this item is closed, j
i (Closed) 86-23-19 "Lack of Design Calculations for CCW Backup Nitrogen Bottles in their Rack (Strap Attachment)"
This item was opened during a Safety System Functional Inspection (SSFI)
at Trojan. The inspector noted that the safety-related Component Cooling Water (CCW) backup nitrogen bottles were loosely mounted. The specifics for securing the N bottles was noted on Wright-Schuchart-Harbor drawing
WSH-FS-111 rev. 6 as being field provided.
During the SSFI inspection, the licensee was unable to obtain the design calculations for the N bottle strap attachment.
This item was opened
pending further review The inspector looked at Request for Design Change (RDC) 86-030-C. The inspector reviewed the design calculations and inspected the installation. Both the calculations and design appeared acceptabic.
This iten is closed, i
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(Closed) 87-09-01, "Acceptance Criteria for Functional Testing of Snubbers" During this previous inspection, the inspector had a concern regarding the testing of snubbers. The inspector inquired if during testing of the snubbers, if the acceptance criteria for snubber lock-up and bleed rate compensate for the affect of temperature at which the functional test was performed. The concern related to the temperature compensation of the viscosity of the fluid.
If the viscosity remains constant, it does not need to be compensated.
If the viscosity does not remain constant, it should be adjusted for or analyzed for its effect on snubber operability.
The inspector looked at Request For Evaluation (RFE) 2736 which addressed this issue. The RFE stated that the viscosity did vary with temperature.
The RFE also stated that the temperature that it was tested at gave conservative results for snubber lock-up and bleed rates.
Based on this evaluation and discussions with the licensee, this item is closed.
(Closed) 87-31-04, "Adequacy of AFW Steam Admission Valve Testing" This item was opened during the last team inspection.
During recent testing of the steam admission valves to the Auxiliary Feedwater (AFW)
terry turbine by Periodic Engineering Test 14-2, the accumulators were to hold these valves open for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The inspector noted that the steam admission valves were specified in an NRC safety evaluation report dated October, 1980 to remain open for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> following a total loss of all AC power. The procedure was revised to have a hold 6ime of only 20 minutes.
A licensee telephone memorandum dated July 29, 1987 indicated that once
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the steam supply valves were open, steam pressure would keep them open.
There was no objective evidence to support this conclusion.
This item was opened, pending further review.
The inspector discussed this item with licensee personnel. The licensee stated that the steam supply to the AFW terry turbine is required to be maintained above 250 Psig due to system constraints. The stem assembly
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holding the valve open is 17/8 inch diameter stem (approximately 2.75 square inches). The valve disc assembly weight is less than 100 pounds.
Therefore, if friction forces which would keep the valve open are conservatively not considered, toe resultant force acting on the valve stem from the steam (Force times Area) is greater than the valve weight, which should keep the valve open once it has been open. The valve should remain open until the residual heat retroval system is operating.
Based on the above discussions with the licensee, this item is closed.
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4.
Followup Items (0 pen) 87-31-02, "Incomplete Design Change Package for Temporary Air Dryers" This item was opened during the last team inspection. As part of this team inspection, design modifications of the instrument and service air system were reviewed. The concerns in this item were:
1)
The "temporary" air dryer installation appears on the Piping and t
instrument drawing (P& ids) and is considered a permanent installation.
2)
The dryer skid is not anchored to the floor and is connected by an undocumented rubber air hose.
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The dryer is powered from an ordinary electrical outlet.
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3)
The flange connecting the rubber hose was missing 3 of its 8 bolts.
4)
A bypass line around the main dryer is required to be partially open for operation of the temporary air dryer, which could compromise the air quality.
The above concerns about the design, installation and design controls were considered as an open item by the team. The licensee was to evaluate this installation and determine its adequacy.
At the time of this inspection, the licensee has not completed their review for this item. This item remains open pending further inspection.
(Closed) 87-31-03, "Gradual loss of Air Test Reevaluation" This item was opened during a team inspection in 1988. The testing of the instrument air system was assessed during that inspection.
NRC Pegulatory Guide (RG) 1.68.3, "Prooperational Testing of Instrument and
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Control Air Systems", April, 1982, specifies that plants which undergo major modifications to the IA system, or portions thereof, should perform both a rapid loss-of-air supply test and a gradual loss-of-air supply test of all branches of the IA system simultaneously.
The licensee has not performed a slow loss of air test.
The licensee stated that they did not feel it necessary to perform the test. The NRC
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was also informed that the licensee was not comitted to the requirements of RG 1.68.3.
The licensee stated that they would reevaluate their position on this issue.
The licensee reevaluated their position ar:d the position is documented in a remo (TDW-396-8CM) T. Walt to D. Swan dated 6/1/88.
In this memo, the licensee stated that they were consnitted to RG 1.68.3 through a PGE in-house position (in the PGE Regulatory Guide Manual, PGE-1028). The
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licensee also noted that no major modifications to the air system i
occurred since RG 1.68.3 was issued.
