ML20236P940
| ML20236P940 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/13/1987 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-CR-3597 NUDOCS 8711190096 | |
| Download: ML20236P940 (4) | |
Text
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- Ell PortlandGeneralElechicCompany David W. Cockfield Vice President, Nuclear November 13, 1987 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nucicar Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sir:
Response to Notice of Violation Your letter of October 16, 1987 forwarded a Notico of Violation concerning inadequato environmental qualification documentation for Rosemount type resistance temperature detectors (RTDs) and Limitorque valvo actuators that were not maintained in a condition similar to that in which they were tested. Our response to the Notice of Violation is provided in the attachment.
Sincerely, l44 Attachment l
c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1
Mr. Dave Yaden, Director
.l State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 8711190096 871113
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PDR ADOCK 05000344 f
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I 121 S W Samon Street Pomarri Oregor 97204
Trojan Nuclear Plant Document Control Desk l
Docket 50-344 November 13, 1987 l
License NPF-1 Attac'nment Page 1 of 3 RESPONSE TO NOTICE OF VIOLATION' Violation No.JL Contrary to Paragraphs (f) and (k) of 10 CFR 50.49 and Sections 5.2.5 and 8.0 of the Division of Operating Reactors (DOR) Guidelines, Qualification File No. 15 for Rosemount Type 176KF and 176KS resistance temperature detectors (RTDs) did not demonstrate that the plant functional perfor-mance requirements for their application were met under the postulated accident conditions.
This is a Severity Level IV violation (Supplement I).
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Response
l Portland General Electric (PGE) acknowledges the violation.
A.
The reason for the Violation.
Although the Westinghouse test report, WCAP-9157, contained in Quali-fication File No. 15, provided documentation to demonstrate qualifi-cation of the Rosemount RTDs to the DOR Guidelines, the Sandia National Laboratory Report, [NUREG-CR/3597 (SAND 84-093) of December 1984), which provides additional supporting documentation, was not included in the file to demonstrate RTD qualification. PGE believed l
that the Westinghouse test report provided sufficient documentation to demonstrate qualification.
B.
Corrective steps that have been taken and the results achieved.
An evaluation of the Sandia lab report [NUREG-CR/3597 (SAND 84-093) of 12/84] has been completed in order to provide supplemental data to demonstrate that performance requirements were met.
Additional in-formation regarding RTD accuracies was also requested from Westing-i house. Westinghouse is the vendor for the Rosemount RTD senr, ors l
tsed at the Trojan Nuclear Plant. Westinghouse has reaffirmed that the methods used to verify RTD accuracies during high-enorgy line break (HELB) conditions are sufficient to demonstrate acceptable l
performance of the RTDs.
Thin position applies to all RTDs
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(including Rosemount Models 176KF and 176KS).
PGE has incorporated this information into Qualification File No. 15.
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The Sandia lab report supports the original qualification methodology used for demonstrating acceptable performance under accident conditions.
l t
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1 1
Trojan Nuclear Plant Document Control Desk Docket 50-344 November 13, 1982 License NPF-1 Attachment Page 2 of 3 f
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C.
Corrective steps that will be taken to avoid further violations.
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PGE is currently involved in an in-depth review of all the' equipment files for environmental qualification of electrical equipment. PGE is also developing thorough and systematic calculations for engineer-ing review of instrument accuracy issues, identification of worst-case errors under accident conditions for instrument loops, and set-point calculations. These activities will assure that our qualifi-l cation program does not have a programmatic weakness in the area of worst-case instrument accuracy, and that the Rosemount RTD perceived j
i file deficiency is an isolated event, D.
The date when full compliance will be achieved.
1 Full compliance has been achieved for Environmental Qualification File No. 15.
Violation No. 2 Contrary to Paragraphs (f) and (k) of 10 CFR 50.49 and Sections 5.2.2 and 8.0 of the DOR Ouidelines, Limitorque valve actuators in containment wore not maintained in a condition similar to that in which they were tested, in that many of their gear case grease relief valves have had. dust caps installed and qualification files covering these Limitorque valve actu-l atora did not contain any justification for the deviation.
l This is a Severity Level V violation (Supplement I).
I
Response
PGE acknowledges the Violation.
A.
The reason for the Violation.
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l Request for Design Change (RDC)86-033 was initiated by PG8 in order j
to provide a comprehensive inspection, maint.enance, and repair. pro-
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gram for all environmentally-qualified Limitorque valve operators at the Trojan Nuclear Plant. This program occurred during the 1987 J
refueling outage.
The installation of gear case reliefs where needed was included. However, the work instructions prepared by engineering did not include an explicit requirement for the removal of any dust caps provided by the vendor for shipping and pre-installation handling. Maintenance and construction work group practices ware l
also inconsistent in that these dust caps were removed from most but l
not all Limitorque valve operators where the installation of a gear case grease relief was required.
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Trojan Nuclear Plant Document Control Desk
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Docket 50-344 November 13, 1987
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License NPF-l' Attachment' i
Page 3 of 3
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B.
The corrective actions that have been taken and the results achieved.
i All Limitorque valve operators with-gear case reliefs were reinspec-I ted for dust caps, and all remaining dust caps were removed. This 1
corrective action was initiated immediately after the deficiency was 4
identified and was completed during the 1987 refueling outage. Gear I
case grease reliefs were installed to accommodate possible grease axpansion during accident conditions. Since the dust caps.are soft plastic and are not qualified, PCE believes that the dust caps would 1
be sufficiently softened and degraded by the accident conditions such that they would not prevent the relief of grease from the casing.
Thus, had a loss of coolant accident or HELB occurred, the potential I
impact of this deficiency would have been negligible.
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C.
The corrective steps that will be taken to avoid further violations.
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PGE will communicate to appropriate Nuclear Plant Engineers the importance of considering the removal of dust caps or other temporary covers during installation.
Engineers will be reminded to be aware
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of the existence of dust caps or other temporary covers on equipment
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being installed, and to explicitly instruct the work groups via the work instructions to remove these items if needed. In addition, recommendations will be made to Plant maintenance, Plant Modifications, and Quality Control that they improve work group awareness of the need to remove dust caps or other temporary covers in this case.
q D.
The date when full compliance wil? be achieved.
Prior to 1988 refueling outage (April 1988).
1 2128W.1187 l
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