ML20149J475
| ML20149J475 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/04/1988 |
| From: | Clark C, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20149J429 | List: |
| References | |
| 50-344-88-01, 50-344-88-1, NUDOCS 8802230076 | |
| Download: ML20149J475 (7) | |
See also: IR 05000344/1988001
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U. S. NUCLEAR REGULATORY COPHISSION
REGION V
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Report No.
50-344/88-01
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Docket No.
50-344
License No.
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Licensee:
Portland General Electric Company
121 S.W. Salmon Street
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Portland, Oregon 97204
Facility Name: Trojan Nuclear Plant
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Inspection at: Rainier, Oregon
Inspection Conducted:
January 4-22, 1988
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Inspector:
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C. C)Ap(, Reactor Inspector
Date Signed
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Approved by:
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S. Richards, Chief
Oate Signed
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Engineering Section
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Summary:
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Inspection During the Period of January 4-22, 1988 (Report 50-344/88-01)
Areas Inspected:
This routine, unannounced inspection involved the areas of
inservice testing of pumps and valves.
The inspection included review of the
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program, procedures, records, and interviews with licensee personnel.
During this inspection, inspection procedures 30703, 73756, and 92701 were
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used.
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Results:
In the areas inspected, a violation was identified for inadaquate
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review of IST surveillance data (paragraph 2.c).
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8802230076 880205
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ADOCK 05000344
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OETAILS
1.
Persons Contacted
a.
Licensee
- D. Nordstrom, Engineer, Nuclear Safety and Regulation Department
- D. Swan, Manager, Technical Services
G. Kent, Supervisor, Surveillance and Testing
G. Bell, Engineer, Surveillance and Testing
b.
Oregon Department of Energy
H. Moomey, Oregon Resident Inspector
- Denotes those personnel in attendance at an exit meeting on
January 8, 1988.
The inspector also held discussions with other licensee and
contractor personnel involved with inservice testing of pumps and
valves.
2.
Inservice Testing (IST) Program
a.
IST Program Status,
Trojan is currently in their second 10 year inspection interval (May
20, 1986, through May 20, 1996) and is following Revision 0 to
PGE-1048, "Trojan Nuclear Plant Inservice Testing Program for Pumps
and Valves Second 10-Year Interval." This new program has been
submitted to NRR for review, and at the date of this inspection, NRR
had not yet issued a safety evaluation report (SER) on the new
program.
The licensee is currently in the process of preparing a
Revision 1 to this new IST program to incorporate changes discussed
during recent NRC inspections.
The current valve and pump IST program is written to comply to the
maximum extent possible with the requirements of the 1983 edition,
summer 1983 addenda, of the American Society of Mechanical Engineers
(ASME) Boiler and Pressure Vessel Code,Section XI.
During this inspection, the inspector performed a cursory review of
the new second 10 year IST program and relief requests, and did not
identify any arct? of concern,
b.
IST Procedures
The licensee implements the policies and procedures for inservice
testing of pumps and valves through various site procedures.
The
following procedures were reviewed:
Administrative Order - A0-6-1, Revision 15, "Periodic
Surveillance."
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Periodic Engineering Test - PET-9-4, Revision 7. "Documentation
of Inservice Testing Data for Pumps and Valves."
Various other Maintenance Test Procedures (MTP), Periodic
Operating Tests (POT), Periodic Engineering Tests (PET),
Periodic Instrument and Control Tests (PICT), and procedures
related to IST pump and valve testing.
During the review of A0-6-1, PET-9-4, various PAT, PET, and PICT
procedures, the following was identified:
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In the above procedures, IST actions were assigned to the plant
test engineer or designee.
These positions and qualifications
for the same did not appear to be identified in the licensee
procedures.
Since the plant test engineer or designee position
is responsible for a majority of the IST actives, these
positions should be defined in the licensee organization.
The
licensee agreed that additional clarification in this area is
required and they will review this item.
The data sheets in the procedures still do not contain a
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clarification / verification signoff statement. When the shift
supervisor, plant test engineer, engineering supervisor, etc.
applin a signature to the applicable data sheet, there should
be a statement included that identifies what they are signing
for.
