ML20244B849

Responds to 890514 Request for Addl Info Re Installed commmercial-grade Item review.Electrically-related & mechanically-related Components & Hangers & Supports Will Be Dispositioned Following Restart from 1989 Refueling Outage

ML20244B849
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/02/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
NUDOCS 8906140004
Download: ML20244B849 (12)

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Portland General MCoi,arsry ;9 E U( sums .r: ..-1V n

David W. Cockfield Vice President, Nuclear pq r.

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J Pl, y June 2, 1989 Trojan Nuclear Plant Docket 50-344 License NpF-1 John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Creekside Oaks Office Park 1450 Maria' Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Martin:

Installed Commercial-Grade Item Review As requested by Nuclear Regulatory Commission (NRC) letter dated May 14, 1989, attached is additional information regarding the review of installed commercial-grade items being performed by Portland General Electric Company. This information supplements the description of the installed commercial-grade item review provided by our April 28, 1989 Reply to a Notice of Violation concerning commercial-grade procurement.

Sincerely, t

U d' Attachment b c: Document Control Desk  !

. N(oc U.S. Nuclear Regulatory Commission

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'00 Washington DC 20555

$$ Mr. William T. Dixon

,s.y State of Oregon

$8 Department of Energy 1 OO .

l ~:Y Mr. R. C. Barr

! jg NRC Resident Inspector

,g Trojan Nuclear Plant gQf '

a s w saem street Ponmd oream 97204 '

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• Trojtn Nuclear Plant Mr. John B. Martin Docket 50-344 Attachment A.

' License NPF-1 June 2, 1989 Page 1 of 7 INSTALLED COMMERCIAL-CRADE ITEM REVIEW INTRODUCTION To support the preparation of the Justification for ~:ntinued Operation (JCO) for commercial-grade procurement issues (JCO' bd - * , originally submitted on November 29, 1988 and revised on February 17, 1989, a review l

of commercial-grade items issued from the warehouse between January 1986 and November 1988 was performed to ensure functional adequacy of the items.

Portland General Electric Company (PGE) is performing an additional review and evaluation of items installed between September 1, 1985 and December 1, 1988 to verify and document the original review and to dedicate those commercial-grade' items installed in safety-related applications. This review and overall evaluation process was described in detail in our April 28, 1989 Reply to a Notice of Violation (NOV) on commercial-grado procurement.

By letter dated May 16, 1989, the Nuclear Regulatory Commission (NRC) requested the following additional information regarding this review and evaluation process of installed items:

1. Summary of results to-date of the review and schedule for replacement of parts.

2. Action to expand the review based on the results to-date.

3. Justification for dispositioning active safety-related components following restart from the 1989 refueling outage.

The information presented belcw supplements the description of the installed commercial-grade itam review provided by our April 28, 1989 NOV response.

1. RESULTS TO-DATE/ SCHEDULE FOR REPLACEMENT of the 1140 Maintenance Requests (MRs) to be dispositioned prior to restart from the 1989 refueling outage, 954 have been dispositioned as of May 26, 1989. A description of how these items have been dispositioned is provided below and is summarized in Table 1. ,

I American Society of Mechanical Engineers (ASME)

Section XI Pressure-Boundary _(PB) Components of the 738 MRs in this group, 649 have teen dispositioned to-date.

Of the 649, 543 have been deferrod to post-outage completion. The reason for the deferral is that these 543 MRs are exempt from ASME Section XI requirements per Subparagraph IWA-7400, " Items Exempt From Requirements of This Article". These MRs were given additional

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Trojen Nuc1 car Plant Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 June 2, 1989 Page 2 of 7 review to determine the types of active components in this category, l) as discussed in Section 3. Typical items in this category are I

gaskets, packing and 1-inch and smaller tubing,' valves, piping and fittings.

One MR was dispositioned by Nonconformance Report (NCR)86-220.

The NCR is a means to document, control, and disposition nonconforming materials, parts and components. This includes notification of affected departments and assignment, approval, and verification of corrective actions.

This NCR, along with Spare Parts Equivalency Evaluation Report (SPEER)88-076, addrescos the heat exchangers for the centrifugal charging pump lube oil and gear reducer oil coolers and the safety injection pump lube oil coolers. The purpose of the SPEER is to evaluate whether a replacement part or material, not of original design, is equivalent to the original, and to determine subsequent action to be taken.

Final action to resolve NCR 86-220 will be replacement of the heat exchangers, as noted in Table 2. This is scheduled for completion during the 2990 refueling outage. Operation with the installed heat exchangers has been evaluated and determined to be acceptable. No other NCRs have been originated for PB group items.

