ML20196D159
| ML20196D159 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 02/08/1988 |
| From: | Zimmerman R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8802170034 | |
| Download: ML20196D159 (1) | |
See also: IR 05000344/1987031
Text
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FEB 0 81938
Docket No. 50-344
Portland General Electric Company
121 S. W. Salmon Street
Portland, Oregon 97204
Attention:
Mr. David W. Cockfield
Vice President, Nuclear
Gentlemen:
Thank you for your letter dated January 26, 1988, in response to our Notice of
Violation and Inspection Report No. 50-344/87-31, dated December 17, 1987,
informing us of the steps you have taken to correct the items which we
brought to your attention.
Your corrective actions will be verified during a
future inspection.
Your cooperation with us is appreciated.
Sincerely,
,
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R. Ifmmerman, chief
Reactor Projects Branch
bec w/ copy of letter datea 1/26/88:
Resident Inspector
Project Inspector
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G. Cook
B. Faulkenberry
J. Martin
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RECEIVED
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David W. Cockfield Vice President. Nuclear
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January 26, 1988
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Trojan Nuclear Plant
Docket 50-3a4
License NPF-1
U.S. Nuclear Regulatory Comission
ATTW: Document Control Desk
Washington DC 20555
Dear Sir:
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Response to Notice of Violation
Your letter of December 17, 1987 transmitted a Notice of Violation and
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Notice of Deviation associated with NRC Inspection Report 50-344/87-31.
Our reply to the Notice.of Violation is provided in Attachment A.
Our
reply to the Notice of Deviation is providtd in Attachment B.
In addition,
you have requested a detailed written description of our action plan to
address deficiencies in the December 17 transmittal letter, as well as
improvements to that plan to ensure successful implementation. After
conversation with your staff, it is our understanding that submittal of an
update to our Engineering Improvement Action Plan would be appropriate in
addressing your concerns. The updated action plan will be forwarded by
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January 29, 1988.
Sincerely.
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Attachments
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c: 1Mr. John B. Martin
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Regional Administrator, Region V
U.S. Nuclear Regulatory Commission
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Mr. William Dixon
State of Oregon
Department of Energy
Mr. R. C. Barr
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NRC Resident Inspector
Trojan Nuclear Plant
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment A
Page 1 of 10
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REPLY TO NOTICE OF VIOLATION
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Violation A
Technical Specification Surveillance Requirement 4.7.1.2.1 specifies, in
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part, "Each safety related duxiliary feedwater pump shall be demonstrated
OPERABLE...by verifying that the steam turbine-driven pump starts...(when
tested pursuant to Specification 4.0.5) . . . ." Specification 4.0.5 stipu-
lates "... inservice testing of ASME Code Class 1, 2 and 3 pumps and
valves shall be performed in accordance with Section XI of the ASME
Boiler and Pressure Vessel Code...."
The 1983 ASME Boiler and Pressure
Vessel Code,Section II, "Rules for Inservice Inspection of Nuclear Power
Plant Components", Division 1. Article IWV-3415. "Fail-Safe Valves",
specifies that "valves with fail-safe actuators shall be tested by
,
observing operation of the valves upon loss of actuator power."
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Contrary to the above, as of October 2, 1987 the AFW turbine driven pun 9,
had not been verified to be capable of starting by operation of the steam
admission valves coincident with loss of actuator power (using only
accumulator air).
This is a Severity Level IV Violation (Supplement I).
FCE Response
PGE does not consider this a violation for the reason described below.
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The auxiliary feedwater (AFW) pump steam admission valves fall as-is
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under loss of air power to the valve actuators. These valves do not have
fail-safe actuators.
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The design of the AFW turbine steam admission valve accumulator / actuator
air system is relatively unique. There are no internal or extern 01
actuator return springs. The valve actuator piston must be pneumatically
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powered in both directions to stroke the valve. Pressurized air is
directed to the upper or lower sides of the actuator piston by a 4-way
solenoid pilot valve.
The solenoid valve is normally energized with the
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steam admission valve in the (normally) closed position.
