IR 05000344/1985020

Insp Rept 50-344/85-20 on 850612-15 & 17-21.Violation Noted: Failure to Follow Procedures for Testing Relief/Safety Valves.Unresolved Item Noted:Incomplete Procedures to Implement SER & ASME Code Requirements

ML20135B365
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/27/1985
From:	Clark C, Compton R, Thomas Young NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20135B360	List: IR 05000344/1985020 ML20135B358 ML20135B363
References
50-344-85-20, NUDOCS 8509110009
Download: ML20135B365 (8)

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U. S. NUCLEAR REGULATORY COMMISSION RECION V Report No. 50-344/85-20 Docket No. 50-344 License No. NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 j Facility Nr.me: Trojan Inspection at: Rainier, Oregon Inspection conducted: June 12-15 and 17-21, 1985 Inspectors: e[ 89 Clark, Reactor Inspect Date Signed dA~$~D&, 4 '

E-?7- W lmpfon, Con u ; ant / / Date Signed

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Approved by: ~

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1  ?(Young, Jr. , Chi , Engine r g Section Date Signed Inspection during June 12-15 and 17-21, 1985 (Report No. 50-344/85-20)

Areas Inspected

This announced inspection consisted of a technical review of the program plan, procedures and records pertaining to the Trojan Inservice Testing program for pumps and valves. Inspection procedure 61700 was covere The inspection involved a total of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> onsite by one NRC inspector and one consultant.

, Results: In the areas inspected, one violation of NRC requirements was identified (failure to follow procedures for testing relief / safety i valves-paragraph 4) and one unresolved item was identified (adequacy of procedures to implement SER and Code requirements - paragraph 2 and 3).

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8509110009 850827 PDR ADOCK 05000344 0 PDR

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DETAILS Persons Contacted

• S. Orser, General Manager - Trojan

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

• D. Reid,' Manager - Plant Services-

• D. R. Keuter, Manager - Technical Services;

• F. C. Gaidos, Manager - Quality Assurance

• G. Kent, Plant Test Engineer

• G. Stein, Mechanical Supervisor - Maintenance -

R. Reinart, I&C Supervisor

• S. Richards, NRC Senior Resident Inspector

• Denotes those attending the exit interview on June 21, 198 The inspectors also interviewed other licensee employees, including members of the technical, operations, maintenance, I&C, and training

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staf . Inservice Testing (IST) Program Plan Inservice testing is required to be performed in nuclear power plants in accordance with the ASME Boiler and Pressure Vessel Code by 10 CFR 50.55.a(g). The ASME Code, Section XI, Subsections IWP and IW, outlines rules for inservice testing of pumps and valves. Amendment 2 to the

" Trojan Nuclear Plant Pump and Valve Inservice Testing Program", issued September 1982, is the document currently detailing the scope, implementation and administration of the IST program. This plan and relief requests from July, August and December 1982 were approved, with additional conditions and requirements, in a Safety Evaluation Report '

(SER) by the NRC Office of Nuclear Reactor Regulation (NRR) on March 14, 198 Implementation of the IST program at Trojan began in January 1981 to the 1977 Edition of the Code through the Summer 1978 Addend In September 1982, the applicable code edition was updated to 1980 through Winter 1980 Addenda. The initial 120 month IST period began on May 20, 1976 and

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extends through May 20, 1986. The program applies to 24 pumps in 10 systems and approximately 390 valves in 20 system The IST Program Plan (Amendment 2) and subsequent relief requests were reviewed for compliance with the applicable edition of the Code, the requests for relief detailed in the plan and the additional conditions imposed by the SE The inspectors consider that the program plan should be updated in a more timely manner to reflect in a consolidated way the approved relief requests, special conditions and additional requests imposed by NRR in the 2\ years since the issue of Amendment 2.

