IR 05000344/1988027

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-344/88-27
ML20154H104
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 09/09/1988
From: Yuhas G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To: Cockfield D
PORTLAND GENERAL ELECTRIC CO.
References
NUDOCS 8809210175
Download: ML20154H104 (1)


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Oocket No. 50-344

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Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Attention:

Mr. David W. Cockfield Vice President, Nuclear Thank you for your letter of August 29, 1988, in response to our Notice of Violation and Inspection Report No. 50-344/88-27, dated July 28, 1988, informing us of the steps you have taken to correct the items which we brought to your attention.

Your corrective actions will be verified during a future inspection.

Your cooperation with us is appreciated.

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Sincerely, c

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G. P. Y6has, Chief Emergency Preparedness and Radiological Protection Branch bec w/ copy of letter 8/29/88:

I docket file State of Oregon A. Johnson

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G. Cook B. Faulkenberry

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J. Martin Resident Inspector Project Inspector

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REGION V

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David W. Cockfield Vce President, NupI'$EP i All: 06 c

August 29, 1988 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Com).ssion ATTN:

Document Control Desk Washington DC 20555

Dear Sir:

Reply to a Notice of Violation

- letter of July 28, 1988 transmitted a Notice of Violation associated

.h Nuclear Regulatory Comission Inspection Report 50-344/88-27.

,tached is our response to that Notice of Violation.

Sincerely

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Attachment c:

John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. Bill Dixon State of Oregon Department of Energy Mr. R. C. Bare NRC Resident Inspector Trojan Nuclear Plant

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Trpjtn Nucicer Plcnt Document Crntrol Desk

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Docket 50-344 August 29, 1988

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License NPF-1 Attachment Page 1 of 2 REPLY To A NOTICE OF VIOLATION

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violation Part 50.59(b)(1) to Title 10 of the Code of Federal Regulations.

[10 CFR 50.59(b)(1)) states, in part, that "The licensee shall maintain records of changes in the facility.

. made pursuant to this section, to

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the extent that these changes constitute changes in the facility as des-cribed in the safety analysis raport... Th9se records must include a written safety evaluation.

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Section 2.1.1.3 of the licensee's Final Safety Analysis Report (FSAR)

states, in part, that the restricted area as defined in 10 CFR 20, is shown in Figure 2.1-5.

Figure 2.1-5 depicts the restricted area as being within the immediate site protected area boundary.

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10 CFR 20.3(a)(14) "Restricted Area" is defined, in part, as any area access to which is controlled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials.

l Section 11.4.2.5 of the licensee's FSAR states, in part, that the onsite i

storage facilitics for packaged radioactive wastes is within the protected area boundary.

Contrary to the above, as of June 30, 1988, the licensee had not performed a written safety evaluation for radioactive materials being stored outside of the protected area during the period of Apell 1987 through June 30, 1988.

This is a Severity Level IV Violation (Supplement 1).

Response Portland General Electric Company (pCE) acknowledges the violation.

1.

Reason for Violation:

The reason for the violation was procedural insdequacy.

Section II.E.4 of the Radiation Protection Manual (RPM) allows storage of radioactive /

contaminated material "... in areas approved by the Radiation Protection Supervisor." This section of the RPM does not reference Section 11.4.2.5 of the FSAR which specifically describes storage areas.

In addition, the RPM doos not require the Radiation Protection Supervisor to perform a safety evaluation when approving a new storage area.

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Dockat 50-344 August 29, 1988

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License NPF-1 Attachment Page 2 of 2 2.

Corrective Action Taken and Results Achieved:

a.

The radioactive material has been either shipped offsite or moved to a new storage location immediately adjacent to the protected area boundary.

This area is within a locked fence, providing improved access control, and is large enough to handle the trailers on which the radioactive material is being stored.

(The trailers were not moved to the storage area inside the protected area due to space limitations.)

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b.

A safety evaluation has been performed for alternate storage locations, including the fenced area where the trailers were moved. The evaluation concluded that no unreviewed safety or environmental questions were involved and that personnel are adequately protected from exposure to radiation and radioactive materials.

3.

Corrective Action to Avoid Further Violations:

i Section II.E.4 of the RPM is being revised to include additional guid-ance for designating radioactive / contaminated material storage areas.

The revision will include specific direction to perform a safety evaluation and is scheduled for completion by October 31, 1988.

Date When Full Compliance Will be Achieved:

Full compliance has been achieved, since the radioactive materials are now being stored in a location for which a safety evaluation has been performed.

TDW/SAB/DLN/mr 2534W.888 i