ML20126A883
| ML20126A883 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/14/1992 |
| From: | Cross J, Robinson W PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212210278 | |
| Download: ML20126A883 (3) | |
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Portland General Electric Company James E. Cross Vice President and Chief Nuclear Officer December 14, 1992 Trojan Nuclear Plant Docket 50-344 Licence NPF-1 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington DC 20555
Dear Sirs:
Reply to a j{ctice of Violation Your letter of November 13, 1992 trancmitted a Notice of Violation associated with Nuclear Regulatory Comialssion Inspection Report No. 50-344/92-29.
Attachment A to this letter contains Portland General Electric Company's response to the violation.
Sincerely, W. R. Robinson for J. E. Cross Attachment c:
Mr. John D. 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 Trojan Nucicar Plant 9212210278 921214 PDR ADOCK 05006344 O
PDR g
121 SW Salmon Street. Portland, OR 97204 i
503/464-8897
r' Trojan Nuclear Plant Document Control Desk-Docket 50-344 December 14 1992 License NPF-1 Attachment A Page 1 of 2 REPLY TO A NOTICE OF VIOLATION yiolation A Technical Specification (TS) 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, November 1972.
RG 1.33, Appendix A, Section J states in part:
' Chemical and radiochemical control procedures should be writter to-prescribe the nature and frequency of sampling analysis,
'These pro edures should specify the laboratory instructions and calibration of laboratory equipment."
Chemistry Manual procedure CM 4,
" Laboratory Quality Control,' Revision 2, dated January 31, 1992, requires that, 'All standards used for calibration shall be traceable to the National Institute of Standards and Technology (NIST), American Chemical Society Certification, natural physical constants, or their equivalents."
chemistry Laboratory Instrument procedure CL-153, " Calibration Check and Efficiency Calibration,' Revision 5, dated June 3, 1991, requires that, 'The efficiency calibration and calibration check are performed by counting a N.I.S.T.
traceable radionuclide standard on a germanium detector...'
Contrary to the above:
1.
On February 3, 1992, the licensee failed to implement CM 4, in that a radioactive standard for which the N.I.S.T. traceability had expired was used to calibrate a germanium detector.
i 2.
From January 1 to October 9, 1992, the licensee failed to implement CL-153, in that a radioactive standard for which the N.I.S.T. traceability had expired was used to perform daily calibration checks on a germanium detector.
This is a Severity Level IV violation (Supplement IV).
Respon12 Portland General Electric Company (PGE) acknowledges the violation.
I 1.
Reason for the violation The reason for the violation was inadequate procedural guidance on use of radioactive standards-that have exceeded the manufacturer's shelf life.
Although NIST traceability can be maintained after a radioactive standard exceeds its shelf life, the-actions necessary to maintain traceability were not performed.
2.
Corrective steps that have been taken and the results achieved A Temporary Change Notice (TCN) was issued to procedure CL-153 to require an' evaluation by chemistry management prior to use of radioactive standards that have exceeded the manufacturer's shelf life.
Information obtained from the vendor confirmed that the radioactive standard can be used for up to three years from the date of calibration.
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Trojan Nuclear Plant Document Control Desk Docket 50-344 December 14 1992 License NPF-1 Attachment A Page 2 of 2 The chemistry department evaluated the expired standard to permit continued use pending receipt of a new standard.
A new radioactive standard was obtained and the existing radioactive standard was disposed of on December 1, 1992.
3.
Corrective steps that will be taken to avoid further violations Procedure CL-153 will be revised to incorporate the TCH and include the criteria for use of radioactive standards that have exceeded the manufacturer's shelf life.
This revision will be completed by January 25, 1993.
4.
Date when full compliance will be achieved Full compliance was achieved on December 1, 1992 when the detector was calibrated with a new NIST traceable radioactive standard.
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