IR 05000344/1987008

Insp Rept 50-344/87-08 on 870316-20.No Noncompliance or Deviations Noted.Major Areas Inspected:Organization & Administration,Followup of Previous Insp Findings & Closure of Open Items

ML20206P244
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/26/1987
From:	Mendonca M, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20206P241	List: IR 05000344/1987008 ML20206P236
References
50-344-87-08, 50-344-87-8, NUDOCS 8704210131
Download: ML20206P244 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report No: 50-344/87-08 Docket N License No. NPF-1 -

Licensee: Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant Inspection at: Rainier, Oregon Inspection con uc ed: arch,1 -20, 1987 Inspector: auf / rdis 1 24 D. B. Pereira, Reactor Inspector Date Signed Approved by: bW 3/41/8' -

M. M. Mendonca, Chief, Date Signed Reactor Project Section 1 Summary:

Inspection During the Period of March 16-20, 1937 (Report 50-344/87-08)

Areas Inspected: This routine, unannounced inspection by the Project Inspector involved the areas of Organization and Administration, followup of previous inspection findings, and closure of open items. During this inspection, inspection modules 30703, 36700, 92701, and 92703 were use Results: No items of noncompliance or deviations were identifie PDH ADOCK 05000344 O PDR

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DETAILS

. Persons Contacted Licensee Personnel R. P. Schmitt, Manager, Operations and Maintenance

! * R. Jarman, Manager, Quality Assurance Department D. Keuter, Manager, Technical Services

* J. D. Reid, Manager, Plant Services l * C. H. Brown,-Operations Branch Manager, Quality Assurance

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. W. L. Kershul, Engineer, Nuclear. Safety and Regulation

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D. L. Bennett, Supervisor, Control and Electrical ,

R. Reinart, Supervisor, Instrument'and Control

• 0. W. Swan, Supervisor, Maintenance R. Russell, Assistance Operations Supervisor,' Quality Assurance '

• G. A. Zimmerman, Manager, Nuclear Regulation Branch'

• A Ankrum, Supervisor, Nuclear Regulation Branch

• R. Susee, Supervisor, Operations G. J. Kent, Inservice Testing Engineer R. Fowler, Senior Engineer B. K. Ward, Nuclear Safety and Regulation Department U.S. Nuclear Regulatory Commission

• R. Barr Oregon Department of Energy

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• H. Moomey, Oregon Resident Inspector

• Attended the Exit Meeting on March 20, 198 . Organization and Administration l The' purposes of this inspection was to determine whether changes to the I licensee's onsite organization are'in conformance with the requirements of the Technical Specifications and whether the use of overtime is in

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accordance with regulatory requirement The inspector examined ~the licensee's applicable Technical Specification Section 6.3.1 which determines the facility staff qualifications. This section states that the facility staff shall meet or exceed the minimum qualification of ANSI N18.1-1971 for comparable positions, except for the

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Radiation Protection Supervisor and the Shift Technical Advisor who have other qualifications. Administrative Order (AO) 1-1, entitled

" Management Organization" delineates the management organization and l responsibilities for the technical support of the Trojan Nuclear Plant, I and A0-1-2, entitled " Plant Organization" describes the plant i

organization. These procedures provide the instructions and guidance for the management and plant organizations as developed onsite. .The l

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inspector's review of the above procedures verified that the licensee's onsite organization is functioning as described in the Technical Specifications.

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The inspector compared ANSI N18.1-1971 with the qualifications of the facility staff and verified that personnel qualification levels are in accordance with ANSI N18.1-197 Figure 6.2-2 of the Technical Specifications provides a diaarar of the onsite facility organization. The inspector reviewed the lins i of authority and responsibility of the onsite organization witn tce applicable A0s and concluded that they are in conformance with the facility's Technical Specification The inspector reviewed records of deviations from maximum overtime limits and verified that such deviations were authorized as required by A0-3-1, entitled " Shift Complement and Work Time," in accordance with its Attachment A and approved by the Plant General Manager / Duty General Manage No violations or deviations were identified in this are . Follow-up on Previous Inspection Findings (Closed) Inspection Followup Item 84-05-04 - Inconsistent Implementing Procedures

