ML20246B321

Responds to NRC 890404 Notice of Violation & Proposed Imposition of Civil Penalty.Payment of $75,000 Encl. Corrective Actions:Procurement Process & Evaluation of Current Inventory Will Be Revised

ML20246B321
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	04/28/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8905090013
Download: ML20246B321 (8)

Text

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. a Portland General Electric Corpsiy

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l David W. Cockfield Vice President, Nuclear April 28, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1 j 1

Director, Office of Enforcement U.S. Nuclear Regulatory Commission ATTN: Document Control Desk l l Washington DC 20555

Dear Sir:

Reply to a Notice of Violation' Your letter of April 4, 1989 transmitted a Notice of Violation and Proposed Imposition of civil Penalty associated with Nuclear Regulatory Commission j (NRC) Inspection Report No. 50-344/88-46. Our response to the Notice of Vio2rtion is attached. Also attached is a check which provides full pay-ment for the imposed civil penalty of-$75,000.-

Sincerely, i

Attachments c: Mr. John B. Martin Regional Administrator, Region V <

U.S. Nuclear Regulatory Commission 3 Mr. William T. Dixon l State of Oregon i l

Department of Energy l Mr. R. C. Barr NRC Resident Inspector I Trojan Nuclear Plant ,

8905090013 890428 PDR O ADOCK 05000344 PDC ' I a sw senon sm eonwo oremn 9ra *pgk f)

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, Trojen Nuclose Plant Docum:nt Control Dask

- . Docket 50-344 Attachment i License NPF-1 April 28, 1989 Page 1 of 7 REPLY TO NOTICE OF VIOLATION l

Applicable Regulations Title 10 to the Code of Federal Regulations, Part 50, (10 CFR 50), Appendix B, Criterion III, " Design Control," requires, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis are correctly translated into specifications, drawings, procedures, and instruc tions . These measures shall include provisions to assure that appro-priate quality standards are specified and included in design documents and l

that deviations from such standards are controlled. Measures shall also be established for the selection and review for suitability of application of l materials, parts, equipment, and processes that are essential to the safety-l related functions of the structures, systems, and components.

10 CFR 50, Appendix B, Criterion IV, " Procurement Document Control," requires that measures be established to assure that applicable regulatory require-ments, design bases, or other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services. To the extent necessary, procurement documents shall require contractors or subcontractors to provide a quality assurance program consistent with the pertinent provisions of Appendix B.

10 CFR 50, Appendix B, Criterion X, " Inspection," requires, in part, that examinations, measurements, or tests of material or products processed shall be performed for each work operation where necessary to assure quality.

Violations contrary to the above, commercial-grade components at the Trojan Nuclear Plant were installed without adequately assuring their suitability for use in safety-related applications:

1. During the 1987 outage, in response to Maintenance Request (MR)

No. 87-4129, 14-inch Schedule 60 piping and fittings purchased from Liberty Equipment and weld metal purchased from Oxarc were installed inside Containment to replace eroded main feedwater system piping.

Portland General Electric Company (PGE) failed to assure the proper selection and review for suitability of application of these materials for this safety-related application. These materials were purchased commercial-grade without adequate audits to assure that the vendors

( fabricated the materials under a Quality Assurance (QA) program consis-tent with the pertinent requirements of 10 CFR 50, Appendix B, and with-out performing tests or examinations to assure the quality of these materials,

Trojan Nuclear Plant Document Control Desk

. . Docket 50-344 Attachment License NPF-1 April 28, 1989 Page 2 of 7

2. Between August 1987 and June 1988, a time-delay relay was installed per MR No. 87-5412. PGE failed to assure adequate design control for the proper selection and review for the commercial-grade purchase of the Agastat time-delay relay (Purchase Order (PO) No. NQ-04064-05] used in the diesel-driven auxiliary feedwater pump in that critical character-istics of the relay were not properly evaluated and specified.

3. Between May 2 and May 4, 1986, a pressure regulator valve was installed per MR No. 86-2180. PGE failed to assure adequate design control for the proper selection and review for the commercial-grade purchase of the pressure regulator valve (PO No. NQ-02468) used in the emergency diesel air start system in that critical characteristics of the valve were not properly evaluated and specified.

This is a severity Level III problem (Nupplement I).

REPLY TO VIOLATIONS 1. 2 AND 3 Portland General Electric Company acknowledges the violations.

1. REASON FOR THE VIOLATIONS:

These violations were the result of a deficient procurement process. The deficiencies were identified by the Nuclear Regulatory Commission (NRC) in 1985 and resulted in a Notice of Violation regarding commercial-grade items. Because of a lack of understanding of the requirements of 10 CFR 50, Appendix B, as they relate to the procurement process, the corrective actions taken by PGE as a result of the 1985 violation were ineffective.

