ML20207B242
| ML20207B242 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/02/1986 |
| From: | Burdoin J, Andrea Johnson, Kellund G, Mendonca M, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20207B225 | List: |
| References | |
| 50-344-86-20, NUDOCS 8607170460 | |
| Download: ML20207B242 (13) | |
See also: IR 05000344/1986020
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U. S. NUCI.U\\R REGULATORY COMMISSION
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REGION V
Report No. 50-344/86-20
Docket No. 50-344
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License No. NPF-1
Licensee:
Portland General Electric Company
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121 S. W. Salmon Street
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Portland, Oregon 97204
Facility Name: Troj an
InspectionCondufted- May 1 - June 12, 1986
Inspectors:
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F.
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eactor Inspector
D' ate Signed
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A. D. Joh
, Enforcement Officer
ITate' Signed
S.A[I M
7/z/w,
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S. A. Ric' hards, Senior Resident Inspector
Date Signed
5. A9M
rom
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G. C. Kellund, Resident Inspector
Date Signed
Approved by:
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M. M. Mendonca, Chief
Date Signed
Reactor Project Section 1
Summary:
Inspection on May 19 - June 12, 1986 (Report 50-344/86-20)
Areas Inspected: A special unannounced inspection by two regional based
inspectors along with the two Trojan NRC resident inspectors to followup
two allegations received in the regional office during April 1986.
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Results: One violation and no deviations were identified.
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06071704'60 860702
ADOCK 05000344
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DETAILS
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1.
Persons Contacted.
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- W. S. Orser, Plant General Manager
- C, A. Olmstead, Manager, Quality Assurance Department
- J. D. Reid, Manager, Plant Services
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- D.
L. Bennett, Supervisor, Control and Electrical
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R. P. Schmitt, Manager, Operations and Maintenance
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C.11. Brown, Operations Branch Manager, Quality Assurance
- H. F. Moomey, Trojan Resident, Oregon Department of Energy
- J. K. Aldersebaes, Manager, Nuclear Maintenance and Construction
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- D. D. Wheeler, QC Supervisor +
R. A. Reinart, I&C Supervisor
- G. J. Stein, Hechanical Maintenance Supervisor
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T. A. Swarers,*'QC Leadman
'*T. L. Warnick, Plant Modifications Engineering Supervisor
J. E. Purcell, ISC Unit Supervisor
C. C. Allen, QC^ Lead Electrical Inspector
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W. T. Craft, QC Specialist
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A. N. Roller, Nuclear Plant Engineer, Electrical Branch Manager
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W.~ Swan, Maintenance Supervisor
- Denotes attendance at exit management meeting on May 23, 1986.
- Denotes attendance at exit management meeting on June 12,1986.
NOTE: The allegation characterization statements contained in this
report are either a paraphrasing of the staff's understanding of the
alleger's concern or statements taken from the allegation source
document. The characterization statements do not represent a staff
assessment, conclusion or position.
2.
Followup of Allegation or Concerns
a.
Allegation, ATS No. RV-86-A-0029
(1) Cha racte rization
The site quality control (QC) supervision directed QC
inspectors not to identify nonconforming conditions except
for work to which the inspectors were specifically
assigned. Nonconforming conditions which were identified
were not processed for corrective action. QC inspectors
were required to have all nonconformance reports (NCR)
screened by their supervisor, thereby preventing NCRs from
being written. A maintenance request (MR) associated with
a potential electrical separation criteria violation
inside a locked manhole may have been falsified.
(2) Implied Significance to Design, Construction or Operation
Improper supervision of QC inspectors and failure to
correct nonconforming conditions may result in known plant
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material deficiencies remaining uncorrected, which could
have an adverse effect on the operation of the plant.
(3) Assessment of Safety Significance
The Quality Assurance Manager was questioned regarding
direction given to QC inspectors to not identify
nonconforming conditions except for deficiencies
associated with work to which the inspectors were
specifically assigned.
