ML20245L143

Notice of Violation from Insp on 890522-0602.Violations Noted:Exams Given to Inservice Insp NDE Contractors Did Not Cover Required Specific Test Areas & Exams Not Closed Book Tests

ML20245L143
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/04/1989
From:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20245L135	List: ML20245L130 ML20245L143 ML20245L147
References
50-344-89-12, NUDOCS 8908220005
Download: ML20245L143 (4)

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APPENDIX A (ls

p.  : NOTICE OF VIOLATION ,

N Portland General Electric- -Docket No. 50-344 Trojan Nuclear Plant License No. NPF-1 An NRC-inspection conducted during the period May L2 through June 2, 1989,

identified five violations of NRC requirements. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR 2, Appendix C (1989), these violations are set forth below.

A. 10 CFR 50, Appendix B, Criterion IX requires that special processes such as qualification,. certification and training of NDE personnel procedures shall comply with the requirements of applicable codes and standards.

The Trojan FSAR, Section 6, invokes ASME Code 1983 Edition and Addenda through Summer 1983. Site procedure MTS-9 AM-300, Rev. O and ASME Section V p(aragraph T-170, Qualification of Personnel, establishSNT-TC-1A_ 198 Personnel Qualification and' Certification" as the requirement for. NDE personnel qualification.

SNT-TC-1A (1980) paragraph 8.3 requires: "The written examinations

-should be administered without access to reference material (Closed Book) except that necessary data, such as graphs, tables, specifications, procedures,.and codes may be provided." i Contrary to the above, the ISI contractor training, qualification and certification of NDE personnel procedure (MTS-QAM-300, Rev. O para 8.1.3) states " Specific examinations shall cover equipment operating procedures, test techniques and codes that the examiners may encounter in specific assignments. The examinations 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 test 7.

Reference material was provided to examinees that contained all test answers.

This.is a Severity Level IV violation. (SupplementII)

B. 10 CFR 50, Appendix B, Criterion IX requires that special processes such as nondestructive testing be accomplished in accordance with applicable codes. Trojan's FSAR and ultrasonic procedure QAP-UP-101, Rev. 1 invoke the~1983 edition and addenda through summer of 1983 of ASME Section XI for ISI requirements. ASME Section XI article 111-3210 and site procedure QAP-UT-101 Rev 1 paragraph 6.5.1 establish that calibration shall include the complete ultrasonic examination system and any change in search units in the system shall be cause for calibration checks of the entire examination system.

Contrary to the above, ultrasonic search unit changes were made during the ISI examination of welds 89-011630, 89-011580 and 89-011620 and the required calibration checks were not performed.

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'This is a Severity Level IV violation. (SupplementII)

C. 19 CFR 50, Appendix B, Criterion IX requires that special processes such as nondestructive testing be accomplished in accordance with applicable codess Trojan's FSAR and site radiographic procedures, QC-RT-1 and MR89-41?9, feedwater piping replacement for "D" system, invokes USAS B31.7 Pre:sure Piping Code, 1969 edition with addenda through summer

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1971.

The USAS B31.7 code, paragraph B-1-140, directs that for pipe wall thicknesses'up to 3/4 inch inclusive sections of welds be rejected that-are shown by radiography to have any elongated indication, with a length greaterLthan i inch.

Contrary to the above, the licensee inspected and accepted USAS B31.7 class 2 weld P25881R4 on feedwater system "D" which contained an.

indication 3/8 inch in length, which is greater than the i inch allowable

-length for thickness up to 3/4 inch inclusive. This indication should Lhave been evaluated and dispositioned; however, at the time of the

. inspection the licensee had not recorded, evaluated'nor dispositioned the indication.

This'is a Severity Level V violation. (SupplementII)

D. Title 10 Paragraph'50.55a of the Code of Federal Regulations' requires that plant inservice inspection programs be performed in accordance with

' appropriate editions of the ASME Code.

The Trojan Final Safety Analysis Report (FSAR), Section 6, states that the inservice inspection program shall meet the requirements of the 1983 Edition of Section XI of the ASME Code with addenda through the' summer of.

'1983, and the Trojan second 10 year inservice inspection program establishes the same code requirements. ASME Section XI article III paragraph 4330 and Appendix III establish requirements to stamp the weld center line, establish zero reference starting points and identify the direction of examination for weld inspections. Also, marking requirements are set forth in site procedure QC-RT-1, dated January 2, 1980.

Contrary to the above, Welds P-28372 and P-25893 each had two zero reference starting points indicating opposite directions of inspection.

welds P-25894, P-25897 and P-25876 had no zero reference starting points established. Weld P-25875 had no weld identification stamp.

This is a Severity Level V violation. (SupplementII)

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E. 10 CFR 50,-Appendix B, Criterion IX requires"that special processes such-

.as nondestructive testing be accomplished in accordance with applicable

' . codes. Trojan's FSAR'and ultrasonic. testing procedure QAP-UT-101 Rev. I-invoke the.1983 edition and addenda through summer of 1983 of' ASME Section XI. ASME Section XI paragraph-IWA-1400 (1) and (h) require that ultrasonic examination data and evaluation results be documented. Proce-

, dure _QAP-UT-101, Rev. I requires plotting of' geometric conditions, such

-as weld root areas, or defects. - The volume of material . examined and any restrictions.or limitations of examiners also are required to be documented.

Contr'ary to the-above, ISI ultrasonic data,for systems 4 330010! 010030, 011570, 035030 and.301120 revealed the following:

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N 1)- The' volume of weld examined was not documented; 2

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. , , s V- 2) ~ Examination limitations were not properly documented; s ,s

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. 3)] -Ultrasonic e amination-records did not have sufficient

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-plots to , ensure that proper examination coverage was obtained;

' J 4) . Recorded indications;were not characterized as defects or geometric

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s,. J , ' 5) UThe ultrasonic' reports did not indicate if the indications were u jacceptable or, rejectable.

U .This is.a4 Severity. Level.V violation. -(Supplement II)

Pursuant to_.the provisions of 10 CFR 2.201, Portland General Electric Company is hereby required to submit.a written statement of explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC-20555 with,a'~ copy to the Regional Administrator, Region V, and a copy to the

.NRC Resident' Inspector, Trojan,'within 30 days of the date of the letter l

. transmitting this Notice. This reply shou 1_d be clearly marked as a Reply to a

. Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2).the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid

.further violations, and (4) the date when full compliance will be achieved.

TIf an adequate reply is.not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, i

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suspended, or revoked or why such other action as may be proper should not be taken. Consideration may be given to extending the response time for good cause shown.

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• F0 THE NUCL AP, REGULATORY COMMISSION

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. .t , e h- p Dated'at Walnut Creek,* California

this 4th - day of puntui 1989.

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