ML20137M706
| ML20137M706 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/06/1985 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Butcher E Office of Nuclear Reactor Regulation |
| References | |
| TAC-59220, NUDOCS 8509130308 | |
| Download: ML20137M706 (9) | |
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- Ell PbetlarxiGerieralMcCorigxuly Eb1 D. Wahers Vce Presdert September 6, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN:
Mr. E. J. Butcher, Jr., Acting Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Conmission Washington DC 20555
Dear Sir:
License change Application 121 Pursuant to our previous discussions concerning License Change Application (LCA) 121, attached you will find our final agreed-upon revision to this LCA.
Sincerely,
.s Bart D. Withers Vice President Nuclear Attachment c:
Mr. Lynn Frank, Director State of Oregon Department of Energy Mr. Robert L. King i
Chairman of County Conmissioners
()0 PDR850913 % 850906
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l 4 DOCK 05000344 P
PbR 121 S.W Satrren Street Portard. Oregon 97204
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LCA 121 l
Page 1 of 2 LICENSE CHANGE APPLICATION 121 i
The'following changes.to Facility Operating License NPF-1 are requested (proposed replacement pages are provided as Attachment 1).
1.
Paae'5. Quality Assurance Page 5lof the Operating License is being revised to reflect the cor-rect name of the Quality Assurance Program. This is not due to a change in the program but a change made to the title only.
2.
Paae 3/4 2-2. Axial Flux Difference (AFD) Surveillance Surveillance Requirement 4.2.1.1.a.2 is being deleted. This surveil-lance item requires monitoring the indicated AFD once per hour for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the AFD monitor alarm has been placed in OPERABLE status.
Although Surveillance Requirement 4.2.1.1.a.2 is required in Revi-sion 4 to NUREG-0452, it is not clear what the basis for this sur-veillance is.. From our review of this requirement, it appears that
-this surveillance is to be performed to ensure that any accumulated AFD penalty minutes are adequately accounted for per Specifica-l tion 3.2.1 or else to ensure that the AFD computer is once again operable, functioning normally, and is recording the appropriate values. If it is a requirement to ensure that the monitor is con-tinuing to function after being returned to an operable status, we do not feel that this Technical Specification Surveillance Requirement
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is necessary. Other means exist to ensure that the AFD monitor is operable and performing its function once it has been returned to an operable status. Although the operators may periodically want to ensure that the AFD is back in service and operating satisfactorily, I
it is not felt to be appropriate to include this specific requirement in the Technical Specifications. Since other alarms and indication are available to inform the operators if the AFD monitor becomes inoperable, hourly surveillance for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter restoring.the AFD monitor to OPERABILITY is not necessary.
However, if this surveillance requirement' is-to ensure that any accumulated AFD penalty minutes are adequately accounted for per Specification 3.2.1, this requirement is adequately performed in.
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accordance with Surveillance Requirement 4.2.1.1.b when the monitor is inoperable. Again, when a monitor becomes inoperable, the data acquired in accordance with Surveillance Requirement 4.2.1.1.b would j
be manually entered into the AFD computer prior to declaring it i
' operable, thereby making one-hour monitoring for.the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after restoring the AFD monitor alarm to an operable status redundant-and unnecessary. Therefore, it is felt that Surveillance Require-ment 4.2.1.1.a.2 is duplicative, unnecessary. and serves as -an unwarranted burden to the operators.
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LCA 121 Page 2 of 2 3.
Pages 3/4 4-19 and 4-20. RCS Specific Activity The Technical Specification 3.4.8 ACTION statement for MODES 1, 2, 3, 4, and 5 is being modified as shown in Attachment 1 to account for j
the recent changes to the reporting requirements of 10 CFR 50.72 and 50.73.
Since these changes to 10 CFR 50.72 and 50.73 occurred after issuance of NUREG-0452 (M-STS), Revision 4. the draft copy of M-STS, Revision 5 was used as a basis for the revision to this Specifica-tion. This change removes all portions of the ACTION statement per-taining to a REPORTABLE OCCURRENCE and the information required to be submitted with it.
4.
Pane 3/4 7-38. Control Buildina Modification Connection Bolts The APPLICABILITY of Technical Specification 3/4.7.11 is being revised to correct an error. The APPLICABILITY shall be "AT ALL TIMES" instead of the current "ALL MODES".
SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i
The revisions associated with this change request fall into one of three categories:
(1) editorial changes or minor rewording made to correct i
errors (2) clarify requirements, or (3) changes made to make the Tech-l nical Specifications agree more closely with the M-STS.
Therefore, a significant hazard consideration is not deemed to exist for this change since it either:
(1) does not make substantive changes to the Technical Specifications, (2) clarifies requirements without changing their intent and thereby continues to meet all existing requirements, or (3) clearly I
falls within existing regulatory guidance (NUREG-0452, Revision 5, draft).
Deletion of Surveillance Requirement 4.2.1.1.a.2 is not felt to involve a significant hazard inasmuch as it is an administrative change, and has no direct affect on reactivity or reactor safety. Deletion of this surveil-lance requirement.does not:
(1) involve a significant increase in the
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i probability or consequences of an accident previously evaluated, (2) create the possibility of a new or different kind of accident pre-
, viously evaluated, or (3) involve a significant reduction in a margin of safety.- The surveillance requirement merely deletes from the Technical Specification the burden of monitoring instrumentation on an hourly basis for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after returning it to an cperable status because such monitoring is unnecessary and duplicative to other alarms and indications that exist in the contrel room. As such, no significant hazard would be created-by its deletion.
l SAFETY / ENVIRONMENTAL' EVALUATION i
Safety and. environmental evaluations were performed as required by I
-10 CFR 50 and the Trojan Technical Specifications. This review deter--
mined that an unreviewed safety question does not exist since Plant operations remain consistent with the Updated FSAR, adequate surveillance is maintaindd, and there is no conceivable impact upon the environment.
l GAZ/BLK/3me/0317G60.0885 g
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