IR 05000344/1989031
| ML20011F573 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/20/1990 |
| From: | Huey F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20011F570 | List: |
| References | |
| 50-344-89-31, NUDOCS 9003060291 | |
| Download: ML20011F573 (18) | |
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. U.: S. _ NUCLEAR REGULATORY COMMISSION -
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REGION Y
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i Report No.'50-344/89-31
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' Docket No. 50-344 r
i License No. NPF-1
Licensee: ' Portland General Electric. Company
121 S. W. Salmon-Street-
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Portland, Oregon 97204 Facility Name: Trojan Nuclear Power Plant Inspection at:. Rainier, Oregon Inspection Conducted:
December'4, 1989 through January 31, 1990
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Inspectors:
J. Burdoin, Reactor Inspec' tor C. Clark. Ranctor Irspector
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- Approved by: p
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F. R. Huey, Chief. Engineery S:t"m
'Date Signed ~
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. Summary:
L Inspection on December 4 1989 through January 31, 1990
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m (Report No. 50-344/89-31)
.A_reas Inspected:
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?An unannounced routine inspection by two regional inspectors of various vital
. areas and equipment in._the plant, Inservice, Testing (IST) activities' and'
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. follow-up of open items from previous NRC inspections.
Inspection Procedures Nos. 30703, 71707, 73756, 92700, 92701 and 92702 were used as-guidance for_the-E
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inspection.
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Results and General Conclusions:
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An example of licensee procedural noncompliance was identified. This
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. violation is a repeat of'aisimilar problems identified in Inspection Report Nos; 50-344/89-24:andL50-344/89-33. Procedure compliance appears to be an-
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~ area requiring additional management attention.
a Also, a fire pump procedure weakness was identified, indicating the need for.
improved engineering and technical performance in the fire protection area.
9003060291 900220
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PDR ADOCK 05000344 h-
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i Licensee follow-up actions and the use of the Trojan Comitment Tracking List
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(CTL) for identification and tracking of NRC identified concerns were found to The have been inaccurate, slow and lacking proper attention to detail.
licensee acknowledged these concerns and stated that:recent licensee organization changes.should prevent recurrence, A sample review of the latest procedures written with the new procedure
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writer's guide for Periodic Engineering Tests, Periodic Operating Tests, and Fuel Handling procedures, Volume III, identified several procedure weaknesses.
It appeared that not all procedure writer's guide requirements had been followed and similar procedures lacked consistency in some areas.
Significant Safety Matters: None Sumary of Violations: One violation was identified involving licensee TiTTure to comply with approved procedures for calibration of safety related equipment.
Open Items Sumary:
Eight open items and one Part 21 were closed. Three open items req 0' ired additional review / work and were left open.
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A DETAILS 1.
Persons Contacted
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- T. Andone, Shift Supervisor
- A. Ankrum Jr., Manager, Nuclear Security
- S. Bauer,in, Supervisor, QA AuditManager, Regulatory Branch
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Benjam K. Bohlander, Nuclear Safety and' Regulation Department
- D.' Cockfield, Vice President, Nuclear J. Neitzmann, Acting Assistant Operations Supervisor
- J. Lentsch, Manager, Personnel Protection Department
- J. Mody, Branch Manager, PSE
- P. Nelson, Acting Branch Manager, NRB
- D. Nordstrom, QA Supervisor M. Peery, Supervising Electrical Engineer, NPE
- J. Popp, Plant System Engineer-J. Reinhart, Manager Operations p
R. Reinhardt, Supervisor, Fire Protection A. Roller, Manager, Nuclear Plant Engineering L
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- M. Schwartz, Branch Manager and STE-
- C. Seaman, Manager,-Nuclear Quality Assurance D. Swan, Manager, Technical Services D. Swanson,. Manager, Nuclear Safety G. Tingley, System Engineer, Supervisor Electrical / Control
- T.' Walt, General Manager, Technical Functions
- J. Whelan, Manager, Maintenance
- W. Williams, Regulatory Compliance Engineer
- P. Yundt, General Manager, Trojan Plant G. Zimmerman, Manager, NSRD
- Attended the Exit Meeting on December 8, 1989.
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- Attended the Exit Meeting on December 21, 1989.
In addition, the NRC Resident Inspectors attended the Exit Meetings.
L The inspectors also discussed inspection related topics with other
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licensee personnel during the course of the inspection.
2.-
Operational Safety Verification (71707)
a.
An inspection was conducted in the Control and Auxiliary Buildin s.
The inspectors examined areas and equipment for debris, potentia hazards, oil and water leakage, and equipment condition, e.g., oil level, valve position, and electrical connection configuration and cleanliness.
