ML20207B242

Insp Rept 50-344/86-20 on 860519-0612.Violation Noted: Corrective Action Not Assigned & Implemented for Nonconformance Rept 86-024 Re Electrical Conduit Support for Hydrogen Combiner Sys Train a

ML20207B242
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/02/1986
From:	Burdoin J, Andrea Johnson, Kellund G, Mendonca M, Richards S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20207B225	List: ML20207B221 ML20207B233 ML20207B242
References
50-344-86-20, NUDOCS 8607170460
Download: ML20207B242 (13)

See also: IR 05000344/1986020

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U. S. NUCI.U\\R REGULATORY COMMISSION

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REGION V

Report No. 50-344/86-20

Docket No. 50-344

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License No. NPF-1

Licensee:

Portland General Electric Company

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121 S. W. Salmon Street

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Portland, Oregon 97204

Facility Name: Troj an

InspectionCondufted- May 1 - June 12, 1986

Inspectors:

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F.

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eactor Inspector

D' ate Signed

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A. D. Joh

, Enforcement Officer

ITate' Signed

S.A[I M

7/z/w,

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S. A. Ric' hards, Senior Resident Inspector

Date Signed

5. A9M

rom

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G. C. Kellund, Resident Inspector

Date Signed

Approved by:

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M. M. Mendonca, Chief

Date Signed

Reactor Project Section 1

Summary:

Inspection on May 19 - June 12, 1986 (Report 50-344/86-20)

Areas Inspected: A special unannounced inspection by two regional based

inspectors along with the two Trojan NRC resident inspectors to followup

two allegations received in the regional office during April 1986.

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Results: One violation and no deviations were identified.

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DETAILS

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Persons Contacted.

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1. • W. S. Orser, Plant General Manager

1. • C, A. Olmstead, Manager, Quality Assurance Department

• J. D. Reid, Manager, Plant Services

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• D.

L. Bennett, Supervisor, Control and Electrical

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R. P. Schmitt, Manager, Operations and Maintenance

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C.11. Brown, Operations Branch Manager, Quality Assurance

• H. F. Moomey, Trojan Resident, Oregon Department of Energy

• J. K. Aldersebaes, Manager, Nuclear Maintenance and Construction

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1. • D. D. Wheeler, QC Supervisor +

R. A. Reinart, I&C Supervisor

• G. J. Stein, Hechanical Maintenance Supervisor

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T. A. Swarers,*'QC Leadman

'*T. L. Warnick, Plant Modifications Engineering Supervisor

J. E. Purcell, ISC Unit Supervisor

C. C. Allen, QC^ Lead Electrical Inspector

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W. T. Craft, QC Specialist

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A. N. Roller, Nuclear Plant Engineer, Electrical Branch Manager

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W.~ Swan, Maintenance Supervisor

• Denotes attendance at exit management meeting on May 23, 1986.

1. Denotes attendance at exit management meeting on June 12,1986.

NOTE: The allegation characterization statements contained in this

report are either a paraphrasing of the staff's understanding of the

alleger's concern or statements taken from the allegation source

document. The characterization statements do not represent a staff

assessment, conclusion or position.

2.

Followup of Allegation or Concerns

a.

Allegation, ATS No. RV-86-A-0029

(1) Cha racte rization

The site quality control (QC) supervision directed QC

inspectors not to identify nonconforming conditions except

for work to which the inspectors were specifically

assigned. Nonconforming conditions which were identified

were not processed for corrective action. QC inspectors

were required to have all nonconformance reports (NCR)

screened by their supervisor, thereby preventing NCRs from

being written. A maintenance request (MR) associated with

a potential electrical separation criteria violation

inside a locked manhole may have been falsified.

(2) Implied Significance to Design, Construction or Operation

Improper supervision of QC inspectors and failure to

correct nonconforming conditions may result in known plant

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material deficiencies remaining uncorrected, which could

have an adverse effect on the operation of the plant.

(3) Assessment of Safety Significance

The Quality Assurance Manager was questioned regarding

direction given to QC inspectors to not identify

nonconforming conditions except for deficiencies

associated with work to which the inspectors were

specifically assigned.