The Quality Assurance Manager
confirmed that the above stated direction was provided by
first line QC supervision to temporary QC inspectors who
had been hired to increase QC activities prior to and
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during the 1986 refueling outage.
When the temporary QC
personnel were hired, the Quality Assurance (QA)
organization wanted to focus their activities on work in
progress.
In an effort to provide this direction, the
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first line QC supervision told QC inspectors not to look
for discrepancies with installntions which were old
construction. The QA Mtnager stated that when he learned
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that this direction was being provided, he took immediate
action to ensure that all QC inspectors understood that
all nonconforming conditions should be documented and
addressed. Discussions with several QC inspectors
confirmed that originally they had received instructions
to narrow their scope of 2nspection, however, they also
confirmed that they now felt free to report any deficiency
they might identify.
The primary method used to document QC inspector
observations is the QC Observation Report (QCOR). The
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QCOR was initiated at the plant as an observation record
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in January, 1986, when the QA organization started to
bring in temporary QC inspectors to augment the full-time
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QC staff.
A sample of these reports were reviewed by the NRC
inspectors to determine whether observations by QC
inspectors had been evaluated and corrective action
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initiated where' appropriate. The NRC inspectors found
QCORs written during the February-March time frame, had
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not been' subject to a review
pursuant'to an established
written procedure'in that one had not been developed at
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the time. Repo'rtedly, these items had been screened and
those appearing to have immediate safety significance were
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processed for evaluation and corrective action.
Discussions with the electrical QC coordinator indicated
that prior to assuming his position in late March, the
procedure to review and disposition the QCORs had not been
fully established. Each QCOR also has a signature space
to signify review by the QC Supervisor (QCS). None of the
first 100 QCORs had been signed by the QCS. QC personnel
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also stated that they had recognized the lack of a
proceduralized review of the early QCORs and they had
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decided to wait until the plant completed the refueling
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outage in early June before re-reviewing the early QCORs
in a more prescribed manner. The NRC inspectors noted
that QCORs written after4 April 1 appear to have been
reviewed and acted on in a reasonable manner. The QC
organization stated that the older QCOR's would be
reviewed and action initiated on all QCORs that had not
previously received a prescribed review. This action was
completed prior to the inspection conclusion. The NRC
inspectors also observed that most of the discrepancies
listed in the early QCORs were not safety related and
generally dealt with conduit support deficiencies, missing
covers and bolts on electric pull and terminal boxes,
labeling errors on electrical raceways, and apparent
discrepancies concerning raceway separation criteria.
The NRC inspectors discussed the process of writing NCRs
with QC supervisory personnel. These QC personnel stated
that QC inspectors had been directed to have their first
line supervisors initiate any NCRs and that this direction
had been given because the procedure required to be
followed to issue an NCR was relatively complex.
supervision felt that having first line supervisors write
NCRs was more efficient administratively than training
each temporary QC inspector in the procedure governing
NCRs.
The NRC inspectors reviewed the NCR log and observed that
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NCRs had been initiated for various apparent nonconforming
conditions that were identified by QC inspectors. The NRC
inspectors further observed that five recent
nanconformance reports (NCR) in the electrical area had
Ieen voided after the NCRs were initiated. The procedure
governing control of NCRs allows voiding if the apparent
nonconformance is determined to be invalid. The procedure
further requires the reason for voiding the NCR be stated
in the corrective action section.
In the case of the
above NCRs, the reason stated was per discussions with the
Manager, Nuclear plant Engineering Electrical Branch. A
technical explanation was not niven and QC personnel were
unable to explain why the NCRs were invalid. The QCS
stated that a more complete explanation for voiding the
NCRs should be included on the NCR and that the matter
would be rereviewed and the appropriate reasons for
voiding the NCRs would be documented on the NCR.
Upon
re-review of the voided NCRs, the licensee determined that
NCR 86-024 had actually documented a valid nonconformance.
This NCR described a conduit support violation associated
with the 'A' train hydrogen recombiner panel in the 'A'
electrical switchgear room.