If electric power f ails or is turned off (ie, when the valve control
switch is moved to OPEN), the solenoid valve de-energizes, changes
position, vents the top side of the actuator piston to atmosphere, and
sicultaneously changes pressurized air from the top side of the actuator
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piston to the bottom side of the actuator piston to stroke open the steam
admission valve.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment A
Page 2 of 10
If the Seismic Category II normal instrument air supply fails, two check
valves in series close on back pressure from a Seismic Category I backup
accumulator so that, with electric power available, the steam admission
valve can be stroked open (or closed) by actuating (de-energizing or
energizing) the solenoid pilot valve.
However, if there is no pressurized air (empty accumulator and (Ailed
instrument air supply) and no electric power, the steam admission valve
fails as-is.
It does not fall safe.
The steam admission valve remains
as-is when the loss of air actuator power occurs. Article IWV-3415
"Fall-Safe Valves", does not apply.
Violation B
10 CFR 50, Section 50.55a(s) sets forth requirements for inservice
inspection and testing of nuclear plant components.
The licensee's
program for inservice testing (IST) of pumps and valves is described in
Topical Report PCE-1048, "Inservice Testing Program for Pumps and Valves,
Second 10-Year Interval".
Section 1.0 "Introduction" of PGE-1048 indi-
cates "...those systems designated Quality Group 1, 2, 3A, and 3B in the
Updated Final Safety Analysis Report (UFSAR) are included in the IST
program...."
UFSAR Figure 10.2-3 "Main Steam System" identifies air
supply valves MS226 and MS222 to AFW Terry turbine steam admission
isolation valve CV 1453 as Quality Group 2.
Contrary to the above, as of October 2, 1987, valves MS 226 and MS 222
had not been included in the licensee's IST program.
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This is a Severity Level IV Violation (Supplement I).
PCE Response
PGE acknowledges the violation.
1.
Reason for Violation
Motor-ope ated valves in the steam supply lines to the turbine-driven
AFW pump wcre replaced with air-operated valves in response to
station blackout concerns to ensure an available water supply to the
As part of this modification, backup Seismic
Category I air accumulators were added which are in parallel with the
seismic Category II normal instrument air supply system.
The
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accumulators are separated from the instrument air system by two
series check valves.
Modifications were performed using American
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National Standards Institute (ANSI) B31.1 for design and construction.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
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License NPF-1
Attachment A
Page 3 of 10
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This portion of the system was originally shown as Quality Group 4B
on Sheet 1 of FSAR Figure 10.2-3, "Main Steam System", which exempted
it from testing in the IST Program.
The current FSAR figure shows
this portion of the system as Quality Group 2, no longer exempt, as
noted in the Notice of Violation.
During 1987, check valves MS 222
and MS 226 were identified as an open item for addition to the IST
Program. The change in FSAR figures was discovered by an independent
contractor who had been secured to perform a detailed review of
Trojan's IST Program. This determination had besn made prior to NRC
Inspection 87-31.
A program revision and change in testing had not
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yet been performed.
2.
Corrective Action Taken and Results Achieved
These valves have been included in a marked-up copy of Topical Report
PGE-1048, "Inservice Testing of Purps and Valves Second 10-Year
Interval". Testing of this system will be modified to meet ASME
Section XI Code requirements for these check valves.
3.
Corrective Steps That Will Be Taken To Avoid Further Violations
Remaining open items which were identified by the 1987 review of the
IST program will be reviewed by System Engineers to improve design
basis testing and code applicability.
The applicable items will be
included in a second revision to Topical Report PCE-1048, which will
be submitted to the NRC by December 31, 1988.
4.
Date When Full Compliance Will Be Achieved
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Revision 1 to Topical Report PCE-1048 is currently under review and
approval for submittal to the NRC by February 15, 1988. Test proce-
dures to implement testing of these check valves will be in place by
March 1,1988, at which full-time compliance will be achieved,
violation C
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10 CFR 50.59 requires that the licensee shall maintain records of changes
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in the facility, to the extent that the changes constitute changes to the
facility as described in the safety analysis report, and must include a
written safety evaluation which provides a bases for the determination
that the change does not involve an unreviewed safety question.
Trojan
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UFSAR Figure 9.5-10 requires the Emergency Diesel Centrator (EDG) Air
Start System pressure regulators to be set such that downstream pressure
is 200 psig.