The Quality Assurance Manager

confirmed that the above stated direction was provided by

first line QC supervision to temporary QC inspectors who

had been hired to increase QC activities prior to and

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during the 1986 refueling outage.

When the temporary QC

personnel were hired, the Quality Assurance (QA)

organization wanted to focus their activities on work in

progress.

In an effort to provide this direction, the

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first line QC supervision told QC inspectors not to look

for discrepancies with installntions which were old

construction. The QA Mtnager stated that when he learned

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that this direction was being provided, he took immediate

action to ensure that all QC inspectors understood that

all nonconforming conditions should be documented and

addressed. Discussions with several QC inspectors

confirmed that originally they had received instructions

to narrow their scope of 2nspection, however, they also

confirmed that they now felt free to report any deficiency

they might identify.

The primary method used to document QC inspector

observations is the QC Observation Report (QCOR). The

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QCOR was initiated at the plant as an observation record

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in January, 1986, when the QA organization started to

bring in temporary QC inspectors to augment the full-time

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QC staff.

A sample of these reports were reviewed by the NRC

inspectors to determine whether observations by QC

inspectors had been evaluated and corrective action

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initiated where' appropriate. The NRC inspectors found

QCORs written during the February-March time frame, had

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not been' subject to a review

pursuant'to an established

written procedure'in that one had not been developed at

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the time. Repo'rtedly, these items had been screened and

those appearing to have immediate safety significance were

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processed for evaluation and corrective action.

Discussions with the electrical QC coordinator indicated

that prior to assuming his position in late March, the

procedure to review and disposition the QCORs had not been

fully established. Each QCOR also has a signature space

to signify review by the QC Supervisor (QCS). None of the

first 100 QCORs had been signed by the QCS. QC personnel

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also stated that they had recognized the lack of a

proceduralized review of the early QCORs and they had

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decided to wait until the plant completed the refueling

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outage in early June before re-reviewing the early QCORs

in a more prescribed manner. The NRC inspectors noted

that QCORs written after4 April 1 appear to have been

reviewed and acted on in a reasonable manner. The QC

organization stated that the older QCOR's would be

reviewed and action initiated on all QCORs that had not

previously received a prescribed review. This action was

completed prior to the inspection conclusion. The NRC

inspectors also observed that most of the discrepancies

listed in the early QCORs were not safety related and

generally dealt with conduit support deficiencies, missing

covers and bolts on electric pull and terminal boxes,

labeling errors on electrical raceways, and apparent

discrepancies concerning raceway separation criteria.

The NRC inspectors discussed the process of writing NCRs

with QC supervisory personnel. These QC personnel stated

that QC inspectors had been directed to have their first

line supervisors initiate any NCRs and that this direction

had been given because the procedure required to be

followed to issue an NCR was relatively complex.

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supervision felt that having first line supervisors write

NCRs was more efficient administratively than training

each temporary QC inspector in the procedure governing

NCRs.

The NRC inspectors reviewed the NCR log and observed that

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NCRs had been initiated for various apparent nonconforming

conditions that were identified by QC inspectors. The NRC

inspectors further observed that five recent

nanconformance reports (NCR) in the electrical area had

Ieen voided after the NCRs were initiated. The procedure

governing control of NCRs allows voiding if the apparent

nonconformance is determined to be invalid. The procedure

further requires the reason for voiding the NCR be stated

in the corrective action section.

In the case of the

above NCRs, the reason stated was per discussions with the

Manager, Nuclear plant Engineering Electrical Branch. A

technical explanation was not niven and QC personnel were

unable to explain why the NCRs were invalid. The QCS

stated that a more complete explanation for voiding the

NCRs should be included on the NCR and that the matter

would be rereviewed and the appropriate reasons for

voiding the NCRs would be documented on the NCR.

Upon

re-review of the voided NCRs, the licensee determined that

NCR 86-024 had actually documented a valid nonconformance.

