ML20141N834
| ML20141N834 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/07/1986 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20141N833 | List: |
| References | |
| NUDOCS 8603180184 | |
| Download: ML20141N834 (6) | |
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March 7, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Comission 1450 Maria Lane, suite 210 Walnut Creek CA 94596-5368
Dear Mr. Martin:
February 7. 1986 Notice of Violation In a Notice of Violation dated February 7, 1986 (Dennis F. Kirsch to Bart D. Withers) PGE was informed of two activities which did not appear to be conducted in full compliance with NRC requirements. The violations, which result from an inspection conducted on October 30 and 31, 1985, involved a failure to execute the Trojan Plant QA Program for certain pro-curement activities. A reply was required within 30 days identifying the corrective actions which have been and will be taken, and the date when full compliance will be achieved. Our response is provided as Attachment A.
As shown therein, adequate procedures are now in place or ere being devel-oped, and a training program has been scheduled to ensure that safety-related procurement activities and 10 CFR 21 reportability criteria fully comply with the applicable requirements of 10 CFR 21 and 10 CFR 50 Appendix B.
Sincerely, u"
Bart D. Withers Vice President Nuclear Attachments c:
U.S. Nuclear Regulatory Comission Document Control Desk Mr. Lynn Frank, Director State of Oregon Department of Energy 86031 Lad 104 060314 PDR ADOCK 05000344 O
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s Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 March 7, 1986 License NPF-1 Attachment A Page 1 of 4 VIOLATION RESPONSES Violation A "PGE Nuclear Quality Assurance Procedure NQAP 114.
. requires PGE per-sonnel to interview signers of Certificates of Conformance for only a sample of the vendors from which safety-related equipment is accepted based solely on Certificates of Conformance. This fails to meet [NP.C] require-monts in that only a sample rather that. all vendors are interviewed, and the interviews are inadequate to verify the effectiveness of the certifica-tion system in areas such as material controls, nonconformance controls, inspection, and tests. As a result, PGE has installed, and is relying on the operation of, safety-related components which have been improperly procured."
This is a Severity Level IV Violation (supplement I).
Response to Notice of Violation Item A PGE has established measures to ensure that purchased material, equipment, and services, whether purchased directly or through contractors and sub-contractors, conform to procurement documents. These measures are docu-mented in the following Nuclear Division Procedures (NDPs) which were issued on February 19, 1986:
NDP 369-1: Procurement Quality Level Classification System Tnis procedure establishes a graded classification system for purchased material, equipment, parts, or services based on complexity and impor-tance to safety.
It also defines the technical and Quality Assurance Program requirements related to each procurement action classification.
NDP 300-2: Selection of Procurement Sources This procedure establishes the requirements and the process for initi-ating evaluationc of the quality systems of procurement sources for items or services classified in accordance with NDP 300-1.
NDP 3_00-3: Evaluation of Commercial Grade Items This procedure establishes the methodology for performing and document-ins engineering evaluations of commercial grade items used in safety-related applications.
Trojan Nuclear Plant Nr. John B. Martin Docket 50-344 March 7, 1986 License NPF-1 Attachment A Page 2 of 4 WDP 300-4: Procurement Document Preparation. Review. and th ane Control This procedure establishes the process for preparation, review, and approval of, and changes to quality-related procurement documents.
It describes the decisions, activities, and documents associated with the procurement process from determination of need through issuance of an award document.
.NDP 300-5: Acceptance of purchased Item or Service This procedure establishes the methods for accepting purchased material, equipment, parts, or services.
It includes methods for establishing and documenting acceptance by receiving inspection and supplemental acceptance by contractor or supplier certificate of conformance, by source verification, and by post-installation testing.
These procedures include provisions for source evaluation and selection, as well as for inspection at the contractor or subcontractor source and for examination of products upon delivery. Requirements for objective evidence of quality furnished by the contractor or subcontractor are also included.
We anticipate obtaining full compliance with these procedures by July 1, 1986. Prior to that time, personnel involved in the procurement process will be trained on specification and procurement requirements to ensure that the procedures are consistently and correctly applied. A training course has been scheduled to present an overview of the p ecurement quality assurance ecdes, standards, and regulatory guides currently used in the nuclear industry. The course will examine the implementation methods for each of the various procurement standards and will include an evaluation of their similarities and differences. The course is structured to assist the participants in their day-to-day implementation of the new procurement procedures. A list of topics to be covered at these training sessions is providad as Attachment B.
We enticipate that this training will be com-plated by April 16, 1986.
Within the procurement quality assurance system, PCE has provided the means to verify the validity of supplier Certificates and the effectiveness of the certification system. The effectiveness of the control of quality by contractors and suppliers is assessed at intervals consistent with the importance, complexity, and quantity of the product or services, and veri-fications are conducted at intervals commensurate with a supplier's previ-ous quality performance.
