ML20151A035

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Application for Amend to License NPF-1,incorporating Miscellaneous Editorial Corrections & Clarifications
ML20151A035
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 07/08/1988
From: Cockfield D
PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20151A030 List:
References
NUDOCS 8807190212
Download: ML20151A035 (8)


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PORTLAND GENERAL ELECTRIC CO!VANY EUGENE WATER & ELECTRIC POAF;D AND PACIFIC POWER & LIGHT COMPANY Operating Licenso NPF-1 Docket 50-344 Licenso Chango Application 168 This License Chango Application requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to incorporato miscellaneous editorial corrections and clarifications.

i PORTLAND GENERAL ELECTRIC COMPANY D. W. Cockfield Vice President Nuclear Subscribed and sworn to before mo this 8th day of July 1988.

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Notary Public of Orgfon My Commission Expires:

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LCA 168 Page 1 of 7 DESCRIPTION OF CHANGES 1.

The reference to Technical Specification 3.3.2.1 on Pages 3/4 3-59 and 3/4 3-64 is corrected to 3.3.2.

2.

Pago 3/4 3-60, Table 3.3-13, footnoto (a) is revised to clarify that two channels of the Wasto Cas Holdup System oxygen monitor must be operable to the indicator on panel C-151 and, to satisfy the requirement of Technical Specification 4.11.2.6.1 for continuous monitoring, an alarm must be operable in the contro1~ room.

3.

Pages 3/4 3-61. Table 3.3-13, and 3/4 3-65. Table 4.3-9, are revised to make Containment Purgo Noblo Cas Monitors PRM-1C and PRM-1D separato ent ries and to apply the **** footnote to PRM-1D.

The rest of the Containment Purgo Monitor entries are renumbered accordingly.

4.

Page 3/4 3-61, Table 3.3-13, is corrected to change the Containment Purgo Effluent Monitoring System flow rate measuring device from FR-3180 to FR-5600 (old Item 3c.d).

5.

Pages 3/4 3-62. Table 3.3-13, and 3/4 3-66, Table 4.3-9, are revised to add PRM-6B to the condensor air ejector noble gas monitor entries (Item 5.a).

6.

Page 3/4 3-62, Table 3.3-13, is revised to remove foutnote (b).

7.

Page 3/4 3-66a, Tablo 4.3-9, is revised to delete the channel check requirement for the post-accident monitoring system Containment effluent. Auxiliary Building offluent, and condenser air-ejector effluent iodino samplers and replace this requirement with a monthly Channel Functional Test.

8.

Page 3/4 3-66a, Table 4.3-9, is corrected to capitalize the "M" for the Item 6.e Channel Functional Test.

9.

Page 3/4 11-3, Table 4.11-1, is revised to add reference to footnote "f" to the principal gamma emitters for releases B.2 and B.3.

10.

Page 3/4 11-3, Table 4.11-1, footnotes

  • and ** are revised to clarify that the activity level at which action is to be taken to draw and composite samples does not include the activity of dissolved or entrained gases.

11.

Pago 3/4 11-3, Table 4.11-1, is corr > acted to make 10-5 pCi/ml in footnote ** 10 s pCi/ml.

f 12.

Page 3/4 11-9, Table 4.11-2, is corrected to make the Principal Camma Emitters footnote "o" instead of "f".

LCA 168 Page 2 of 7 13 Pages 3/4 12-1, 3/4 12-8 and 6-17 are changed to make the reporting required for unavailability of milk or fresh leafy vegetable samples or a new land use census location part of the Somiannual Radio-logical Effluent Releaso Report instead of a Special Report.

i 14.

Page 6-15c is corrected to make the references'to the Process l

Control Program and Offsite Dose Calculation Manual Specifica-l tier.: 6.14 and 6.15, respectively.

REASONS FOR CHANCES 1.