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The inspectors noted several instances where tests are not being performed as required and relief has not been requested. These instances are discussed in paragraph 3 of this repor There were no violations of NRC requirements identifie . IST Program Procedures The Trojan IST Program Plan is implemented through various site procedures. The following procedures were reviewed for compliance with the ASME Code, the IST Program Plan and 10 CFR 50 Appendix B requirements:

Administrative Order-AO-6-1, Rev. 14, " Periodic Surveillance" Administrative Order-AO-3-9, Rev. 20, " Maintenance Requests" Periodic Engineering Test-PET 9-4, Rev. 4, " Documentation of Inservice. Testing Data for Pumps and Valves" Various other maintenance and surveillance procedures related to pump and valve testin Site procedures correctly referenced the requirements of Section XI and the surveillance procedures included gauge identification number and calibration dates and provided acceptance criteria. The Plant Test Engineer (PTE) reviews test results, compares them to a current Data Log which reflects acceptance criteria for alert and action ranges, and determines component operability. This Data Log serves as the year's summary of test records for each component. If the results are out of tolerance, a Form PET 9-4-DB is written to docu:nent the condition and the recommended corrective actions. The following findings were identified in regard to site procedures:

' Section XI and PET 9-4 require the full range of instruments used for IST, to be no more than three times the reference value or les However, the following gauges used for IST exceed these limits:

(1) PI 601 and-602, Residual Heat Removal (RHR) pump suction pressure gauges, with reference values of approximately 25 psi; range 0-600 psi (2) PI 1953 and 1954, RHR pump discharge pressure gauges, with'

reference values of approximately,200 psi; range 0-1000 psi (3) PI 3733A-D, SW B tump-suction pressure gauge, with reference

values of approx rately'.13 psi; range 0-60 psti (4) PI 3044A and B, AfW pump suction pressure gauge with' reference values of approximately 12 psi;' range 0-100 psi,

, Section XI and PET 9-4 require pump, tests to be performed by setting either flow or differential, pressure at..the reference value and then determining the other parameters. The IST procedures for the

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Containment Spray, Component Cooling Water and Residual Heat Removal pumps do'not pre-establish either flow or differential pressure to a reference value. Tests are run at various conditions and results evaluated based on allowable range for each parameter. No relief request has been generated for this test approach. This test method may also be contributing to problems discussed in paragraph 4 of this repor Valve SF 51 is listed in the Program Plan as a Category "A" valve requiring leak testing. However, this valve did not appear in the 1984 outage report for'the containment Local Leak Rate Test result No other leak test procedure applies to this valv In a letter to NRR on December 9, 1983, the licensee committed to recategorize accumulator discharge check valves 8956A through D as

"AC" and perform leak testing in accordance with the Code. However, per Periodic Operating Test (POT) 2-4, these valves are only leak tested if the first check valves from the RCS leaks. As these first valves have not yet leaked, 8956e-D have not been leak teste Pressurizer power operated relief valves PSV-455A and $56 and Main Steam system air opera _ted relief valves CV-2210, 2230, 2250 and 2270 are not set pressure tested as required for relief valves by IW-351 Several problems were noted regarding safety and relief valve test procedures. Procedure MP-5-1 for Pressurizer Safety Valves was not clear as to what constitutes an unacceptable' test,.who determines ultimate corrective action and what actio'n is required (testing of additional valves). As found lift tests are not required to be performed for valves being repaired (September 1984 test of SV8010C). This defeats part o,f the purpose of Section XI testing; i.e., verification of operational readiness, and precludes taking corrective action to test additional valves if set pressure problems do exis .,. , ' _1,

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In addition, this procedure and MP-12-15, which" tests all.other

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relief values except Main Stesm, reliefs; 'allos averaging of lif t test values to determine. acceptability.~ <This. approach would allow two tests, both outside' of the specified set pressure tolerance, to be averaged to make a satisfactory test'. The'ASME Performance Test Code PTC 25.3-1976 which details the:re'quirement's for relief / safety valve testing does not address' test averaging. . ANSI /ASME OM-1-1981,

" Requirements for Inservice ^Per'fo'rmance-Testing of-Nuclear Power Plant Pressure Relief Devices", ' requires "a .minimumi of, two consecutise openings within, Code---tolerance" to dbmonstrate satisfactory repeatabilit ,, y Individually the above findings are not of great significance, but collectively they indicte that IST program proc,edures need to be reviewed to assure that all requirements of the IST program are being properly addresse .

