ML20151U766

Notice of Violation from Insp on 851030-31.Violation Noted: QA Procedure Nqap 114, Verification of Vendor Certificates of Conformance Resulted in Improper Procurement of safety- Related Components Due to Lack of Sufficient Interviews

ML20151U766
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/07/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20151U745	List: IR 05000344/1985038 ML20151U766
References
50-344-85-38, NUDOCS 8602110103
Download: ML20151U766 (2)

Text

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i APPENDIX A NOTICE OF VIOLATION Portland General Electric Company Docket No. 50-344 121 S. W. Salmon Street License No. NPF-1 Portland, Oregon, 97204 As a result of the inspection conducted on October 30 and 31, 1985, violations of NRC requirements concerning procurement activities for the Trojan Nuclear-Power Plant were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the violations are set forth below:

A. 10 CFR 50, Appendix B, Criterion VII, states in part, " Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors atad subcontractors, conform to the procurement documents. These measures shall include ,

provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery."

The Final Safety Analysis Report (FSAR), Revision 10, commits to ANSI 45.2.13-1976 and Regulatory Guide 1.123 (Rev. 1). ANSI 45.2.13 " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants," as supplemented by Regulatory Guide 1.123, requires that when certificates of conformance are used to provide the documentary evidence that items conform to procurement documents, means 9 shall be established to verify the validity of supplier certificates and the effectiveness of the certification system, such as the performance of audits of the Supplier or independent inspection or test of'the item.

I Contrary to the above, PGE Nuclear Quality Assurance Procedure NQAP 114,

" Verification of Vendor Certificates of Conformance" dated February 1984, f

_ requires PGE personnel to interview signers of Certificates of

$_ Conformance for only a sample of the ve aors from which safety-related equipment is accepted based solely on krtificates of Conformance. This?

fails to meet the above listed requirements in that only a sample rather than all vendors are interviewed, and the interviews are inadequate to verify the effectiveness of the certification 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) 0602110103 PDR ADOCK

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V B. 10 CFR 50, Appendix B, Criterion V,. states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or

drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or

drawings."

! 10 CFR 21.3 defines a defect as "A deviation in a basic component

delivered to a purchaser for use in a-facility..." and 10 CFR Part 21.21 states, in part, "(a) Each individual, corporation, partnership, or other

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entity subject to the regulations in this part shall adopt appropriate procedures to: (b)(1)... notify the Commission when he obtains information reasonably indicating a failure to comply or a defect...."

Contrary 1to the above, PGE Nuclear Division Procedure NDP 700-4, "10 CFR 21 Reporting of Nuclear Plant Defects or Noncompliances" 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," thereas, defects found before final acceptance for operation are required to be reported by 10 t CFR 21.

This is a Severity Level V Violation (Supplement I).

. Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) the correc'tive steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid

.further items of noncompliance; and (3) the date when full compliance will be achieved. Consideration may be given to extending your response-

.f time for good cause shown.

ik FEB 0 71986 g7 Dated R. T. Dodds, Chief j~ Reactor Projects Section 1 3

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