Contrary to the above, on October 2, 1987, the eight EDC Air Start System
pressure regulators downstream pressure setpoints were 180 to 190 psis.
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Trojan Nuclear plant
Document Control Desk
Docket 50-344
January 26, 1988
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License N)F-1
Attachment A
page 5 of 10
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3.
Corrective Steps That Will Be Taken To Avoid Further Violations
A revision to Administrative Order (AO) 5-4, "plant Setpoint
a.
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Changes", bos been prepared and will be submitted for approval.
This will provide specific z.',uidance on the need for a safety
evaluation when changing a pressure reguintor's setting.
b.
Other pressure regulators in safety-related applications will be
reviewed for consistency with setpoints specified in the FSAR.
4.
Date When' Full Comp 1'anc* Will Be Achieved
Since a safety evaluttion hs.s been performed supporting the current
regulator setpoint, t'ull cospliance has been achieved.
In addition,
the revision to A0 5-4 har already been submitted and should be
approved by February 29. 1988.
The riiview of other pressure
regulatory setpoints will be completed by December 31, 1988.
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Violation D
10 CFR 50, Appendix B Criterion V, requires that activities affecting
quality shall be prescribed by documented instructions, procedures or
drawings and shall be accomplished in accordance with these instructions,
procedures or drawings.
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1.
Bruce GM Diesel Inc. Drawing A071F07001, Revision 9 - Schematic
Diagram - Air Start System for Tandem Engine Unit, requires the EDG
Air Start System lubricators to be installed upstream'of the relay air
valves.
2.
Drawing A071F07001, noted abcve, does not indicate installation of a
pressure sage on the EDG Air Start System Relay air valves.
3.
Drawing A071F07001, noted above, requires EDG Air Start System
pressure gages downstream of it.e pressure reducing valves to be
0-300 psig Suges.
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Contrary to the above, on October 2, 1987.
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1.
All eight lubricators of the EDG Air Start System were downstream of
the relay air valves.
2.
One of eight relay air valves was equipped with a pressure sage.
3.
One of eight pressure reducing valves downstream pressure gages was a
0-200 psig gage.
This is a Severity Level IV Violation (Supplement I).
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Trojan Nuclear Plant
Document Contr01 Desk
Docket 50-344
January 26, 1988
License hPF-1
Attachment A
Page 6 of 10
PGE Response
PGE acknowledges this violation.
1.
Lubricators
a.
Reason for Violation
PGE concurs that the installation of the lubricators does not
comply with the vendor's schematic drawing, Bruce GM Diesel Inc.
Drawing A071F07001 (PGE Drawing No. M16-19, Rev. 9).
However, the
installation does comply with the vendor's detailed description of
the installation and function of the lubricator (including a
photo) in Section 14 of Technical Manual M16-90 (Pages 14-1 and
14-5).
We have contacted the vendor, who advised us that the
installation is proper. The drawing was as-built by the vendor in
December 1974.
b.
Corrective Action Taken and Results Achieved
The drawing has been revised to reflect the proper installation of
the lubricators.
Corrective Steps That Will Be Taken To Avoid Further Violations
c.
A Piping and Instrumentation Diagram (P&ID) will be prepared by
PGE for the diesel air start system by April 1988.
d.
Date When Full Compliance Will Be Achievad
Since the drawing has alrea.d
S=an revised, full compliance has
been achievid.
2.
Relay Air Valve Pressure Gauge
a.
Reason for Violation
PGE concurs that a 0-600 psi gauge was it. stalled in the air start
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system on East Engine B K106A2 on the north side, and a pulsation
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- dampener is installed in tubing to the governor air boost on the
south side of the West Engine K106B1, neither of which is identi-
fled on the vendor's drawing or other design documents.
The
reason for the installation has not yet been determined.
Because
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the gauge does not have a tag denoting temporary installation, it
is possible that this equipment was installed during startup.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment A
Page 7 of 10
b.
Corrective Action Taken and Results Achieved
An evaluation was initiated, Nonconformance Report (NCR)88-013,
to determine disposition of the gauge and pulsation dampener. The
gauge was determined not to be necessary and was removed. The
evaluation of the puisttion dampener has not been completed.
c.