The areas and equipment inspected included:
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Two 4160/480V switchgear rooms (trains A and B).
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Two 125V battery rooms.
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Two battery equipment areas, i
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-The cable spreading room.
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Two diesel generator rooms.
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The plant control room.
Housekeeping and equipment status appeared to be acceptable, j
'(EDGs)pection was conducted of the emergency diesel generators, and it wa An ins R
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had three yellow limit use tags and one white maintenance tag
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installed on four of the seventeen instruments.
Discussions with-the system engineer and other applicable personnel identified the
following:-
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The calibration work was performed per Trojan Maintenance Procedure MP 2-0, " Installed Plant Instrument Maintenance and
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Calibration." The May 5, 1989 calibration data sheet, TI-3821X.II.2Y (Form I&C-4) identified this instrument as a l
quality-related instrument.
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Section note 6.2.6.d of revision 12 of maintenance procedure MP 2-0, states in part, "if.the as found reading for quality-related instrumen.ts are outside the stated tolerance..." The I&C technician shall... bring it to the attention of the I&C supervisor or his designee.
They shall installed instrument out-of-calibration initiate a Form I&C-10,lity-related instruments."
investigation...for qua When the
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inspector requested a copy of the form I&C-10 issued as a
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result of instrument TI-3821X calibration failure on.May 5, 1989,.the licensee could not find any records that indicated one had been issued.
The licensee acknowledged that a Form I&C-10, should have been issued for this instrument. The fact that a Form I&C-10 was not issued for instrument TI-3821X, is an apparent violation (50-344/89-31-01).
The licensee :
identified they would issue a Form I&C-10 on this instrument,
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to meet the procedure requirement.
This is another example of.
licensee procedure noncompliance contributing to an apparent t
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violation.
A similar violation was issued in inspection report 50-344/89-24.
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During the inspection of the EDGs, the inspector performed a sample review of Periodic Operating Test (P0T 12-1
" Monthly Idle-Start andLoadingofEmergencyDieselGenerators,], revision 27, effective date November 17, 1989, and identified several procedure weaknesses.
This procedure was one of the new procedure revisions that was g
issued using the requirements provided in the new Trojan Procedure
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Writer's Guide, Periodic Engineering Tests, Periodic Operating Tests, Fuel Handling Procedures, Volume III.
The following procedure weaknesses were identified:
Sections 2.1.10 procedure and 2.1.13 data sheets of the Volume III Writers Guide indicate that the procedure and data sheets should identify the instrument identification number from which data is to be recorded.
In POT 12-1 there are a
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minimum of seventeen pages in this fifty eight page procedure, were the instrument identification number from which data is-to be recorded is not. identified.
Each of-these seventeen pages has several places where instrument data is required to se recorded.- An up to date surveillance procedure should-identify
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the instrument identification number from which data is to be recorded, to ensure the correct data is recorded.
l Sections 2.1.11 Acceptance Criteria (8.0) and 2.1.13
Data sheets of the volume III Writers Guide indicate that a
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method for the procedur'e user and the reviewer / approver to signify that the acceptance criteria have been met, should be.
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provided in the procedure Pages 42, 48, 52 and 56 of POT 12-1
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1 ave places for signoff b the operator, Shift Supervisor and ineer/ Level II ester, but there is no
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System Eng/information on those sheets that indicates that the statement acceptance criteria have been met, or what-the signatures are for.
In the last, similar signoffs have been performed by L
personnel witi the understanding that their signature only indicated that the procedure work had been accomplished, not-that all the acceptance criteria had been met.
An up to date surveillance procedure should identify on the same page exactly what a signature is signifying.
One violation was identified in this area (paragraph 2.b).
3.
Inservice Testing of Pumps and Valves (73756)
During this inspection,-the inspector notified the licensee that he wanted to observe available ASME Code,Section XI Inservice Testing (IST)
of pumps and valves.
The inspector observed a December 20 1989 surveillancetestperformedoncheckvalveSW-2014perPerIodicOperating Test P0T-7-3, Revision 4, " Service Water System - Booster Pump and Valve Inservice Testing." The performance of this test appeared to provide acceptable results, and the inspector did not identify any L
concerns.
No. violations or deviations of NRC requirements were identified in the areas reviewed.'
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4.
Onsite Follow-up of Written Reports of Nonroutine Events at Power Reactor Facilities (92700)
(CLOSED) 50-344/89-02-P, Part 21 "Limitorque Motor Operators, Failure of Torque Switches" The concern of this Part 21 is that limitorque motor operator sizes SMB-000 and 00, when placed in manual operation, allow the energy stored in the spring pack to be released.
