ML20246E104
| ML20246E104 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/05/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8907120104 | |
| Download: ML20246E104 (5) | |
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' David W.' Cockfield Vice President, Nuclear July 5, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sir:
Reply to a Notice of Violation Your letter of June 5, 1989 transmitted a Notice of Violation based upon Nuclear Regulatory Commission Inspection Report No. 50-344/89-10.
Enclosed please-find our reply to the' Notice of Violation provided in to this letter.
Sincerely, Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant I
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- Docket 50-344~
Attach:: lent 1 L
License NPF-1' July 5, 1989 L
Page 1'of 4-Response to Notice of Violation Violation A Technica1 Specification 4.0.5 requires, in part, inservice testing of American Society of Mechanical Engineers (ASME) Code Class 1, 2, and 3 pumps in.accordance with Section XI of the ASME Boiler-and Pressure
- vessel Code land applicable addenda.
In implementation of.this requirement. Licensee Topical Report PGE-1048' I
states that the requirements of the 1983 Edition through Summer 1983 Addenda of Section XI will be implemented.
Paragraph IWP-4110 of Section XI, 1983 Edition through Summer 1983 Addenda,. requires 'an. instrument accuracy of plus or' minus five percent of full scale for the measurement of vibration amplitude.
Contrary to the above, on March 23, 1989, measurement of vibration anrplitude was performed for inservic,e. testing of. the "A" Containment Spray Pump with instrument T-5410, which had an accuracy of less than plus or minus five percent of full scale.
This is a Severity Level IV violation (Supplement I).
Response
P;.rtland General Electric.(PGE) acknowledges the violation.
'1.
Reason for the violation.
I The reason for the violation was personnel error in the original interpretation and application of the ASME Section XI.
Article IWP-4000 requirements.
The instrument used to monitor pump vibration for the Trojan Inservice Testing (IST) Frogram was.the IRD Model 308 hand-held vibration monitor. This instrument has been used to perform this particular surveillance since the start of the IST vibration monitoring program in the late 1970s. The IRD Model 308 vibration meter and its associated pickup pm N were calibrated as an assembly I
to plus or minus 1.0 mil on a 0-10 :eu scale. The acceptability of using this instrument fc the IST was based on its full-range capability (0-100 mils in eight overlapping ranges). The ASME Section XI. Article IWP-4000 requirement should have been applied to each of the eight overlapping ranges rather than the entire 0-100 mil range. The misapplication of the ASME Section XI code requirements has resulted in the use of an instrument that has a plus or minus 10 percent accuracy rather than the plus or minus 5 percent accuracy required by the code version in use at PGE.
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Trojen Cucicer Plcnt Document Control D:sk
.'*f Docket 50-344, Attachment'l License NPF-1 July 5,'1989 Page 2 of 4 4
Training on'the ASME Code requirements for nucicar pumps and' valvec had recently been received..However, the deficiency associated with IRD Model 308 vibration meter had not yet been Identified.
2.-
Corrective steps.that have been taken and the results~ achieved.
A.
As a result of the identified' problems concerning the accuracy of the vibration instrument.being used for the IST, the use of an alternate vibration monitoring system during IST of pumps was initiated. The Trojan Maintenance Department han been performing separate full spectrum vibration monitoring on all
- pumps in the IST Program using vibration monitoring equipment, which meets the accuracy requirement of ASME Section XI.
All IST surveillance testing performed af ter May 22, 1989 was completed using the Trojan Maintenance Department vibration monitoring equipment. Vibration readings were taken at the same locations required by the.IST surveillance to assure consistency for the data evaluation.
B.
The PGE Surveillance and Test Department has ordered..and
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subsequently received, new portable vibration monitoring equipment.for its own use that meets the accuracy requirements of the ASME Section XI Code.
3.
The corrective steps that will be taken to avoid further violations.
The calibration of portable vibration monitoring equipment used to meet the requirements of the ASME code will be maintained to the accuracy specified in Paragraph IWP-4110 of Section XI, 1983 Edition through Summer 1983 Addenda.
The Event Report (ER-89-043) associated with Inspection Report 89-10 (Violation A) has been reviewed by the IST group. As a result of the review, the group will evaluate all instruments used in the IST program to ensure the accuracy requirements of the applicable ASME Codes are met.
4.
The date when full compliance will be achieved.
Full compliance for vibration instrumentation accuracy was achieved l
L on May 22, 1989.
J.
Trojtn Cuclsir Pitnt DocumInt Control Dssk Docket 50-344
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License NPF-1 July 5, 1989 1
Page 3 of 4 I
i violation B Title 10 to the Code of Federal Regulations, Part 50 (10 CFR 50),
Appendix B, Criterion V, states in part:
" Activities affecting quality
]
shall be prescribed by documented instructions, procedures, or drawings, j
of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drswings".
f Administrative Order A0-3-6, titled " Conduct of Operations-Shift Records", Revision 17,' dated March 3, 1988, requires, in part, that control room log entries shall include entry into a different mode.
l Contrary to the above, on April 6, 1989, the Plant entered Mode 2 during the scheduled shutdown in preparation for the 1989 Refueling Outage; however, the entry into Mode 2 was not recorded in the control room log until April 14, 1989.
This lu a Severity Level V violation (Supplement I).
Response
Portland General Electric (PGE) acknowledges the violation.
1.
Reason for the violation.
The reason for the violation is personnel error in that the control operator failed to make a los entry when the Plant entered Mode 2 on April 6, 1989. Prior to this incident taking place, the Plant was in the process of shutting down for the annual refueling outage.
The main turbine was tripped at 0022 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> on April 6, 1989. A subsequent los entry was made as required. At 0025 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />, a reactor shutdown began. This event was also lotted, as required. The transition from Mode 1 to Mode 2 occurred during this period. The log entry to record this information was omitted.
Subsequent entry into Mode 3 was correctly logged at 0040 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />.
2.
Corrective steps that have been taken and the results achieved.
A.
The importance of maintaining a complete and accurate log was l
discussed with the individual omitting the los entry.
L B.
A deviation was issued to Plant shutdown Procedure General Operating Instruction (G01)-3 to remind the control operator to i
log the entry to Mode 2 when the Plant reaches a power level of I
less than 5 percent.
C.
The procedure for Plant startup, GOI-2, was reviewed.
It was noted the point-of-entry to Mode 2 during a reactor startup wes not clearly defined. A revision has been issued to COI-2 to define this transition poi..t and to remind the control operator to make the appropriate log entry.
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Trojtn Cuclear Plcnt Docum nt Control Desk Docket 50-344
- Licence NPF-1 July 5, 1989 Page 4 of 4 3.
The corrective steps that will be taken to avoid further violations.
The deviation issued to Plant Shutdown Procedure GOI-3 will be
' incorporated in the next procedure revision. This action is part of the Procedure Upgrade Program and is scheduled to be completed by October 1989.
4 Date when full compliance will be achieved.
Full compliance has been achieved.
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