ML19209C911
| ML19209C911 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/05/1979 |
| From: | Frank L OREGON, STATE OF |
| To: | Goodwin C PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 7910180468 | |
| Download: ML19209C911 (2) | |
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LAdOR & INDUSTRIES BUILDING. ROOM 11 t SALEM. OREGON 97310 PHONE 378-4040 October 5, 1979 60 ' 3 Charles Goodwin Portland General Electric Co.
121 S.W. Salcon Portland, OR 97204 b
Dear Mr. Goodwin:
BACKGROUND Portland General Electric Comoany's letter dated August 13,1979 re-quested NRC approval of license amendment (LCA55) for its Trojan Nuclear Plant.
The change reflects reorganization of the plant staff.
PGE has provided the Oregon Decartment of Energy with a copy of the proposed changes for comment.
DISCUSSION Currently the person responsible for radiation controls at Trojan re-ports to the Plant "anager. As propose 3, the Radiation Protection Super-visJr would report to the Manager, Tecnnical Services, 'aho reports to the Plant Mana ger.
The Department is concerned about this change because it reverses PGE's previous efforts to increase management attention to ra-diation controls.
The Department believes tnat effective mnigerent cf radiatior. controls can be improved by (1) having the Radiation Protection Supervisor report to the Plant Manager; (2) requirinq the Sianager, Technical Services, to nave the qualifications equivalent to lagulatory Suice 1.2; or (3) en-suring adequate off-site responsibility and authority in the area of radia tion controls.
P'IE has the capdoi'i ty to accor:Ulisn sj o f +he above, out none of these options are reflected in the pro:Osed licens' change.
It is understocc that the pro.sosed chanjes have reen under consideration for several months and that indivicuals have been informally acvised of ti.ei r assi gnments.
Given the ;ignifica::: cancern craviously expressa dbout this issue, it is anfortuna p tha; the pi r 2d reorgsnization could not ham been discussea sarlier I recognize :nat m.anagement of the clar i: your responsibility -- not mine -- out we do nave a responsibility to ensur? that safety considera-tions, inclucing raciation orotection,
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Charles Goodwin I
cortland General Electric Co.
I Jfl iL Outober 5,1979 While any of the three alternatives offered would resolve our concerns about radiation protection reporting, the extended delay in implementing the reorganization and the informal notice of assignment practically pre-clude the first two options.
Consequently, only the third option may well be available.
The Radiation Protection Supervisor at Trojan is responsible for estab-lishing procedures to ensure compliance with radiation protection regu-lations and for the day-to-day implementation of T. hose procedures.
PGE has additional radiation control expertise outside Trojan.
This exper-tise through the Radiation Protection Corrmittee, t'uclear Operations Board and ticclear Projects Quality Assurance Departrent provides advice, review of major. issues and audits for compliance with plant procedures.
The existing off-site organizational structure does not, however, assign any one individual the responsibility for establisning a radiation pro-tection program at Trojan and the authority to ensure plant compliance wi th tha t program.
Establishing the off-site responsibility and authority may well strengthen the radiation protection effort.
For example, if the off-site persons knowledgeable in radiation protection had the authority to require im-provements at Trojan along with the resconsibility for ensuring the res-olution of problems, then the on-site supervisor would be free to manage day-to-day implementation of the program. Additionally, the off-site group vo"1d be better able to work with other off-site groups to resolve i2 sues that inhibit effective radiological controls, such as inadequate equipment design. A comprehensive review may identify equivalent methods for increasing management attention to mdiation controls.
ACTION Wh.le we would concur witn tne proposed recrganization at Trojan, we do consider it essential to ensure adequata responsibility for radiation controls.
I am therefore requesting a written management review of the responsibility and authority for tne radiation orotection program for the purpose of identifying how increasej management a ttention could be given to this area.
In a broader sense, I believe that PGE's review would be enhanced if it took a similar look at other areas relating to support of Trojan A res;'onse is requested by hmoer 30,1979, on how PGE's review aill ce performed and anen it aill be completed.
Sincerely, As I
l//;*;?);') l, fQn :W-Lyffn Frank Director LF '03:swd
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cc C. Trammel, iRC R. Engleken, NRC 'l P. Yundt, Trojan