It was found in valve actuators supplied with Melamine torque switches (where the valve had been over-torqued) that the energy released from the spring pack created an impact load which damaged the torque switch.
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SMB-000'and 00 valve actuators manufactured by limitorcue having serial numbers lower than-354839 and 233218 respectively coulc have been.
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supplied with Melamine torque switches.
Melamine torque switches can be easily identified by a white or gray colored insulating material.
The Melamine torque switch was~primarily-used in actuators qualified for harsh environments.
Limitorque recommends, as corrective action that all Melamine SMB-000 qualifiedFiberite(brown)torqueswitch.placedwiththeenvironmentally
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and old style SMB-00 torque switches be re SMB-00 actuators with serial numbers of 233218 or greater were furnished with the new style--00 torque switch which is not subject to cam binding or lug breakage.- Limitorque changed the SMB-000 torque switch from Melamine to Fiberite in 1983, therefore SMB-000 actuators with serial numbers greater than 354839 were-shippedwithFiberiteswitches.
The licensee action taken to date, in response to this part 21 was to
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upgrade all inside containment EQ safety-related limitorque actuators with EQ qualified Fiberite switches.
This was accom)11shed under Requested Design Change (RDC)86-033, DCP-4.
The scledule for the
replacement of the remaining switches is as follows:
r (1) Outside containment actuators scheduled for preventative maintenance in 1990 (approximately 29 actuators).
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(2) Outside-containment actuators scheduled for preventative maintenance c
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in 1991 (approximately 18 actuators).
(3) Outside containment actuators scheduled for preventative maintenance in 1992 (approximately 36 actuators).
The inspector examined in detail RDC 86-033, DCP-4 for the upgrading of the safety related limitorque actuators inside containment.
The RDC package calls for the environmental qualification upgrade of some forty t
eight limitorque operators located inside containment by the replacement of unqualified motors, limit switches, and torque switches.
The above identified documents appeared to be in good order and to be complete.
It is concluded that the modifications for the environmental qualificatiot, upgrade, including installation of qualified Fiberite torque switches, in safety-related limitorque actuators inside containment was adequately planned, implemented and documented.
This Part 21 is closed.
L No violations or deviations of NRC requirements were identified in the areas reviewed.
5.
Follow-up (92701)
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(CLOSED) 50-344/85-20-01; Unresolved
"IST-Program Procedure l
Findings" l
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In 1985 Region V and a NRC consultant performed an inspection of all L
Region V Licensees Inservice Test (IST) programs.
A concern L
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identified during these inspections, was that a majorit of the surveillance procedures reviewed at some licensee facil ties did not have a clear verification signoff statement prior to the reviewer signatures.
This statement should clearly identify if-the i
surveillance data' recorded met the acceptance criteria.
Examples were found where unacceptable surveillance data had been recorded in i
a surveillance procedure and the Shift Supervisor, IST Engineer, System Engineer etc. had all signed off for a review of the recordedsurveillancedata.- It appeared that the people reviewing
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these procedures had not identified that the recorded surveillance data was unacceptable.
Discussions with licensee personnel-who were signing off in these surveillance procedures, revealed that some personnel considered that their signature only identified that the procedure had been performed in an acceptable manner, not that the.
recorded data was acceptable.
Some Shift Supervisors considered that either an IST or system engineer had the' responsibility to evaluate the acceptability of t1e recorded data.
This procedure weakness was-identified to the Trojan staff in 1985,
as identified in Inspection Report 50-344/85-20 and the licensee stated they would review their surveillance procedures and revise them as required.
This procedure weakness has been discussed in Inspection Reports 87-14 and 88-01.
Other licensees in Region V have updated their surveillance procedures with clear signoff statements, such as "were all applicable tech. spec. surveillance requirements satisfied? _,Yes -- No", etc.
During this inspection, several signoff sheets from the latest revised periodic operating test (POT) procedures were reviewed, and the following was identified:
The best example of a signoff data sheet found during this
review was.page 35 of 53 in P0T-2-4 (revision 19).
The verification statement before the final signoff signatures stated "ALL LEAKAGE ACCEPTABLE YES N0 (provide details in comments)", and then a comment sectionT after the signoff signatures stated " Comments (indicate any problems encountered, any data not meeting acceptance criteria and actions taken.)"
Other signoff data sheets such as page 21 of POT-7-3 (revision 4) and page 8 of POT-1-5 (revision 11) had only the signatures followed by a comments section, similar to the one identified above.
These procedures did not have a test data acceptability verification statement prior to the signoff signatures.