Corrective Steps That Will Be Taken To Avoid Further Violations
A diesel air start P&ID will be prepared by April 1988,
d.
Date When Full Compliance Will Be Achieved
corrective action for the pulsation dampener will be determined by
February 15, 1988. Full compliance will be achieved no later than
April 1988.
3.
Air Start System Pressure Gauge
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a.
Reason for Violation
PGE concurs that West Engine A K106Al on the south side has a
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0-200 psi gauge installed on the regulator, which is not in
accordance with the latest revision of the vendor's drawing in
PGE's controlled drawing system which requires a 0-300 psi gauge.
A review of Plant records revealed that on May 15, 1981, the
installed 0-300 psi gauge failed a preventive maintenance check
and was replaced with a 0-200 psi gauge. This incorrect instella-
tion may have been due to an older (1972) revision of the vendor
drawing, contained in the technical manual, which shows a
0-200 psi gaugc. This drawing was stamped in December 1986 with
s notice that refers the user to the controlled drawing in PGE's
drawing system. This method of control is permitted by PGE
Nuclear Division Procedure (NDP) 100-3, Section 5.4.
The stamping
occurred as the result of a special task force effort to improve
control on all Technical Manuals.
b.
Corrective Actions Taken and Results Achieved
A new 0-300 psi gauge has been installed. A 300 psi gauge is
preferable because this local gauge is used to indicate a normal
line pressure of about 200 psig.
It should be noted that this
same line pressure is also sensed by another 0-300 psi gauge which
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is mounted on a panel in the same room.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment A
Page 8 of 10
c.
Corrective Steps That Will Be Taken To Prevent Further Violations
The new diesel air start system P&ID will be prepared by April
1988.
d.
Date When Full Compliance Will Be Achieved
Since a new 0-300 psi gauge has been installed, full compliance
has been achieved.
Violation E
10 CFR 50 Appendix B Criterion II requires the establishment of a QA pro-
gram.
PGE Nuclear Quality Assurance Program, Supplement 1, incorporates
ANSI N18.7-1976, Paragraph 5.2.8, specifies that a sur-
veillance testing and inspection program shall be prescribed to insure
that safety-related structures, systems and components will continue to
operate, keeping parameters within normal bound, or will act to put the
plant in a safety condition if they exceed normal bounds.
Contrary to the above, eight EDG Air Start System air receiver relief
valves had not been tested, inspected or set since original construction.
This is a Severity Level IV violation (Supplement I).
PGE Response
PGE acknowledges the violation.
1.
Reason for Violation
The EDG Air Fatart System air receiver relief valves are not included
on any P&ID and had not been considered for inclusion in any test or
inspection program. A recent review of the Trojan safety-related
component list has identified these relief valves as Quality
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Group 3B.
An evaluation had not yet been completed to determine
appropriate testing and inspection requirements.
2.
Corrective Action Taken and Results Achieved
An evaluation is being performed to determine testing and inspection
requirements commensurate with the safety-related function of the
valves.
This evaluation will be complete by June 1988.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment A
Page 9 of 10
3.
Corrective Steps That Will Be Taken To Avoid Further Violations
Following the recent upgrade of the safety-related list, other system
components are being evaluated for possible inclusion in the IST
program. This review will ensure that safety-related components are
appropriately addressed in or exempted from a test and inspection
program.
4.
Date When Full Compliance Will Be Achieved
Full compliance will be achieved by June 1988.
Violation F
10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and
Drawings", requires that "Activities affecting quality shall be
prescribed by... drawings ...and shall be accomplished in accordance
with these... drawings." Trojan Nuclear Plant drawing number HBD-80-50
delineates the installation of support H 834 on the safety related portion
of the instrument air supply line to the actuator of main steam isolation
valve CV 2216.
Contrary to the above, on September 22, 1987, support 11834 was not
attached to the air supply line.
This is a Severity Level V violation (Supplement I).
PGE Response
PGE acknowledges the violation.
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1.
Reason for Violation
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Pipe Support H 834 was removed as part of work on a design change
made in the area during the 1987 refueling outage.
The modification
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involved the installation of new deck grating.
The design change
package recognized the possibility of hanger interfereneus, but did
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not specifically identify the need for removal of Support H 834.
