ML20236X803

Notice of Violation from Insp on 870921-25.Violation Noted: Adequate Measures Not Yet Established to Ensure Appropriate Review of Fire Protection Program Activities

ML20236X803
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/25/1987
From:	Pate R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20236X774	List: IR 05000344/1987034 ML20236X772 ML20236X803
References
50-344-87-34, NUDOCS 8712100279
Download: ML20236X803 (3)

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i APPENDIX A l

NOTICE OF VIOLATION _

l Portland General Electric Company Docket No. 50-344 Trojan Nuclear Plant License No. NPF-1 As a result of the inspection conducted on September 21-25, 1987, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR 50, Part 2, Appendix C (1985), the following violations were identified: i

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A. Technical Specification 6.8.1 requires that written procedures be established, implemented and maintained covering the activities of the fire protection program. Technical Specification 6.8.2 requires that each procedure or administrative policy, and changes thereto, including tamporary changes, be reviewed and approved prior to implementation as set forth in Technical Specification 6.5.3. Technical Specification 6.5.3.1 states, in part, that " Proposed changes or modifications to plant nuclear safety-related structures', systems and ccmponents shall be reviewed by a qualified individual / group other than the individual / group which designed the modification" and that "Each such review shall be performed by ouslified personnel of the appropriate discipline."

l The licensee _: lear Quality Assurance Program, Section 2.0, Appendix A, " Quality Assurance and Administrative Controls for Fire Protection,"  ;

states, in part, that " Measures will be established to assure that new '

designs and plant modifications, including fire protection systems, are reviewed by qualified personnel to assure inclusion of appropriate fire protection requirements." ,

Contrary to the above, on September 25, 1987, adequate measures had not yet been established to ensure appropriate review of fire protection program activities in that: '

1. The licensee's Nuclear Division Procedure No. 200-1, " Design Change Control," referenced fire pr0tection interface control of Design Change Packages (DCP's), but did not require that personnel qualified in fire protection review proposed changes or j

modifications to ensure inclusion of appropriate fire protection i requirements. The licensee acknowledged that there was no I consistent policy in place to require the review be perforned by a j fire protection engineer; the licensee also could not demonstrate i that a qualified fire protection engineer had reviewed all DCP's relating to fire protection.

This is a Severity Level IV violation (Supplement 1.D).

B. 10 CFR 50, Appendix B, Criterion XVI, and the licensee's Nuclear Quality  ;

Assurance Program, Section 16.0 and Section 2.0, Appendix A, paragraph h, l require, in part, that "In the case of significant conditions adverse to quality, (the) measures shall assure that the cause of the condition is determined and corrective action taken to preclude repetition."

8712100279 871125  :

PDR ADOCK 05000344 l G PDR l

F. .

~2-Licensee Nonconforming Activity Report (NCAR) No. P86-123, issued in January,1987, identified that " Supervisors issuing welding and cutting permits were not trained or experienced appropriately to perform that activity." The NCAR also stated that the same deficiency was identified by a licensee audit in December, 1983.

Contrary to the above, as of September 25, 1987, adequate corrective action to NCAR No. P86-123 was not accomplished to assure that the cause of significant conditions adverse to quality were corrected to preclude repetition: All supervisors issuing welding and cutting permits had not been trained to perform this activity in accordance with the corrective action contained in NCAR No. P86-123. Furthermore, some untrained supervisors have regularly issued welding and cutting permits.

This is a Severity Level IV violation (Supplement 1.D).

C. Technical Specification Nos. 6.2.2(F) and 6.4.2 require that a 5-man site fire brigade be maintained on site at all times and require training for the fire brigade to meet or exceed the requirements of NFPA 27-1975.

NFPA 27-1975 requires that fire brigade training programs be adapted to the purpose of the particular brigade and the program be maintained so that the brigade's ability to perform the operations they are expected to carry out is maintained.

Contrary to the above, as of September 25, 1987, the licensee's training program for fire protection had not been maintained so that the brigade's ability to perform the operations they are expected to carry out is maintained as follows:

1. The sice fire brigade receives no training in fighting internal structural fires.

2. Because the licensee discontinued the site fire brigade's extinguishment of external structural fires during outside practice sessions, the fire brigade no longer receives this training.

3. The offsite fire department has received no tours of plant vital areas to familiarize themselves with the plant layout and simulate the use of firefighting equipment in support of the site fire brigade. ,

4. The offsite fire department had not been educated in the operational precautions and specific radiological conditions that might be present during abnormal conditions while supporting fire brigade firefighting activities in various areas of the plant.

5. Despite an offsite fire department a0rcement that has been in force since February 6,1974, specifying that all offsite fire department personnel assisting in fire fighting activities at the site be-provided with security clearances to gain access to the site, offsite fire department personnel have received no security l

1 clearances or site access badges. This has resulted in continuous- l denied or delayed site access to offsite fire riepartment personnel when responding to the site on fire emergencies. l

6. The offsite fire department's copy of the site pre-fire plans was outdated and there was no licensee system in place to promptly update the plans to assure that the offsite fire department is kept .'

abreast of changes to the plans as they occur.

7. The offsite fire department agreement with the site did not clearly specify the responsibilities and expectations of both parties.

This is a Severity Level IV violation (Supplement 1.0).

Pursuant to the provisions of 10 CFR 2.201, Portland General Electric Company is hereby required to submit a written statement or explanation to the U. S.

Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, Region V, within 30 days of the date of the letter transmitting this Notice. This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation if admitted, (2) the corrective steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should nct be taken. Consideration may be given to extending the response time for good cause shown.

FOR THE NUCLE R REGULATORY COMMISSION obert J.'Pate, Chief Reactor Safety Branch Dated at Walnut Creek, California this 25 thday of Novembe r , 1987

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