ML20153F171

Responds to NRC Re Violations Noted in Insp Rept 50-344/88-26.Corrective Actions:On 880604,Procedure QCP-34 Revised & Approved to Include Requirements of Procedure JM-004-88M

ML20153F171
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/29/1988
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8809070136
Download: ML20153F171 (3)

Text

__ _ _ _ _ _ _

~

ammmm. umme r - Elll PortlandGeneralElectricCong]erly Dav;d W. Cockfield Vice President. Nuclear August 29, 1988 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTW: Document Control Desk Washington DC 20555 Dear Sirt Reply to_a Notice of Violation By Nuclear Regulatory Commission (NRC) lotter dated July 29, 1988 (Kirsch to Cockficid) Portland General Electric Company (PGR) received Inspection Report No. 88 26 and a Notico of Violation concerning non-compliance with criterion V of Appendix B to Part 50 of Title 10 of the Codo of Federal Regulations.

Our reply to the Notice of Violation 10 provided in tho attachment to this letter.

Sincerely, y

Attachment et Mr. Jchn B. Martin Regional Administrator. Region V U.S. Nuclear Regulatory Comission Mr. Bill Dixon Stato of Oregon Department of Energy Mr. R. C. Barr NRC Resident inspector Trojan Nuclear Plant 8809070136 800829

$DR ADOCK 05000344 PNV

. ::, . w .., a c,.. , m

[f k

~

'. Trojen Nucicer Plcnt Document Centrol Deck Docket 50-344 August 26, 1988 License NPF-1 Attachment Page 1 of 2

, VIOLATION 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".

Nuclear Quality Assurance Program (PCE-8010), Section 5.2 states in part.

"Activities affecting quality shall be accomplished in accordance with approved, documented instructions, procedures, or drawings".

Contrary to the above

1. During May 25 through June 4, 1988, visual (VT-3) inspections were performed on ASME Section XI pipe support, utilizing the unapproved guidelines in PCE memorandum JM-004-88M for acceptance criteria.

2. As of June 10, 1988, written instructions or procedures were not established to prescribe the engineering evaluation process being performed on QC-identified discrepancies of ASME Section XI pipe supports.

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

PCE Rt.sponse

1. Portland General Electric (PCE) acknowledges the violation.

A. Reason for Violations (1) During the 1988 outago, piping supports were being examined by Quality Control (QC) to the requirements of QC Procedure (qCP)-14 "Visual Examination". The procedure contained a requirement that deformation and structural degradation is unacceptable. On May 24, 1988 Nonconforming Activities Report (NCAR) P88-088 was issued because the terms of "deformation and structural degradation" were not adequately defined, and some of the QC findings did not appear to be either structural deformation or degradation. The NCAR recompended that QC work with Wuclear Plant Engineering (NPE) to define the terms of deformation and structural degradation.

(2) WPE subsequently reviewed QCP-34 and determined it was appropriate to add the recommended clarification and to include a verification of construction quality along with the inspection for service-related deficiencies. On May 26, 1988, NPE Memorandum JM-004-88N was issued. The memorandum was then used by QC as revised acceptance criteria without

s'

'e

• Trojtn Nucioce Picnt D3cument Control D3sk Docket 50-344 August 26, 1988 License NPF-1 Attachment Page 2 of 2 being incorporated into QCP-34. On May 31, 1988, NCAR P88-094 was issued to document that inspections were being performed to unapproved acceptance criteria. The practice of inspection to the ,

I memorandum was immediately suspended.

B. Corrective Actions Taken and Results Achieved.

On June 4, 1988, QCP-34 was revised and approved to include the requirements in JM-004-88M. QC personnel have received training on the revised procedures. Items previously inspected have been identified and reinspected.

C. Corrective Action Taken to Avoid Purther Violations.

QC staff personnel have been instructed to perform inspections in accordance with properly approved procedures and not engineering memoranda.

D. pate When Full Comp 11snee Will be Achieved.

Full compliance was achieved on June 4, 1988.

l 2. PCE Responset l PGE does not consider this a violation for the reasons described below.

Engineering evaluation of the VT-3 reports reviewed by the inspector I were completed under PCE Nuclear Division Procedure (NDP) 600-1, Control of Nonconforming Parts and Components. This procedure establishes measures to assure that indeterminate and/or nonconforming l

items (as identified in the VT-3 reports in this case) will be ade-l I

quately documented and controlled, affected organizations will be I notified, corrective action responsibility will be appropriately assigned, recommended corrective action will be approved by res-ponsible management, and corrective action implementation will be independently verified.

1 1 VT-3 reports were generated during the outage due to rework and repnir

) associated with the Pipe support Design Verification Program and as a l result of inservice inspections of pipe supports. When the Quality control inspectors flagged conditions which they could not conclude were or were not nonconforming, they requested evaluation by NPE. NPE performed the evaluation in accordance with NDp 600-1 as they would for any potentially nonconforming item. In all cases, the VT-3 report flagged items were resolved through the NCR process. In a few cases, the QC inspector resolved a flagged item by reference to design documentation which demonstrated a nonconformance did not exist. In most of the cases, an NCR or Maintenance Request were needed to correct the identified nonconformance.

TDW/SAB/TRR/sf/2531W.888 I

_