When this item was identified to the licensee, the k
licensee' Inservice Testing (IST) surveillance group stated.that a procedure improvement program is now in operation, and this area of the surveillance procedures will be reviewed in the future and revisions made as required.
Based on the above, this item is closed.
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(CLOSED) 50-344/87-34-05; 55.55E Report
" Fire Detector Sensitivity Testing"
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This; item identified the NRC concern that the licensee's maintenance program for periodic measurement of fire detector instrument set point drift (sensitivity) was inadequate, in that no program had been formally-approved by the licensee and no trial program was in place.
The licensee had drafted and approved Maintenance Procedure
MP 12-21 " Smoke Detector Cleaning and Sensitivity Testing"1988).
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this item was last reviewed by Region V inspectors (August D
The inspector examined in detail procedure MP 12-21 which became effective November 20, 1989.
The procedure requires testing of one
hundred percent of ionization smoke detectors without the use of scaffolding in a five year period. -The testing is set'up on a group basis.
If two detectors in one group fail, this will require tlat
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two additional groups of detectors to be tested in the same year.
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The inspector concluded that the procedure adequately addresses the NRC concern.
This item is closed,
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c.
(CLOSED) 50-344/87-34-08; 50.55E Report
" General Employee Training (GEI)"
-Inspection Report No. 50-344/87-34 identified that a review of the licensee's General Employee Training (GET) program on fire protection at the site, identified the following:
The program instructs general employees'to make technical
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assessments about the. type and size of a fire before attempting to extinguish fires, but the program did not provide the degree of training and experience to enable them to accurately make such decisions.
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By directing general employees to attemat to extinguish. fires first and notify the control room / fire arigade after extinguishment of the fire, the-program places first-line
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responsibility for fire extinguishment on general employees.
By following these directions, a fire brigade response could be delayed.
The program contains terminology that may not have been easily comprehended by the novice to fire protection.
The instructions given to general employees appeared in some instances to be in conflict with the requirements of other
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h regulatory agencies, such as the Occupational Safety and Health Administration (OSHA).
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In response to the initial inspector observations, the licensee indicated that the fire protection portion of the GET program would be reviewed and revised where necessary; particularly in the area where the potential exists for general employees to delay fire brigade responses to actual plant fires.
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i During~this'insaection, the inspector reviewed administrative order A0-10-2, : ire Protection, Revision-25 and the latest Fire Protection (G1-C-01-HO, Revision 0)-information provided in the licensee GET program, and found it satisfactory.
This training
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information now instructs licensee personnel to report all fires to the control room, prior to any actions to extinguish a fire.
This item is closed, d.
(OPEN) 50-344/87-34-09; 50.55E Report
" Implementation of Modifications Required by Amendment No. 22 to Licensee No. NFP-1" This item identified the NRC concern that the licensee niay not have.
completed all of the modifications that were required to be implemented by Amendment No. 22 to the facility operating license.
In response to'this concern, the licensee performed a reassessment of the plant configuration and the required scheduler modifications.
According to the licensee, the results of this reassessment indicate some of these modifications may not have been implemented or have been modified as a result of recent modifications made to achieve Appendix R compliance.
The licensee indicated that-the evaluation oftheseconditionsjustifiedtheplantconfigurationandproposeda schedule to complete modifications to bring the plant in conformance with the 1978 SER and other SER supplements.
The licensee, in order to achieve compliance, submitted an amendment request to NRR November-30,.1988.
TheinspectorcoordinatedwiththeNRRProjectManagerand determined that the amendment request is still under review.
This item will remain open pending further licensee and NRC action, e.
(CLOSED) 50-344/88-13-04: Unresolved
" Adequacy of Corrective Actions Following Initial IST Valve Failures"
' Inspection Report No. 50-344/88-13 identified that when two valves failed surveillance testing, the initial actions taken by the licensee operator was to cycle the valves several times until their stroke times decreased to an acceptable value.
One valve (CV-10014)
did not change position on the first attempt to stroke the valve.
The follow-up investigation identified that the licensec had not provided operators with any documented guidance on what operator actions should be taken if a valve, pump or other equipment falls to change position / status, when called upon-to operate.
In some cases, I
attempting to stroke a valve or start a pump a second time, i/
something has failed, could result in equipment / system damago.
During normal operation or surveillance testing, if a valve, pump or other equipment failed to change positions, or perform as expected conservative action would normally require documentation an.), the (i.e., a valve to open or shut, pump to start or stop etc d
evaluation of the problem prior to any additional attempts to operate i _
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During this inspection licensee management made a commitment that the licensee would revlse or issue new procedures to provide specific documented guidance for operator actions to take if a valve, pump, or other equipment fails to perform as expected (i.e.,
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a valve to open or shut, pump to start or stop etc.) by February 28, 1990.