The licensee redocumented
this nonconformance on NCR 86-121. The staff concluded
that by incorrectly voiding NCR 86-024, the licensee had
failed to take appropriate corrective action for a valid
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nonconforming condition. This is an apparent violation of
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10 CFR 50, Appendix B, criterion XVI (344/86-20-01).
The NRC inspectors reviewed the QCOR file and the
maintenance request (MR) log to determine whether an MR
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had been falsified such that the MR indicated that an
electrical separation criteria discrepancy had been
identified and documented on the MR prior to the date a QC
inspector had observed the apparent discrepancy. The
staff review of the MR log and QCOR file did not identify
any indication that falsification of an MR had occurred.
(4) Staff position
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First line QC supervisors did direct QC inspectors to
limit the types of deficiencies that they should identify,
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however, the QA Manager corrected the problem when he
learned that the direction was being provided. The
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deficiencies identified by QC inspectors during the
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February and March, 1986, timeframe, were not res'ewed and
acted upon in a systematic manner such that neveral of the
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QCORs reviewed had no documented evidence of corrective
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action where. action appeared required. The licensee has
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re-reviewed the early QCORs and initiated corrective
action where appropriate. A procedure is now in place to
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ensure QCORs are reviewed in a prescribed manner. The
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staff found that NCRs had been written for deficiencies
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identified by QC inspectors when an NCR was the
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appropriate corrective action mechanism. The staff found
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no indications of maintenance requests being falsified.
The allegations were found to be partially substantiated.
The licensee has taken action to resolve each area of
concern.
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(5) Action Required
Followup on licensee action for the identified violation.
One violation and no deviations were identified.
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b.
Allegation, ATS No. RV-86-A-0036
(1) Characterization
Multiple assertions concerning lack of quality in the
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licensee's instrumentation and control procedures and
practices. The specific assertions are described below
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under the section, Assessment of Safety Significance.
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(2)
Implied Significance to Design, Construction and Operation
The lack of quality in instrument and control procedure
and practices could adversely affect the safety of plant
operations.
(3) Assessment of Safety Significance
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Specific, allegations are:
(a) " Signal wires to indicators in control panels in
control room have bare shields at ends which may
short out terminals on backs of adjacent indicators."
The inspector examined the installation of signal
wires in two walk-in type control panels in the
control room. .This examination found some signal
wires equipped with shrink tubing to insulate the
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shield where it had been trimmed back to allow
insulation removal for terminating the cable. Also
,.found,were some_ signal wires where shrink t.ubing was
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not used. However, in all cases the shield had been
trimmed back neatly and sufficiently far back from
'the terminal block so as not to pose the problem of
shorting out adjacent terminals. The installation
standards E-3/E-4 requires the use of shrink tubing
only when the shield is tied down to a terminal on
the terminal block. The inconsistent use of shrink
tubing on signal wires, where the shield is not tied
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down, is at.tributed to the individual practice of
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installers during the constraction period of the
plant, and does not pose a potential to short-out
terminals on adjacent indicators.
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(b) " Total lack of specific procedures for equipment
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calibration:
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"A.
Generic procedures necessary for calibration are
not listed on work requests /MR's.
"b.
Method of calibration changes dependent upon
technique and other factors, so results may not
be consistent.
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"C.
Technicians allowed to become lax in performance
of tests - fudge factor."
The licensee used generic procedures for equipment
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calibration.
These procedures identified the
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equipment vendor's specific procedures to be used in
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the calibration of specific equipment.
In those
cases where the licensee concluded the tendors
procedures for calibrating a specific piece of
equipment were inadequate, the licensee developed a
specific procedure for calibrating that particular
piece of equipment.
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The generic procedures necessary for calibrations
were identified on the-instrument calibration data
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cards (old system) and on the calibration data sheets
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(new system). These data cards / sheets are part of
maintenance request package (see below for
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description of these systems),
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Methods of calibration of instrumentation equipment
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differed slightly in that input data could be
different,
i.e., milliamps versus millivolts; but the
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output which determined the calibration was measured
in.only one parameter.