This NCR described a conduit support violation associated

with the 'A' train hydrogen recombiner panel in the 'A'

electrical switchgear room.

The licensee redocumented

this nonconformance on NCR 86-121. The staff concluded

that by incorrectly voiding NCR 86-024, the licensee had

failed to take appropriate corrective action for a valid

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nonconforming condition. This is an apparent violation of

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10 CFR 50, Appendix B, criterion XVI (344/86-20-01).

The NRC inspectors reviewed the QCOR file and the

maintenance request (MR) log to determine whether an MR

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had been falsified such that the MR indicated that an

electrical separation criteria discrepancy had been

identified and documented on the MR prior to the date a QC

inspector had observed the apparent discrepancy. The

staff review of the MR log and QCOR file did not identify

any indication that falsification of an MR had occurred.

(4) Staff position

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First line QC supervisors did direct QC inspectors to

limit the types of deficiencies that they should identify,

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however, the QA Manager corrected the problem when he

learned that the direction was being provided. The

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deficiencies identified by QC inspectors during the

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February and March, 1986, timeframe, were not res'ewed and

acted upon in a systematic manner such that neveral of the

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QCORs reviewed had no documented evidence of corrective

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action where. action appeared required. The licensee has

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re-reviewed the early QCORs and initiated corrective

action where appropriate. A procedure is now in place to

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ensure QCORs are reviewed in a prescribed manner. The

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staff found that NCRs had been written for deficiencies

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identified by QC inspectors when an NCR was the

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appropriate corrective action mechanism. The staff found

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no indications of maintenance requests being falsified.

The allegations were found to be partially substantiated.

The licensee has taken action to resolve each area of

concern.

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(5) Action Required

Followup on licensee action for the identified violation.

One violation and no deviations were identified.

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b.

Allegation, ATS No. RV-86-A-0036

(1) Characterization

Multiple assertions concerning lack of quality in the

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licensee's instrumentation and control procedures and

practices. The specific assertions are described below

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under the section, Assessment of Safety Significance.

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(2)

Implied Significance to Design, Construction and Operation

The lack of quality in instrument and control procedure

and practices could adversely affect the safety of plant

operations.

(3) Assessment of Safety Significance

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Specific, allegations are:

(a) " Signal wires to indicators in control panels in

control room have bare shields at ends which may

short out terminals on backs of adjacent indicators."

The inspector examined the installation of signal

wires in two walk-in type control panels in the

control room. .This examination found some signal

wires equipped with shrink tubing to insulate the

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shield where it had been trimmed back to allow

insulation removal for terminating the cable. Also

,.found,were some_ signal wires where shrink t.ubing was

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not used. However, in all cases the shield had been

trimmed back neatly and sufficiently far back from

'the terminal block so as not to pose the problem of

shorting out adjacent terminals. The installation

standards E-3/E-4 requires the use of shrink tubing

only when the shield is tied down to a terminal on

the terminal block. The inconsistent use of shrink

tubing on signal wires, where the shield is not tied

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down, is at.tributed to the individual practice of

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installers during the constraction period of the

plant, and does not pose a potential to short-out

terminals on adjacent indicators.

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(b) " Total lack of specific procedures for equipment

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calibration:

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"A.

Generic procedures necessary for calibration are

not listed on work requests /MR's.

"b.

Method of calibration changes dependent upon

technique and other factors, so results may not

be consistent.

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"C.

Technicians allowed to become lax in performance

of tests - fudge factor."

The licensee used generic procedures for equipment

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calibration.

These procedures identified the

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equipment vendor's specific procedures to be used in

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the calibration of specific equipment.

In those

cases where the licensee concluded the tendors

procedures for calibrating a specific piece of

equipment were inadequate, the licensee developed a

specific procedure for calibrating that particular

piece of equipment.

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The generic procedures necessary for calibrations

were identified on the-instrument calibration data

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cards (old system) and on the calibration data sheets

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(new system). These data cards / sheets are part of

maintenance request package (see below for

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description of these systems),

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Methods of calibration of instrumentation equipment

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differed slightly in that input data could be

different,

i.e., milliamps versus millivolts; but the

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output which determined the calibration was measured

in.only one parameter.