In addition, a contributing factor to the violations was the fact that the Nuclear Quality Assurance Department (NQAD) became so involved with the formulation of the procurement process that they were unable to perform their intended function of providing critical and independent oversight of procurement activities.

2. CORRECTIVE STEPS TAKEN OR BEING TAKEN TO PREVENT FUTURE VIOLATIONS AND RESULTS ACHIEVED:

Effective November 28, 1988, PCE began requiring an engineering evalu-ation be completed prior to issuing a commercial-grade item for a safety-related application. PGE has also implemented a procurement policy that items purchased for safety-related applications will be purchased as basic components whenever feasible. When items for safety-related appli-cations are procured commercial-grade, the items will be dedicated as discussed below.

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. Trojtn Nuclear Plant Docum:nt Control Dask

. - Docket 50-344 Attachment License NPF-1 April 28, 1989 Page 3 of 7 Revisions to the Procurement Process and Evaluation of Current Inventory l To ensure that all commercial-grade items intended for. safety-related applications are properly specified and accepted for use as basic compo-nents, two new temporary procedures were issued on December 29, 1988. l l \

Administrative Order (AO)-T-29, " Material Issue Control", provides l l instructions to control the issue of items for use in safety-related applications and supplements the current procedure for material control and identification. A0-T-30, " Material Engineering Evaluation", estab-lishes.the requirements, methods and processes for performing engineering evaluations of warehoused or purchased commercial-grade items prior to utilization in a safety-related application. The evaluation function is being performed by Nuclear Plant Engineering and includes determining the item's critical characteristics for its intended safety function, and identifying those attributes necessary for acceptance of the item as a basic component.

These procedures ensure that commercial-grade items currently in inven-tory, presently on order, and procured in the future meet all regulatory cnd industry requirements for their intended applications. The proco-dures also establish procurement requirements, including a verification inspection program for commercial-grade items, for all future procurement of standard inventory items.

The controls established by these two temporary procedures are being incorporated into Nuclear Division Procedures (NDP) 300-1 through 300-5, the Procurement Series. The revisions to the NDP-300 Series will be completed by June 30, 1989.

The evaluations of commercial-grade items utilize the dedication method-ology delineated in Electric Power Research Institute (EPRI) Docu-ment NP-5652, " Dedication of Commercial-Grade Items". The modifications to the EPRI guidelines for acceptance methods that are recommended in l Generic Letter 89-02, " Actions to Improve the Detection of Counterfeit l and Fraudulently Marketed Products", are incorporated in PGE's program.

, Acceptance of items is performed and implemented in accordance with the l EPRI guideline (with the noted exceptions) and Regulatory cuide 1.123,

" Quality Assurance Requirements for Control of Procurement of Items and l Services for Nuclear Power Plants". l This program has ensured that all commercial-grade items installed in l- safety-related applications after November 28, 1988 have had adequate review to establish that they are acceptable for the specific application.

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Trojan Nuclear Plant Document Control Dask )

Docket 50-344 Attachment License NFF-1 April 28, 1989 Page 4 of 7 Evaluation of Installed Items To address commercial-grade items installed in safety-related applica-tions prior to November 28, 1988, an installed item evaluation was performed. j To support the preparation of the Justification for Continued Operation (JCO) for commercial-grade procurement issues (JCO 88-15) originally submitted on November 29, 1988 and revised on February 17, 1989, a review ,

of commercial-grade items issued from the warehouse between January 1986 ]

and November 1988 was performed to ensure functional adequacy of the ]

items. Subsequently, PGE has performed an additional review and evalu-ation of. installed items to verify and document the original review and more thoroughly address commercial-grade items installed in safety-related applications. This review and evaluation process is shown in ,

Figure 1.

The first step of ths effort was to perform a screening process of over 20,000 MRs issued between September 1, 1985 and December 1, 1988 to determine if commercial-grade items or materials were issued from the warehouse for environmental qualification (EQ), American Society of Mechanical Engineers (ASME)Section XI (Boiler and Pressure Vessel Code),

Standard Technical Specifications, or safety-related applications. This first step identified 3400 MRs that required a more detailed review.

The second step was to review these 3400 MRs in detail to identify those that performed safety-related work. Of the 3400 MRs, 2700 were identi-fled as performing safety-related work. These 2700 MRs were evaluated to identify items involving EQ, seismic qualification, and ASME Section XI pressure-retaining installations. Approximately 1200 of the 2700 safety-related MRs fall in this category. . These items will'be completely evaluated and dispositioned prior to restart from the 1989 refueling outage.