Technlcal Specificat39n 3.3.2.1 was renumbered to 3.3.2 by Amendment 131. The chtnges to pages 3/4 4-59 and 3/4 3-64 were l

inadvertently not included in Amendment 131.

This is an editorial l

change.

2.

Footnotc (a) to Table 3.3-13, Radioactive casoous Process and Effluent Honitoring Instrumentation, specifies that the two required Waste cas Holdup System oxygen monitor channels consist of the portion of the monitor from the sensing element to the indicator on panel C-151.

Panel C-151 is not normally manned. Footnoto (a) is revised to include a requirement for the single alarm in the control room to also be operable to provide for continuous monitoring of the Wasto cas Holdup System oxygen monitors.

This change is necessary to make the Table 3.3-23 requirements consistent with the require-ments of Technical Specification 4.11.2.6.1.

3.

Currently Table 3.3-13 Item 3c.a. allows either PRM-1C or PRM-1D to satisfy the requirement for one Containment purge noble gas monitor.

PRM-1C and PRM-ID do not have the same ranges.

During rstmal purging, the noble gas activity level is in the PRM-1C rango. This chango will requiro PRM-1C to be operating for Containment purge or Action 28 will be required. If PRM-1C is not on-scale, then PRM-1D is required to be operating or Action 28 will be required. This change makes the PRM-1C a"d PEM-1D requirements when they are per-forming their Containment purgo monitoring function consistent with the requirements when they are performing their RCS leakage detec-tion and Containment ventilation isolation monitoring functions.

The remaining entries for Containment purgo effluent monitoring are renumbered accordingly, and Table 4.3-9 is revised to keep the entries consistent with Table 3.3-13, 4.

The Containment purgo effluent monitoring system flow rate measuring devico is incorrectly listed in Table 3.3-13 Item 3c.d as FR-3180.

This change corrects the device number to FR-5600.

5.

There are two monitors for condenser air ejector noble gas monitor-ing, PRM-6A and PRM-6B.

Currently, only PRM-6A is listed in Tables 3.3-13 and 4.3-9, Item 5.a.

Either monitor PRM-6A or PRM-6B

s LCA 168 Page 3 of 7 can be used to monitor condensor air ejector noblo gas activity.

This change will allow PRM-6B to be used to setisfy the channel operability requirement for condenser air of,ector noble gas activity monitoring.

6.

Tablo 3.3-13, footnote (b), specifies thst the condenser air ejector monitoring requirements for Items 5.b t'4 rough S.e are applicable after the moisture remuval system is installed and operable for PRM-6.

The PRM-6 moisture removal system is installed and oporable and footnoto (b) is no longer required. This is an editorial change.

7.

In accordance with noto (3) of Table 4.3-9, the channel check requirement for the Containment of fluent, Auxiliary Building and condenser air ejector iodine samplers (Table 4.3-9, Items 6 b, 6.d.

and 6.f) consists of the verification of flow through the sampler.

The post-accident iodino samplers do not normally have flow through them.

Flow is lined up to the iodino samplers when the respectivo system is in the accident mode. The current channel check requires each system to be switched to the accident mode overy shift.

Such a surveillance is more appropriately performed as a Channel Functional Test since the function of the simplers is actually boing tested.

8.

Capitalizing the "M" for the Table A.3-9, Item 6.0, Channel Functional Test, corrects a typographical error.

9.

In Table 4.11-1, footnoto "f" describos the principal gamma emitters and discusses their reportin;. Anondment 99 inadvertently did not include this footnote with the principal gamma emitters entry for releases B.2, 011 Waste Separator Dischargo, and B.3, Service Water System in Table 4.11-1.

The addition of footnoto "f"

to Page 3/4 11-3 le editorial.

10.

Footnotes

  • ar.i ** of Table 4.11-1 require grab samples to be taken of the associated release paths for compositing whenever activity exceeds 10 s microcuries per milliliter (pci/ml).

The purpose of compositing is to determine the releaso concentrations for radio-nuclides other than dissolved and entrained gases.