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The inspector reviewed followup item 84-05-04. This open item described several licensee implementing procedures which did not adequately address the regulatory guides and standards referenced in the licensee's Nuclear Quality Assurance Program for Operation The results of this review are presented below in sub-items:

(1) Purchasing Department Procedure (PDP)-8, Indoctrination and Training, Section 5.3, entitled " Purchasing Department Corrective Action Program" appeared to be unrelated to the purpose of the procedure which was to provide instructions for indoctrination and training of purchasing department personne The inspector reviewed the revised Purchasing Department Quality Assurance Procedure (PDQAP) with the same title, and the new Section 5.3, "Documentttion." This section documents each indoctrination pertaining to quality assurance, indicating the scope, objective, and method of indoctrination. This sub-item is close (2) Records Management Services Procedure (RMSP) 200-4 Rev. 4,

" Processing DCNs and IDCNs," did not provide adequate instructions for controlling the distribution of the drawings, P& ids or DCN A transmittal form is referenced in RMSP 200-4 )

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. 3 as Attachment C; however, the form was not included as part of the procedur The inspector reviewed.RMSP 200-4, Rev. 5, and the Attachment C is now included as part of the procedur This sub-item is close '

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(3) Failure to establish a procedure similar to ADM-103 for controlling the distribution of P& ids and DCNs in the control

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room provided another example of the inconsistencies with

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l l The inspector reviewed ADM-103, Rev. 14, and paragraphs 4.6 and l 4.9 provide for control and distribution of P& ids and DCNs, l respectively ir, the control room. This sub-item is closed.

l l (4) Policies and/or requirements for assuring that the evaluations I of Nuclear Quality Assurance Department audit findings are promptly resolved as recommended by Criterion XVI, " Corrective Actions," of 10 CFR 50, Appendix B and NQAP-107, Rev. 7,

" Control of Conditions Adverse to Quality and Corrective Action" have not been adequately establishe The inspector reviewed the current NQAP-107, Rev. 9, and paragraph 5.4 entitled " Corrective Action Status" which provides time limits for NCARs responses. For example, for severity level II NCARs, a response shall be due within 30 days of its distribution and for severity level I NCARs, a response is due in less that 30 calendar days of receipt of the NCA This sub-item is closed, i

l (5) Licensee procedure " Storeroom Practice SP-1 Packaging for t Storage" references licensee commitment to ANSI N45.2.2 but

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does not require evaluation and classification of quality related procurements into one of the environmental protective measure categories ~specified.in ANSI N45.2.2 Section '

This procedure and licensee storage practices do not reflect the minimum requirements for storage of quality related materials contained in ANSI N45.2.2 Section 3. The inspector reviewed the current SP-1, Rev. 4, and paragraph IV.A entitled " Determining Storage Level Requirements" provides

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for evaluation and classification into classified Level A, B, j C, or D in accordance with the classification of ANSI

! N45.2.2-1972. In addition this paragraph provides for the

! storage level requirements ~of not only quality related but for l all materials received. This sub-item is close (6) Licensee procedure " Storeroom Practices SP-3 Handling and Shipping" is inconsistent with ANSI N45.2.2 with respect to the need to palletize or use skids for storage of safety related material.

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. . 4 The inspector reviewed the current SP-3, Rev. 2, and paragraph B entitled " Crates, Skids, Pallets" provides instructions that items will be stored on cribbing or pallets to allow air circulation and to avoid trapping of water. This sub-item is close .

(7) Administrative Order (AO)-12-2, " Determination of Quality Requirements" is aimed principally at the need to establish quality assurance program controls for purchases of replacement parts and does not address environmental protective measures.to assure adequate quality is maintained during handling, storage or shippin The inspector determined that A0-12-2 has been deleted, and that Nuclear Division Procedure (NDP) 300-4, Rev. 1, paragraph 5.7.A provides the quality assurance program controls necessary to prevent damage, deterioration, and contamination for safety-related (Q-listed) item In addition, the protective measure requirements, which include packaging, shipping, receiving, storage, and handling of an item, are divided into four levels in accordance with ANSI.N45.2.2-197 This sub-item is close (8) F0DP 101, " Procurement Control" provides measures for the preparation, review, approval, and control of procurement documents. Section 5.3.3, " Preparation of Purchase Requisitions" does not specifically require the originator to evaluate whether special handling, shipping, identification, or environmental controls, are appropriate and should be referenced in procurement document The inspector determined that F0DP-Q 200 superseded F00P 101, and F00P-Q 200 references NDP 300-4 which specifies in paragraph 5.5 the procurement specifications for modifications, spare parts, and replacement parts. Included in these specifications are the requirements for the classification of items to prevent damage, deterioration, or contaminatio These protective measure requirements include packaging, shipping, receiving, storage, and handling of an item. This

