ML20042E288

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Forwards Revised Response to NRC Re Violations Noted in Insp Rept 50-344/89-12.Corrective Actions: Comprehensive Review of Util Nuclear QA Procedures 116 & 120 Performed
ML20042E288
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 04/13/1990
From: Walt T
PORTLAND GENERAL ELECTRIC CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9004200539
Download: ML20042E288 (3)


Text

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~M PDttiarid M MM April-13, 1990

. Trojan Nuclear Plant Docket 50-344t Licenne NPF-1 i

U.S. Nuclear Regulatory Commission--

-Attn: Document Control Desk Washington-DC 20555

Dear Sirs:

Revision to Notice to Violation Response Your letter of' August. 4, 1989 transmitted aLNo. ice of. Violation'(NOV)-

A associated with Nuclear. Regulatory _Comission _(NRC) Inspection Report. 50-344/89-12 to which we responded in a letter _ dated September 8, l;

1989 contesting Violation A of the inspection-report.

Discussions with the inspectors. associated with Inspection. Report 89-12'cnd'NRC. Region V, have brought; additional information into consideration. Based upon these discussions, Portland Ceneral Electric Company (PCE).has revised the original response-to Violation A.

The revised response is attached.

j Sincerely, I

T. D.. Walt l

Acting Vice President, Nuclear i

Attachment j

c:

Mr. John B. Martin Regional Administrator, Region-V U.S. Nuclear Regulatory Commission

'Mr. David Stewart-Smith State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector

.i Trojan Nuclear Plant I

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121 SW Sa! mon Street Portfarx!. Oregon 97204 -

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=c Trojan Nuclear Plant-Document Control Desk g

Docket 50-344 April 13, 1990 License NPF-1 Attachment Page 1 of 2 P

1:

REVISION TO A NOTICE OF VIOLATION RESPONSE Violation A Ticle 10 of the Code of' Federal _ Regulations,'Part 50 (10 CFR 50),

Appendix. B. Criterion IX, - requires that'special processes - such as quali-fication; certification, and. training of nondestructive: examination (NDE) personnel procedures shall comply with the requirements of applicable i

codes.and standards. -The Trojan Final Safety Analysis Report (FSAR),

Section 6, invokes American Society of Mechanical Engineers,(ASME) Code 1983 Edition and Addenda through Summer 1983.

Site Procedure MTS-9 AM-300, Revision 0, and ASME Section.V,' Paragraph'T-170, " Qualification.

of Personnel", establish SNT-TC-1A'(1980. Edition),." Recommended Practice

- for Nondestructivef Testing Personnel Qualification-andl Certification", as

.the requirement for NDE personnel qualification.

SNT-TC-1A (1980), Paragraph 8.3,' requires, "The written examinations-should bo. administered without access to reference material-(Closed-Book) except that necessary data,'such asugraphs, tables, specifications, procedures,. and ~ codes' may be provided."

contrary to the above,.the inservice Inspection (ISI)1 contractor training, qualification, and certification of NDE' personnel procedurel (MTS-QAM-300, Revision 0, Paragraph 8.1.3) states " Specific examinations chall cover equipment operating procedures, test techniques :and codosi that-the examiners may encounter in specific assignments.

The examina-tions may be administered as an Open Book Test".

The examinations given to ISI NDE contractors did not cover the required specific test areas, nor were the examinations' closed book tests. Reference material'was provided.to examinees that contained all' test answers.

This is a Severity Level IV violation.

I i

Response

Portland Ceneral Electric Company (PGE) acknowledges the violation.

1.

Reason for Violation:

The reason for the violation was personne1' error, failure to adequately review the ISI. contractors certification procedure, MTS-QAM-300 Revision 0, to ensure compliance to SNT-TC-1A requirements.

The contractors' written practice did not comply with the standard phraseology of SNT-TC-1A 1980 edition paragraph 8.3 1

whichl identifies the specific examination as a. closed bonk test except the necessary data such as graphs, tables, specifications,.

procedures,land codes may be provided.

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d Tcojan Nuclear' Plant ~

l Document Control _ Desk-g

" Docket _50-344 April 13,-1990 Licence NPF-1 Attachment

-Page 2 of 2 2.

Corrective Steps That Have Been_Taken and.the Results Achieved:

a.

The 1989 ISI contractor has been notified of the inappropriate phraseologyLin NTS-QAM-300 Revision 0 and.nas committed to revise their program-to achieve complianc9 with SNT-TC-1A and the responses v.o inquiries 89-1 and 89-2 from ATWT regarding'the availability of information to answer specific examination questions.

b.

A comprehensive review of._PGE's Nuclear Quality Assurance Procedures,(NQAP).116 and 120 has=been performed.

These certification procedures have been found to be in compliance-with SNT-TC-1A (1930 Edition) requirements.

c.

PGE has retained a new ISI~ contractor:for the 1990 Outage.

Certification procedures were. reviewed' March 9, 1990-to the requirements of. Administrative ~0roer (AO)l3-23, American Society of Mechanical Engineers-(ASME)'Section1XI Inservice and

-Preservice-Inspection, Section 4.10,-Vendor NDE Procedures to ensure' that they aro Plant specific and that questions and reference material are structured in keeping with the guidance provided by ASNT responses to letters of inquiry.89-l'and 89-2.

3.

The Corrective Steps That Will be Taken to Avoid Further Violations:

a.

No further corrective action is required.

4.

The Date When Full Compliance-Will be Achieved:

Full compliance has been achieved.

PGE certification procedures and ISI contractor certificatio. procedures-have been reviewed and are in compliance with code requirements.

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