As it stands now, the data sheets can be signed off
whether the data is acceptable or not.
This item has been
carried since May of 1985 as unresolved Item Ne
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50-344/85-20-02, which has been discussed in NRC Inspection
Reports 85-20 and 87-14.
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The licensee has assigned IST responsibilities to personnel and
organizations for prncedures, scheduling of testing, testing,
certification and calibration of instruments, and training of
personnel.
But not all of these activities are covered in
detail in the licensee's IST procedures, such as training of
personnel performing IST surveillances.
The licensee stated
they are in the process of writing some new position
description procedures that may provide additional
clarification of the above assigned responsibilities.
c.
IST Records
Various final IST records for pumps and valves were examined in the
records vault, and the following was identified:
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A review of data sheet (POT-5-1-DA) for POT-5-1 auxiliary
feedwater system testing, performed December 23, 1987,
identified the following:
(1) test data for paragraph 7.1.7,
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"Turbine AFWPP Parameters," on this data sheet had been changed
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from 450 to 4550 without any identification of who changed the
test data.
(2) this data sheet did not appear to h6ve been
reviewed by the plant test engineer or designee, since there
was no signature in this signoff area.
All other data sheets
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reviewed had a signature in the plant test engineer sig e ff
area.
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PET-9-4 states, "The objective of this procedure is to document
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all IST pump and valve data and monitor operating parameters
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for signs of component degradation."
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PET-9-4 also states, "IST-related parameters shall be compared
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to the reference data for each pump and will be used to
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determine the ultimate operability of the' pump," "The plant
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test engineer or designee shall review the test to determine
the need for increased frequency of testing on the alert list,"
and "IST-related parameters shall be compared to the data
(from the most recent, previous data) for each valve, and will
be used to determine the ultimate operability of that valve."
The supervisor of the licensee surveillance and testing group
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identified that the above required actions to compare / trend
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IST-related pump and valve parameters are documented two ways,
first by signing off in the plant test engineer signature area
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on each applicable MTP, PET, POT, and PICT data sheet (to
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document review of the applicable test data) and the second by
recording the IST-related parameters in the applicable IST
pump and valve data log for comparison.
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In the case of POT-5-1-DA data sheet information, the inspector
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reviewed the subject 1987 IST pump and valve data log for
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Procedure Data Sheet POT-5-1-DA/DB and found that the December
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23, 1987, data had not been entered in the log. When the
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licensee was question about the above item, they could not-
provide any evidence that the IST-related parameters had been
reviewed or compared to previous data to determine the ultimate
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operability of the applicable pump and valves. The licensee
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stated that since the plant engineer's signature area had not
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been signed off in the applicable data sheet in the record
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vault and this information was not recorded on the applicable
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data 109, it appeared the ASME surveillance and testing group
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had not received and reviewed the subject data to determine the
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ultimate operability of the applicable pump and valves.
Test
data from other tests perfomed during the same time period had
been entered on the applicable log sheets. The licensee did
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identify that whenever the next quarterly data sheet POT-5-1-DA
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test information was received and entered on the 1988 log
sheet, that the reviewer should note that the 1987 log sheet
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was missing the December 23, 1981 data and should obtain it for
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comparison / trending of new data against the previous data.
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The inspector provided a copy of the applicable December 23,
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1987, POT-5-1-DA data sheet to the ASME surveillance and
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testing group for review and comparison with previous test
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data,
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Based on the above information, it appears that a pump and/or
valves tested per POT-5-1 on December 23, 1987, could have
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deteriorated IST-related parameters, that would have gone
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unreviewed for a minimum period of at least 3 months.
7hese
unreviewed IST parameters could lead to the failure cf a pump
or valve that could affect safe operation of the plant.
Failure of the licensee to compare the December 23, 1987
POT-5-1-DA data sheet IST-related parameters to the data from
the most recent (previous) data for each pump and valve (as
required by PET-9-4), to determine the ultimate operability, is
an apparent violation (344/88-01-01).