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Inspections'on the conduct of I&C tests have not
observed any laxness on the part of the technicians.
This allegation was not substantiated.
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(c) " proper tests may not always follow maintenance
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activities."
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Administrative order A0-3-9, " Maintenance Requests,"
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identified the requirements for post-maintenance
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testing. Also, this procedure required the cognizant
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supervisor (mechanical / electrical) to identify on the
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maintenance request (MR) the requirement for
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post-maintenance testing. The inspector reviewed this
procedure and examined a number of MRs. The
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licensee's procedures and practices acceptably
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specified post-maintenance test requirement, and this
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allegation was not substantiated.
(d) " Preconditions, precautions and prerequisites unique
to each situation,
i.e., loop calibration may not be
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properly followed up by technicians because they are
not known by techniciars."
Administrative order A0-3-14 " Safety-related
Equipment Outages," described the procedure for
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planning equipment outages.
It ensured proper
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scheduling, technical specification surveillances on
redundant trains, actification of other groups
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(maintenance / operation) before removal of equipment
from service; and also ensured proper testing of
equipment on return to service. The inspector
examined this procedure in detailed and discussed
with the licensee the practices followed in removing
from service control / instrument systems and equipment
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for loop testing and calibration.
At Trojan, the I&C technicians, because of their
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detailed knowledge of the various control and
instrument systems, aid the operators in removing
from service for calibration and loop testing certain
equipment and instrument systems.
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The licensee's procedures and practices for the
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removal from service for calibration / loop testing
appeared to be acceptable and sufficiently detailed
to enable the operators and technicians to be aware
of applicable preconditions, precautions and
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prerequisites peculiar to each control / instrument
system and piece of equipment.
Inspection activities have found that preconditions,
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precautions and prerequisites are complied with
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during testing of control / instrument systems and
equipment. This allegation was not substantiated.
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(c) " Computerized Calibration Cards given to Technicians
list too many details which are not necessary for the
performance of the task and cause the necessary
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information to be lost or ignored, e.g. ,
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Generic procedures required to perform the task
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are not listed.
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"B.
Data tables are often on separate pages which
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causes confusion,
i.e., the table may be broken
in the middle and completed on the next page.
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Significant information is lost amongst blank
entries and entries which are not needed for the
task."
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Last fall the licensee placed in service a new fully
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computerized maintenance scheduling system, referred
to as TSS (Trojan Scheduling System). This system
was replacing the old Maintenance Scheduling System
which was not fully computerized. The TSS is used to
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schedule control / instrument systems and equipment
loop tests and calibrations. The new system produces
the calibration data sheet which contains/ lists all
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the necessary information, such as instrument
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identification, location, manufacture, drawings,
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procedures, tools / parts required, special conditions,
etc.. - During the present outage, the licensee, to be
assured of proper shift-over to the new TSS with no
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loss of valuable instrumentation' calibration and test
data,: backed-up the new system by continued use of
'the old "hard-card" system. To this end, the
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instrument" calibration cards (hard-card) from the old
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system were attached to the calibration data sheets
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for all loop tests and calibrations of instrument
systems and equi'pment.
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The inspector examined in detail the calibration data
sheet from'TSS'and the old "hard-card" and found both
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data sheets to be thorough and complete in the
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information provided for calibration and testing of
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instrument loops and equipment. The licensee
contended that the calibration data sheet and
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hard-card were designed to provide all information
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necessary for I&C technicians to calibrate and test
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instrument loops and equipment. The inspector
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concurred this allegation was not substantiated.
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(f) " Work is performed on Q class Equipment without a
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paper trail."
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Twenty. completed maintenance requests were selected
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by number from the QC inspection schedule / record and
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seven of ther.e MRs (86-1692, 2233, 2446, 2448, 2450,
2451, and 2662) were examined in detail to determine
if records of work accomplished and QC inspections
performed were properly documented on maintenance
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request forms as required by administrative procedure
A0-3-9.
