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Ack Receipt of in Response to NRC Re Violations Noted in Insp Rept 50-344/90-21
	ML20059M698
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	09/25/1990
From:	Richards S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cross J; PORTLAND GENERAL ELECTRIC CO.
References
	NUDOCS 9010050203
	Download: ML20059M698 (1)
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Attention:? Mr. James E.' Cross

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Gentlemen:

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Thank you for 'your' letter of September 14, 1990lLin response to our Notice of

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Violation and Inspection' Report nom 50-344/90-21, dated August-16, 1990,

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, informing us of the steps you haveitaken to correct th'e item whichLwen

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brought to your4 attention.: Your; corrective actions will be verified during a:

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Your coop,eration,with us)is' appreciated.

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James E. Cross Vice President, Nuclear.

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September 14 1990

Trojan ~ Nuclear Plant

Docket 50-344

License NPF-1-

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U.S.

vuclear Regulatory Conunission

A%N: Document Control Desk

Washington DC 20555-

Dear Sir:

Reply to a Notice of Violation

Your' letter of August 16, 1990 transmitted one Notice of Violation-(NOV)

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. associated with Nuclear Regulatory Conunission Inspection

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Report 50-344/90-21. Attachment 1 is our response to the NOV.

Sincerely,

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Attachment

c: Mr.-John B. Martin

Regional' Administrator. Region V

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U.S. Nuclear Rquiatory Commission

Mr. David Stewart-Smith

State of Oregon

. Department of. Energy

Mr. R. C..Barr

NRC Resident Inspector

Trojan Nuclear Plant

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121 SW Salmon St. Portland, OR 97204

503/464 8897

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Tro[an Nuefear~ Plan

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Docket 50-344

Document Control Desk'

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License NPF-1-

September 14, 1990.

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Attachment 1

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Page 1 of 4

JtEPLY TO NOTICE OF VIOLATION

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Violation

Technical Specification 3.7.9 states:

"All 3-hour penetration fire

barriers protecting safety related areas shall be. functional."

Limiting Condition for Operation 3.7.9.'a states in part'that "With one or

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more of the above required penetration fire barriers nonfunctional in.

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areas with'a combustible loading of greater than 1 lb/ft2 equivalent

wood, prpvide,either a continuous fire watch on at least one side'of the

affected; penetration within one-hour or verify the OPERABILITY of fire

detectors on-at least one side of the fire barrier and establish an

hourly fire watch patrol."

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On March 23, 1990 the 3-hour fire barrier between the 77-foot and 93-foot

level of the' Auxiliary Building (Fire Areas Al and A6).was declared

.non-functional by the-licensee and a continuous fire watch was

established for fire protincisi~ n.~ ~ ~ '

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\\ ontrary to the above, on July

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19, 1990, at approximately 7:00 a.m. the

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' fire watch was not continuous-in that the fire watch appeared to be

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' asleep and inattentive to his dutic:;.

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This is a' Severity Level IV violation (Supplement I).

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Response

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Portland General Electric Company (PCE) acknowledges the violation.

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Reason for the Violation:

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The violation was caused by personne1' error on the part of the posted

firewatch.

As outlined below,' Nuclear Security Operations Branch

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. Personnel, who man all firewatches, were, on several' previous

occasions, instructed on the necessity for attentiveness when

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assigned to firewatch duties. Personnel were briefed on various

methods and devices available to maintain attentiveness while posted.

as a firewatch.

In addition, the availability of relief watches,

with no stigma associated with relief requests, was emphasized.

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On April 19, 1990, the Branch Manager, Security Operations met

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with Security Department watchpersons and discussed the extreme

importance of being alert while on duty.

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was in attendance at the meeting.

The inattentive employee

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Docket 50-344

Document Control Deskc

_ September- 14.--1990

License NPF-1

Attachment 1

Page 2 of 4

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-* On June 8,' 1990, Nuclear Security Operations Branch personnel,;

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including the subject 1 inattentive ~firewatch, were issued- copies of

y memorandum by the the Branch Manager, Security Operations which

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detailed the elements of being inattentive and the-consequences of

. violating attentiveness requirements. Specifically, the memorandum

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,.:- . stated that indicators of inattention included.being in a

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. motionless state, failure to acknowledge the presence of personnel

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in the area, and being slumped in a chair. The memo also

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emphasized that' employees found inattentive were subject to

immediate tennination.