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Inspections'on the conduct of I&C tests have not

observed any laxness on the part of the technicians.

This allegation was not substantiated.

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(c) " proper tests may not always follow maintenance

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activities."

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Administrative order A0-3-9, " Maintenance Requests,"

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identified the requirements for post-maintenance

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testing. Also, this procedure required the cognizant

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supervisor (mechanical / electrical) to identify on the

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maintenance request (MR) the requirement for

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post-maintenance testing. The inspector reviewed this

procedure and examined a number of MRs. The

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licensee's procedures and practices acceptably

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specified post-maintenance test requirement, and this

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allegation was not substantiated.

(d) " Preconditions, precautions and prerequisites unique

to each situation,

i.e., loop calibration may not be

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properly followed up by technicians because they are

not known by techniciars."

Administrative order A0-3-14 " Safety-related

Equipment Outages," described the procedure for

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planning equipment outages.

It ensured proper

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scheduling, technical specification surveillances on

redundant trains, actification of other groups

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(maintenance / operation) before removal of equipment

from service; and also ensured proper testing of

equipment on return to service. The inspector

examined this procedure in detailed and discussed

with the licensee the practices followed in removing

from service control / instrument systems and equipment

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for loop testing and calibration.

At Trojan, the I&C technicians, because of their

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detailed knowledge of the various control and

instrument systems, aid the operators in removing

from service for calibration and loop testing certain

equipment and instrument systems.

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The licensee's procedures and practices for the

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removal from service for calibration / loop testing

appeared to be acceptable and sufficiently detailed

to enable the operators and technicians to be aware

of applicable preconditions, precautions and

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prerequisites peculiar to each control / instrument

system and piece of equipment.

Inspection activities have found that preconditions,

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precautions and prerequisites are complied with

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during testing of control / instrument systems and

equipment. This allegation was not substantiated.

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(c) " Computerized Calibration Cards given to Technicians

list too many details which are not necessary for the

performance of the task and cause the necessary

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information to be lost or ignored, e.g. ,

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Generic procedures required to perform the task

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are not listed.

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"B.

Data tables are often on separate pages which

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causes confusion,

i.e., the table may be broken

in the middle and completed on the next page.

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Significant information is lost amongst blank

entries and entries which are not needed for the

task."

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Last fall the licensee placed in service a new fully

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computerized maintenance scheduling system, referred

to as TSS (Trojan Scheduling System). This system

was replacing the old Maintenance Scheduling System

which was not fully computerized. The TSS is used to

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schedule control / instrument systems and equipment

loop tests and calibrations. The new system produces

the calibration data sheet which contains/ lists all

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the necessary information, such as instrument

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identification, location, manufacture, drawings,

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procedures, tools / parts required, special conditions,

etc.. - During the present outage, the licensee, to be

assured of proper shift-over to the new TSS with no

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loss of valuable instrumentation' calibration and test

data,: backed-up the new system by continued use of

'the old "hard-card" system. To this end, the

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instrument" calibration cards (hard-card) from the old

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system were attached to the calibration data sheets

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for all loop tests and calibrations of instrument

systems and equi'pment.

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The inspector examined in detail the calibration data

sheet from'TSS'and the old "hard-card" and found both

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data sheets to be thorough and complete in the

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information provided for calibration and testing of

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instrument loops and equipment. The licensee

contended that the calibration data sheet and

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hard-card were designed to provide all information

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necessary for I&C technicians to calibrate and test

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instrument loops and equipment. The inspector

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concurred this allegation was not substantiated.

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(f) " Work is performed on Q class Equipment without a

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paper trail."

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Twenty. completed maintenance requests were selected

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by number from the QC inspection schedule / record and

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seven of ther.e MRs (86-1692, 2233, 2446, 2448, 2450,

2451, and 2662) were examined in detail to determine

if records of work accomplished and QC inspections

performed were properly documented on maintenance

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request forms as required by administrative procedure

A0-3-9.