The remaining 105 MRs were dispositioned by identifying and verifying the item's critical characteristics or determining that the item did not provida a safety function or affect the function of safety-related equipment.

There are 89 MRs remaining to be dispositioned prior to restart from the 1989 refueling outage.

Environmental Qualification (EQ)

Of the 348 MRs in this group, 267 have been dispositioned to-date.

Further review determined that 13 MRs were actually for non-EQ applications and the MRs were deferred to post-outage completion.

Four MRs have been dispositioned by replacing Limitorque torque switches during the 1989 refueling outage, as noted in Table 2.

This work had already been planned for this outage as a result of concerns with Limitorque's control of subvendors.

One new NCR is being generated because two spring packs in Limitorque valve actuators that were not exact replacements were e installed without a SPEER being issued. Although Limitorque MRs are being reviewed as part of the EQ group .this NCR addresses mechanical items that are outside the scope of Title 10, Code of Federal Regulations, Part 50.49, " Environmental Qualification of Electric Equipment Important to Safety for Nuclear Power Plants".

This NCR is currently under evaluation and will be dispositioned prior to restart from the 1989 refueling outago.

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I" Trojen Nuclear Plant Mr. John B. Martin Docket 50-344- Attachment A License NpF-1 June 2, 1989

,, Page 3 of 7 Tho remaining 248 MRs were dispositioned by identifying and verifying the item's' critical characteristics, determining.that the item did Lnot provide a safety function or affect the function of safety-related equipment, or determining that the item was not required to o

maintain the environmental qualification of the c'mponent.

There.are 81 MRs remaining to be dispositioned prior to restart:from the 1989 refueling outage.

Seismically Sensitive Electromechanical Equipment (Seismic) l Of the 54 MRs in'this group, 38 have been dispositioned. Further review determined that 4 of these MRs were actually for non-seismic ~

applications and the MRs were deferred to post-outage completion.

l Table 2 identifies items from 18 of the MRs that'will be replaced,

.and their schedule for replacement.

The remaining 16 MRs were dispositioned by reviewing the safety-related function of each item and determining the impact of a

' seismic event, or determining that the item did not provido a safety function.or affect the function of sa'lety-related equipment. The non-seismic critical characteristics have been verified by post-l- irastallation, tests,' periodic surveillance tests and normal operation.

Documentation of these critical characteristics will be completed by October 31 ,1989.

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l. The 16_ MRs for which dispositj oning is in progress hav.s been .

i evaluated in sufficient depth to judge the items acceptable. The documentation for these items will be completed prior-to restart from the 1989 refueling outage.

E' 2. REVIEW SC0pE l~

lg Based on the fact that all replacements identified to-date as a

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result of the installed commercial-grade item review are being made

'because of insufficient documentation only, it has been determined th'at it is not necessary to expand the scope of the overall review

/ to MRs issued prior to September 1,1985. ' The replacement items are l identified in Table 2.

The se pe of the review has been expanded for specific cases, as noted below.

A review of safety.-related molded-case circuit breakers was performed in response to NRC Bulletin 88-10, " Nonconforming Molded-Case Circuit Breakers". This study covered a period from August 1, 1983 to present. One breaker of 147 safety-related breakers procured in that time frame was not traceable to the original manufacturer. This breaker is being replaced as noted in Table 2.

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[. Trojan Nuclear Plent Mr. John B. M2rtin D6cket 50-344 ' Attachment A License NPF-1 June 2, 1989 Page 4 of 7 In addition, ,all commercial-grade 7000 and 2400 series Agastat relays in safety-related applications are being reviewed. This action was initiated in response to NRC Information Notice 87-66, " Inappropriate Application of Commercial-Grade Components". An NCR has been initiated to ensure these items will be properly dispositioned (i.e.,

operability assessment or replacement) prior to restart from the 1989 refueling outage.

If further review identifies an increase in the number of non-conforming or indeterminate items or a need for replacement for reasons other than documentation, expansion of the scope will be considered.

3.' ACTIVE CCKPONENTS TO BE DISPOSITIONED FOLLOWING RESTART 2n addition to the 560 MRs referenced in the "Results" section

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( ASME Section XI exempt, 13 non-EQ and 4 non-seismic MRs), 740 other MRs will be dispositioned following restart from the 1989 refueling outage, but prior to October 31, 1989. These 1300 MRs have been divided into the following categories of items:

Electrically-Related 270 (plus 13 non-EQ and 4 non-(non-harsh EQ) Components seismic from above)

Mechanically-Reinted 152 (plus 543 Section XI exempt (non-PB) Components from above)

Hangerr and Supports 200 Emergency Diesel Generator 118 Components To develop a level of confidence that active components in these groups will perform their intended safety function, MRs were reviewed

/ from each of the categories, and the commercial-grade items and their applications were identified.