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The licensee agreed to investigate the above findings to determine what actions need to be taken. Pending completion of the licensee's review, these apparent discrepancies between site procedures and the ASME Code and Licensee commitments will be identified as Unresolved Item (50-344/85-20-01) and will be examined on future inspection . IST Records o Various types of IST records for pumps'and valves were examined for conformancq to Code and site procedural requiremen'ts. The, inspectors m

noted significant and continuing improvements in the overall program conformance to requirements and' commitments and'in,the overall_t'est documentation in the last 18 months. For. example,:during 1982 and 1983, there were no pump test status and corrective action summ'aries as-required by Code. Also, prior.to 1984~the specified acceptance criteria for pump tests did not conform with-Code' guidelines and no justification was provided. This condition was. identified, evaluated and corrective action taken by the new PTE in Janu'ary 198 .

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In general, the inspectors considered that.the' documentation of corrective action, results of the action'and the closecut of

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unsatisfactory pump and valve <IST results'need to be improved to provide clear traceable records. In addition, licensee evaluation and improvement of the pump and relief valve test programs appears necessar Following are discussions of the specific inspection areas and observations for the review of pump and valve IST records:

• Pumps a

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The inspectors consider that the overall program for inservice

' testing of pumps needs to be analyzed and upgraded to assure that accurate and complete information required by Section XI is i

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provided. The fo11owing observations contribute to this general rencern:' ,

(1) In 1983, the results of over 70 pump tests were in the alert or action range. Although fewer unsatisfactory test results have been re' corded since 1983, the number is still high. Constantly placing pumps in a. alert or action status can lead to a desensitizing of personnal to test reaults being outside a

" normal"' range and possibly affect performance of necessary in depth evaluations' and corrective action '

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i (2) It appears that, in general, reference values are reestablished

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more frequently than normally observed and at times the new

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values are not representative of normal pump performance. For

) example, the new reference.yalue for flow on RHR pump "A"

' established April 25, 1985 was the second highest flow rate

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recorded for this pump in the last 20' tests. Conversely, repeated tests of Service Water Booster, Boric Acid and Diesel

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Oil Transfer, ' Service Water and Auxiliary Feedwater pumps were -

high for differential pressure and were accepted by the PTE based on pump curvW analysis. PTE written comments included W

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" low bareline" values. However, new reference values were not established in these cases. Uncharacteristically low reference values would tena to mask pump degradation. The reasons and justifications far reestablishing new reference values and applicable ranges are often not listed or specifi (3) The RHR pumps have not been operating at proper levels since 1982.- Twenty-one of 40 tests on pump "A" have been unsatisfactory, with eight tests in the " action" rang Actions taken to evaluate and resolve this problem are still continuing and no effective plan to promptly and decisively settle this issue is apparen (4) Problems with repeatability of tests and/or with meeting operability limits for the Boric Acid Transfer and Diesel Oil Transfer Pumps indicate possible procedural or instrumentation problems. The Diesel Oil Transfer pumps are operating at less than 50 percent of the manufacturers pump curve. Test report summaries by the PTE and PET 9-4-DB reports often contain references to " history of non-repeatability" and " historical instrument drift" and acceptance is repeatedly made based on pump curve analysi The pump test program needs a thorough engineering review to assure that the test procedures and existing instrumentation are providing the level of information needed. The findings identified in paragraphs 3a and b of this report are also related to this proble The review should also include the appropriateness of existing reference values and acceptance range The inspectors selected approximately 20 instruments used during IST to verify. range, accuracy and calibration record In addition to the problem with instrument range noted in paragraph 3.a. of this report, the inspectors found that gauge FI 2066 which has a two year calibration interval had last been calibrated on November 10, 198 Numerous "Out of Calibration" (000) Investigation forms had been generated by Maintenance. These forms require disposition by Engineering. Sixteen were over one year old and had not yet been dispositioned. Many of these 00C's dated back to 1984, e.g.,