This commitment and date were verified at the December 21, 1989 exit based on the licensee commitment, it appears appropriate action has been taken for this concern.
This item is closed.
f.
(CLOSED) 50-344/88-13-05) Unresolved
" Stopwatch Used in IST Not Calibrated" Inspection Report No. 50-344/88-13-05 identified that the timing equipment / stopwatches used by the licensee to measure valve stroke times,werenotaurchasedormaintainedintheTrojancalibration program.
All otler licensees in Region V, maintain stopwatches used to measure valves stroke times, in their calibration programs.
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initial report identified that the licensee had not requested relief from using calibrated timing equipment during ASME Section XI inservice IST pump and valve testing, and that they stated they wouldeitherincludethesubjecttimingequipmentinthecalibration program or submit a relief request to NRR.
During this inspection, the licensee provided a memorandum MRS-13-88, dated May 1, 1988, that documented its position for not includingstopwatchesintheTrojancalibrationpro This
memorandum and discussions with licensee personnel, gram.
identified the following:
The licensee is committed to ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of i
Nuclear Power Plants, and section 5.2.16, states "it is not the i
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L intent of this Standard to imply a need for special calibration and control measures on rulers, tape measures, levels and other such devices, if normal commercial practices provide adequate L
accuracy." The licensee IST engineering staff has taken the j
position that a mechanical /electronical stop watch is similar L
to a ruler (no moving parts), tape measure (one or two moving L
parts), level (with a floating bubble), and that normal l
commercial practices will provide adequate accuracy.
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in the same paragraph of Section 5.2.16 of ANSI N18.7-1976, it states" Tools, instruments,testingequlpmentandmeasuring devices used for measurements, tests and calibration shall be of the proper range and type and shall be controlled calibratedandadjustedandmaintainedatspecifiedIntervals
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or prior to use to assure the necessary accuracy of calibrated devices." The licensee has taken the position, that the above portion of Section 5.2.16 did not identify a stop watch by name, so it does not apply to stop watches.
This item is closed.
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(CLOSED) 50-344/88-34-08; 50.55E Report'
" Service Water Backup" At this facility, fire pumps are used as a backup for the service water system.
At various times the diesel fire pump may be-
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scheduled to be out of service for maintenance.
Therefore,-during those maintenance periods it will not be available for backup for the Service Water System.
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During the initial inspection, the licensee identify that they were evaluating what (if any) compensatory measures should be implemented I
during a diesel fire pump maintenance period.
After the initial Appendix R audit inspection, the licensee issued internal Memorandum No. RQR-Q15-88, dated August 31, 1988, which concluded the following:
For a fire in fire areas M3 (Man Hole 3), M4 (Man Hole 4) and 11 (Service Water Pump Room), both fire pumps would be required
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supply for the service water system.
- Therefore, during the period that either fire pump is out of.
service, fire patrols wil.1 be established to detect and mitigate a fire in any of the three fire areas to prevent the loss of all three service water pumps and the subsequent need
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to use these fire pumps.
The fire' patrol measure will continue until an indepth-review is completed or relief is granted by the NRC.
During this inspection, the licensee identified this item was closed in the CTL.
The inspector reviewed the following licensee
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controlled documents, and identified a procedure weakness.
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Attachment A to'a April 28, 1989 letter from the licensee to
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l Region V, identified that the licensee had completed its review l-of the compensatory measures-implemented for fire pump outages.
The licensee determined that the use of hourly fire patrols was the most feasible means of ensuring the availability of service
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water during fire pump outages.
Administrative Order A010-2, " Fire Protection", Revision 25,
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which established the requirements and responsibilities for implementing the Fire Protection (FP) Program.
This procedure k
identified that recuests for periodic fire patrols shall be
completed in accorcance with A010-7, " Fire Protection System l"
Outages Periodic Fire Patrol Requests, and Fire Patrol /SWS
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Duties,"andrequiredallmaintenancerequests(MRs)tobe l-reviewed for Fire Protection Program requirements.
Administrative Order A0 10-7, Revision 2, identified in L
Section 4.1.4 that:
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.(1) During working-hours the Shift Supervisor (or designee)'
shall notify the FP Supervisor (or designee) of any impairments to the FP system.
(2): During non-working. hours, the Shift Supervisor (or designee)shallcom)1etea"FPsy"stemontageworksheet" and Periodic Fire )atrol Request.which shall be submitted to the FP supervisor or designee the next working day.
