IR 05000344/1988026
| ML20151T077 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/28/1988 |
| From: | Richards S, Wagner W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20151S925 | List: |
| References | |
| 50-344-88-26, NUDOCS 8808160249 | |
| Download: ML20151T077 (5) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No:
50-344/88-26 Docket No:
50-344 License No:
NPF-1 Licensee:
Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204 Facility Name:
Trojan Nuclear Plant Inspection at:
Rainier, Oregon Inspection conducted:
June 6-10 and June 14-17, 1988 Inspector:
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,neering Sectten Summary:
Inspection During the Period of June 6-10 and June 14-17, 1988, (Report 50-344/88-26)
Areas Inspected:
Routine, unannounced inspection by regional based inspector of commercial grade procurement and Inservice Inspection activities.
NPC Inspection Procedures 30703, 38703 and 73753 were covered during this inspection.
Results:
Of the areas inspected, two violations were identified; use of an unapproved procedure (paragraph 2.a) and failure to provide procedures prescribing the engineering evaluation process (paragraph 2.c).
8808160249 880729 PDR ADOCK 05000344 Q
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DETAILS
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1.
Persons Contacted
- C. A. Olmstead, General Manager
- J. D. Reid, Manager, Plant Services
- J. K. Aldersebaes, Manager, Plant Modifications
- C. Brown, QA Operations Branch Manager
- 0. Wheeler, QC Supervisor
- 0. W. Swan, Manager, Technical Services
- 0. L. Nordstrom, Compliance Engineer
- L. Erickson, Manager, Nuclear QA Department
- G. Zimmerman, Manager, Nuclear Regulation Branch
- T. Walt, Manager, Nuciear. Safety and Regulation
- G. Kent, Supervisor, Surveillance and Testing
- M. Schwartz, Manager, Surveillance and Testing
- J. Duhe, PM/EA Evaluator
- Attended the Exi t Meeting on June. 10, 1988.
- Attended the Exit Meeting on June 17, 1988 The inspector also held discussions with other licensee and contractor personnel during the course of this inspection.
2.
Inservice Inspection - Observation of Work and Work Activities Inservice Inspection (ISI) activities were previously observed and documented in NRC Inspection Report No. 50-344/88-18.- That report identified certain weaknesses in implementation of the ISI program develop *d for the second 10 year inspection interval. The purpose of this insoection was to evaluate the effectiveness of the visual'
examinatic. program in meeting the requirements specified in Section XI of the ASME Boiler and Pressure Vessel Code.
a.
Review of Visual Inspection Procedures The licensee's Quality Control Procedure (QCP) utilized for visual examination of nuclear power plant components and their supports is QCP-34 entitled "Visual Examination." On May 25, 1988, the Engineering Department issued memorandum JM-004-88M for use in conjunction with
"P-34.
The purpose of this memorandum was to
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provide guidance to QC inspectors for visual examination of ASME fcction XI pipe supports.
During this outage, the QC inspectors v ere using the acceptance criteria provided in this memorandum.
This memorandum constitutes a revision to QCP-34 and consequently should not have been issued without receiving proper approval.
QCP-1 entitle "Administrative Control of Quality Control Procedures (QCPs)",Section I states that revisions to QCPs shall receive the same review and approval as the original.
The use of an unapproved procedure for visual examination of pipe supports is an apparent violation of 10 CFR 50 Appendix B, Criterion V (50-344/88-26-01).
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The inspector also recognized that this memorandum contained visual welding acceptance criteria identical to that described in NCIG-01, Revision 2.
NCIG stands for the Nuclear Construction Issues Group which in Volume 1 provides "Visual Weld Acceptance Criteria for
~ Structural Welding at Nuclear Power Plants." NCIG-01 was conceptually approved by the NRC in 1985. This meant.that.any licensee desiring to use NCIG-01 had to submit a formal request, along with an explanation of intended application, to the NRC for approval, prior to use.
In May 1988, Regulatory Guide 1.84 Revision 25 endorsed Code Case N-430 which contains visual weld acceptance standards from NCIG-01. However,-the licensee informed the inspector that Trojan is not an ASME Code built plant and.
therefore cannot use the Code case.