Auxiliary Feedwater Pump Suction pressure gauge out of calibration August 17, 1984. Prompt evaluation of 00C's is necessary to determine if instrumentation errors could have affected surveillance tests and operability determination Valves Test- records for approximately 20 power operated valves were selected at random to verify that stroke times, test frequencies and necessary corrective action conformed to Code and procedural

. requirements. Two discrepancies were'note (1) The stroke time of valve CV-3004D2 was unsatisfactory on the November 1983 test. When the valve.was cycled again, the stroke time was just at the upper limit of 15 seconds. This

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second test was accepted by the PTE'. -Subsequently, this valve would not open at all on the first attempt during the next quarterly test. Valve stroke tests.;m,ust be evaluated and on the first attempt only to assure that results are effective for emergency condition operatio (2) The April 1985 stroke times. for HCV-606 and 607 appear to have exceeded the limit 125% of previous time, detailed in Section XI, Subsection IWV-3417. Test records do'not show any documentation of this deviation, or the Code required corrective action, to increase test frequencie ~

Test results were examined for valves addressed in th'e March 14, 1984 SER paragraphs II.C.4, 5', 8, 9,10 and 15 for which NRR invoked additional requirements. One problem was note The partial stroke test of SI-8956A through D is to be performed at each cold shutdown (not more frequently than 3 months) per the Program Plan. No test results exist for valves A, B and D from 1/25/83 through 4/29/84 although the plant was in cold shutdown mode until July 11, 1983 and the "C" valve was tested-in July 1983. Other tests and results examined were in conformance with requirement The records related to the testing of all 54 IST program relief and safety valves were examined. In addition to the concerns discussed in paragraph 3.f of this report, several problems were noted. Subsection IWV-3513 requires additional valves in a system to be tested if any valve fails. When Pressurizer safety valve PSV-8010C failed high on August 19, 1982 no additional tests were performed until a new PSV-8010B valve was tested acceptable on November 7, 1982. Pressurizer Safety Valve PSV-8010A was tested acceptable later on January 26, 1983. Component Cooling Water (CCW) System valve PSV-3323A failed a test in 1985 but companion valve PSV-3323B was not tested. -It is noted that both of these valves had failed their only earlier lif t tests in 1983. In addition, the Residual Heat Removal (RHR) system has four relief valves. During testing two valves (PSV-8709 & PSV-8856B) failed in 1982, one valve (PSV-8356A) failed in 1983 and two valves (PSV-8708 &

PSV-8856B) failed in 1984, without additional valves being teste Unsatisfactory relief / safety valve tests and required corrective actions are not documented in any clear, formal manner. The standard IST failure documentation, form PET 9-4DB, is.not used. In general, relief valve test documentation was found to be fragmented and hard to retrieve from the file The failure to perform relief / safety valve testing as required by the ASME Code. is an apparent violation of paragraph 4.0.5 of the Trojan Nuclear Plant Technical Specifications (50-344/85-20-02).

The overall adequacy of the pump testing program is considered part

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, of. Unresolved Item (50-344/85-20-01) and.will be evaluated'during

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future ~ inspectio . QA' Activities

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Quality assurance personnel were interviewed and audit or surveillance schedules were examined to determine QA activity related to IS Specific IST audits or surveillances have not been performed since 1981.

i Surveillances .of Relief Valve testing activities were scheduled for July , -

1985.

. Exit Meeting

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On June' 21, 1985, an exit meeting was conducted with the licensee j' representatives identified in paragraph 1. .The inspector summarized the

. scope of the. inspection and findings as' described in this report. .The ,

l licensee' committed to review the concerns identified with the IST program and take remedial action as require :

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