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Maintenance Procedure MP-12-8, " Fire Pump Diesel Engine"
(Revision 24), identified the following:
"An outage of this pump for greater than two hours,
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necessitates backup fire protection consisting of placing a
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fire pumper truck from the Rainier Fire Department, inside the plant protection area."
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i-None of the-licensee controlled / formally issued site procedures initiated the special compensatory fire patrols of fire areas M3, M4 i
and 11, when a fire pump was declared inoperable because of scheduled maintenance or identified damage.
Instead these formal
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procedures only directed that the FP supervisor (or designee) be forwarded a completed FP system outage work sheet.
When the FP
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L group receives this document, maintenance requests, etc., they
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referenced an internal manual that contained Fire-Protection Equipment Outage Compensatory Measures sheets, and direct that the y
required actions on the applicable sheets for that equipment be l
accomplished.
This internal FP manual was not a licensee formally
controlled manual.
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The procedure weakness identified with the existing licensee l-procedures, was the fact that a fire pump could be declared inoperable on Friday.at 8:00 p.m. because of equipment failure, and
L there was no licensee procedures / systems in operation to initiate
_4 fire protection equipment outage compensatory measures until Monday when the~FP staff, review personnel were available onsite to review
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the fire protection outage work sheet.
When this_ procedure weakness was identified to the licensee, they acknowledged it and agreed to review their procedures and correct -
this weakness.
During this inspection, the licensee issued a new
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procedure, Off-Normal Instruction ONI 67, " Loss of the Diesel or
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Electric Fire Pumps", Revision 0, effective date December 18, 1989.
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This instruction described the compensatory measures to be taken uaon the loss of either the Diesel or Electric Fire Pumps, to meet i
tie commitment documented in NRC Inspection Report 88-34.
This procedure weakness reinforced the continuing NRC concern about the adequacy of the licensee engineering and technical work in the Fire Protection Area.
When the licensee proposed, reviewed and l
implemented the compensatory fire patrols, acceptable reviews should have identified that there was no instructions to cover establishment of the patrols over weekends and holidays.
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s A' sample review of the " Periodic Fire Patrol' Logs" identified that the licensee has been performing hourly fire patrols in the applicable fire areas (M3, M4 and 11) for several months, as the results of work on fire doors, systems, etc.
There were no examples identified were a fire pump had been declared inoperable, or out for maintenance, and hourly fire patrols had not been performed.
.After reviewing the information identified above, it appears the licensee has corrected the identified procedure weakness and addressed the original concern in this area satisfactory.
This item is closed.
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(CLOSED) 50-344/88-34-14; 55.55E Report
" Trending Fire Protection Events"
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This item identified the NRC's concern that the licensee had not h
trended the several fire protection Licensee Event Reports (LERs)
l that had been submitted during the past year.
Consequently, trends if any, for these LERs had not been determined.
or common causes, initiated a review of the fire protection LERs to The licensee had determine any trending.
However, at the time of the inspection the review-had not been completed.-
The licensee's Plant Monitoring and Event Analysis (PMEA) group completed the review of-fire protection LERs and issued their report.
in November 1988.
The inspector ' examined in detail PMEA's report dated November 22,
-1988 on " Observation of Fire Patrols and Fire Barriers".
The report
' identified a number of areas of weakness-and provided recommendations to address these deficiencies, such as improved administrative controls of fire barriers and additional training of fire patrol personnel.
The report did not identify a common source as the cause for the several fire protection LERs submitted during the past year.
LThe inspector determined that the licensee had taken measures to implement the recommendations to correct the deficiencies and thst NRC concerns had been properly addressed.
This item is closed.
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(OPEiO 50-344/88-36-03; Unresolved" Lack of Redundacy on RCS Cold Leg, Hot leg, and Wide Eenge Steam Generator Level Instrumentation" During the August 8 to 12, 1988, Regulatory Guide (RG) 1.97 audit, the NRC inspectors identified that the redundancy requirements for Reactor Coolant System (RCS) temperature and Steam Generator wide-range level indication were not met by the Trojan design.
There was a lack of full redundancy on the power sources and instrumentation for these variables.
One failure of either vital instrument bus leaves the operator with minimal information on these variables, used in cooling down the plan.
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e During this inspection the inspector reviewed the following documents and informat on:
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A November 1989 Commitment Tracking List (CTL) printout listed
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licensee action for this item as " closed-action completed".
An
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NRC review of the licensee action on this item identified that U
the licensee had not completed their actions for this concern.
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An October 14, 1988, attachment B response to this-concern, identified.the following scheduled corrective actions:
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(1) The licensee had issued a nonconforming activity' report (NCAR) to initiate evaluation and correction to topical.
report PGE-1043 " Accident Monitoring Instrumentation
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Review." ArevisiontoPGE-1043wasscheduledtobe
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issued by December 15, 1988.
