ML20153E938
| ML20153E938 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/29/1988 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8809070062 | |
| Download: ML20153E938 (3) | |
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David W. Cockfield Vice President. Nuclear August 29, 1988 Trojat Nt:cicar Plant Docket 50-344 License WPF-1 U.S. Nuclear Regulatory Comission ATTN Document Control Desk Washington DC 20555 Dear Sirt Eeply to a Notice of Violation Your letter of July 28, 1988 transmitted a Notice of Violation associated with Nuclear Regulatory Comission Inspection Report 50-344/88-27.
Attached is our response to that Notice of Violation.
Sincerely, Attachment et Mr. John B. M. t.in Regional Administrator, Region V U.S. Nuclear Regulatory Comissior.
Mr. Bill Dixon State of Oregon Department of Energy Mr. R. C. Barr NRC Resident Inspector Trojan Nuclear Plant 8809070062 800829 PDR ADOCK 05000344 G
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Docket 50-344 August 29, 1988 License NPF-1 Attachment q[
Page 1 of 2 s
REPLY TO A NOTICE OF VIOLATION Violation J
r Part 50.59(b',(1) to Title 10 of the Code of Federal Regulations,
[10 CFR 50.59(b)(1)] atates, in part, that "The licensee shall maintain records of chainges in the facility... made pursuant to this section, tn the extent that these changes constitute changes in the facility as des-cribed in the safety analysis report.
. These records must include a written safety evaluation... ".
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
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shown i.e Figure 2.1-5.
Figure 2.1-5 depicts the restricted ares as being i
dthin the invaediate site protected area boundary.
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l 10 CFR 20.3(a)(14) "Restricted Area" is defined, in part, as any area q
access to which is controlled by the licensee for purposes of protection i
of individuals from exposure to radiation and radioactive materials.
1 Section 11.4.2.5 of the licensee's FSAR states, in part, that the onsite j
storage facilities for packaged radioactive wastes is within the protected i
1 area boundary.
l Contrary to the above, as of June 30, 1988, the licensee had not perfomed j
a written safety evaluation for radioactive materials being stored outside of the protected area during the period of April 1987 through June 30, 1988.
This is a Severity Level IV Violation (Supplement I).
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Response
l Portland General Electric Company (PCE) acknowledges the violation, j
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Reason for Violation:
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The reason for the violation was procedural inadequacy.Section II.E.4 I
of the Radiation Protection Manual (RPM) allows storage of radioactive /
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contaminated material "... in areas approved by the Radiation i
Protection Supervisor." This section of the RPM does not reference l
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Section 11.4.2.5 of the FSAR which specifically describes storage l
areas.
In addition, the RPM does not require the Radiation Protection j
Supervisor to perfom a safety evaluation when' opproving a new storage
- area, i
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Trojan Nue10cr Plcnt Document Contr:1 Desk
- ' osk;t 50-344 August 29, 1988 D
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 te, a new storage location immediately adjacent to tha 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 woro not moved to the storage area incide the pr9tected area due to space limitations.)
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:
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.
4 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 l
performed.
i TDW/SAB/DLN/mr 2534W.888 I
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