ML20214D635
| ML20214D635 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/07/1986 |
| From: | Richards S NRC |
| To: | |
| Shared Package | |
| ML20214D602 | List: |
| References | |
| 50-344-86-23, TAC-65350, NUDOCS 8611240183 | |
| Download: ML20214D635 (3) | |
Text
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APPENDIX A NOTICE OF VIOLATION Portland General Electric Company Docket No. 50-344 Trojan Nuclear Plant License No. NPF-1 As a result of the inspection conducted during the period of August 11 through August 22, 1986, certain violations of NRC requirements were identified.
In accordance with the General Statement of Policy and Procedure for NRC Enforcement Actions, 10 CFR Part 2 Appendix C, as revised, 49 FR 8583 (March 8, 1984), the violations are set forth below:
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 standsrd 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 i
"daty 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 were performed at a battery temperature of approximately 90 F, without correcting the results accordingly for the elevated temperature.
This is a Severity Level IV Violation (Supplement I).
B.
Plant technical specification 4.0.5 provides requirements for periodic inservice testing and states in part that:
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" 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..."
Section 9.2.2 of the Updated Safety Analysis Report (USAR) identifies the below listed check valves as being ASME Code Class 3 valves. Furthermore, 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 XI 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 (Numbers not Containment air cooler vent check valves specified)
Contrary to the above, at the time of the inspection, the inservice test program implemented by the licensee did not include the above listed valves and the valves had not been periodically tested.
This is a Severity Level IV Violation (Supplement I).
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 HP-1-14 had not been properly maintained, 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 01-4-2 and ONI-14 had not been properly maintained, in that they were not consistent with the plant 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 0I-4-2 had not been properly maintained in that it was not consistent with the plant design
3 V
e 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.
This is a Severity Level IV Violation (Supplement I).
D.
Plant technical specification 6.8.1 provides requirements for station procedures and states in part that:
" Written procedures shall be... implemented... covering... surveillance and test activities of safety related equipment."
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.
This is a Severity Level V Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company is hereby required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in response to each of the above violations, including: (1) the corrective steps which have been taken and the results achieved, (2) corrective steps which will be taken to avoid further i
violations, (3) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
NOV 071986 S
Dated Stuart Richards, Chief Engineering Section
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