, sub-item is close Followup Item 84-05-04 is closed based upon the above sub-items

, being close B. (Closed) Followup Item 86-23-03 - Adequacy of Analysis for One Relief Valve on the CCW Surge Tank A previous inspection team noted that one of two CCW surge tank reserve relief valves had been gagged to correct a nitrogen leakage problem. Although this temporary modification was made in accordance with the licensee's administrative procedures, no design analysis was performed to document the adequacy of continued plant operation with one of two CCW surge tank pressure relief valves gagged shu Interviews with plant personnel indicate that engineering judgement l

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was used in lieu of design analysis and that this judgement was not documente .The inspector reviewed the licensee's subsequent analysis that has

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been performed to document the adequacy of one relief valve to l

protect the CCW surge tank from overpressure transients. In Bechtel Power Corporation letter BP-12573, dated August 29, 1986, Bechte1~

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informed the licensee that either safety valve on each surge tank has' adequate capacity to pass nitrogen flow from credible failures l of'the seismic and non-seismic nitrogen supply system. Their l

analysis indicated that nitrogen flow from credible failures would l

be less than 900 SCFM and since the safety valve capacity is 3000 i SCFM, they concluded that a single safety valve is adequate to meet potential nitrogen inflo Item 86-23-03 is closed.

l (Closed) Followup Item 86-23-06 - Inspection for Adequacy of CCW Backup Nitrogen Supply and (Closed) Followup Item 86-23-11 Failure to Periodically Test Backup Nitrogen Supply to CCW Surge Tan .

! The inspector reviewed the licensee's analysis which verified that l the nitrogen supply system has sufficient capacity to perform its function. The licensee's system engineers also indicated to the inspector that surveillance on the nitrogen pressure regulating valves is accomplished once per year when the system is brought up after an outage. Additionally, the licensee engineers pointed out that the system is monitored by high and low pressure alarms to

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assure functioning. Items 86-23-06 and 86-23-11 are closed.

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! (Closed) Enforcement Item 86-23-07 - Failure to Account for Reduced Voltage on Station Batteries in Surveillance Procedures.

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Licensee surveillance procedure MP-1-14 had not been properly l maintained, in that it was not revised to reflect a 1981 l modification which removed two cells from the safety related station batteries. Licensee operating instructions 0I-4-2 and ONI-14 had not been properly maintained because the operating instructions permitted a maximum CCW heat exchanger outlet temperature of 140 F, whereas, the Containment pressure analysis, as referenced in USAR

[ table 6.2-14, limited CCW heat exchanger outlet temperature to a maximum of 120 F. Licensee operating instruction 01-4-2 had not been properly maintained because the operating instruction specified a 90 psig and 100 psig setting for the two CCW surge tank backup nitrogen system regulators. The plant instrument index required

, both regulators to be set at 95 psig.

The inspector reviewed the licensee responses to the above l violations and noted that revisions for each of the affected

! procedures / instructions had been prepared correcting the identified l deficiency. In particular, HP-1-14 will reflect a 1981 modification

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removing two cells from the station batteries, 01-4-2 and ONI-14 will limit CCW heat exchanger outlet temperature to a maximum of 120 F; and a separate maintenance procedure addresses setting the

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regulator at 95 psig as required by the plant instrument index.

