ML20212E321

Responds to NRC Re Violations Noted in Insp Rept 50-344/86-23.Corrective Actions:Battery Svc Test Procedure MP-1-14 Revised to Require Temp Compensation & Inservice Testing Program Amended

ML20212E321
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/08/1986
From:	Lindblad W PORTLAND GENERAL ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20212E234	List: ML20212E231 ML20212E321
References
NUDOCS 8701050296
Download: ML20212E321 (6)

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PORTLAND GENERAL ELECTRIC COMPANY !Vbh 121 S. W. S A LM O N STREET WILLIAM J. LINDBLAO PORT LAN o, O R EGO N 97204 ,Q

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< s om us. ..,, A II: 0 3 REGlott y December 8, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin ,

Regional Administrator, Region V U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Martin:

Response to Notice of Violation (NRC Inspection Report No. 50-344/86-23)

Your letter of November 7, 1986 forwarded a Notice of Violation concerning various test procedures and operating instructions for the station batteries and the Component Cooling Water System. In accordance with 10 CFR 2.201, our response to the Notice of Violation is attached. In your letter, you also requested that an action plan be provided regarding our program to improve access to and use of design basis information and overall engineering performance. That action plan will be forwarded under separate letter shortly.

Sincerely, e . g. -s9 _

Attachments c: Mr. Lynn Frank, Director State of Oregon Department of Energy Subscribed and sworn to before me this 8th day of December 1986, 8701050296 861231 & & Ne r =J PDR ADOCK 05000344 N tary Public of Oregon P PDR My Commission Expires: M C /f78 YA r

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-Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 December 8, 1986 License NPF-1 Attachment Page 1 of 5 10 CFR 2.201 RESPONSE TO NOTICE OF VIOLATION Violation A:

Plant technical specification 4.8.2.3.2.d provides requirements for periodic surveillance testing of the safety-related station batteries and reads that the batteries are to be tested:

"At least once per 18 months, during shutdown, by verifying that the battery capacity is adequate to supply and maintain in operable status all of the actual emergency loads for thirty minutes when the battery is subjected to a battery service test."  ;

IEEE Standard 450(1980), Recommended Practice for Maintenance, Testing and Replacement of Large Lead Storage Batteries, is the industry standard for battery capacity testing and states that:

"6.6 Service Test. A service test is a special battery capacity test which may be required to determine if the battery will meet the design requirements (battery duty cycle) of the system .... (2) The discharge rate and test length should correspond as closely as practical to the design requirements (battery duty cycle) of the system."

The Updated Safety Analysis Report (USAR) provides the design basis for the station batteries and, in section 8.3.2.1.2, defines the battery

" duty cycle" as being a current discharge profile of 554 amps for-1 minute, followed by 306 amps for 28 minutes and 321 amps for the final minute. The USAR also states that the batteries meet the duty cycle requirements without decreasing individual cell voltages below 1.75 volts at 50 F.

Contrary to the above, the battery service test, MP-1-14, performed in May 1985 and May 1986 to verify the battery capacity, utilized a constant current load of 300 amps and was performed at a battery temperature of approximately 90 F, without correcting the results accordingly for the elevated temperature.

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Response

PGE acknowledges and admits the violation described above. The battery service test procedure, MP-1-14, has been revised to require temperature compensation. The procedure will be further revised to reflect the newly i derived duty cycles for each station battery by the end of January 1987.

All future testing of the batteries will be done in accordance with IEEE 450-1980 using the new duty cycles. The Updated Final Safety

Analysis Report will also be revised by July 1987 to include the new duty cycle profiles.

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O Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 December 8, 1986 License NPF-1 Attachment Page 2 of 5 An inadequate understanding of the engineering design basis and battery performance characteristics can be considered an underlying cause of this 4 violation. Corrective steps to avoid further violations include: a design basis review and update of the safety-related 125-V de system; a review of associated operation, maintenance, surveillance, and testing activities; and a confirmation that these activities reflect current design basis information. These steps are described as part of a comprehensive improvement program in Attachment 2.

Full compliance will be achieved upon revision of the test procedure by the end of January 1987.

Violation B:

Plant technical specification 4.0.5 provides requirements for periodic inservice testing and states in part that:

" Inservice ... testing of ASME Code Class 1, 2 and 3 pumps and valves shall be performed in accordance with Section II of the ASME Boiler and Pressure Vessel Code ..."

Section 9.2.2 of the Updated Safety Analysis Report (USAR) identifies the below listed check valves as being ASME Code Class 3 valves. Further-

more, the first two listed valves are check valves that are normally in other than their required post-accident condition position. These valves are required by subarticle IWV-3522 of Section II of the ASME Code to be periodically tested to confirm their ability to reposition

1"-GBD-26 CK Normal nitrogen supply to CCW surge tanks-1/2"-CBD-5 CK Emergency nitrogen supply to CCW surge tanks (Numbera not Containment air cooler vent check valves specified)

Contrary to the above, at the time of the inspection, the inservice test program intplemented by the licensee did not include the above listed j valves and the valves had not been periodically tested.

