IR 05000344/1987012

Insp Rept 50-344/87-12 on 870330-0403.No Noncompliance or Deviations Noted.Major Areas Inspected:Areas of Design Changes & Mods,Qa Program Measuring & Test Equipment, Followup of Previous Insp Findings & Closure of Open Items

ML20212R243
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	04/10/1987
From:	Mendonca M, Pereira D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212R239	List: IR 05000344/1987012 ML20212R236
References
50-344-87-12, NUDOCS 8704270010
Download: ML20212R243 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

, Report No: 50-344/87-12

< Docket No. 50-344 License No. NPF-1

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Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojan Nuclear Plant

Inspection at: Rainier, Oregon j Inspection conducted: March 30-April 3, 1987 j

Inspector: %^ -

D.B.Pereira,ReactorInspector(j'

b V8*47 Date Signed J

Approved by: _

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YN /# 7 M. M. Mendonca, Chief, Date Signed l

Reactor Project Section 1  ;

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Summary: ,

j Inspection During the Period of March 30-April 3,1987 (Report 50-344/87-12)

Areas Inspected: This routine, unannounced inspection by the Project Inspector involved the areas of Design Changes and Modifications, QA Program

)j Measuring and Test Equipment, follow-up of previous inspection findings, and

, closure of open items. During this inspection, inspection modules 30703, 37702, 35750, and 92701 were used.

I Results: No items of noncompliance or deviations were identifie ,

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PDR ADOCK 05000344 G PDR

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1. Persons Contacted i Licensee Personnel

• D. Cockfield, Vice President, Nuclear

• C. A. Olmstead, Plant Manager

• R. P. Schmitt, Manager, Operations and Maintenance

• R. Jarman, Manager, Quality Assurance Department

• D. Keuter, Manager, Technical Services J. D. Reid, Manager, Plant Services

• C. H. Brown, Operations Branch Manager, Quality Assurance W. L. Kershul, Engineer, Nuclear St.fety and Regulation Department D. L. Bennett, Supervisor, Control and Electrical R. Reinart, Supervisor, Instrument and Control

• D. W. Swan, Supervisor, Maintenance R. Russell, Assistance Operations Supervisor, Quality Assurance G. A. Zimmerman, Manager, Nuclear Regulation Branch

• A. Ankrum, Supervisor, Nuclear Regulation Branch

• P. Yundt, General Manager, Technical Functions U. S. Nuclear Regulatory Commission

• G. Suh Oregon Department of Energy

• H. Moomey, Oregon Resident Inspector

• Attended the Exit Meeting on April 3, 198 . QA Program Measuring and Test Equipment The purpose of this inspection was to determine whether the licensee has j developed and implemented a QA Program relating to the control of

measuringandtestequipment(M&TE)thatisinconformancewith l regulatory requirements, connitments in the application and industry

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TheinspectorreviewedAdministrativeOrder(A0)-13-6, entitled" Control of Portable Measuring and Test Equipment" which establishes the program to control the use and calibration of portable measuring and testing equipment utilized in the inspection, testing, and monitoring of quality-related items. The inspector's review of this procedure indicated that the following items are addressed:

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a. The criteria and responsibility for determination of calibration frequency are addressed in paragraphs II.A and II.A.3 of A0-13-6, which states that each responsible supervisor shall ensure that a calibration program schedule is prepared and maintained for M&TE and lists the frequency of calibration based on manufacturer's literature and practical experienc b. The documentation of M&TE calibration history includes the following items:

(1) Traceability to the calibration sourc (2) As-found and as-calibrated dat (3) Identification of standards use (4) Identification of calibration procedures use (5) Date of calibration and date of next required calibratio (6) Name of person performing the calibratio A0-13-6 paragraph II.C.2 provides instructions for technicians or maintenance journeymen performing the calibration of M&TE to include the above stated items as a minimum. In addition, the required tolerance or accuracy is stated as well as the corrections or adjustments necessary to obtain satisfactory calibration. A0-13-6 states that the standard used for the calibration has an accuracy equal to or greater than the accuracy required by the equipment being calibrate c. The inspector reviewed the licensee's action when M&TE or reference standards are found out of calibration, lost, or stolen, including a documented evaluation of the validity of previous tests. In paragraph II.C.3 of A0-13-6, it states that the supervisor is responsible to ensure that the necessary investigations are performed and documented to determine the validity of previous inspection or test results and the acceptability of previously inspected or tested equipment which utilized this instrument during the interval in question. In addition, any instrument found to be chronically out of calibration or any instrument that cannot be satisfactorily calibrated is reworked or replace d. The inspector reviewed the written requirements of the M&TE program which prohibits the use of M&TE which is not currently calibrated and controls inadvertent use of such equipment, and provides environmental handling or storage requirements. Paragraph II.D of A0-13-6 describes the use and storage of M&TE and states that the person shall examine the calibration sticker or other records for the equipment to ensure that the calibration date has not expired and will not expire while the equipment is in use. In addition, all M&TE is stored in protected locations and environment '

