ML20195H501
| ML20195H501 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 06/22/1988 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| GL-86-10, NUDOCS 8806280310 | |
| Download: ML20195H501 (4) | |
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Portland General ElectricCompany David W. Cockfield Vice President, Nuclear June 22, 1988 Trojan Nuclear Plant Docket 50-344 Licenso NPF-1 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington DC 20555
Dear Sir:
Response to a Notico of Violation Your lotter of May 23, 1988 transmitted a Notico 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 lotter.
Sincerely.
Attachment c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission l
Mr. Bill D'ixon j
State of Oregon Department of Energy Mr. R. C. Bare NRC Resident Inspector Trojan Nuclear Plant g
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A 8806280310 880622 PDR ADOCK 05000344 O
DCD w a w mui:iWe Powd O*eyn 97204 L
Trojan Nuclear Plant Document Control Desk Docket 50-344 June 22, 1988 Liaense NPF-1 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 Reguletory 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 ware 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 General Electric /PGE) 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 I
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 rystem survey performed by a licensed fire protection engineer in 1984, conclu-de6 these detectors should be removed since all of these detectors were in areas not requ'--d to achieve safe shutdown, did not comply with the spacing and locatior 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 modifications be maintained ad infinitum.
It reads:
"The licensee may proceed with and is required to com-l 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 bc completed
' R3 Trojen Nucistr Pitnt Document Control Desk Docket 50-344 Juno 22, 1988 License NPF-1 Attachment Page 2 of 3 by the end of the second refueling outage of the Trojan facility and prior to roturn 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 accordance with the schedule con-tained theroin.
In the event theso dates for submittal cannot be met, the licenseo shall aubmit a report explaining the circumstances, together with a revised schedulo".
PGE's interpretation of the license condition was that the fire detection system could be changed under the provisions of 10 CFR 50.59 and that NRC approval was not required for subsequent fire protection program changes.
{
As noted in Generic Letter 86-10. "Implementation of Fire Protection Requirements",'this has been a confusing issue industry-wido.. Generic Letter 86-10 notes that "variations have created problems for licensees and for NRC inspectors in identifying the operativo and enforceable fire protection requirements at each facility. These license conditions also create difficulties because they do not specify when a licenseo may make changes to the approved program without requesting a license amendment".
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It should be noted that the evaluation and decision to remove the 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 ihe modifications committed to be made as referenced in the Amendment No. 22 license 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 Trojan Final Safety Analysis Rcport.
Therefore, upon NRC approval of LCA 151 the ability to evaluato and modify fire protection program fea-I tures under 10 CFR 50.59 will be available.
That process will eliminate the potential of any similar violations.
Any discrepancies identified in the review noted in Item 2 above between the 1978 SER commitments and the present Plant configuration will be evaluated.
PGE will submit these completed evaluations for NRC review and approval.
These evaluations will either justify the present Plant configuration or stato the schedule for modifications, as necessary, to conform to the 1978 SER and Supplements.
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,C Trojan' Nuclear Plant-Document Control Desk
- Docket 50-344 June 22, 1988 i
License NPF-1 Attachment Page 3 of 3 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 review and approval by December 1, 1988.
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