Footnotes

  • and
    • of Table 4.11-1 are revised to clarify that the 10 s pCi/mi limit for taking samples for compositing excludes dissolved and entrained gases.

11.

Changing 10-5 pCi/ml to 10~5 pCi/ml in footnote ** of Table 4.11-1 corrects a typographical error.

12.

Changing the Principal camma Emitters footnote in Table 4.11-2 to footnoto "e" corrects the footnote references.

There is no footnote "f" for Table 4.11-2.

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LCA 168 Page 4 of 7 1

13.

Paragraph "a." of the ACTION statement for Specification 3.12.1 requires a Special Report within 30 days of the end of the current semiannual period if milk or fresh loafy vegotables are unavailablo from any of the required sample locations. A similar Special Report at the end of the current semiannual period is required by Specifi-cation 3.12.2 if a land use census identifies a location which yields a calculated dose or doso commitment greater than the loca-tion currently being used. Both of these conditions require a change to the Offsito Doso calculation Manual (ODCM) and thus, the Special Reports duplicato the requirement of Specifications 6.9.1.5.4 and 6.15 that any change to the ODCM be reported in the Semiannual l

Radioactivo Effluent Release Report.

Specification 6.9.2.q is also revised since there is no longer a Special Report associated with Specification 3.12.2.

An editorial change has been made to Paragraph b of the Action Statement for Technical Specifica-tion 3.12.2 as the sentenco did not make literal sense as written.

14.

The Specification references in Section 6.9.1.5.4 for the Process Control Program and the ODCM are wrong and are being corrected.

SIGNIFICANT HAZARDS CONSIDERATIONS In accordance with the requirements of Part 50.92 of Title 10 of the Code of Federal Regulations (10 CFR 50.92), this License Change Request is judged to involve no significant hazards based upon the following considerations:

1.

Does the proposed license amendment involve a significant increase in the probability or consequences of an accident?

l i

The first change corrects references betwoon Technical Specification sections. This is an editorial change and has no offect on the probability or consequences of an accident, i

The second change adds a requirement for a waste gas holdup system oxygen monitor alarm in the control room to Table 3.3-13.

This change makes Table 3.3-13 consistent with Technical Specifica-tion 4.11.2.6.1 and is administrative in nature. As such, this change has no effect on the probability or consequences of an accident.

The third change makes the requirements for PRMs 1C and ID con-sistent betwoon the diffsrent functions tho-monitors can perform in.

Tables 3.3-13 and 4.3-9.

This is an editorial chango and has no effect on the probability or consequences of an accident.

The fourth change corrects the number for the containment purgo j

effluent monitoring flow rate measuring device in Table 3.3-13 j

3 Item 3c.d.

This is an editurial change and has no effect on the 4

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probability or consequences of on accident.

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t LCA 168 Paga 5 of 7 The fif th chango adds condonsor air ejector noblo gas monitor PRM-6B to the gaseous and offluent monitoring instrumontation to Tables 3.3-13 and 4.3-9.

This change holps ensure monitoring of the condensor air ejector noble gas monitor without reliance on the Action statement. This change has no effect on the probability or consequences of an accident.

The sixth chango removes the footnoto referring to the installation of the moisture removal system for the condonsor air ojector moni-toring system in Table 3.3-13.

The moisture removal system is installed and the footnoto is no longer applicable.

This is an editorial chango and has no offect on the probability or consequentos of an accident.

The seventh chango dolotes the channel check requirement for the containment offluent, Auxiliary Building and condonsor air ejector post-accident iodino samplers and replaces this surveillance requirement with a monthly Channel Functional Test.

The iodino samplers provido post-accident doso information and have no effect on the probability or consequences of an accident.

The eighth change corrects a typographical error by capitalizing the "M" for the monthly channel functional test in Table 4.3-9, Item 6.e and has no effect on the probability or consequences of en accident.