(2) Ajustificationforcontinuedoperation(JCO)wouldbe issued for the RCS temperature and steam generator level loss of redundancy, by October 31, 1988.
(3) A design alternative to resolve the conflicts between the Detailed Control Room Design Review (DCRDR) and RG 1.97
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would be evaluated, to determine a means of meeting the requirements of both by February 28, 1989.
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A licensee November 4,1988 letter (TDW-813-88M, JC0 88-14, Rev 0) and November 8, 1988 telephone call-(between NRC Rob Barr and Trojan Scott Bauer), identified the licensee did
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not issue a JC0 by October 31, 1988.
The JC0 was issued November 4, 1988.
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A licensee January 27, 1989 memorandum (DLF-0035-89M)
identified four design alternatives to address this concern, and recommended alternative 2. -Alternative 2 was recommended by the licensee staff, since they identified that it had already been reviewed and approved by the NRC, and was the-least expensive alternative.
This memorandum identified that a'
Request for Design Change (RDC) had been initiated to perform the modifications in alternative 2, and would be forwarded to
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the management review group for prioritization and inclusion into the five year plan.
The inspector requested a co)y of the RDC for alternative 2, and a copy of the five year plan t1at identified the priority assigned to
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this RDC.
The licensee identified that:
The Commitment Tracking List (CTL) had incorrectly listed this item as closed.
The applicable RDC for alternative 2 had never been completed and included in the five year plan.
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. j, The licensee issued memorandum WJW-04-90M on January 5, 1990, to request additional licensee actions to resolve this concern.
A copy of the memorandum was received by the NRC in Region V on January 18, 1990.
Based on the licensee failure to take actions to resolve this concern and the improper closure of it in the CTL, this item will remain open pending review during a future. inspection of additional closure actions taken by the licensee.
6.
Follow-uponItemsofNoncomplianceandDeviations(92702]
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(OPEN) 50-344/87-34-01; Enforcement
" Lack of Qualified staff~
Involvement in Fire Protection Program Implementation" Inspection Report No. 50-344/87-34 identified that licensee procedure No. NDP 200-1 required a fire protection review of Design Change Packages (DCPs) to assure that fire protection requirements E
were adhered to.
However, the procedure did not require that a qualified fire arotection engineer perform this review prior to or subsequent to' tie plant review board (PRB) approval of procedures, changes or modifications to plant nuclear safety-related structures,
-systems or components.
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Inspection Report No. 50-344/88-17 Identified the following:
The licensee initial response to the subject violation acknowledged and indicated revisions to licensee's procedures would be issued to specify the qualifications required for personnel to perform the subject reviews.
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The licensee's initial response further stated in part that,
"these requirements would be equivalent to those provide:I in BTP Chemical and Mechanical Engineering Branch 9.5 1."
The NRC April 18-31, 1988 inspection'of the latest licensee
procedure disclosed that the revised procedure did net conform to the appropriate NRC licensing documents.
Regardingthebroaderconcernforaqualifiedfireprotection engineer s consistent involvement in the design control process as part of the routine fire protection program implementation, during this later inspection the licensee took the position that after a careful reading of Technical Specifications and PGE-8010 (PGE Nuclear Quality Assurance Program), these i
documents do not explicitly require that a Fire Protection Engineer" review new designs and modifications.
The licensee feels that their response to statement No. A.~1 of Branch Technical Position (BTP) APCSB 9.5-1 substantiates their position.
Therefore, the various members of the licensee Engineering Department who are knowledgeable in fire protection system designs and the requirements of Nuclear Plant Safety are qualified to perform these reviews.
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The inspector informed the licensee that this issue would be reviewed with NRR for resolution.
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During this inspection, the inspector reviewed the available information and a three way telephone conference call was held on
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During this l:
call,thelicensee'againstatedthattheybelievedvariousmembers
of their Engineering Department who were knowledgeable in fire protection system designs and the requirements-of nuclear plant i
safety, were qualified to perform the subject fire protection D
reviews.
The licensee agreed to provide NRR with copies of available training arocedures, records, etc. to document the qualificationsoft1eirstaffforthesubjectreviews.
This item will remain open pending completion of NRR review of the information provided by the licensee, b.
(CLOSED) 50-344/88-17-01; Enforcement
" Failure to Install Fire Detector on the 93 Foot Elevation of the Fuel Building" Inspection Report No. 88-17-01. identified that:
Sections 5.4.4 and 5.4.6 of the NRC's Trojan Safety Evaluation Report (SER) dated March 1978, and Amendment No. 22 to Facility-Operating License No. NPF-1 required-the licensee to install two additional fire detectors over the Fuel Building Radwaste Storage Area and two additional fire detectors in the New and Spent Fuel Pool Storage Areas, at elevation 93 feet, by the end of the 1979 refueling outage.
