ML20149J475

Insp Rept 50-344/88-01 on 880104-22.Violation Noted.Major Areas Inspected:Inservice Testing of Pumps & Valves, Including Review of Program,Procedures,Records & Interviews W/Personnel

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: ML20149J425 ML20149J462 ML20149J475
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

Docket No. 50-344

License No. NPF-1 l

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Licensee: Portland General Electric Company

121 S.W. Salmon Street

Portland, Oregon 97204

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Facility Name

Trojan Nuclear Plant

1 Inspection at: Rainier, Oregon  ;

Inspection Conducted: January 4-22, 1988  ?

Inspector: / M 0 f 8

C. C)Ap(, Reactor Inspector Date Signed l

Approved by: bbl 2< 1!hBB i

S. Richards, Chief Oate Signed ,

Engineering Section l

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4 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 '

q program, procedures, records, and interviews with licensee personnel.

During this inspection, inspection procedures 30703, 73756, and 92701 were '

used.

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Results: In the areas inspected, a violation was identified for inadaquate ,

4 review of IST surveillance data (paragraph 2.c).  ;

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8802230076 880205 I

PDR 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 ,

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

50-344/85-20-02, which has been discussed in NRC Inspection

Reports 85-20 and 87-14. ,

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:

• A review of data sheet (POT-5-1-DA) for POT-5-1 auxiliary I

feedwater system testing, performed December 23, 1987,

identified the following: (1) test data for paragraph 7.1.7, i

"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

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area.

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PET-9-4 states, "The objective of this procedure is to document i

, all IST pump and valve data and monitor operating parameters 1

for signs of component degradation."

l PET-9-4 also states, "IST-related parameters shall be compared (

to the reference data for each pump and will be used to .i

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determine the ultimate operability of the' pump," "The plant '

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  !

identified that the above required actions to compare / trend }

IST-related pump and valve parameters are documented two ways,

first by signing off in the plant test engineer signature area ,

, on each applicable MTP, PET, POT, and PICT data sheet (to  ;

l 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. l

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  ;

i 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 '

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 j

operability of the applicable pump and valves. The licensee i

stated that since the plant engineer's signature area had not l

! been signed off in the applicable data sheet in the record +

i vault and this information was not recorded on the applicable  !

data 109, it appeared the ASME surveillance and testing group l

. had not received and reviewed the subject data to determine the  !

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 i

! identify that whenever the next quarterly data sheet POT-5-1-DA )

test information was received and entered on the 1988 log  ;

sheet, that the reviewer should note that the 1987 log sheet }

was missing the December 23, 1981 data and should obtain it for  ;

comparison / trending of new data against the previous data. I

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l The inspector provided a copy of the applicable December 23,  !

i 1987, POT-5-1-DA data sheet to the ASME surveillance and j

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testing group for review and comparison with previous test l

data,

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! Based on the above information, it appears that a pump and/or I

valves tested per POT-5-1 on December 23, 1987, could have ,

deteriorated IST-related parameters, that would have gone t

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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 i

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,

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 l

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coments.

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- The October 13, 1987 "power removed" position for valve i

M0-8703 had been signed off with reference to a note which

read, "Power not removed locking collar installed on I

i control switch." l

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- The September 15, 1987 "power removed" position for valve

M0-8703 had been signed off with reference to a note which

read, "Power is removed via lockout switch in lockout with

j 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

POT-2-3-0B verifications identified above were inconsistent. .

The licensee agreed that they have had a problem in the past

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with personntl making their own interpretations of procedure

instructions, but stated they have been emphasizing procedure

. compliance in all recent training. The licensee has emphasized

j to their personnel that they either follow the procedure as  ;

written or if something is not clear, stop and request an l

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 ,

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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1 requested some additional information from the licensee and taat-this 'l

l- information would be reviewed in the region, and the inspector's findings-

identified in this report.

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