IR 05000344/1988039
| ML20248J260 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 04/04/1989 |
| From: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| Shared Package | |
| ML20248J264 | List: |
| References | |
| EA-89-016, EA-89-16, NUDOCS 8904140375 | |
| Download: ML20248J260 (4) | |
Text
- - - _ _ _ - _ _ _ _
i M tc
.
.if UMTED STATES T
NUCLEAR REGULATORY COMMISSION
,
o
,
[
f'
1450 MARIA LANE,SulTE 210
REGION V
^
-
WALNUT CREEK, CALIFoRNI A 94596
- + -
Docket No.
50-344 License No.
NPF-1 EA 89-16 Portland General Electric Company ATTN:
Mr. David W. Cockfield Vice. President, Nuclear 121 S. W. Salmon Street, TB-17 Portland, Oregon 97204 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY (NRC INSPECTION REPORT NOS. 50-344/88-39 AND 50-344/88-46)
This refers to the inspection conducted on August 8-12, October 24-27, and November 28 - December 1, 1988, at the Trojan Nuclear Plant, and inspection-related telephone conversations between Region V and your personnel on January 18 and 19, 1989.
The inspection focused on the implementation of your procurement and vendor interface program.
The reports documenting these inspections were sent to you by. letters dated September 13, 1988 and January 24, 1989.
During.
these inspections, violations of NRC requirements were identified.
The apparent violations, their causes, and your corrective actions were discussed with you during an enforcement conference held in this office on January 26, 1989.
The summary of the enforcement conference was sent to you on February 14, 1989.
The violations in the enclosed Notice of Violation and Proposed Imposition of j
Civil Penalty (Notice) involved failures to adequately assure the quality of installed materials.
Specifically, on numerous occasions in 1987, you o
{
purchased and installed c omercial grade replacement pipe, pipe fittings, and weld material in the saf..iy-related portion of the Main Feedwater System inside containment withect adequately evaluating the suitability of the materials for use in then,e applications.
You neither purchased the piping and welding materials from a vendor with a Quality Assurance (QA) program (
consistent with 10 CFR Part 50, Appendix B, nor performed adequate testing or i
examinations to verify the adequacy of the materials for the intended application.
Similarly, Violations 2 and 3 involve a commercial grade Agastat time delay relay installed in the diesel driven auxiliary feedwater pump system, and a commercial grade pressure regulator valve installed in the emergency diesel air start system for which proper evaluations were not made to assure their suitability in the intended applications.
Specifically, appropriate critical characteristics were not properly evaluated and, specified.
These violations resulted from deficient procurement practices similar to those that were identified by the NRC at your facility in 1985 and for which a previous notice of violation of NRC requirements was sent to you regarding procurement of commercial grade items.
Although several opportunities arose to do so, you failed to prevent this type of violation from recurring.
These opportunities included reviews of procurement practices by your QA and mechanical engineering group.
CERTIFIED MAIL
'
RETURN RECEIPT REQUESTED 8904140375 890404
- - -
P
- "
"
&c
_ _ _ _ _ _ _ _ - _ _ _ _ _
'
APR 0 41989
.
-
.
,
, -
Portland General Electric Company-2-In particular, we are troubled that your Nuclear Quality Assurance Department (NQAD) failed to recognize a number of very clear indications of problems in the procurement area, and that NQAD became so involved with the formulation of your procurement process that they stopped performing their intended function I
of providing critical and independent oversight of procurement activities.
In addition, following our inspection and in preparation for the enforcement conference held in part to discuss the status of the Main Feedwater piping, NQAD performed a review of those actions taken which would provide assurance that the piping was acceptable for service.
Du' ring and subsequent to the enforcement conference, it became clear that the NQAD review was incomplete, requiring further action by your engineering personnel to ascertain the accurate status of the piping.
This event has generally served to underscore our previous perception that your QA organization is not functioning as a demanding and critical oversight group.
To emphasize the need to maintain a strong independent Quality Assurance organization, and to properly evaluate and procure materials and equipment to be used in safety-related structures, systems, and components, I have been authorized, after consultation with the Director, Office of Enforcement, and the Deputy Executive Director for Nuclear Materials Safety, Safeguards, and Operational Support to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Seventy-five Thousand Dollars ($75,000) for the violations described in of the enclosed Notice.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, 53 Fed. Reg. 40019 (October 13, 1988) (Enforcement Policy), the violations described in the enclosed Notice have been categorized in the aggregate as a Severity Level III problem.
The base value of a civil penalty for a Severity Level III problem is $50,000.
The escalation and mitigation factors of the Enforcement Policy were considered.
With regard to your corrective actions, you changed your QA program and tested materials, but you failed to complete your QA review to ascertain the accurate status of the piping at the time of the enforcement conference. This demon-strates the failure of the QA department and management to clearly focus on this important issue.
Therefore, on balance neither mitigation or escalation is appropriate for this factor.
Because of the number of examples of procurement violations, 50% escalation of the base civil penalty was considered warranted.
The other factors of the Enforcement Policy were considered not applicable for the circumstances at Trojan in this case.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence.
After reviowing your response to the
.
Notice, including your proposed corrective actions ad the results o.f future l
inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirements.
l l
l l
--e;
.'
APR 04 nr.,
'
.
!
Portland General Electric Company-3-
.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Action of 1980, Pub. L. No.95-511.
Sincerely,
^
t1 p Regional Administrate Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty ec w/ enclosure:
T. D. Walt, General Manager, Technical Functions C. P. Yundt, General Manager, Trojan Nuclear Plant L. A. Girard, Vice President and General Counsel W. Dixon, DOE (Oregon)
.
,
.-.._
.
_
. _ _.
-
. - __ -__, - -..
'h-
'
H,m;,
%
,'
'
. _
,,
,'
.
,
.
.
.
>
>
,
( t..
- Portland General Electric. Company
"'
.
DISTRIBUTION!
- '
'
PDR-
,
'LPDR-
'
-SECY
.3 CA-
'
s HThompson,-DEDS
.'
- 4
.JMTay1or, DEDR
.
~
'
' '
JLieberman,~ 0E.,
.
- JBMartin, RV
,
q-
,
,
,.
- LChandler, ~ OGC ~
"
TMurley,' NRR-
_
,
'
'
SVarga, NRR 4 c'
^
,,
Enforcement Coordinato'rs
'
'
i RI,;RII, RIII, RIV,LRV.'
,
Resident Inspectot '
FIngram,,GPA/PA',
3, 7, > j.
.;
.
BHayesp OI
'
,
>
.
l FHerr,".01 A..
.4
'
>
<
EJordan,AEOD
,
,
,
HWong,~0EJ
.
,
OE: Chron '
"
'
.,
OE: EA '
]JMarkin.-
REG V/ dot-
'
pt
.*
AJo n.
MBlume.
DKir b =-
RZimmerman
-
4/i /
.
4/L{/89
.p/p/89 j/3n/89
'4/g/89 EST COPY ] hES / /REQt4ST-COPY ] TEh / NOREQUEST COPY ]@ REQUEST COPY
.
ST COPY-]
/YE$/ /
NO
]
NO
]/
-]
S) / NO
]NES/
]
v v
-
v TO PDR - ] '
/ NO
']
OE RA:RV OGC D:0E DEDS, HWong-JMartin LChandler JLieberman HThompson-3/ /89 3/ /89-
'3/ /89 3/ /89 3/ /89 i
,
____-_____D