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i Enforcement Item 86-23-07 is close .

l l Enforcement Item 86-23-09 - Failure to Account for Correct Load l Profile and Temperature in Battery Surveillance Test.

l Contrary to requirements, the battery service test, MP-1-14, , -

performed in May 1985 and May 1986.to verify the battery capacity, a l utilized a constant current load of 300 amps and was performed at a battery temperature of approximately 90 F, without correcting th "

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results accordingly for the elevated temperatur , ,

The inspector verified that MP-1-14 had been revised to require 1 temperature compensation and has been revised to reflect the newly -

i derived duty cycles for each station battery. The licensee  :

indicated in their response to this violation that all future

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testing of the batteries will be done.in accordance with *

IEEE-450-1980 using the new duty cycle Enforcement Item 86-23-09 is close ' (Closed) Enforcement Item 86-23-10 - Failure to Completely Document Battery Voltage in Service Tes Contrary to requirements in MP-1-14, during the May 1985 performance of procedure MP-1-14, the final battery voltage following the 30 '

minute discharge'was not recorded for battery 0-1 t The. inspector verified that the licensee's corrective actions were responsive to the violation issue and were complete. The cause of the violation was personnel error involving misreading of the data sheet and inadequate review of the test data. The violation had been discussed with those individuals who record data and review the test dat <

A Enforcement Item 86-23-10 is close (0 pen) Followup Item 86-23-02 - Adequacy of Motor Overcurrent Protection and Horsepower Rating Discrepancy

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For modification ROC 84-058, no review of overcurrent protection was performed even though the motor on the valve operator to CCW valve MO 3294 was changed. The adequacy of the motor overcurrent protection could not be confirmed during the previous inspectio because of inconsistent documentation.of motor data for this valv An overload relay study performed in 1976 used a value of horsepower for the motor. -However, the latest motor-operated valve inspection and maintenance data sheet indicated that this valve has a 1.3 horsepower motor; but the routine test data received with the new replacement motor indicated that this motor is only 0.70 horsepower. Because M0 3294 is located inside containment, nameplate data could not be obtained during the inspection to confirm the-actual horsepowe .

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o . 7 The licensee system engineer informed the inspector that during the 1987 outage,..the licensee plans on conducting a walkdown to verify correct horsepower ratings on the subject motor operated valve This item will remain open pending the results of the walkdow (0 pen) Followup Item 86-23-08 - Improper Use of Plant Configuration Chang A Plant Configuration Change (PCC) No.'E 85-511 was questioned by previous inspections because it allowed two nonsafety-related fans to be installed on safety-related Post Accident Monitoring Instrumentation (PAMI) panels, which contain the reactor vessel level indicator and the subcooling margin monitor. A review of the performance records for these instruments revealed a higher failure rate after the fans were installed; which indicates that the corrective actions taken to prevent the instruments from overheating was inadequat Licensee letter from B. P. Ducamp.to E. L. Davis, dated February 19, 1987, reviews the NRC open item and discusses the lessons learned which are that future fan installations.should consider the need for a seismic review, and that suspected temperature-related effects and failures of electronic equipment require careful evaluation and documentation in order to identify the root cause and to justify the need for more cooling. In addition, post-installation testing and data collection should be perfor.acd to verify that the as-built modification does indeed achieve its intended purpose. The licensee plans on replacing the subcooling margin monitor during the upcoming 1987 Outage. This item will remain open pending replacement of the subcooling margin monito (Closed) Followup Item 86-23-12 - Improper Splices and Terminations in MOVs and Procedural Inadequac Several Motor-Operated Valves (MOV) were inspected and found to have several observations such as wire splices, field run wires clipped off, with no heat shrink tubing on the ends, and a wire with damaged insulation that was covered with electrical tape. While the above described observations did not appear to adversely effect the

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operability of these valves, the licensee was informed that it would be prudent to prescribe repairs in a proceduralized manner. Trojan Maintenance Procedure MP-12-5 " Valve Motor Operators" did not have any instructions for specifically looking for and repairing occurrences of improper splices and terminations or presence of electrical tape at those location The inspector discussed this open item with the Maintenance Supervisor who indicated that in the.1987 Outage RDC-86-033 would conduct a complete inspection of MOVs, checking for miswiring, and improper splices or terminations or presence of electrical tap The licensee reviewed this open item and concluded that no change was necessary for MP-12-5. Item 86-23-12 is considered closed.

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o .. 8 4. Exit Interview The inspector met with the licensee representatives denoted in paragraph 1 on March 20, 1987, and summarized the scope and findings _of the inspection activitie ,

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