Of the 287 electrically-related MRs, 92 hare reviewed in detail; of 695 mechanically-related MRs, 120 were reviewed in detail; and of the 118 emergency diesel generator NRs, 43 were reviewed in detail. The hangcr and support group was not reviewed since this group does not contain any active components.

The active components identified as a result of this sampling and the justification for deferring these items until after restart is provided in Attachment B. These examples of active components are representative of the types of components found in the group of 1300 MRs deferred to post-outage completion. These items are

Trojtn Nuclo!r Plant. Mr. John B. Martin Docket'50-344 Attachment A j

!icense NPF-1 June 2, 1989 Page 5 of 7 c

typically items whose post-accident environment is no more severe than normal operation and whose operability hae been verified by periodic surveillance and post installation testing. Based on this review, PCE is confident thot startup and.oporation prior to disposition of these Es will not adversely affect safe operation of the Trojan Plant.

The passive corponents are identified in Attachment C. A justification for deferring these items until after startup from the 1989 refueling outage is also provided.

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L , 'e : g Trojan Nuclecr 'Plent Mr. John B. Mzrtin Docket 50-344 Attachment A

l. License NPF-l' June 2, 1989 l Page 6 of 7 TABLE 1

SUMMARY

OF PRESSURE BOUNDARY (PB), ENVIRONMENTAL QUALIFICATION (EQ) AND SEISMIC MAINTENANCE REQUEST (MR) REVIEW

Category of MR l Number of MRs PB EO Seismic TOTAL Total MRs 738 348 54 1140 MRs Dispositioned 649 267 38 954 By Nonconformance Report 1(4) 2 18(4) 21 Critical characteristics 105 248 16 369 verified'cr deemed non-safety-related Post-outage deferral 543(1) 13(2) 4(2) 560 Other - 4(3) _ 4 MRs. remaining to be dispositioned 89 81 16 186 prior to restart from the 1989 refueling outage NOTES:

(1) Exempt per ASME Section XI Subparagraph IWA-7400 (2) Non-EQ and non-seismic applications ,

i (3) Previously scheduled replacement of Limitorque torque switches j (4) Replacement items identified in Table 2 PGN/3129W,0589 l

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Trojen Fucisar Plent Mr. John B. Martin Docket 50-344 Attachment A License NPF-1 June 2, 1989 Page 7 of 7 TABLE 2 INSTALLED COMMERCIAL-CRADE ITEM REVIEW REPLACEMENT ITEMS Equipment Make/Model Number / Schedule Function Seismic Breaker (I) ITE/HE3-A005 1/before restart 480-V Motor Control Center (MCC)

Relay Agastat/7000 1/before restart Diesel generator control, Series 32/later(2) solid-state protection system (SSPS), Residual Heat Removal (RHR) indi-cation, feedwater control.

Relay (3) ' Square D/' 14/before restart Diesel generator control.

Type KPD13 Environmental Qualification Torque Switch Limitorque 4/before restart Motor Operator Valve l 6/later (4) Control l Pressure Boundary Heat Exchanger Ross/ITT 1/later(5) Oil coolers for Safety Standard Injection and Centri-fugal Charging Pumps NOTES:

(1) Equipment supplier is now Telemecanique.

(2) The operability assessmo vi s.1 L 4 completed prior to restart.

Replacement based on, materia

• ree',;1bility, but no later than 1990 refueling outage.

(3) Equipment supplier is now Morrison-Knudsen.

(4) Justification for Continued Operation (JCO)88-005 addresses continued operability and replacement by December 31, 1990.

(5) Nonconformance Report (NCR)86-220 addresses continued operability.

Replacement is scheduled for the 1990 refueling outage.

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~ Trojen Nuclear Plent Mr. John B. Martin Docket 50-344 Attachment B License NPF-1 June 2, 1989 Page 1 of 3 ACTIVE COMPONENTS Based on the sampling of the' electrically-related, mechanically-related and emergency diesel generator MR groups, the following active components were identified. The justification for dispositioning these items following restart is provided.

Part Description Justification Emergency Diesel Generator

• Installed in July 1986.

Air Start Motor

. Original equipment manufacturer supplied identical replacement part certified to be equal to or better than the original.

. Operability verified following installation.

+ Periodic surveillance testing has been performed since installation.