During a plant tour on April ~20, 1988, the inspector and the licensee staff observed that no fire detectors were installed over the radwaste storage area, or in the new and spent fuel pool storage areas.
Further, the inspector's review of the licensee's fire protection general plant drawing (figure 3-1.4)-
for this elevation of the Fuel Building disclosed that the
drawing also indicated that there were no fire detectors installed in these areas.
The licensee was not certain that the fire detectors were installed within the schedular requirement of amendment No. 22 j
or that they were removed at some point during 9 years of plant operation.
During this inspection, the inspector reviewed the following documents:
A licensee June 22, 1988, response to this notice of violation, which identified the following:
(1) The licensee acknowledged the violation, in part.
(2) The licensee had verified that the subject fire detectors were installed prior to the end of the 1979 refueling
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outage as required by amendment'No,'22 to the operating-license; (3) The subject detectors were subsequently removed, per a-
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survey performed by a licensed fire protection engineer in 1984.
s-(4) The licensee interpretation.of the license condition was'
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that the fire detection system could be changed under the'
provisionsof10CFR50.59andthatNRCapprovalwasnot
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required for subsequent fire protection program changes.
(5) ThelicenseesubmittedLicenseChangeApplication (LCA) 151, " Fire Protection Program to the NRC on December 24,-1987 to implement the standard fire protection license condition recommended by Generic Letter 86-10.
TheTrojanFireProtectionProgramis-currently, _by reference, part of the Trojan Final Safety Analysis Report.
Therefore,_upon NRC approval'of LCA 151, the ability to evaluate and modify fire protection program features under 10 CFR 50.59 will be available.
-(6) The licensee has initiated a review of the status of the modifications committed to be made, as referenced in the
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amendment No. 22 license condition.
Any discrepancies
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identified in this review and the present plant t-configuration will be evaluated and reported to the NRC.
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A November 30, 1988, letter from the licensee.to the NRC, provided the results of a licensee review of the fire protection modifications committed to in Amendment No. 22 of the Trojan Facility Operating License. This letter was issued to meet the licensee commitment made to the NRC in the licensee June 22, 1988' letter.
Thisletter.identifiedthatthesubject fire detectors were installed prior to the end of the 1979 i~
l-Refueling.0utage, as required by Amendment No. 22.- The subject i
detectors were subsequently removed in 1984.
A fire detection system survey performed by a licensed fire protection engineer
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concluded'these detectors were in areas not required to achieve safe shutdown, did not comply with the spacing and-location requirements of National Fire Protection Association (NFPA)
72E-1984, " Automatic Fire Detectors," and if installed per NFPA 72E, would not respond adequately to smoldering fires.
Therefore, on the basis of this review, reinstallation of the subject fire detectors was not warranted.
This letter identified status of existing modifications plans and
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justificationstotheNRC,forreviewandapproval.
The inspector held telecon discussions with the NRR staff and the following was identified:
An internal Safety Evaluation Report (SER) was issued in August 1989 and is going through the review circuit now.
This document will address the subject fire detectors.
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The LCA 151 is still in the review circuit.
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Based-~on the facts that the NRC/NRR staff is addressing these concerns in the new SER and LCA 151, it appears that Region V has no-further action in this' area.
This item is closed.
7.
Comments on Licensee Performance in Following Up on NRC Identified Concerns and Use of the Trojan Commitment Tracking List (CIL)
During this inspection, while working with the CTL for identified NRC concerns and licensee actions, the inspectors noted the following:
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Follow-up Inspection Report 88-36-03 (record number 21992) had its status identified as closed-action completed, when the licensee had not issued a request for design change (RDC) that was identified as j
issued.
- It appeared that there were not independent licensee reviews of the l,
identified licensee closure actions and reference documents, to ensure all the required actions had been identified and completed.
It was a slow process to locate and retrieve some of the documents l.
identified / referenced in the CTL for some of the identified NRC
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concerns.
8.
Exit Meeting (30703)
1:
The inspectors met with licensee management representatives denoted in L
paragraph 1 on December 8 and 21, 1989.
The scope of the inspection and L
the inspector's finding up to the time of the meetings were discussed.
At these meetings, the inspector identified that they had obtained some information and requested some additional information be sent to the regional office, that would be reviewed later in the region, with the findings documented in this report.
The available information was reviewed and the findings included in paragraphs 2, 5 and 6 of this report.
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