ML19331B595
| ML19331B595 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/08/1980 |
| From: | Goodwin C PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8008120478 | |
| Download: ML19331B595 (2) | |
Text
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Pcdland General Elechic Ccgany 4
al aman yym accer.n e a s sn.. a w-August 8, 1980 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555
Dear Sir:
Portland General Electric Company (PGE) provides the following response to your letter of June 17, 1980 concerning a postulated Fuel Handling Accident Inside Containment (FRAIC). The NRC Safety Evaluation of the FRAIC attached to your letter of June 17, 1980 concluded that equipment modifications and/or Technical Specification changes are required at the Troj t, Nuclear Plant to provide assurance that the limits of 10 CFR 100 are not exceeded following an FRAIC. PGE believes that the NRC Safety Evaluation utilizes overly conservative assumptions and models which greatly overpredict the activity released and subsequent offsite doses as a result of an FRAIC.
Specifically, PGE still contends that the fuel gap activities are over-estimated in Regulatory Guide 1.25 by at least an order of magnitude and that thermal convection in the refueling cavity would greatly reduce the activity released to the atmosphere. These contentions were substantiated by analyses, tests and scientific literature submitted to the NRC by letters on January 10,1977, March 7,1977, October 19, 1977, October 7, 1978 and November 2, 1978.
"7E also believes that the NRC Safety Evaluation insufficiently addressed the effect of an area radiation monitor located on the refueling cavity manipulator crane. An area radiation monitor, with Containment isolation capability, located on the crane, would detect rising radiation levels prior to the activity escaping from the refueling cavity water. Suffi-cient time would be provided to prevent escape of all or part of the activity from the Containment.
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Porthuld W MCcuiperly Mr. Robert A. Clark August 8, 1980 Page 2 PGE also believes that a fucl handling accident over the reactor core involving more than one fuel assembly would not significantly increase offsite doses because of the increased mixing volume above the refueling cavity if the accident occurred in the core area. Additionally, the velocity of air over the refueling cavity from the refueling pool exhaust system is minimal over the core area.
While ICE does not agree with the above overconservative assumptions and models used in the NRC Safety Evaluation, PGE has decided to not further contest the Safety Evaluation at this time. The NRC letter of June 17, 1980 required PGE to submit a License Change Application (LCA) incorporat-ing one of three options. Accordingly, PGE selects Option 3 which will restrict Containment purge / exhaust fan operation during actual fuel movement inside Containment for the first 285 hr. following reactor shutdown. An LCA incorporating the above requirement will be forwarded to you as soon as possible. The above restriction will be implemented prior to the next refueling shutdown currently scheduled for spring 1981.
Please contact me if questions arise on this matter.
Sincerely, 4
e S. J C. Goodwin, Jr.
Assistant Vice President Thermal Plant Operation and Maintenance CG/JWL/MQH/4mg3A10 c:
Mr. Lynn Frank, Director State of Oregon Department of Energy
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