Diesel Auxiliary Feedwater + Installed in November 1986.

Pump Turbocharger

+ Identical replacement part supplied by original equipment manufacturer from the recommended parts list.

+ Operability verified following installation.

• Periodic surveillance testing has been performed since installation.

Emergency Diesel Generator + Installed in May 1986.

Soakback Lube 011 Pump

• Identical replacement part supplied by original equipment manufacturer from the recommended parts list.

Operability verified following installation.

+ Periodic surveillance testing has been performed since installation.

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g . Trojan Nuclear l Plant- Mr. John'B. Martin-Docket.50-344 Attachment B License NPF June 2, 1989 Page 2'of 3 l \

Part Description Justification o

Bearings, e.g., '

+ Bearings are standard parts used'univers-Service Water Pump, ally in many. industries and are only avail-Component Cooling Water ~ - able on a commercial basis.

Pump, "A" Auxiliary Feedwater + Manufactured to many other non-nuclear Pumpf industry standards and specifications.

• Post-installation testing verified proper g installation and operation. Continued L operation and surveillance testing verifies

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continued satisfactory operation.

Valve Stems and. + Post-maintenance functional testing of all Diaphragms' air-operated.and motor-operated valves.

• Automatic isolation valves are installed redundantly on the process line to minimize the effect of single component failures. , ,

Valve ~ Disks

• Post-maintenance functional testing of.

all air-operated and motor-operated valves.

• Automatic isolation valves are installed redundantly on the process-line to minimize the effect of single component failures.

. Leak testing is performed following maintenance involving the' valve seating areas to ensure the required leakage criteria is met.

Pump Shafts, e.g., + Post-maintenance functional testing veri-Boric Acid Transfer Pump, fies the proper operation of each pump.

"A" Auxiliary Feedwater This includes an operational check as well Pump as vibration analysis.

+ Periodic surveillance testing ensures the pump shaf ts perform their design function.

• Actual accident conditions are not more severe than routine surveillance testing conditions.

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i Troj:n tuelser Plant Mr. John B. Martin Docket 50-344 Attachment.B License NPF-1. June 2, 1989 Page 3 of 3 1

Part Description Justification Pump Shafts, e.g., (cont) +RPumps are designed redundantly to minimize the effects of any single shaft failure.

+ Pump shafts in active safety-related applications are not materially different from those used in other multi-industry applications.

Pump Impe11 err, e.g.,

• Post-maintenance funct?onal testing veri-

"A" Auxiliary Feedwater fies the proper operation of each pump.

Pump This includes verification of proper flow rates and vibration analysis.

+ Periodic surveillance testing ensures the pump impe11ers perform their design function.

• Pumps are designed redundantly to mini-  !

mize the effects of any single impeller failure.

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,. Docket 50-344- Attachment C l License NPF June 2, 1989 Page 1 of 1 PASSIVE COMPONENTS The sampling of the electrically-related, mechanically-related and emergency dinsel generator MR groups idantified the following examples of passive components. Deferral of these items is justified, since they do not perform an active safety function or prevent an active component from performing its intended safety function. In addition, installation of these items is controlled by approved installation standards, maintenance procedures and vendor manuals.

Wire and cable Wire connectors Heat shrink tubing Electrical tape Tie wraps Terminal blocks Fuse blocks Unistrut fasteners Conduit and fittings Anchor bolts Grout Junction boxes Structural metals Lubricants Resistors  !

Capacitors Diodes Fuses '

Integrated circuits Potentiometers Printed Circuit boards Power supplies Overload heaters Adhesives Transformers Fasteners Light bulbe Fire-break foam Chart paper In-line snubber Gauges Gaskets Tubing Packing Wolding rod Seals Tube fittings Relay base Sealants 0-Rings Filters Pressure cap Springs Fuel injector Regulator kit Valve seat Relief valves Manual isolation valven Valve repair kit Caulk Lamp holders Mechanical seals Flashers Key stock Cotter pins Deferral of these items may also be justified for one or more of the following reasons:

1. Post-installation testing exposes the item to its worst-case oper-ating conditions (i.e., not EQ or seismically sensitive equipment).

2. The items / components undergo surveillance testing to periodically verify their proper operation.

3. The items have simple critical characteristics controlled by the manufacturer and verified by receipt inspection / installation.

4. The commodity items are only available commercially or were procured from the original equipment manufacturer. 2

5. The items are manufactured to other industry standards (i.e., Under-writers' Laboratories (UL) listings, military specifications, American Society for Testing and Materials (ASTM), etc.).

6. The material testing program has evaluated a large number of these items (i.e., f asteners) .

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