A review of data sheet (POT-5-1-DA) for POT-5-1 (perfomed
August 21,1987) identified that unacceptable test data in
paragraph 7.1.9.3 for valve CV-1452 stroke time had been
changed from 12 seconds to 5 seconds. The acceptable stroke
time for the valve was 10 seconds. Based on the available
information, the inspector could not identify if the valve had
been stroked the first time in 12 seconds, and then restroked a
second time in 5 seconds. These valves are required to be
timed on their first stroke. The change had been initialed,
but there was no date to identify when this change was made.
The licensee stated their procedures for making changes to
official test data only require an initial, but they agree
that it might be a good idea to add some additional
clarification infonnation for pen and ink changes that change
unacceptable test data to acceptable test data at some
unidentified point in time.
They will look into this item.
The valve was retested the same day, August 21, 1987, and
evaluated acceptable per a data sheet PET-9-4-DBY.
A review of data sheet (POT-8-1-DCE) for POT-8-1 (performed
February 27,1987) identified that a test data conversion
value, in the note under paragraph 7.4.6, was changed from 49
to 52 for instrument FI-3208, without any initial or signature
to identify who changed this value. The licensee stated they
would look into this item.
A review of POT data sheets, discussions with licensee
personnel, and tours of plant equipment indicate that there are
no position location markers or instructions issued by the
licensee, to ensure pump bearing temperatures are always taken
at the same location each time. A licensee representative
agreed that good engineering practice would be to obtain all
test data from the same location each time, and they are
reviewing this item now based on inhouse coments.
d.
Work Observation
During this inspection, the inspector observed the performance of
monthly POT-2-3-DB, Revision 24, data sheet. "Safety injection
System Train B ECCS Valve Lineup Verification." Paragraph 7.2 of
this POT stated, "Verify Train B valve positions and breaker or
power lockout switch positions." On January 5, 1988, the operator
identified that he could not verify the power lockout switch
position for valve M0-8703 (RHR hot leg injection) since the data
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sheet listed the position as "power removed." The operator and
other shif t members understood the tem "power removed" to identify
that power had been removed from the valve motor by opening the
local breaker switch and tagging it with a danger tag (see paragraph
7.3.1.3.7 page 8 of this POT for a similar example). The control
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switch for valve MO-8703 had been modified, so that for this valve
lineup the control switch was required to be pulled to the lockout
position with the lockout collar installed on the control switch.
Since the data sheet had an incorrect position statement for valve
M0-8703, the operator did not sign for the valve position and added
the following comment, "Power not removed, collar installed not
satisfied requirements M0-8703 deenergized."
In accordance with Administrative Order - A0-4-2, "Plant Operating
Manual, Use of Procedure," the operator requested a change to the
POM procedure. On January 6,1988, deviation number D88-002 was
issued to change the position of valve M0-8703 from "power removed"
to "control switch in lockout with collar installed."
When the inspector reviewed previous POT-2-3-08 data sheets,
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the following was identified:
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The December 8, 1987 "power removed" position verification
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for valve MO-8703 had been signed off with no 'dditional
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coments.
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The October 13, 1987 "power removed" position for valve
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M0-8703 had been signed off with reference to a note which
read, "Power not removed locking collar installed on
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control switch."
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The September 15, 1987 "power removed" position for valve
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M0-8703 had been signed off with reference to a note which
read, "Power is removed via lockout switch in lockout with
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collar installed as per GOI-1 and O!-4-1."
Based on the above information, it appears that the operator
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actions taken during the performance of the previous data sheet
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POT-2-3-0B verifications identified above were inconsistent.
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The licensee agreed that they have had a problem in the past
with personntl making their own interpretations of procedure
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instructions, but stated they have been emphasizing procedure
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compliance in all recent training. The licensee has emphasized
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to their personnel that they either follow the procedure as
written or if something is not clear, stop and request an
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official procedure change.
Within the area inspected, one violation was identified.
3.
Exit Meeting
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The inspector met with the licensee representatives idantified in
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paragraph 1 on January 8, 1988. The scope of the inspection and findings
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up to that date were discussed. The inspector identified that he had
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requested some additional information from the licensee and taat-this
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information would be reviewed in the region, and the inspector's findings-
identified in this report.
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