The ninth change adds footnote "f", which describes the principal gamma emitters to all of the principal gamma emittor entries in Table 4.11-1.

This is an editorial chango and has no effect on the probability or consequences of an accident.

The tenth change adds a clarification to footnotes

  • and ** of Table 4.11-1 that the 10 s pCi/ml limit for taking samples for compos! ting excludes dissolved and entrained gases.

The samples are for effluent monitoring and there is no increase in the probability or consequences of an accident.

The eleventh change corrects a typographical error in Table 4.11-1 footnote ** by changing 10-5 to 10~5 and has no effect on the probability or consequences of an accident.

The twelfth chango corrects the principal gamma emitter footnote in Table 4.11-2 to footnoto "e".

This is an editorial change and has no ef fect on the probability or consequences of an accident.

The thirteenth change corrects duplicato reporting requirements for unavailable milk or fresh leafy vegetable samples and monitoring locations. This change involves administrative reporting require-monts and has no offect on the probability or consequences of an accident.

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LCA 168 pago 6 of 7 The last chango corrects coforencos between Technical Specification sections.

This is an editorial chango and has no offect on the probability or consequences of an accident.

2.

Does the proposed licenso amendment croato the possibility of a new or different kind of accident from any accident previously evaluated?

As discussed above, changos 1-4, 6, and 8-14 are editorial and administrativo and havo no effect on the accident analysis.

The fif th chango adds condensor air ejector noble gas monitor PRM-6B to the gaseous and offluent monitoring instrumentation in Tablos 3.3-13 and 4.3-9.

This monitor is already installed and provides additional monitoring capability.

Its addition to the Technical Specification does not create the possibility of a new or different kind of accident.

The soventh chango dolotes the channel check requirement for the Containment offluent Auxiliary Building, and condensor air ejector post-accident iodine samplers and replaces this surveillance requirement with a monthly Channel Functional Tost.

This is a chango to a surveillance requirement for an existing pieco of monitoring equipment and does not create the possibility of a new or different kind of accident.

3.

Does the proposed amendment involvo a significant reduction in a margin of safety?

As discussed above, changes 1-4, 6, and 8-14 are editorial and administrativo and havo no offect on the accident analysis.

The fif th change adds condensor air ejector noble gas monitor PRM-t B to the gaseous and offluent monitoring instrumentation in Table 3.3-13.

This additional monitoring capability increases the operator's ability to detect a problem and does not affect the overall margin of safety.

The seventh change deletes the channel check requirement for the containment effluent, Auxiliary Building and condensor air ejector post-accident iodine samplers and replaces the surveillance requiro-j ment with a monthly Channel Functional Test.

The samplers provido 3

post-accident doso information and have no effect on the margin of safety.

)

In the April 6, 1983 Federal Register, the NRC published a list of exampics of amendments that are not likely to involvo significant hazards concerns.

The majority of the changes are editorial and administrativo.

Examplo 1 of the Federal Register list states the following to show why

1.

' i o,

LCA'168 page 7 of 7 these changes are not considered to involve a significant hazards consideration:

l "A purely administrative change to Technica1' Specifications, es, a

]

change to achieve consistency throughout the Technical Specifica-l tions, correction of an error, or a change in nomenclature".

l The fif th change adds condenser air ejector noble gas monitor PRM-6B to the gaseous and effluent monitoring instrumentation. Example 2 of the Federal Register list states the following to show why thcse changes are not considered to involve a significant hazards consideration:

"A change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, eg, l

a more stringent survelliance requirement."

S_AFETY/ ENVIRONMENTAL EVALUATION i

Safety and environmental evaluations were performed for the proposed l

changes as required by 10 CFR 50 and the Trojan Technical Specifications.

l Thl review determined an unreview'd safety question does not exist since plant operations remain consistent with tha Final Safety Analysis Report, adequate survalliance is maintaine1, and there is no conceivable impact j

upon the environment.

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