These completed MRs appeared to contain all

the required information. From this

review / examination of maintenance records, it

appeared that records were kept on work performed on

Q class equipment in accordance with procedure

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requirements. This allegation was not substantiated.

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(g) " Valve and pipe fittings on pneumatic systems are

most often over tightened so that threads are

stretched and otherwise damaged and leaks occur."

This concern was discussed in great detail with the

licensee mechanical maintenance group.

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the licensee's practice, when they open the

containment for refueling, to walkdown all of the

instrument tubing systems to identify all leaks and

prepare maintenance requests (MRs) for repair of

these leaks'during the plant outage. Most of the

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Icaks are due to leaking compression fitting ferrules

which result from several causes. Two frequent

causes are:

(1) Scratches on stainless steel tubing

surfaces where ferrule mates with tubing, and (2)

surface hardening on heavy wall tubing prevents the

ferrule from getting a good " bite" into the tubing.

The licensee's procedures and practices to reduce to

a minimum leaks in stainless steel tube fittings were

reviewed and appeared to be acceptable.

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The inspector also reviewed with the licensee the

practices followed in tightening compression type

stainless steel tube fittings.

The licensee employs

the tube fittings manufacturer's reconunendations

which limit overtightening the fittings to prevent

damage to the threads. These recommendations include

use of a manufacturer's special wrench with a small

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lever arm and limiting the number of turns to

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tighten.

The inspector examined instrument lines around twenty

transmitters for leakage. No leakage or indication

of over tightening was identified.

It appeared that damaged threads due to over

tightening of fittings is not a major.cause of leaks

in stainless steel tube fittings at the Trojan Plant.

Therefore, this allegation was not substantiated.

(h) " Questionable materials,

i.e.,

teflon tape, are

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widely used in containment."

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The present practice at Trojan is not to allow the

use of teflon tape on the primary system.

However,

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it is used on secondary system instrument piping in.

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sizes 1/2" and 3/8" inside containment. The tape is

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.used on stainless steel to stainless steel pipe

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thread fittings.

It is not used on tube fitting

threads.

It appears from published technical

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information that some teflon tape begins to decompose

at about 400*F and releases high concentrations of

halogens, fluorides, chlorides, and others which are

highly corrosive to NSSS materials. The use of

teflon at Trojan is restricted to use on systems

which do not exceed temperatures of 250'F.

The

Chemical Assessment Section at the Trojan plant in

presently analyzing the particular type of teflon

tape used on site to determine an exact assessment of

the material and to determine its limitations for

usage at Trojan.

It appeared as though the licensee was aware and

implemented limitations on the use of teflon tape

inside containment and is presently performing his

own analysis to determine if additional restrictions

on it use inside containment are required. The

allegation was substantiated but was acceptably

addressed by the licensee.

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(i) " Equipment modifications may not show up in Technical

Manuals and can cause delays and/or mistakes in

maintenance."

This item was reviewed with the licensee. About a

year ago the licensee initiated a program to upgrade

all the plant technical manuals; and to this end, the

licensee appointed a technical manual task group to

accomplish this assigntient. The inspector examined

the program with the task group leader.

Approximately ten people are presently assigned to

the task group. The program calls for reviewing all

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technical manuals at the plant to verify that they

include all the latest as-built changes,

modifications and revisions. The manuals are also

being reviewed for dividing / indexing the text into

more logical divisions; a thorough review process

will verify the accuracy of the manuals; the manuals

are then to be reprinted, and after final

review / checking new copies of the new technical

manuals will be issued. The present scheduled

completion date for this project is July 1987.

The licensee's program for completely overhauling the

plant technical manuals appeared to be thorough and

addressed this allegation.

(j) " Improper wiring of RTD on main coolant pump:

Wrong size of lug for screw size

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Spade lug used instead of round lug

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There was potential for shorting of signals"

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The inspectors examined the wiring of the seal water

RTDs on the "B" reactor coolant pump (TE 170 and TE

171). These RTDs have no safety related function

other than being required to maintain the pressure

boundary following a seismic event.

