ML20236S830
| ML20236S830 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/25/1987 |
| From: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8711300122 | |
| Download: ML20236S830 (1) | |
See also: IR 05000344/1987013
Text
_
_ _ _ _ _ _ - _ - -
.
.
. . . .
NOV 251987
Docket No. 50-344
Portland General Electric Company
121 S. W. Salmon Street
Portland, Oregon 97204
Attention:
Mr. David W. Cockfield
Vice President, Nuclear
Gentlemen:
Thank you for your letter dated November 13, 1987 in response to our Notice
of Violation and Inspection Report No. 50-344/87-13, dated October 16, 1987,
informing us of the steps you have taken to correct the items which we
brought to your attention.
Your corrective actions will be verified during a
future inspection.
Your cooperation with us is appreciated.
Sincerely,
D @ el A;n s up
Denn9s F.% YPsch, Director
I
Division of Reactor Safety and Projects
bec w/ copy of letter dated 11/13/87:
Resident Inspector
Project Inspector
B. Faulkenberry
,J. Martin
docket file
M. Smith
LFMB
DKir%
REGION V
va
DPere$ragt
MMendonca
RZimmerman
sph
11/4
/2f/87
11/pt/87
ll/gp/87
,EQUEST COPY J4EQtlEST COPY J REQUEST f(PY ] REQUESTJrQY1
' YES*/ NO
]YES / (NO3 ] YES / [N0) I
YESi / N0
%
w
tttfATO PDR ]
YES ) NO
]
-
8711300122 871125
,
ADOCK 0000
4
gDR
.
'_,N
l
i
V
j
/g
/
- - - _ _ _ _ _ ___- - - - _ --
_
--
}
o
.
.c
.
s
' '
'
.,, l}
'
.-
_
E!E
gg! C--[ PDftland General ElechicCOrunry
-
gg 7.g ',o
" > J,_
l
r
y,
David W. Cockfield Vice President, Nuclear
'
November 13, 1987
V'
Trojan Nucicar Plant
Docket 50-344
License NpF-1
U.S Nuclear Regulatory Commission
ATTN: Document Control Dock
l
Washington DC 20555
Dear Sir:
Response to Notice of Violation
Your letter of October 16, 1987 forwarded a Notice of Violation concerning
inadequate 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 werc
!
tested. Our response to the Notice of Violation is provided in the
)
attachment.
Sincerely,
1
Attachment
c: d r. John B. Martin
Regional Administrator, Region V
U.S. Nuclear Regulatory Commission
Mr. Dave Yaden, Director
State of Oregon
Department of Energy
,
Mr. R. C. Barr
NRC Resident Inspector
Trojan Nucicar Plant
!
l
d
}
- n m,+//1cr J J o(D
y'
-
w i fW
y
,
1
121 S W Sa mon 5:wa Pon an Ore;pn 9723
_ _ _ _ _ _ _ _ _
____________._____
_ __ ---
.-
_
_
_
_
_
_
- ..
'
- .
.
.*
Trojan Nuclear Plant'
Document Control Desk
Docket 50-344
. November 13, 1987
License NPF-1
Attachment
j
_ Page 1 of 3
]
RESPONSE TO NOTICE OF VIOLATION
Violation'No. l'
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.
f
i
This is a Severity Level IV violation (Supplement 1).
!
!
Response
Portland General Electric (PGE) acknowledges the violation.
A.
The reason for the Violation.
Although the Westinghouse test report, WCAP-9157,zcontained in Quali-
i
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
that the Westinghouse test report provided sufficient documentation
to demonstrate qualification.
.9
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
3
demonstrate that performance requirements were met. Additional in-
formation regarding RTD accuracies was also requested from Westing-
house. Westinghouse is the vendor for the Rosemount RTD sensors
used at the Trojan Nuclear Plant. Westinghouse has reaffirmed that
the methods used to verify RTD accuracies during high-energy line
break (HELB) conditions are sufficient to demonstrate acceptable
performance of the RTDs. This position applies to all RTDs
(including Rosemount Mod.cis 176KF .tnd 176KS).
PGE has incorporated this information into Qualification File No.15,
1
The Sandia lab report supports the original qualification methodology
used for demonstrating acceptabic performance under accident
conditions.
i
.
.
l
- _ _ _ _ - _ _ _ - - _
__
.
,
'
'
'
.
Trojan Nuclear Plant
Document Control Desk
Docket 50-344
November 13, 1987
License NPF-1
Attachment
Page 2 of 3
l
C.
Corrective steps that will be taken to avoid further violations.
l
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 enginecr-
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-
cation program does not have a programmatic weakness in the area of
worst-case instrument accuracy, and that the Rosemount RTD perceived
file deficiency is an isolated event.
D.
The date when full compliance will be achieved.
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 Cuidelines, Limitorque valvo actuators in containment were
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-
ators did not contain any justification for the deviation.
This is a Severity Level V violation (Supplement 1).
Response
PGE acknowledges the Violation.
A.
The reason for the Violation.
Request for Design Change (RDC)86-033 was initiated by PGE in order
to provide a comprehensive inspection, maintenance, and repair pro-
gram for all environmentally-qualified Limitorque valve operators at
the Trojan Nuclear Plant. This program occurred during the 1987
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 were
also inconsistent in that these dust caps were removed from most but
not all Limitorque valve operators where the installation of a gear
case grease relief was required.
____
- - - - _ - - . . - _ - _ - - - -
- - _
/
- -
. y* .
st
q
,
,
,
\\
.,~
Trojan Nuclear Plant
Document Control Desk-
Docket 50-344
November 13, 1987
j
License NPF-1
Attachment
.Page 3 of 3
B. .The corrective actions that have been taken and the results achieved.
)
All Limitorque valve' operators with gear case reliefs were reinspec-
ted for dust caps, and all remaining dust caps were removed. This
corrective action was initiated immediately:siter the deficiency was
identified and was' completed during the 1987 refueling outage. Gear
-case grease reliefs were installed'to accommodate possible grease'
expansion during accident conditions. Since the dust caps'are soft
.l
plartic and are not qualified, PGE believes that the' dust caps-would
!
be sufficiently softened and degraded by the accident conditions such
j
that they would-not prevent the relief of grease fror 'he casing.
1Thus, had a loss of coolant accident or HELB occurrec,'the potential
impact of this deficiency would have been negligible,
,
.
C.
The corrective steps that will be taken'to avoid further violations.
PGE will communicate to appropriate' Nuclear Plant Engineers the
- )
importance of considering the removal of dust caps or other temporary-
j
covers during installation. Engineers will be reminded to be aware
of the existence of dust caps or other temporary covers on equipment
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.
D.
The date when full compliance will be achieved.
Prior to 1988 refueling outage (April 1988).
!
!
,
1
2128W,1187
.- -
.
i