ML20151B957
| ML20151B957 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/08/1988 |
| From: | Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| References | |
| NUDOCS 8807210171 | |
| Download: ML20151B957 (1) | |
See also: IR 05000344/1988017
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JUL - 81988
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Docket No. 50-344
Portland General Electric Company
121 SW Salmon Street
Portland, Oregon -97204
Attention:
Mr. David W. Cockfield
Vice President, Nuclear
Gentlemen:
Thank you for your letter dated June 22, 1988,-in response.to our Notice of
Violation and Inspection Report No. 50-344/88-17, dated May 23, 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.
Sincerely,
Ori inaJ S',9ned
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Robert J. Pate, Chief
Reactor Safety Branch
bec w/ copy of letter cated 6/22/88:
Resident Inspector
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Project Inspector
G. Cuck
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A. Johnson
B. Faulkenberry
J. Martin
J. Zollicoffer
Docket File
bcc w/o copy of letter dated 6/22/88:
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RECEIVED
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NRC
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Portland General Electric Company
REGION V
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David W. Cockfield Vice President. Nuck
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June 22, 1988
Trojan Nuclear Plant
Docket 50-344
Licenso NPF-1
U.S. Nuclear Regulatory Cennission
Attn:
Document Control Desk
Washington DC 20555
Dear Sir:
Response to a Notice of Violation
Your lotter of May 23, 1988 transmitted a No'. ice of Violation based upon
Nuclear Regulatory Commission Inspection Report 50-344/88-17, Fire
Protection Program Implementation.
Our response to the Notico of Violation
is provided in the Attachment to this letter.
Sincerely,
,
Attachment
c:
Mr. John B. Hartin
Regional Administrator, Region V
U.S. Nuclear Regulatory Commission
Mr. Bill D'ixon
State of Oregon
Department of Energy
Mr. R. C. Barr
NRC Resident Inspector
Trojan Nuclear Plant
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Trajtn Nuclotr Pltnt
Docket 50-344
Document Control Desk
License NPF-1
June 22, 1988
Attachment
Page 1 of 3
RESPONSE TO A NOTICE OF VIOLATION
Violation:
As a result of the inspection conducted on April 18-21, 1988, and in accor-
dance with the "General Policy and Procedures for Nuclear Regulatory Commis-
sion (NRC) Enforcement Actions" Title X, Code of Federal Regulations, Part 50
(10 CFR 50), Part 2, Appendix C (1987), the following violation was identified:
Amendment No. 22 to Facility Operating License No. NPF-1 required the
installation of early warning fire detectors over the radwaste storage
area, new fuel storage area, and the spent fuel pool storage area of the
93-ft elevation of the Fuel Building by the end of the 1979 Refueling
Outage.
Contrary to the above, as of April 20, 1988, the required fire detectors
for the radwaste storage area, the new fuel storage area, and spent fuel
pool storage area of the 93-ft elevation of the Fuel Building were not
installed.
No fire detectors were installed to provide the required
early warning capability.
This is considered a Severity Level IV violation (Supplement 1.D).
Portland Gen 9ral Electric (PCE) Response:
PGE acknowledges the violation, in part, as outlined below.
1.
Reason for the violation:
PGE has verified that the subject fire detectors were installed prior to
the end of the 1979 Refueling Outage as required by Amendment No.
22 to
the Operating License.
The subject detectors were subsequently removed. A fire detection system
survey performed by a licensed fire protection engineer in 1984,
conclu-
ded these detectors should be removed since all of these detectors were
in areas not required to achieve safe shutdown, did not comply with the
spacing and location requirements of National Fire Protection Association
(NFPA) 72E, "Automatic Fire Detectors", and if installed per NFPA 72E
would not respond adequately to smoldering fires.
,
The wording of the license condition contained in Amendment No. 22 did
not specifically require the mrdifications be maintained ad infinitum.
It reads:
"The licensee may proceed with and is required to com-
plete the modifications identified in Paragraphs 3.1.1
through 3.1.18 of the NRC's Fire Protection Safety
Evaluation Report on the Trojan Nuclear Plant dated
March 22, 1978.
These modifications shall be completed
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Tesjan Nuclear Plant
Docket 50-344
Document Control Desk
License NPF-1
June 22, 1988
Attachment
Page 2 of 3
by the end of the second refueling outage of the Trojan
facility and prior to return to operation for Cycle 3.
In addition, the licensee shall submit the additional
information identified in Table 3.2 of this safety
Evaluation Report in ac,cordance with the schedule con--
tained therein. In the event these dates for submittal
cannot be met, the licensee shall submit a report
explaining the circumstances, together with a revised
schedule".
PCE's interpretation of the license condition was that the fire detection
system could be changed under the prtvisions of 10 CFR 50.59 and that NRC
approval was not required for subseqtent fire protection program changes.
As noted in Generic Letter 86-10, "I.aplementation of Fire Protection
Requirements", this has been a ca.iusing issue industry-wide.
Generic Letter 86-10 notes that "variations have created problems for licensees
and for NRC inspectors in identifying the operative and enforceable fire
protection requirements at each facility.
These license conditions also
create difficulties because they do not specify when a licensee may make -
changes to the approved program without requesting a license amendment".
It should be noted that the evaluation and decision to remove thn detec-
tors occurred well before the issuance of Generic Letter 86-10,
2.
Immediate corrective action:
PGE has initiated a review of the status of the modifications committed
to be made as referenced in the Amendment No. 22 licenso condition.
3.
Corrective steps to be taken to avoid further violations:
PGE submitted License Change Application (LCA) 151, "Fire Protection Pro-
gram" to the NRC on December 24, 1987 to implement the standard fire
protection license condition recommended by Generic Letter 86-10.
The
Trojan Fire Protection Program is currently, by reference, part of the
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Trojan Final Safety Analysis Report.
Therefore, upon NRC approval of
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LCA 151 the ability to evaluate and modify fire protection program fea-
tures under 10 CFR 50.59 will be available.
the potential of any_similar violations.
That process will eliminate
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Any discrepancies identified in the review noted in Item 2 above betwoon
the 1978 SER commitments and the present Plant configuration will be
evaluated.
PCE will submit these completed evaluations for NRC review
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and approval.
These evaluations will either justify the present Plant
configuration or state the sebe ule for modifications, as necessary, to
conform to the 1978 SER ano Supplements.
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Trojan Nuclear Plant
Document Control Desk
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Docket 50-344
June 22, 1988
License NPF-1
Attachment
Page 3 of 3
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4.
The date when full compliance will be achieved:
Approval of LCA 151 by the NRC is on. hold, pending issuance of additional
generic guidance. PGE will revise LCA 151 as required to comply with NRC
requirements.
The evaluations and/or modification plans described in Item 3 above will
be submitted for NRC revidw and approval by December 1, 1988.
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