The size of the

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lugs installed appeared

adequate for the screw size and no evidence of

shorting or ir. adequate gaps between adjacent lugs was

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found. The minimum distance observed between

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adjacent lugs was approximately 3/16 inch which does

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not present any shorting problems due to the low

voltages involved.

The inspectors observed evidence of both ring lugs

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and spade lugs installed on the termination block.

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The licensee's new electrical installation standard

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calls for ring lugs to be used, however, the old

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standard in use at the time of installation allowed

the use of spade lugs. The licensee intends to

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conduct any new terminations in accordance with the

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new standard and use ring lugs but does not intend to

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replace the existing spade lugs in place throughout

the plant.

The inspectors also noted that some of the lugs had

been bent upward apparently to facilitate

installation due to the small amount of space

available in the head of these particular RTDs.

The

licensen previously identified the issue of

insufficient space in the RTD head and initiated a

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Request for Evaluation (RFE) to deter 1mine the

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acceptability of the present configuration.

The allegation is partially substantiated in that

spade lugs were installed on the RTD termination

block. However, the installation standard they were

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installed to allowed this. The remainder of the

allegation regarding the use of the wrong size of lug

for the screw size and the potential for shorting of

signals was not substantiated. The related issue of

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inadequate space for installation of lugs on the RTD

termination block has been previously identified by

the licensee and is currently being addressed. The

allegation has minor safety significance.

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(k) Source range channel N31 is erratic and should not be

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relied upon for refueling activities.

In addition,

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the N31 detector was replaced without' supporting

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documentation and the N31 SOLA power supply was

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, installed incorrectly.

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The inspector reviewed the past performance and

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maintenance history of the N31 source range channel.

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The channel has behaved somewhat erratically for many

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years due to a high noise level and sensitivity to

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outside influences.

The licensee has replaced the

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detector preamplifier during the current outage with

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a different model that should improve performance.

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Refueling records were reviewed and personnel were

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interviewed to determine if the licensee took

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appropriate actions in response to channel spikes

during refueling activities. The inspector verified

that reactor core alterat. ions were suspended whenever

spiking occurred and were not resumed until the cause

was determined. The spiking was usually attributed

to welding, grinding or use of heat guns or portable

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radios in the vicinity of the detector cable.

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With regard to the contention that the N31 detector

was replaced without supporting documentation, the

inspector reviewed the maintenance records for the

detector. The detector was replaced in April, 1986

under a maintenance request (MR 86-2200). The

maintenance request and supporting documentation

appeared to control and document the work performed.

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The allegation that the N31 S01.A power supply was

inntalled incorrectly was also investigated. The

inspector found no evidence that a SOLA power supply

for the N31 channel was replaced. The inspector did,

however, determine that a SOIA power supply for the

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nuclear instrumentation cabinets had been installed.

This power supply had been installed incorrectly,

however, the licensee subsequently identified the

problem and corrected it.

The allegation that the source range channel N31 has

behaved erratically is partially substantiated in

that the channel has been somewhat erratic. Iloweve r,

the inspector determined that appropriate actions

consistent with procedures and Technical

Specifications were taken whenever the channel

malfunctioned. The allegations concerning the

undocumented replacement of the N31 detector and the

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improper installation of the SOLA power supply were

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determined to be not substantiated. The detector

replacement was controlled and documented, and the

power supply installation error was discovered and

corrected by the licensee. The inspector determined

that acceptable procedures and programs exist to

control work and to identify and resolve problems in

this area.

(4) Staff position

The staff concludes that the licensee established

procedures and impicmented programs that addressed the

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allegers' concerns; and that in the normal process of

following prescribed procedures, the cbove identified

allegations were acceptably addressed.

(5) Action Required

None.

No violations or deviations were identifir

3.

Exit. Meeting

The inspectors conducted exit meetings on May 23 and June 12,

1986, with the general manager of the plant, members of the plant

staff, and other staff personnel.

During these meetings, the

inspectors summarized the scope of the inspection activities and

reviewed the inspection findings as described in this report.

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