ML20247E170
| ML20247E170 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/19/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905260150 | |
| Download: ML20247E170 (5) | |
Text
. _ _ _ _ _.
~
r
- Elll PbrtlandGeneralElechicCoiway David W. Cockfield Vice President, Nuclear May 19, 1989 Trojan Nuclear Plant Docket 50-344 License NPF-1.
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sirs:
Reply to a Notice of Violation Your letter of April 19, 1989 transmitted a Notice of. Violation associated with Nuclear Regulatory Commission Inspection Report 50-344/89--05.
Attached is our response to that Notice of Violation.
Sincerely,
/
I Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. William T. Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector I
Trojan Nuclear Plant 8905260 h 890519 0,
PDR ADUCK 05000344 O
PDC 121 S w. Sarnon Smet Portland. Omgan 97204
1 Trojan Nucicar Plcnt Document Control Desk
' Docket 50-344 Attachment License NPF-1 May 19, 1989 Page 1 of 4 REPLY TO A NOTICE OF VIOLATION Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50),
L Appendix B, Criterion V, states, in part:
l
" 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."
l VIOLATION A Nuclear Division Procedure (NDP) 600-1, Revision 4, dated February 10, 1987 entitled, " Control of Nonconforming Materials, Parts, and Components," section 1.0, states in part, "This procedure establishes measures to assure that nonconforming materials, parts, and components will be adequately documented and controlled.
Contrary to the above, during the 1987 outage, nonconforming weld filler material was identified and documented on a Nonconformance Report (NCR) form, but the NCR was not processed in accordance with the established Quality Assurance (QA) Program procedurcs.
This is a Severity Level IV violation (Supplement 1).
REPLY TO VIOLATION A Portland Cencral Electric Company (PCE) acknowledges the violation:
1.
Reason for Violation:
The reason for this violation was personnel error. An NCR was initiated, but the initiator's supervisor failed to follow Huclear Division Procedure (NDP) 600-1, " Control of Nonconforming Materials, Parts, and Components," by not assuring the NCR was processed through to the Nuclear Quality Assurance Department (NQAD). An NCR was clearly necessary to document and evaluate the deficient characteristics of the filler material.
i 1
l l
Trojtn Nuclose F1Ent Docum:nt Control D sk I
' Docket 50-344 Attachment License NPF-1 May 19, 1989 Page 2 of 4 2.
Corrective Steps Taken and Results Achieved:
j 1
l a.
The weld filler material of concern was placed on hold in the warehouse under NCR tags. This was completed on February 6, 1989. This action ensures that the weld filler material will not be issued for use while the NCR is being dispositioned.
b.
The original NCR was properly transmitted to NQAD, assigned l
l number 89-172 on May 10, 1989, and is being properly processed I
in accordance with NDP 600-1.
The disposition of the NCR will l
address any use of the weld filler material onsite before it was placed on hold under NCR tags.
c.
Nuclear Division management has placed additional continuing emphasis on procedural compliance in the time since the occurrence of this violation.
On December 21, 1988, the Vice President, Nuclear, issued to his managers the " Nuclear Division Mission and 1989 Goals," Which included emphasis on procedural compliance. These goals have since been disseminated to Nuclear Division employees at all icvels, d.
The supervisor responsible for not transmitting the NCR has left PGE.
Therefore, no specific disciplinary action was taken for this employee. Procedural compliance has been emphasized to employees in General Employee Training (CET).
3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
All corrective steps have been completed.
4.
Date When Full Compliance Will Be Achieved:
Full compliance was achieved with the issuance of NCR 89-172, l
u j
c.
I
?
Trojan Nuclasr Plant Document Control Desk Docket 50-344 Attachment License NPF-1 May 19, 1989 Page 3 of 4 l
VIOLATION B Nuclear Plant Engineering Procedure (NPEP) 200-6, Revision 3, dated May 29, 1985, entitled, " Preparation of Engineering Drawings," requires, in part, that drawing change notices (DCNs) be incorporated in new or revised drawings within 90 days of issuance or whenever the number of DCNs exceeds five in number for a particular drawing.
Contrary to the above, DCNs 80 and 84 to Revision 8 of Drawing E-22, the electrical fuse schedule, were issued on August 23, 1988 and October 12, 1988, respectively, and were incorporated into Revision 9 of Drawing E-22 on February 14, 1989, which exceeded the 90-day requirement.
DCNs 80 and 84 dealt with safety-related components of the auxiliary feedwater system (AFWS) and chemical and volume control system (CVCS), respectively.
In addition Draving E-22 had 15 associated DCNs for Revision 8 before Revision 9 was issued.
This is a Severity Level IV violation (Supplement 1).
REPLY TO VIOLATION B PGE acknowledges the violation:
1.
Reason for Violation:
The reason for this violation was inadequate management attention in overseeing the drawing change process. Noncompliance with the requirements for drawing revisions was limited to electrical drawings.
2.
Corrective Steps Taken and Results Achieved:
a.
Management attention to due dates for the revision of safety-i related drawings has been elevated.
The Nuclear Plant Engineering Department now receives a computer printout of all open DCNs and their associated due dates bi"cekly.
Procedural-ization of this process was completed March 16, 1989. This i
printout provides engineering management with the means to oversee and control the incorporation of DCNs.
b.
A review of all outstanding safety-related DCNs has been completed. No other safety-related DCNs were identified which had not been incorporated within the required time frame, nor were there any other safety-related drawings with more than five DCNs outstanding.
r Trojen Nuclear Plc ',,t Docum2nt Control Dssk
- Docket 50-344 Attachment License NPF-1 May 19, 1989 Page 4 of 4 3.
Corrective Steps That Will Be Taken to Avoid Further Violations:
All corrective steps have been completed.
4.
Date When Full Compliance Will Be Achieved:
Full compliance has been achieved.
SAB/LCD/mr 3073W.0589 I
l i
- _ _ _ _ - _ _ _ _ _ _