These completed MRs appeared to contain all
the required information. From this
review / examination of maintenance records, it
appeared that records were kept on work performed on
Q class equipment in accordance with procedure
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requirements. This allegation was not substantiated.
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(g) " Valve and pipe fittings on pneumatic systems are
most often over tightened so that threads are
stretched and otherwise damaged and leaks occur."
This concern was discussed in great detail with the
licensee mechanical maintenance group.
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the licensee's practice, when they open the
containment for refueling, to walkdown all of the
instrument tubing systems to identify all leaks and
prepare maintenance requests (MRs) for repair of
these leaks'during the plant outage. Most of the
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Icaks are due to leaking compression fitting ferrules
which result from several causes. Two frequent
causes are:
(1) Scratches on stainless steel tubing
surfaces where ferrule mates with tubing, and (2)
surface hardening on heavy wall tubing prevents the
ferrule from getting a good " bite" into the tubing.
The licensee's procedures and practices to reduce to
a minimum leaks in stainless steel tube fittings were
reviewed and appeared to be acceptable.
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The inspector also reviewed with the licensee the
practices followed in tightening compression type
stainless steel tube fittings.
The licensee employs
the tube fittings manufacturer's reconunendations
which limit overtightening the fittings to prevent
damage to the threads. These recommendations include
use of a manufacturer's special wrench with a small
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lever arm and limiting the number of turns to
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tighten.
The inspector examined instrument lines around twenty
transmitters for leakage. No leakage or indication
of over tightening was identified.
It appeared that damaged threads due to over
tightening of fittings is not a major.cause of leaks
in stainless steel tube fittings at the Trojan Plant.
Therefore, this allegation was not substantiated.
(h) " Questionable materials,
i.e.,
teflon tape, are
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widely used in containment."
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The present practice at Trojan is not to allow the
use of teflon tape on the primary system.
However,
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it is used on secondary system instrument piping in.
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sizes 1/2" and 3/8" inside containment. The tape is
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.used on stainless steel to stainless steel pipe
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thread fittings.
It is not used on tube fitting
threads.
It appears from published technical
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information that some teflon tape begins to decompose
at about 400*F and releases high concentrations of
halogens, fluorides, chlorides, and others which are
highly corrosive to NSSS materials. The use of
teflon at Trojan is restricted to use on systems
which do not exceed temperatures of 250'F.
The
Chemical Assessment Section at the Trojan plant in
presently analyzing the particular type of teflon
tape used on site to determine an exact assessment of
the material and to determine its limitations for
usage at Trojan.
It appeared as though the licensee was aware and
implemented limitations on the use of teflon tape
inside containment and is presently performing his
own analysis to determine if additional restrictions
on it use inside containment are required. The
allegation was substantiated but was acceptably
addressed by the licensee.
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(i) " Equipment modifications may not show up in Technical
Manuals and can cause delays and/or mistakes in
maintenance."
This item was reviewed with the licensee. About a
year ago the licensee initiated a program to upgrade
all the plant technical manuals; and to this end, the
licensee appointed a technical manual task group to
accomplish this assigntient. The inspector examined
the program with the task group leader.
Approximately ten people are presently assigned to
the task group. The program calls for reviewing all
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technical manuals at the plant to verify that they
include all the latest as-built changes,
modifications and revisions. The manuals are also
being reviewed for dividing / indexing the text into
more logical divisions; a thorough review process
will verify the accuracy of the manuals; the manuals
are then to be reprinted, and after final
review / checking new copies of the new technical
manuals will be issued. The present scheduled
completion date for this project is July 1987.
The licensee's program for completely overhauling the
plant technical manuals appeared to be thorough and
addressed this allegation.
(j) " Improper wiring of RTD on main coolant pump:
Wrong size of lug for screw size
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Spade lug used instead of round lug
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There was potential for shorting of signals"
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The inspectors examined the wiring of the seal water
RTDs on the "B" reactor coolant pump (TE 170 and TE
171). These RTDs have no safety related function
other than being required to maintain the pressure
boundary following a seismic event.
