IR 05000344/1989010

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/89-10. Corrective Actions Will Be Verified During Future Insp

ML20247C528
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/14/1989
From:	Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8907240374
Download: ML20247C528 (1)

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' Docket No. 50-344-Por'tland General Electric Company-4121~S.lW. Salmon Street Portland, Oregon 97204 Attention: Mr.' David N. Cockfield Vice President, Nuclear Thank you for your letter of July 5,1989, in respoNsehto our Notice of.

,LViolation and Inspection Report No. 50-344/89-10, dated ~ June-5, 1989, informing us of the steps you have taken to correct the items'which we brought to your attention. .Your corrective-actions will be ' verified during a future.

inspection.

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f Your cooperation with'us is appreciated.

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Sincerely, g

M.' M.

h ndonca EAct g' Chief Reactor Projects Branch

, bec,w/ copy of letter 7/5/89:

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, A. Johnson .)

G. Cook l B. Faulkenberry 6

! J. Martin- l'

.I Resident, Inspector

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.- PortlandGeneralElectricCompany 7 L. ,, o, David W. Cockfield Vice President, Nuclear ,

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~ s. 7 t9: 55 July 5, 1989 Trojan Nuclear Plant Docket 50-344 License NPt-1 ,

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

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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 Attachment 1 to this letter.

Sincerely,

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Attachment i c: 'Mr. John B. Martin <

Regional Administrator, Region V U.S. Nuclear Regulatory Commission

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Mr. William T. Dixon  !

State of Oregon  ;

Department of Energy '

Mr. R. C. Barr NRC Resident Inspector -

Trojan Nuclear Plant

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Trojan Nuclose Plant Documsnt Controf Dssk.

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Docket 50-344 Attachment 1

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License NPF-1 July 5, 1989 Page 1 of 4 Response to Notice of Violation violation A

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Technical 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 and applicable addenda. ,

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In implementation of this requirement, Licensee Topical Report PGE-1048 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 amplitude was performed for inservice tcsting 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 Portland General Electric (PGE) acknowledges the violation.

1. Reason for the violation.

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) Program 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 probe were calibrated as an assembly to plus or minus 1.0 mil on a 0-10 mil scale. The acceptability of using this instrument for the IST was based on its full-range .'

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capability (0-100 mils in eight overlapping ranges). The'ASME Section XI, Article IRP-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 Secticn 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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. .. Trojan Nucletr Pltnt Document Control D:sk Docket 50-344 Attachment 1 License NPF-1 July 5, 1989 Page 2 of 4 Training on the ASME Code requirements for nuclear pumps and valves 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.

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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 has 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 after 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 PCE Surveillance and Test Department has ordered, and 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 evalucte 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 schieved.

Full compliance for vibration instrumentation accuracy was achieved on May 22, 1989.

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Trojan Nucle:r Plcnt

• Document Control D ck Docket 50-344 Attachment 1 License NPF-1 July 5, 1989 Page 3 of 4 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, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings". -

Administrative Order A0-3-6, titled " Conduct of Operations-Shift Records". Revision 17, dated March 3, 1988, requires, in part, that contfoi room los entries shall include entry into a different mode.

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 is a Severity Level V violation (Supplement I).

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Response Portland General Elcetric (PGE) acknowledges the violation. I l

1. Reason for the violation.

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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 log 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 logged, 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 discussed with the individual omitting the log entry.

B.

A deviation was issued to Plant Shutdown Procedure General Operating Instruction (G01)-3 to remind the control operator to log the entry to Mode 2 when the Plant reaches a power level of less than 5 percent.

C. The procedure for Plant startup, G01-2, was reviewed. It was .

noted the point-of-entry to Mode 2 during a reactor startup was not clearly defined.

A revision has been issued to GoI-2 to define this transition point and to remind the control operator to make the appropriate log entry.

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a Docket 50-344- Attachment l'

. License NPF-l' July 5, 1989:

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3. The corrective stept. .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.

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l 4. Date when fu11' compliance will be achieved.

Full compliance has been achieved.

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RMN/SAB/WJW/mr 3248W.0689 ~

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