ML20206J535
| ML20206J535 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/18/1988 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8811290023 | |
| Download: ML20206J535 (3) | |
Text
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W Gorieral MCorim David W. Cockfield Vice President, Nuclear November 18, 1988 Trojan Nuclear Plant Docket 50-344 l
License NPF-1 t
U.S. Nuclear Regulatory Comission ATTN Document Control Desk Washington DC 20555
Dear Sir:
Response to Notice of Violation Your letter of October 20, 1988 transmitted a Notice of Violation based f
upon iluelear Regulatory Comission Inspection Report 50-344/88-34. Our l
resp'snse to the Notice of Violation is provided in the attachment to this letter.
l Sincerely.
I I
Attachment et Mr. John B. Martin Regional Administrator. Region V U.S. Nuclear Regulatory Comission l
Mr. William T. Dixon State of Oregon f
Department of Energy Mr. R. C. Barr WRC Resident Inspector Trojan Nuclear Plant 68112900P3 001118 PDR ADOCK 0b000344 O
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Document Control Desk Document C:ntest Desk Docket 50-344 November 18, 1988 l
License NpF-1 Attachment i
page 1 of 2 RESPONSE TO NOTICR OF VI0tJ. TION I
Violation As a result of the innpection conducted on August 22-26, 1988, and in f
accordance with the "General policy and procedures for Nuclear Regulatory Comission (NRC) Enforcement Actions". Title 10, code of Federal Regulations Section 50, part 2, (10 CFR 50.2) Appendix C (1985), the following violation was identified:
10 CFR 50.48 required the licensee to install emergency lighting units with at least an 8-hour battery power supply in all areas needed for operation of safe shutdown equipment, and in access l
and egress routes thereto, in accordance with Section III.J of j
Appendix R to 10 CFR 50.
Accord 8.ng to the licensee's May 20, i
1987 letter to the NRC, the licensee completed implementation of I
required emergency lighting modifications prior to startup from
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the last refueling outage.
l Contrary to the above, as of August 23, 1988, there were no 8-hour battery k l
power supply emergency lighting units installed in the following areas
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needed for operation of safe shutdown equipment and in access and egress i
routes theretot j
a.
On the south wall and west of t% Intake Structure in support of f
m=nual actions.
b.
At the designated fire hydrant east of the circulating water
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pump pit in support of manual actions.
L c.
In the circulating water pump pit at the pump discherge and suc-
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tion valves in support of manual actions.
This is considered a Severity Level IV violation (Supplement No. 1.D).
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Responre I
portland General Electric (pCE) acknowledges the violation.
l l
1.
Reason for the Violation l
l Section III.J of Appendix R to 10 CFR 50 requires that "Emergency f
lighting units with at least an 8-hour battery power supply shall be l
provided in all areas needed for operation of safe shutdown equipment t
and in access and egress routes thereto".
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L In order to meet this requirement, pCE installed at fixed indoor loca-h tions, approximately 100 emergency battery lanterns (EBLs) with an
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8-hour battery power supply. However, at outdoor locations, it was not
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practical to install fixed E3Ls because of the lack of readily avail-l able power supplies and the difficulty in providing pectoctioa against harsh weather.
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e Document Control Deck Document Control Dock Docket 50-344 November 18, 1988 License NF7-1 Attachment page 2 of 2 As an alternative to ins'1111nf fixed EBLs in outdoor areas, the use of portable lighting re: ovnPJated.
From this evaluation it was concluded the use of portable lighting units, as described below, mot the require-ments of Section III.J on the basis that an equivalent 8-hour battery supply would be provided for those outdoor aress where the manual opera-tion of safe shutdown equipment was needed:
a.
Four weatherized portable lanterns with 6-hour pownr supplies were proulded in dedicated indoor storage locations. Because only two outdoor locations are required for lighting at any given time for tasks lasting 20-30 minutes, two additional lanterns are provided to give a combined 8-hour continuous lighting capability, b.
Mounting brackets were provided near outdoor components to guarantee proper light positioning and operator flexibility.
c.
plant procedures were revised to include provisions for the control and use of the portable lighting units.
Before the above actions were implemented, this approach was discussed with the Trojan NRC project Manager in Nuclear Reactor Regulation.
It was pCE's belief that an exemption for this approach was not required.
2.
Corrective Steps That Have Been Taken and the Results Achieved pCE will file an exemption request for use of the portable lighting units as currently implemented. To ensure the capability to respond with the portable lighting units, a night order was written on November 14, 1988 to it,struct the operators on use of the portable lighting units and where the lighting units and their mounting brackets are located.
3.
Corrective Steps That Will be Taken to Avoid Further Violatione pCE will file an exenption request for use of the portable lighting units as currently implemented.
4 Date When Full Compliance Will be Achieved The date when full compliance will be achievod is predicated on NRC approval of an exemption request for use of the portable lighting units as currently leptemented. This exemption request will be submitted to the NRC by December 31, 1988.
DRS/mr 3190P.1188