IR 05000344/1989005

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/89-05

ML20247Q976
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/01/1989
From:	Mendonca M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8906070101
Download: ML20247Q976 (1)

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> Docket' No. ; 50-344 t

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. Portland' General / Electric Company

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121lSW Salmon' Street', TB-17

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. Portland, Oregon 97204,

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, iAttention: 'Mr.- David'W..Cockfield

14 Vic6 President, Nuclear p, .

s e Gentlemen:

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Thank!you for your. letter ' dated May 19, 1989, in* response to our Notice'of Violation and 50-344/89-05,. dated April 19, 1989,

" informing'usfoInspection f the' steps Report you have No.taken to correct-the-items which we brought

.to.your. attention. .Your corrective actions;will be verified during af future

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Your cooperation with us isOppreciated.

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Sincerely,

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M. M. Mendonca, Acting" Chief =

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Reactor Projects; Branch'

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r bec w/ copy of[' letter dated 5/19/89: 1-Docket File <

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Resident Inspector Project Inspector

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0 .A. Johnson' .

, B. Faulkenberry J. Martin- 1 LFMB-State of Oregon-I ' '

bec w/o , copy. of letter' dated 5/19/89

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mumme 5 Portland General Electric C0ii vis or

David W. Cockfield Vice President, Nuclear May 19, 1989 Trojan Nuclear Plant Docket 50-344 License NPP-1 U.S. Nuclear Regulatory Commission.

ATTN: Document Contrcl 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 Nuclecr Regulatory Commission Inspection Report 50-344/89-05.

Attached is our response to that Notice of Violation.

Sincerely,

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Attachment [;

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c: . John B. Martin ro Regional Administrator, Region V

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P U.S. Nuclear Regulatory Commission y E

.. .; H Mr. William T. Dixon a

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l State of Oregon e Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant l

l 121 S W Salmon S9eet Potat O'egan 97204 1 A C A :r o L tv i cm I

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Trojtn Nuciccr Plcnt Document Contr:1 Deck

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Dock;t 50-344 Attachment

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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),

Appendix B Criterion V, s' cates, 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."

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

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material was identified and documented on a Noncenformance Report (NCR) i form, but the NCR was not processed in accordance with the established Quality Assurance (QA) Program procedures.

This is a Severity Level IV violation (Supplement 1). ]

REPLY TO VIOLATION A Portland General Electric Company (PGE) acknowledges the violation:  !

1. Reason for Violation: j The reason for this violation was personnel error. An NCR was initiated, but the initiator's supervisor failed to follow Nuclear j Division Procedure (NDP) 600-1, " Control of Nonconforming Materials, 4 Parts, and Components," by not assuring the NCR was processed I through to the Nuclear Quality Assurance Department (NQAD). An NCR was clearly necessary to document and evaluate the deficient j

characteristics of the filler material.

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, Trojan Nuclosr Plant Documsnt Control D3sk

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, " Docket 50-344 Attachmsnt License' NPF-1 May 19, 1989 Page 2 of 4 2. Corrective Steps Taken and Results Achieved:

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 wold filler material will not be issued for use While the NCR is being dispositioned, b. The original NCR was properly transmitted to NQAD, assigned number 89-172 on May 10, 1989, and is being properly processed in accordance with NDP 600-1. The disposition of the NCR will address any use of the weld filler material onsite before it was placed on hold under NCR tags.

c. Nuclear Division nanagement has placed additional continuing emphasis on procedural compliance in the time since the occurrence of this violation. On December 21, 1980, 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 levels, 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 Wheu Full Compliance Will Be Achieved:

Full complianew was achieved with the issuance of NCR 89-172.

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TrajCn NuclGar Plcnt Document Control D ck Et ,

Dockat 50-344 Attachment

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' L3 cense NPF-1 fly 19, 1989

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Page 3 of 4 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 l

revised drawings within 90 days of issuance or whenever the number of l

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, Drawing 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 tho 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-related drawings has been elevated. The Nuclear Plant Engineering Department now receives a computer printout of all open DCNs and their associated due dates biweekly. Procedural-ization of this process was completed March 16, 1989. This 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.

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'Trojcn NuclC r Plcnt Document Contr31 Desk

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May 19, 1989 Page 4 of 4

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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

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