NDPs 300-1 through 300-5 do not allow acceptance of safety-related equip-ment based solely on Certificates of Conformance.
In addition, PCs Nuclear Quality Assurance Procedure NQAP 114. " Verification of Supplier's Certifi-cates of Conformance", has been revised to require that at least once each 12 months, all safety-related (Quality Level Code D) purchase orders issued
Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 March 7, 1986 License NPF-1 Attachment A Page 3 of 4 during the previous 12 months be reviewed to identify the suppliers to be visited for verification of certificates. At least 10 percent of the sup-pliers of safety-related equipment providing certificates will be visited each year. This procedure revision was issued on December 26, 1985.
The verification of the validity of supplier certificates and the effec-tiveness of the certification system is accomplished as an integral part of the total supplier control and product acceptance program. The degree of verification required depends upon the type of item or service and its safety isnortance. The unans of verifying whether a supplier has fulfilled procuremera Cocument requirements and whether his certification system is effective may include source witness / hold points; source audits and docu-ment reviews; indepenient inspections at the time of material receipt; user tests on selected commodities; and tests after installation on selected components and systems.
The following corrective actions, subordinate to NDPs 300-1 through 300-5, will be completed by June 1, 1986:
1.
A new PCE Evaluated Contractor and Supplier List (ECSL) including Quality Level Code D Contractors and Suppliers will be issued.
2.
The existing Quality Level Code A listing of Contractors and suppliers will be revised to include the new procurement categories required by NDP 300-2.
3.
Nuclear Quality Assurance Department Procedure NQAP 105, " Contractor and supplier Evaluations", will be revised to reflect new procurement categories and vendor evaluations.
4.
Nuclear Quality Assurance Department Procedure WQAP 115. " Control of the Evaluated Contractor and supplier List for Quality-Related Procurements", will be revised to reflect new procurement categories.
We anticipate that full compliance with NRC requirements for procurement quality assurance programs will be achieved by July 1, 1986.
Violation B "PGi Nuclear Division Procedure NDP 700-4.
. does not satisfy the requirements of 10 CFR 50 Appendix B or 10 CFR 21 in that section 5.1D states that ' Defects or noncompliances found... Prior to final acceptance of a structure, system or component for operation shall not be subject to reporting under 10 CFR 21,' Whereas, defects found before final acceptance for operation are required to be reported by 10 CFR 21."
This is a severity Level V Violation (Supplement I).
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Trojan Nuclear Plant Mr. John B. Martin Docket 50-344 March 7, 1986 License NPF-1 Attachment A Page 4 of 4 Response to Notice of Vloistion Item B PGE Nuclear Division Procedure NDP 700-4, "10 CFR 21 Reporting of N clear Plant Defects or Noncompliances", has been revised to require that vendor-caused defects or noncompliances discovered during the implementation of quality control measures (eg, reviews, inspections, tests, or nondestruttive examinations) at Trojan are subject to reporting under 10 CFR 21.
This change was included in Revision 2 to NDP 700-4 which was issued for use on October 21, 1985.
NRC Inspection Report 50-344/85-038 dated January 15, 1986, Item 4, indi-cated that a review of the revised Part 21 procedure by the inspectors determined the procedure to be adequate.
PGE's corrective action in response to this violation item is complete.
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Trojan Nuclear Plant Mr. John B. Martin
. Docket 50-344 March 7, 1986 License NPF-1 Attactunent B PROCUREMENT QUALITY ASSURANCE COURSE TOPICS
- Introduction to Procurement QA Terminology and Definitions
- Applicable Codes, Standards and Regulatory Guides
- Understanding 10 CFR 21 Applicability
- Safety-Related vs Quality-Related
- Procurement Quality Level Classification System
- Quality Level Procurement Requirements
- Organisational Interfaces and Responsibilities
- Preaward Evaluation of Procurement Sources
- PGE Evaluated Contractor and Supplier List for Quality-Related Procurements
- Determining Appropriate Quality System (s)
- Engineering Evaluation of Commercial Grade Items
- Procurement Document Preparation, Review and Approval
- Control of Changes to Procurement Documents
- Procurement Specifications
- Classification of Items to Prevent Demage, Deterioration, or contamination
- Engineering and Quality Verification Documer.ts
- Use of Standard Procurement Requirements l
- Methods of Acceptance of Items or Services
- Receipt Inspection and Source Inspection Plans
- Supplier certificate of Conformance
- Post-Installation Test Acceptance
- Post-Award Audits
- How to Complete New Forms
- QA Records of Procurement Activities i
ARA /kal 0358P.386,
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