During installation of the modification, the job coordinator did not
recognize H 834 as a seismic support on a safety-related system and
f ailed to provide written instructions, as required, to ensure the
support was properly reinstalled.
Following installation of the deck
grating, the final closecut inspection failed to identify the
disconnected pipe support.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment A
Page 10 of 10
2.
Corrective Actions Taken and Results Achieved
a.
The pipe support was immediately reinstalled.
b.
An analysis was performed to determine the effect of the discon-
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nected support on the operability of the instrument air system.
Calculation TM-248 determined that removal of the support did not
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render the system inoperable.
c.
The job coordinator was instructed on the required actions regard-
ing removal and reinstallation of pipe supports.
Affected work
groups have been instructed that they not perform work outside the
scope of specific work instructions.
d.
An investigation was performed which determined that the
responsible job coordinator was not assigned any other jobs
involving pipe supports during the 1987 refueling outage.
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3.
Corrective Steps That Will Be Taken To Avoid Further Violations
A general instruction will be issued to job coordinators to remind
them of the necessity of written instruction for seismic supports.
4.
Date Wnen Full Compliance Will Be Achieved
Full compli nce has been achieved.
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Trojan Nuclear Plant
Document Control Desk
Docket 50-344
January 26, 1988
License NFF-1
Attachment B
Pago 1 of 2
Deviation A
UFSAR, page 9.3.4 stated, in part, that Required air cleanliness is
maintained by the following features:
"oilless compressor cylindar"
"filters inctalled in all lines to instruments and valves"
Contrary to the above, at the tire of the inspection the Trojan instru-
ment air system utilized a rotary compressor with the screw lubricated by
an air / oil mixture.
Additionally, air lines to the main steam isolation
valves and the steam isolation valves for the auxiliary feedwater steam
turbine did not havo in-line filters.
This is a deviation.
PCE Response
1.
Oilless Compressor Cylinder
a.
Reason for Deviation
When the sullair compressor (C116) was installed, the subsequent
FSAR revlsion did not clarify that "oilless compressor cylinder"
referred only to the reciprocating compressors (C102A, B, and C).
b.
Corrective Steps Taken and Results Achieved
No immediate corrective steps have been taken.
Changes to the
FSAR will be initiated to provide clarification.
The Sullair air
compressor is a screw compressor and does not have a cylinder.
It does, however, use a lubricant (non-petroleum based) which is
injected with the intake air and removed before discharge. Addi-
tional protection for the discharged air is provided by particu-
late and coalescent filters identified in Section 9.3.4 of the
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FSAR.
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c.
Corrective Steps Which Will Avoid Further Deviations
Our current design procedure requires that any changes to the
FSAR due to a Plant modification be initiated by the Action
Engineer.
Since the Action Engineer has detailed knowledge of
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each modification, the completeness of future changes will be
enhanced.
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Trojan Nuclear Flant
Document Control Desk
Docket 50-344
January 26, 1988
License NPF-1
Attachment B
Page 2 of 2
d.
Date When Full Compliance Will Be Achieved
The FSAR changes will be completed by July 1988.
2.
Filters
a.
Reason for Deviation
Both the nain steam isolation valves and the auxiliary feedwater
turbine steam isolation valves have solenoid pilot valves.
Discussion with the solenoid vendor and review of the vendor
catalog have confirmed the existence of filters in the inlet to
the solenoid valves. Therefore, air supplied to the isolation
valves for both systems is filtered. However, the referenced
commitment on Page 9.3-4 of the Trojan FSAR is general and does
not specifically identify how that commitment is met for each
portien of the air system. Furthermore, discussions with the
main steam isolation valve vendor indicates that local filters
are not required when filtered instrument air is supplied to the
branc.h lines,.
Further investigation is in progress.
b.
Corrective Steps Take and Results Achieved
since initial investigation has revealed that both systems have
filters installed, no further immediate corrective action was
taken. However, clarification of the FSAR commitment may be
necessary.
c.
Corrective Steps Which Will Avoid Further Deviations
A system review and clarification of the FSAR as it relates to
filters installed in air systems will be performed.
d.
Date When Full Compliance Will Be Achieved
The system review and FSAR clarification will be completed by
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July 1989.
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