Commercial-grade items installed by the remaining 1500 MRs will be reviewed once the high-priority installations have been addressed and will be dispositioned by October 31, 1989. Startup and operation of Trojan prior to dispositioning these items is justified for the reasons stated in JCO 88-15.

The evaluation of each MR involves identifying the commercial-grade item (s) installed in a safety-related application. The commercial-grade items are dispositioned in one of three ways:

(1) The critical characteristics will be identified and verified, or (2) A determination will be made that the item neither provides a safety-related function nor does it affect the safety-related performance of other equipment, or

Trojan Nucicar Plcnt Docum:nt Control Dask l Docket 50-344 Attachment License NPF-1 April 28, 1989 Page 5 of 7 (3) A Nonconformance Report (NCR) will be prepared to either replace the item or justify continued operation with the item installed.

l To assist in performing the engineering evaluations, the installed item review, and the revisions to the procurement procedures, PGE contracted personnel experienced in material management. These individuals are I working with PGE employees to provide training in procurement require-ments and the commercial-grade dedication process. Their expertise and l industry-wide experience in the area of commercial-grade procurement has enabled PCE to develop a strong procurement program that meets all regu- i latory requirements. l Ouality Assurance Assessment r l To enable NQAD to independently assess the procurement process, the i responsibility for the procurement procedures was transferred to the Material Services Manager in December 1988.

NQAD has conducted three separate surveillance to assess the adequacy of the systematic review and evaluation of commercial-grade materials.

These surveillance covered the methodology used for preparation of the original JC0 88-15, the process for identifying MRs which installed com-mercial-grade materials in safety-related systems, and the evaluations of installed commercial-grade materials.

These surveillance have verified that the review and evaluation process is comprehensive and effective. Recommendations made by NOAD for improvements to work instructions were incorporated during the course of the third surveillance.

In addition, all evaluations performed by Nuclear Plant Engineering on commercial-grade items intended for safety-related applications are subject to independent review by NQAD personnel specifically assigned to thit. =ctivity, Corrective Steps to Address Specific Violations violation 1:

The commercial-grade items installed in the safety-related portion of the main feedwater system have been identified and a testing program has been established to demonstrate their acceptability for safety-related service. The scope of the testing program is described in our JC0 for Safety-Related Main Feedwater Piping (JCO 89-01) dated February 21, 1989. Testing will be completed prior to testart following the 1989 refueling outage.

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, Trojan Nuclear Plant Document Control Desk

- - Docket 50-344 Attachment License NPF-1 April 28, 1989 Page 6 of 7 Violation 2:

The commercial-grade time delay relay utilized for the diesel-driven auxiliary feedwater pump will be replaced with a fully qualified replace-ment prior to restart following the 1989 refueling outage.

Violation 3:

A commercial-grade itent evaluation will be performed for the pressure regulator valve installed in the emergency diesel generator air start system. The evaluation will include identification and verification of the valve's critical characteristics. This evaluation will be completed prior to restart from the 1989 refueling outage.

3. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:

PGE's procurement process for commercial-grade items intended for safety-related applications is in full compliance with regulatory requirements.

The various portions of PGE's action to address other aspects of the commercial-grade process will be completed as stated above.

GAZ/SAB/PGN/mr 3024W.0489

l Trojan Nuclear Plant Document Control Desk

• Docket 50-344 April 28,1989 License NPF-1 Attachme-  !

Page 7 of 7 REVIEW OF INSTALLED COMMERCIAL-GRADE ITEMS  !

l Over 20,000 MR's issued between No F September 1,1985 and December 1, m Return '

1988 were reviewed to determine to storage if any parts with OA Level Codes C, C1,C2, or D were Installed in ASME Section XI pressure retaining, Safety-Related, EO, or Technical Specification applications YesT r

3400 MR's identified for further evaluation if Detailed review done to No F 700 MR's out '

determine if MR performed >t of scope  ;

safety-related work Yes I P r '

2700 MR's for further evaluation ,

if MR's evaluated to No 1500 MR's recetve '

determine If E0, Seismic  ; complete evaluation j or ASME Section XI pressure g by October 31,1989 ;

retalning application Yes Y lI 1. Critical characteristics of item F are identlfled and verified, or 1200 MR's receive '

complete evaluation p 2. Documented safety evaluation that prior to restart the item is not safety-related, or

3. NCR ls prepared to replace item or justify continued operation FIGURE 1

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