ML20238C769

Notice of Violation from Insp on 870921-1002.Violations Noted:Failure to Verify Auxiliary Feedwater Turbine Driven Pump Capability & Exclusion of Valves Ms 226 & Ms 222 from Inservice Testing Program

ML20238C769
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/17/1987
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20238C763	List: IR 05000344/1987031 ML20238C760 ML20238C769 ML20238C773
References
50-344-87-31, NUDOCS 8712310205
Download: ML20238C769 (3)

Text

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APPENDIX A NOTICE OF VIOLATION Portland General Electric Company Docket No. 50-344 Trojan Nuclear Power Plant License No. NPF-1 During an NRC inspection conducted September 21 through October 2, 1987, I 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 (1987), the violations are listed below:

1 A. Technical Specification Surveillance Requirement 4.7.1.2.1 specifies, in j part, "Each safety related auxiliary feedwater pump shall be demonstrated l OPERABLE...by verifying that the steam turbine-driven pump starts...(when tested pursuant to Specification 4.0.5)...." Specification 4.0.5 stipulates "... 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...." The 1983 ASME Boiler and Pressure Vessel Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components", Division 1, Article IWV-3415, " Fail-Safe Valves",

specifies that " valves with fail-safe actuators shall be tested by observing operation of the valves upon loss of actuator power."

Contrary to the above, as of October 2,1987 the AFW turbine driven pump had not been verified to be capable of starting by operation of the steam admission valves coincident with loss of actuator power (using only accumulatorair).

This is a Severity Level IV Violation (Supplement I).

B. 10 CFR 50, Section 50.55a(g) sets forth requirements for inservice inspection and testing of nuclear plant components. The licensee's program for inservice testing (IST) of pumps and valves is described in Topical Report PGE-1048, " Inservice Testing Program for Pumps and Valves, Second 10-Year Interval ." Section 1.0 " Introduction" of PGE-1048 indicates "...those systems designated Quality Group 1, 2, 3A, and 3B in the Updated Final Safety Analysis Report (UFSAR) are included in the IST program...." UFSAR Figure 10.2-3 " Main Steam System" identifies air supply valves MS226 and MS222 to AFW Terry turbine steam admission isolation valve CV 1453 as Quality Group 2.

Contrary to the above, as of October 2, 1987, valves MS 226 and MS 222 had not been included in the licensee's IST program.

This is a Severity Level IV Violation (Supplement I).

C. 10 CFR 50.59 requires that the licensee shall maintain records of changes 3

in the facility, to the extent that the changes constitute changes to the facility as described in the safety analysis report, and must include a written safety evaluation which provides a bases for the determination that the change does not involve an unreviewed safety question. Trojan USAR Figure 9.5-10 requires the Emergency Diesel Generator (EDG) Air 8712310205 871217 PDR ADOCK 05000344 0 DCD

Start System pressure regulators to be set such that downstream pressure is 200 psig.

Contrary to the above, on October 2, 1987, the eight EDG Air Start System pressure regulators downstream pressure setpoints were 180 to 190 psig.

The setpoint had been changed without documenting the performance of a safety evaluation.

ThisisaSeverityLevelIVViolation(Supplements).

D. 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures or drawings and shall be accomplished in accordance with these instructions,.

procedures or drawings.

1. Bruce GM Diesel Inc. Drawing A071F07001, Revision 9 - Schematic Diagram - Air Start System for Tandem Engine Unit, requires the EDG Air Start System lubricators to be installed upstream of the relay air valves.

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2. Drawing A071F07001, noted above, does not indicate installation of a j pressure gage on the EDG Air Start System Relay air valves.

3. Drawing A071F07001, noted above, requires EDG Air Start System i pressure gages downstream of the pressure reducir.g valves to be 0-300 psig gages.

Contrary to the above, on October 2, 1987 1

1. All eight lubricators of the EDG Air Start System were downstream of the relay air valves.

2. One of eight relay air valves was equipped with a pressure gage.

3. One of eight pressure reducing valve downstream pressure gages was a 0-200 psig gage.

This is a Severity Level IV Violation (Supplement I).

E. 10 CFR 50 Appendix B Criterion II requires the establishment of a QA program, pGE Nuclear Quality Assurance Program, Supplement 1, l incorporates ANSI N18.7-1976. ANSI N18.7-1976, Paragraph 5.2.8, I specifies that a surveillance testing and inspection program shall be prescribed to insure that safety-related structures, systems and i components will continue to operate, keeping parameters within normal i bound, or will act to put the plant in a safe condition if they exceed  ;

normal bounds.

Contrary to the above, eight EDG Air Start System air receiver relief I valves had not been tested, inspected or set since original construction. {

1 This is a Severity Level IV violation (Supplement I).

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F. 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings," requires that " Activities affecting quality shall be-prescribed by... drawings,...and shall be accomplished in accordance with these... drawings." Trojan nuclear plant drawing number HBD-80-50 delineates the installation of support H 834 on the safety related portion of.'the instrument air supply line to the actuator of main steam isolationivalve CV 2216.

Contrary'to'the above, on September 22, 1987, support H.834 was not. <

attached to the air supply line.

This. is a Severity Level V violation (Supplement I).

I Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company is hereby required to submit a written statement or explanation to the'U.S. ,

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC -]

20555 with a copy to the Regional. Administrator, Region V, and a copy to the NRC Resident Inspector, Mr. R. Barr, within 30 days of the date of the letter transmitting this Notice. This reply- should be. clearly marked as a " Reply to a Notice of Violation" and should include for each violation: -(1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further. violations, and (4) the date when full compliance will be achieved. 1

. If an adequate reply'is not received within the' time specified in this Notice, an order may be issued to show cause why.the license should not be modified, suspended, or. revoked or why such other actions as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

1 FOR THE NUCLEAR REGULATORY COMMISSION' DEC 17195 gggd L Dated at Walnut Creek, California Dennis F. Kirsch, Director Division of Reactor Safety and Projects l

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