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,3 The inspector verified the implementation of the M&TE program by reviewing the calibration records of several pieces of M&TE and checking that they identified the items mentioned in paragraph 2 abov It was noted that the M&TE are properly stored, identified by a unique number, and calibration status is formally maintaine The calibration procedures are available and are properly controlled, and the M&TE are recalled for calibration in accordance with an established schedule. The inspector questioned the Instrument and Control Supervisor about the aspects of the M&TE program as discussed above and felt that he understands the program as presently defined. The inspector verified that a log-out/ log-in system is in use to control the use of M&TE, although only for

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personnel outside the Instrument and Control group. The inspector concluded that adequate accounting is being maintained by use of surveillance data sheets which requires naming the M&TE used and ensures adequate accounting of use of MT&E and assume responsibility for its us The inspector's review of the M&TE program indicated that the licensee has developed and implemented a progran which controls M&TE in conformance with regulatory requirements, commitments in the application, and industry standard No violations or deviations were identified in this are . Desian Changes and Modifications Program The purpose of this inspection was to determine whether the licensee is implementing a QA Program relating to the control of design changes and modifications that is in conformance with regulatory requirerents, connitments in the application, and industry guides and standard The inspector reviewed the following procedures which have been established for the control of design and modification change requests: NuclearDivisionProcedure(ilDP)200-1, entitled"DesignChange Control", Rev. NDP 200-2, entitled " Plant Configuration Changes", Rev. NDP 100-5, entitled " Preparation of Safety Evaluations required by 10 CFR 50 and Trojan Technical Specifications", Rev. Administrative Order (AO)-5-1, entitled " Plant Changes and Alterations", Rev. 1 A0-6-2, entitled " Temporary' Modifications" Rev.1 iluclear Plant Engineering Procedure (NPEP) 100-3, entitled

" Indoctrination and Training", Rev. _ . . . -. . __ _ _ _ . _ . _ -..

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Nuclear Plant Engineering Procedure (NPEP) 200-11, entitled i " Verification of Design", Rev. 1.

! NPEP 200-14, entitled " Detailed Construction Package Preparation and i Control", Rev. 4.

i Paragraph V.A of A0-5-1 provides the method for initiating a plant design change and which states that the processing shall be in accordance with

. NDP 200-1 Design Change Control. These changes are normally initiated by Nuclear Division engineers and follows paragraph 5.2 of NDP 200-1 1 which describes the process by the responsible party and their actio The design change request control form is called by the licensee a

Request for Design Change (RDC) and is Attachment B of NDP 200-1, which '

, provides for documentation of completed reviews, evaluations, and approvals prior to inplementing the change.. The method for assuring that the proposed design change does not involve an unreviewed safety question as described in 10 CFR 50.59 is handled by licensee procedure NDP 100-5,

! Preparation of Safety Evaluation '

NDP 200-1 provides for identification of the organizations or persons l responsible for performing design work, review of the status and adequacy

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of the overall design change, and final approval of the design change.

l The procedure provides for identifying, reviewing, and a) proving design

input requirements. It provides for design interfacing )etween different organizations and are established in writin

NPEP 100-3 provides for the training of personnel in the design change and modifications program procedures.

i i NPEP 200-11 provides the methods, procedures, and responsibilities for

] performing independent design verifications. This design review is a

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critical step to provide assurance that design documents such as

drawings, calculations, analyses, or specifications are correct and J satisfactory. The procedure provides for three verification methods l which are design reviews, alternate calculations, and qualification l testin .

