IR 05000344/1988039

Discusses Insp Repts 50-344/88-39 & 50-344/88-46 on 880808- 890119 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $75,000.Violations Involved Failures to Adequately Assure Quality of Matls

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: IR 05000344/1988039 ML20248J274
References
EA-89-016, EA-89-16, NUDOCS 8904140375
Download: ML20248J260 (4)

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o UMTED STATES NUCLEAR REGULATORY COMMISSION

REGION V

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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, 198 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, 198 Durin these inspections, violations of NRC requirements were identifie 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, 198 The violations in the enclosed Notice of Violation and Proposed Imposition of j Civil Penalty (Notice) involved failures to adequately assure the quality of o installed material Specifically, on numerous occasions in 1987, you

{ 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 application 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 applicatio 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 application Specifically, appropriate critical characteristics were not properly evaluated and, specifie 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 item 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 grou CERTIFIED MAIL

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RETURN RECEIPT REQUESTED 8904140375 890404

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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 activitie 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 pipin This event has generally served to underscore our previous perception that your QA organization is not functioning as a demanding and critical oversight grou 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 Notic 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 proble The base value of a civil penalty for a Severity Level III problem is $50,00 The escalation and mitigation factors of the Enforcement Policy were considere 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 issu 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 warrante The other factors of the Enforcement Policy were considered not applicable for the circumstances at Trojan in this cas You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your respons In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrenc After reviowing your response to the

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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.

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. 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 Roo 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. 95-51

Sincerely,

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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)

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