The size of the
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lugs installed appeared
adequate for the screw size and no evidence of
shorting or ir. adequate gaps between adjacent lugs was
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found. The minimum distance observed between
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adjacent lugs was approximately 3/16 inch which does
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not present any shorting problems due to the low
voltages involved.
The inspectors observed evidence of both ring lugs
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and spade lugs installed on the termination block.
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The licensee's new electrical installation standard
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calls for ring lugs to be used, however, the old
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standard in use at the time of installation allowed
the use of spade lugs. The licensee intends to
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conduct any new terminations in accordance with the
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new standard and use ring lugs but does not intend to
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replace the existing spade lugs in place throughout
the plant.
The inspectors also noted that some of the lugs had
been bent upward apparently to facilitate
installation due to the small amount of space
available in the head of these particular RTDs.
The
licensen previously identified the issue of
insufficient space in the RTD head and initiated a
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Request for Evaluation (RFE) to deter 1mine the
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acceptability of the present configuration.
The allegation is partially substantiated in that
spade lugs were installed on the RTD termination
block. However, the installation standard they were
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installed to allowed this. The remainder of the
allegation regarding the use of the wrong size of lug
for the screw size and the potential for shorting of
signals was not substantiated. The related issue of
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inadequate space for installation of lugs on the RTD
termination block has been previously identified by
the licensee and is currently being addressed. The
allegation has minor safety significance.
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(k) Source range channel N31 is erratic and should not be
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relied upon for refueling activities.
In addition,
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the N31 detector was replaced without' supporting
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documentation and the N31 SOLA power supply was
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, installed incorrectly.
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The inspector reviewed the past performance and
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maintenance history of the N31 source range channel.
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The channel has behaved somewhat erratically for many
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years due to a high noise level and sensitivity to
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outside influences.
The licensee has replaced the
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detector preamplifier during the current outage with
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a different model that should improve performance.
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Refueling records were reviewed and personnel were
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interviewed to determine if the licensee took
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appropriate actions in response to channel spikes
during refueling activities. The inspector verified
that reactor core alterat. ions were suspended whenever
spiking occurred and were not resumed until the cause
was determined. The spiking was usually attributed
to welding, grinding or use of heat guns or portable
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radios in the vicinity of the detector cable.
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With regard to the contention that the N31 detector
was replaced without supporting documentation, the
inspector reviewed the maintenance records for the
detector. The detector was replaced in April, 1986
under a maintenance request (MR 86-2200). The
maintenance request and supporting documentation
appeared to control and document the work performed.
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The allegation that the N31 S01.A power supply was
inntalled incorrectly was also investigated. The
inspector found no evidence that a SOLA power supply
for the N31 channel was replaced. The inspector did,
however, determine that a SOIA power supply for the
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nuclear instrumentation cabinets had been installed.
This power supply had been installed incorrectly,
however, the licensee subsequently identified the
problem and corrected it.
The allegation that the source range channel N31 has
behaved erratically is partially substantiated in
that the channel has been somewhat erratic. Iloweve r,
the inspector determined that appropriate actions
consistent with procedures and Technical
Specifications were taken whenever the channel
malfunctioned. The allegations concerning the
undocumented replacement of the N31 detector and the
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improper installation of the SOLA power supply were
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determined to be not substantiated. The detector
replacement was controlled and documented, and the
power supply installation error was discovered and
corrected by the licensee. The inspector determined
that acceptable procedures and programs exist to
control work and to identify and resolve problems in
this area.
(4) Staff position
The staff concludes that the licensee established
procedures and impicmented programs that addressed the
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allegers' concerns; and that in the normal process of
following prescribed procedures, the cbove identified
allegations were acceptably addressed.
(5) Action Required
None.
No violations or deviations were identifir
3.
Exit. Meeting
The inspectors conducted exit meetings on May 23 and June 12,
1986, with the general manager of the plant, members of the plant
staff, and other staff personnel.
During these meetings, the
inspectors summarized the scope of the inspection activities and
reviewed the inspection findings as described in this report.
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