! NPEP 200-14 provides for the format and content of the Detailed

{ Construction Package (DCP), methods for its control and implementation, and instructions for final disposition. This procedure provides the administrative direction for design document control for approved design change documents, recalling obsolete design change documents such as

~j revised drawings, and release and distribution of approved design change documents. This procedure provides the administrative controls to ensure i that design documentation and records, which provide evidence that the design and review process was performed, are collected and transmitted to records storag '

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Administrative controls and responsibilities have been established to assure that design changes will be incorporated into plant procedures, operator training programs, and plant drawings. These controls are established in A0-5-1 which provides that plant supervisors shall review system change descriptions to identify Plant Operating Manual (POM)

procedures that require revision. The supervisor is also to ensure that procedure changes required at turnover are available at completion of the plant design change. The walkdown and acceptance of DCPs is detailed in paragraph V.C. The walkdown is a verification of the installation and physical integrity of system mechanical, electrical, and structural components. Trojan Plant Engineering specifies the installation checks, inspections, and required testing prior to system turnover to operation The administrative controls necessary for temporary modifications (TMs),

lifted leads and jumpers are presented in A0-6-2. This procedure specifies that THs are controlled in a manner that ensures awareness of operators, conformance with design intent and operability requirements, and preserves plant and personnel safet A0-6-2 provides the controls for the review and approval of TMs in accordance with Section 6 of the Technical Specifications and 10 CFR 50.59. These controls require the use of detailed approved procedures when performing TMs, assign responsibility for approving these procedures, and require that a formal record be maintained of the status of TMs, lifted leads and jumpers, etc. In addition, controls are established which require evaluation of the need for independent verification of the installation and removal of TMs, lifted leads and jumpers; functional testing of equipment following installation or removal of TMs; and periodic reviews of lifted lead and jumper record Paragraph IV of A0-6-2 provides the instructions for TM initiation, evaluation, approval TM installation, and TM restoration to the original configuratio The licensee's design change and modification program appears to be conducted in accordance with regulatory requirements, and industry guides and standard No violations or deviations were identified in this inspectio . Follow-up on Previous Inspection Findings (Closed) Inspection Follow-up Item 86-23-16 Potential for Corrosion in Component Cooling Water (CCW) by chloride and review of reportability to NR The inspector reviewed follow-up item 86-23-16 which described the probability of chloride induced stress corrosion cracking in the componentcoolingwater(CCW)systemfromusingBetzOrocol-220.In a previous inspection report, the licensee found high chloride content (1.0-1.5 ppm) in the CCW system as a result of using improved analysis methods for coolant chemistry. The licensee determined that the CCW system operated between 1975 and 1986 with

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unknown chloride levels under the belief that the analytical test results of 0.15 ppm chlorides were accurate. The origin of the chlorides appeared to be the corrosion inhibitor use in Trojan's CCW system. In mid-1986 the licensee replaced the inhibitor with a new material believed to be free of chlorides. This was done via CCW feed and bleed over a two month perio The inspector reviewed a licensee letter from Jeff Carter to Gordon Rich, dated August 22, 1986 which evaluated the probability that chloride stress corrosion cracking of austenitic stainless steel components had taken place in the CCW system under its former chemistry control regime. It was concluded that the probability of such cracking in the presence of the inhibitor chemicals and the low chloride levels seen is very low. This letter presents a Japanese study which compiled data on 715 cases of stainless steel shell and tube heat exchangers. Examination of their graphs indicated that problems are not conson at the 1 ppm chloride level until temperatures approach 200 C. Based on the considerations given in the cases studied, the licensee determined the probability of chloride stress corrosion cracking in the CCW system has always been very lo Based on the inspector's review of the licensee's evaluation, it is decided that follow-up item 86-23-16 is close b. (Closed) Inspection Follow-up Item 86-23-18 Need to establish design basis of systems to validate training The inspector reviewed follow-up item 86-23-18 which described several errors in the licensee training documents 02-A-11-SD, and 02-A-11-HO. These errors were in the CCW system training documents and were corrected by the licensee on January 19, 198 Based on the inspector's review of the corrected training documents, follow-up item 86-23-18 is considered close c. (Closed) Inspection Follow-up Item 86-23-20 Cracked Areas in Masonry wall in battery rooms and HVAC ductwnrk During a previous inspection, the inspector noted six cracked areas in the masonry block walls surrounding station ESF battery rooms 39 ,

and 40 in the control building. The licensee informed the inspector thatperiodicengineeringtest(PET)-9-1requiresinspectionofall structures once every three years, and that the control building was inspected in April, 1984 and was to be inspected again before the end of April, 1987. At the time of that NRC inspection, the cracks observed had not been evaluated by the licensee, Upon notification, the licensee promptly documented the condition and initiated a review and evaluation, d

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During this inspection, the licensee had evaluated the masonry wall and conducted a calculation to verify if the wall was satisfactory as is. The calculation was reviewed and checked by the Nuclear Engineering Department and the conclusion was that the masonry wall was satisfactory as i Based upon the licensee's evaluation, follow-up item 86-23-20 is close . Exit Interview The inspector met with the ifcensee representatives denoted in paragraph i 1 on April 3,1987, and summarized the scope and findings of the inspection activities.

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