Response

l A specific discussion of each of the listed valves follows:

1-CBD-26 Normal nitrogen supply to CCW surge tanks 1/2-HBD-65 Backup nitrogen supply to CCW surge tanks I. PGE acknowledges the concerns raised regarding the normal and backup nitrogen supply valves. While recognizing countering arguments address-ing interpretation of the applicable requirements, we feel that it is both reasonable and beneficial to include these valves in inservice testing and have amended the Trojan Inservice Testing (IST) Program (PCE-1048) appropriately. Full compliance has been achieved.

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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 December 8, 1986 License NPF-1 Attachment Page 3 of 5 3/4-HBD-31 CAC vent check valves (32 valves) 3/4-NBD-32 PCE disagrees with the determination that these valves should be included in the IST Program.

These valves have been exempted from the Program under Article IWV-1200(a) as valves used for operating convenience only. These valves perform no specific function in shutting down the reactor to cold shutdown condi-tions or in mitigating the consequences of an accident. They are used during system startup to provide an automatic high point vent for the CACs. Sufficient redundancy has been provided to preclude a single failure from affecting system performance. Two of these valves and the float air vent valve in series must simultaneously fail during a LOCA where Containment pressure is greater than CCW return header pressure before a single train of CCW could possibly be affected. Even if these worst-case conditions were to occur, the result would not be a release of gases from the Containment via the CCW System since the CCW System is a closed system (with a design pressure of 150 psig). The only credible release path would be via the relief valves on the CCW surge tank should they open. These relief valves are set at 130 psig and 135 psig. This mode of failure is not likely since the setpoints significantly exceed the expected Containment pressure and the expected CCW System operating pressure, and these relief valves are tested in the IST Program. No testing of these 32 check valves is required under ASME XI.

Violation C:

Plant technical specification 6.8.1 provides requirements for station procedures and states in part that:

" Written procedures shall be... maintained covering... applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33...

surveillance and test activities of safety-related equipment."

Regulatory Guide 1.33, Appendix "A" identifies typical procedures for pressurized water reactors and includes procedures for operation of safety related plant systems.

Contrary to the above, at the time of the inspection:

1. Licensee surveillance procedure MP-1-14 had not been properly main-tained, in that it was not revised to reflect a 1981 modification which removed two cells from the safety related station batteries.

2. Licensee operating instructions OI-4-2 and ONI-14 had not been properly maintained, in that they were not consistent with the plant

Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 December 8, 1986 License NPF-1 Attachment 1 Page 4 of 5 design basis, as defined in the Updated Safety Analysis Report (USAR). In particular, 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.

3. Licensee operating instruction OI-4-2 had not been properly main-tained in that it was not ecnsistent with the plant design basis, as defined in the plant instrument index. In particular, 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.

Response

PGE acknowledges and admits the violation described above. Revisions for each of the affected procedures / instructions have been prepared correct-ing the identified deficiency and will be approved by the end of December 1986. Temporary procedure deviations have already been implemented. The revisions will achieve the following:

1. MP-1-14 will reflect a 1981 modification removing two cells from the station batteries.

2. 0I-4-2 and ONI-14 will limit CCW heat exchanger outlet temperature to a maximum of 120*F.

3. Instructions for setting the two CCW surge tank backup nitrogen system regulators will be removed from 0I-4-2. A separate mainte-nance procedure will address setting the regulators at 95 psig as required by the Plant instrument index.

To avoid further violations, corrective steps include: a design basis review and update of the safety-related 125-V de and the CCW systems; a review of associated operation, maintenance, surveillance, and training activities; and a confirmation that these activities reflect current design basis information. These steps are described as part of a comprehensive improvement program in Attachment 2.

Full compliance will be achieved upon implementation of procedure /

instruction revisions by the end of December 1986.

Violation D:

Plant technical specification 6.8.1 provideo requirements for station procedures and states in part that:

" Written procedures shall be... implemented... covering... surveillance and test activities of safety relaf.ed equipment."

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• Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 December 8, 1986 License NPF-1 Attachment 1 Page 5 of 5 Station procedure MP-1-14 provides requirements for performance of battery service testing on the safety related 125 VDC station batteries.

Step III.c.3.j of procedure MP-1-14 requires that the battery voltage at the end of the 30 minute discharge be recorded.

Contrary to the above, during the May 1985 performance of procedure MP-1-14, the final battery voltage following the 30 minute discharge was not recorded for battery D-11.

Response

PGE acknowledges and admits the violation described above. The cause of the violation was personnel error involving misreading of the data sheet and inadequate review of the test data. This violation has been dis-cussed with those individuals who record data and review the test data.

Full compliance has been achieved.

DLN/kal 1328W.1286 l

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