ML20030C454
| ML20030C454 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 08/19/1981 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| TAC-43461, NUDOCS 8108260123 | |
| Download: ML20030C454 (5) | |
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Portland General BectricCompany r
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Donaid J Broehl Assistant Vce Presdent August 19, 1981 Trojan Nuclear Plant
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Docket 50-344 License NPF-1
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Director of Nuclear Reactor Regulation
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ATTN:
Mr. Robert A. Clark, Chief k
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Operating Reactors Branch No. 3 g
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C Division of Licensing
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U. S. Nuclear Regulatcty Commission ik h2 gQ Washington, D. C. 20555
Dear Mr. Clark:
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Your letter of July 31, 1981 provided us with a Draft Facility Attachment i
(FA) for Safeguards Application at Trojan Nuclear Plant. We have review:J L
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the FA and provide the attached comments.
i We understand that the FA is a standard document which applies to various types of facilities throughout the world. As such, the language in the FA is intended to be broad and gereral. We agree with your comments that clarifying details need to be added in order to implement the FA.
The i
attached comments were prepared to identify such areas. We plan to forward proposed words to clarify those items of the Facility Attachment on which our comments are based for your consideration in implementation.
Federal Regulation 10 CFR 75.S.(b) states that "The Commission will issue license amendments, as necessary, for implementation of the principle text of the agreement and the Facility Attachment" (emphasis added).
Since the Safeguards Application at the Trojan Nuclear Plant is scheduled to last for only two to three years, and since the FA is too broad and ambiguous to be used for a license document, we do not believe that issuance of a license amendment referring to the FA is an effective implementation mechanism. An NRC letter setting forth the specific requirements to be met would provide a positive means to accomplish the same result as a license amendment. We request that the NRC
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8108260123 810819 PDR ADOCK 05000344 PDR p
O RW Swen Ste. Prandi Oregen 97204
Portland General Electric Company Mr. Robert A. Clark August 19, 1981 Page two reevaluate the necessity and difficulty of implementing the FA through a license condition.
Sincerely, S
Attachment c:
Lynn Frank, Director State of Oregon Department of Energy l
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i ATTACHMENT 1 Sheet 1 of 3 Trojan Nuclear Plant Comments to Facility Attachment (May 1981 Draf t)
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Item Code Page Comments 1
2.2 2
Requirements for an advance notification should be clearly specified as 70 days before modificatiens affecting items in the DIQ are scheduled to be complete.
It should also be clarified that no IAEA approval for modifications are required and the modifications can be initated without prior notifi-cation or review by the IAEA and the NRC.
Language describing areas for notification are too broad and should be changed to limit notifications only to sub-stantial changes.
Clarifying details should be added to specify the magnitude of changes requiring reporting.
Particular creas of concern are changes in design of reactor fuel, nominal enrichment of the fuel, refuel-ing equipment or methods, access routes to the reactor area, equipment for assemblying/disassenblying of fuel assemblies, and introduction of new heat removal equipment.
2 3.1.1 3
The material balance area for Trojan should be specified for the reactor facility inside the security fence.
3 3.1.3 3
Nominal timing for the physical inventory of at least once per year should be clarified as every refueling, since that is the only time a physical inventory can be taken.
4 3.1.3 3
" Identification" for a physical inventory needs to be clarified to only verify the existence of fuel assemblies.
It should not require any special method such as verification of serial numbers or actual lifting of assemblies in the spent fuel pool. Since the word " Identification" appears in various places of the Facility Attachment, there should be a clear definition of " identification".
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,.1 5&7 10 CFR 75.3.(b).1 exempts "special nuclear material 4.2 8
in gram quantities or less as a sensing component in 5.1.1 9
instruments". This exemption applies to an instru-ment such as fission chamber. On the other hand, the Facility Attachment requires accounting of small quan-tity nuclear material (each less than 0.01 effective kilogram).
This requirement in the Facility Attachment needs to be deleted to be consistent with 10 CFR 75.
6 5.1.2 10 See Item 4 above for definition of " identification".
ATTACHMENT 1 Sheet 2 of 3 Item Code Page Comments 7
5.2.1 10 Since the operating data are to establish changes in the quantities and composition of nuclear material, information regarding specific location of certain fuel assembly seems unnecessary.
Identi-fication of location (ie, core, fresh fuel storage or spent fuel storage) in general should be satis-factory enough.
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11-13 Reporting requirements are delineated in 10 CFR 75.31 through 35 which correlate the requirements to the existing NRC/ DOE Forms 741 and 742. However, some inconsistency exists between these requirements which could be resolved by additional clarifications.
Form 742 is required to be submitted twice a year while the IAEA material balance report only needs to be submitted once a year (30 days af ter discharge). We agree with the IAEA requirement for upon-discharge reporting and suggest the NRC modify the 742 Form instruction to be consistent with the IAEA require-ment for the safeguard application plant.
Specifically, 742 and 742C Forms should be required only upon reft.aling of the reactor to satisfy the IAEA requirements.
Only 742 Forms (not 742C Forms) should be required on March 31 and September 30 every year.
Instructions for completing 742C Forms should allow reporting of data by attaching computer output of indi.idual fuel assembly isotopic weights, since transferring data from the computer output to the forms would be unnecessarily cumbersome.
The 741 Forms should not be used to report burnup and decay, since they are not designed for this purpose. Burnup and decay can be determined by comparing values reported on 742 Forms in successive reporting periods and it should not be necessary to report these values on additonal forms.
9 6.2.2 12 Precise forecast is an improper use of words. By definition, a forecast cannot be precise. The use of "best" to modify forecast would be appropriate.
10 6.3.2 13 The batch data for only KMP A will be based on the shipper's record. KMPs B and C will be based on operator's data. This paragraph as well as Code 4.2 on Page 8 need to be changed accordingly.
ATTACHMENT 1 Sheet 3 of 3 Item Code
. Page Comments 11 7.3 14 See Item 4 above for definition of " identification".
4 12 7.4.2, 15 See Item 4 above for definition of " identification".
l 7.4.3 i
13 7.4.4 15 The Auxiliary Building does not constitute a strategic i
l point for Containment and surveillance of nuclear i
material.
It should be changed to Fuel Building.
I 14 7.4.3 15 The Seals on containers of fresh and irradiated fuel are provided by shipper / suppliers. It should be 4
noticed that PGE can only verify the integrity of the seal visually. A statement regarding "other seals" needs to be specified.
15 7.5 15 It should be clarified in a license amendment that equipment discussed here is the IAEA's own equipment.
Furthermore, it should be specified that use of the i
IAEA equipment will be arranged for when it would not impact Plant Operations / refueling schedules.
i 16 7.9.1, 16 Specific details need to be provided for services 7.9.2 which have to be provided by PGE free of chargcs 1
(ie, magnitude of power supply, scope o f measure-ments and required equipments).
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