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On June 20, 1990 Nuclear.' Security Operations Branch personne11

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. were issued a memorandum by the Branch Manager, Security Operations

which again' addressed inattention to duty-and the fact that

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anti-sleep devices were now standard equipment available'for all

stationary security /firewatch posts.

Personnel were encouraged to

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utilize tho' devices. ~The inattentive firewacch in this: event:had

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. an anti-sleep device immediately available', but did not use it.

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On June 27, 1990, Nuclear Security Operations Branch personnel,

including the inattentive firewatch, were issued personal copies of

the Nuclear Division policy memorandum on " Attentiveness To Duty".

This memorandum, which was issued to all Nuclear Division

personnel, reiterated that inattentiveness-(defined as eyes closed,

in a relaxed position, and unresponsive to normal stimuli) would

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result in termination'on the first offense'.

0n June 28, 1990 . ica vests were made available for posted

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firewatches due to warm temperatures. * This action was communicated

to firewatches by means of additions to thair assigned post

orders.

Despite warm temperatures in the assigned area, the

inattentive firewate' /as not wearing an ice vest when this event

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occurred.

During the month of' July 1990; Nuclear Security Operations Branch

personnel attended briefings on Nuclear Division " Standards and

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Expectations". The cornerstones of these briefings were adherence

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to procedures.and attentiveness to duties. The inattentive

firewatch~ attended the briefings on July 3, 1990.

The inspection report noted that the individual involved in this

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event had previously been found inattentive at the same firewatch

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post in April of 1990.

Following the previous incident, he was

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counseled and a letter of discipline was placed in his flie.

Since

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this individual was a ten-year veteran of $.he Security Department who

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had not previously exhibited performance problems, he was allowed to

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Document Control Desk.

Docket 50-344

September 14, 1990-

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Attachment 1

Page 3 of 4

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continue his employment. .In keepin5 witL our June 1990 attentiveness

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policy. he was immediately terminated.following the second incident.

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In. summary, this. event resulted.from an isolated personnel. error

involving:antemployee:who violated. procedures _and. failed to utilize

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available methods.for ensuring! procedural compliance.

The employee

had Tocalved numerous, briefings -concerning attentiveness. - During

this incident he had;been~ posted as a firewatch for. a short time

(approximately:one-hour) prior to being_ discovered inattentive.

An

anti-sleep device and an ice-vest were immediately available but not

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used by the employee.

The employee's statement acknowledges his.

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inattentive-state and his belief that he was well-rested prior to

reporting.for duty. Also, a sufficient number of relief personnel

were available if a relief had been requested.'

2.

Corrective' Steps Taken and Results Achieved':

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As a result. of this event the subject individual's employment at the

Trojan Nuclear Plant was terminated on the day of the event.

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F011owing this incident, the Branch Manager, Security Operations met

with all Security operations Branch personnel to emphasize the need

for attentiveness.

In addition, a mandatory policy requiring either

standing or the use of an anti-sleep device was implemented for all

security personnel during assignments at stationary posts.

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Since the event.. attentiveness and use of anti-sleep devices have

been addressed at numerous pre-shif t: briefings.

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. The subject firewatch post has been changed from a two-hour to a

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one-hour assignment, and a continuous standing position is required.

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Ice vests remain available for firewatches.-

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3.

Corrective Steps That Will Be Taken to Avoid Further Violations:

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Based on recent events involving poor performance and/or aberrant

behavior we recognize the need to improve in this general area.

Our

Nuclear Division Improvement Plan, as described to the NRC at the

May 10, 1990 management meeting, is already addressing improvements

in the entire area of managing performance problems.

In addition,

enhancements are being made to our behavioral-observation program.

In addition to existing employee monitoring programs (e.g.,

behavioral observation Fitness for Duty) . Security Department

personnel with potential performance problems, including

attentiveness on' duty, will be closely monitored by supervisory

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Trojan Nuclear Plant

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Docket 50-344

Document Control Desk

' License NPF-1:

. September 14,!1990

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' Attachment 1

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personnel.:- supervisors will also be tasked with routine evaluation

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of:firewatch posts for conditions which might lead to attentiveness

difficulties (e.g., isolated location, machinery noise, elevated

temperatures). . Additional measures such as+one-hour. rotation and

mandatory standing position will be implemented as needed.

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Additional anti-sleep devices will:be-obtained-to ensure a continuing.

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sufficient quantity.

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Date When Full. Compliance Will Be Achieved:

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Full compliance was achieved on July 19, 1990 when~the inattentive

individual was replaced and a continuous firewatch was reestablished,

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ML20059M698

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