Therefore, no testing had been i
perfomed on the air system, i
These clarifications resolve and close out this item.
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(0 pen) 87-31-07, "Integral Test o_n_pe IA Instrument Circuits" This item was opened during the last team inspection. As part of this team inspection, the routine surveillance testing (calibration) of instrument and service air system was reviewed. The concerns in this item were:
That the individual items (pressure switches, alarms, etc.) on the instrement and service air were calibrated separately. The licensee had no verification that the entire system had been integrally tested. That is, when the system is depressurizing, do all the relays and solenoids trip, and does the alarms in the contro'i room actuate at the correct setpoints.
At the time of the inspection, the licensee had not yet completed their evaluation. This item will remain open pending the licensee's review.
I (0 pen)87-31-09,"InstrumentIr.La,x_.Setpoints" i
This item was opened during the lot team inspection. As part of this team inspection, the setpoint index of the instrument and service air system was reviewed. The NRC reviewed 12 instrument setpoints for accuracy and identified 9 instruments were incorrect relative to the actual calibrated condition. This inspection report stated that the licensee should review all instrument index setpoints for the IA/SA system and correctly document existing system setpoints.
At the time of the inspection, the licensee was attempting to define the scope of work for this concern. The due date for this work to be
completed is 8/1/89.
The NRC will review the program in the future when the scope of the work has been defined. This item remains open,
.(Open) 87-31-11, "Controls for Bypassing IA Dryers and Filte m "
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This item was opened during the last team inspection. As part of this team inspection, the operation of the instrun.ent and service air systw.
was reviewed.
The NRC had a concern that licensee procedures allow the IA dryers and filters to be totally bypassed without evaluation of the effects of toisture i.nd particulates on the IA system and air actuated components.
Tl.is action places the IA system with air being used of an indeterminate quality. There were no compensatory measures being instituted, such as air quality verification or time limits for operating the systen in the degraded condition:
The inspector was infomed that the licensee had not completed their review of this item, but were planning en modifying appropriate procedures (e.g.01-7-5)
This item recains open, pending review of operating procedures.
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(0 pen) 87-31-20, "Vendor Manual Reconnendations" This item was opened during the last team inspection. As part of this team inspection, the implementation of vendor recommendations into the maintenance of the instrument and service air, system was reviewed.
The inspectors reviewed several vendor manuals and noted that the licensee does not vigorously 4plement vendor manual recommendations.
Three technical manuals were mentioned: (1) Technical Manual M123-9, Instruction Manual Main Steam Isolation-Stop and Main Steam Check Valves, November,1969,(2)ASCOBulletin8316,and(3)TechnicalManualM35-8, Instruments and Service Air Dryers and Filter:,, Revision 3.
The licensee did not fully implement vendor recomendations and did not have a documented evaluation or rationale for not complying with vendor reconnendations.
At the time of the inspection, the licensee had not completed their review. Their review was due to be completed on 9/1/88. This item will remain open until the licensee has completed their response.
(0 pen) 87-31-21. "011 on Valves with EPR Material"
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This item was opened during the last team inspection. As part of this l
team inspection, the licensees,sview of industry experiences with air systems of the instrument and service air system wat assessed.
IL Notice 86057, "Operating Problems with Solenoid Operated Valves at Nuclear Power Plants," July 11, 1986, addressed the possible problem of
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hydrocarbon contaminants in air systems causing degradations of valve seat and seals made with ethylene propelene (EPR) materials.
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licensees review of this notice said that there were no problems with hydrocarbon contaminants at T.ojan. During the inspection valves with EPR material were noted to oil present on the exhausts ports of that valve, i
The licensee has not completed their response to this item.
This item is due to be completed by the licensee on 9/1/88.
This item remains open pending completion of the licensee's reviev.
(0 pen) 87-31-22, "Maintenance Procedure Weakness" This item was opened during the last team inspection. As part of this team inspection, the licensees administrative controls for maintaining instrument and service air system reliability was assessed.
Several procedural weaknesses were identified.
These weaknesses are:
1.
Procedures did not exist which specified cleanliness standards, in process controls, or cleanliness verifications for maintenance activities on the air system.
2.
Procedures did not exist for verifying proper coeration of the air system oiler.
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3.
Procedures-did not exist for specifying inspection or replacement requirements for in-line air filters.
4.
A specific listing did not exist of equipment which use air pressure regulators, oilers, or in-line air filters to assist in preventative maintenance of these components.
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The licensee has not completed their review of this item.
The current target date for the licensee to complete their review is 10/1/88.
This item will remain open pending review of the licensees assessment of i
these procedural weaknesses.
5.
Exit Meeting i
On July 22, 1987, an ex!t meeting was held with the licensee representatives identified in paragraph 1.
The inspector sunearized the inspection scope and findings as described in this report.
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