The inspector recommended the licensee submit, to the NRC, a proposed change to the appropriate section of the FSAR describing where they are planning on applying NCIG-01; and that continued use of NCIG-01 was at their own risk pending NRC approval. During the exit meeting on June 10, 1988, the licensee said they would submit a formal request and use the guidelines of NCIG-01 in the interim.
b.
Visual Inspector Qualifications The inspector reviewed the qualification and certification records of the contractors performing the visual examinations of the comp ~ mt supports. QC ir cetion were provided by the Basin Engineering Services, Int
- asin) and by Townsend and Bottum Services Group, Inc. The sonnel records reviewed, four from e
Townsend and Bottum as: six from Basin, revealed the QC inspectors were qualified in ac urdance with the comparable levels of competency as defined in ANSI N 45.2.6 entitled "Qualifications of Inspection, Examination, and Testing Personnel for Nuclear Power Plants." The records also indicated that the licensee performed a 100% verification of the qualifications and certifications of all Basin QC inspectors, such as previous certifications, employment history and training. These verifications were perfomed because Basin provided pre-qualified Level II QC inspectors for the visual examinations, c.
Data Review and Evaluation The purpose of this review was to ensure that QC inspector findings, which are identified on Visual Examination Reports, were being adequately addressed and dispositioned.
The inspector reviewed approximately 100 VT-3 inspection reports. VT-3 are visual examinations conducted to determine the general mechanical and structural conditions of components and their supports. Of the 100 reports reviewed, the following 14 identified significant discrepancies such as missing welds, incomplete welding, loose nuts and missing bolts: VT-3 report numbers 182, 197, 201, 208, 225, 239, 246, 249, 253, 259, 269, 273, 282 and 286. This effort revealed two important observations.
First, all flagged QC inspector items, identified on the visual examination report, were acceptably addressed by the onsite engineering department. Written justification was provided for use-as-is or rework, and in some
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instances the design evaluations were referenced.
There was no evidence of unacceptable evaluations of identified problems.
These evaluations are documented on the original visual examination report.
submitted to engineering by the QC department.
The second observation was noted when reviewing the sequence of events leading up to, and resulting in an engineering evaluation.
QCP-34 Revision 2, issued June 4, 1988, added the requirement that "when abnormalities or relevant indications are present, the VT Report form shall be forwarded to the appropriate engineer for evaluation."
From this point on, there are no written procedures or instructions prescribing how the engineering evaluation process is accomplished.
As described to the inspector, the VT-Reports are hand-carried by QC to onsite engineeriug, engineering performs the evaluation and subsequently notifies QC upon completion of their review.
The engineering evaluations were performed without a procedure addressing important quality activities, such as identification of reviewer responsibilities, specifying an appropriate acceptance criteria, and how the evaluations are resiewed for adequacy, approved for release by authorized personnel, and distributed to QC.
Failure to provide procedures addressing the engineering performed evaluations of QC identified discrepancies is an apparent violation of 10 CFR 50 Appendix B, Criterion V (50-344/88-26-02).
d.
Disposition of Nonconforming Reports lhe inspector reviewed several nonconforming reports (NCRs)
resulting from VT-3 inspections that identified miscellaneous loose or missing parts.
Seventeen of the NCRs were disposition either
"use-as-is" or "not honconforming" by the QA Operations Branch Manager.
Justification for these dispositions were provided to the inspector.
Each NCR was supported by an engineering evaluation of sufficient detail to adequately explain the technical basis for the applicable disposition.
3.
Commercial Grade Procurement The inspector reviewed the licensee's program for procuring commercial grade items for intended use in safety-related applications.
Procurement of commercial grad 9 items are based on an engineering evaluation conducted in accordance with NDP 200-3 antitled "Evaluation of Commercial Grade Items" issued February 16, 1986.
These items are designated as Quality Level Code C.
Six vendors that have supplied C materials utili.;ed in safety-rblated applications were selected foh review.
The inspector was unable to review these procurement documents during this inspection.
Therefore, verification that these items were properly dedicated as acceptable for nuclear safety-related applications will be performed during a future inspection.
This is an open item (50-344/88-26-03).
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4.
Exit Interview The inspector met witle the' licensee representatives, denoted in paragraph 1 on June 10 and. June 17, =1988..< The scope-of the inspection and the inspectors' findings as.noted in this report were discussed.
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