ML20238D022

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Forwards List of Deficiencies in Util 871109 Application for Amend to License NPF-1,changing Tech Spec Section 3.9.9 Re Containment Ventilation Isolation Sys.Application Should Be Revised & Resubmitted
ML20238D022
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 12/22/1987
From: Chan T
Office of Nuclear Reactor Regulation
To: Cockfield D
PORTLAND GENERAL ELECTRIC CO.
References
TAC-66638, NUDOCS 8801040048
Download: ML20238D022 (3)


Text

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el December 22, 1987 Docket No. 50-344 l

Mr. David W. Cockfield Vice President, Nuclear Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204

Dear Mr. Cockfield:

Subject:

License Change Application IL9 (TAC 66638)

By letter dated November 9,1987, Portland General Electric Company (PGE) requested an amendment (LCA 159) to Facility Operating License NPF.1 regarding TechnicclSpecificationSection3.9.9(ContainmentVentilationIsolationSystem).

The staff has reviewed the November 9, 1987 submittel and has determined the application to be deficient in overall content to support a review. The specific deficiencies are discussed in the Enclosure. The appropriate portions of the application should be re-reviewed and revised as necessary to address the identified areas and resubmitted.

This letter does not constitute a denial of LCA 159. Therefore, we request that your resubnittal be provided to us within 90 days from receipt of this letter or provide an alternate schedule for doing so within 15 days.

1 Sincerely, I

criginal signed by

%o1040048e712g{44 Terence L. Chan, Project Manager I

ApoCK 0500 ppa Project Directorate - V g

p Division of Reactor Projects - III, IV, V, and Special Projects Office of Nuclear Reactor Regulation i

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1 Mr.-David W.-Cockfield-

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Portland General Electric Company Trojan Nuclear Plant i

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Senior Resident Inspector U.S. Nuclear Regulatory Comission Trojan Nuclear Plant Post Office Box 0 Rainier, Oregon 97048 Michael J. Sykes, Chainnan

' i Board of County Commissioners i

Columbia County i

St. Helens, Oregon 97501 j

.i Mr. David Yaden Oregon Department of Energy Salem, Oregon 97310 Regional Administrator, Region V U.S. Nuclear Regulatory Comission j

l 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 l

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ENCLOSURE Overview The intent of Technical Specification (TS) Sections 3/4.9.4 and 3/4.9.9 is to restrict the release of radioactive material from the Containment atmosphere to the environment during refueling mode as stated by their corresponding bases.

Deficiency Although the proposed change is categorized as an " Administrative" change, the application fails to consider:

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the appropriateness of TS 3.9.4 and proposed TS 3.9.9 during those Mode 6 periods when core alterations or movement of irradiated fuel within the Containment is not in progress, yet heavy load (e.g., reactor vessel head, overhead loads) activities may be in progress over the refueling cavity; j

2.

the absence of a TS under such ccnditions, which would pennit such operations to be conducted without requiring containment isolation capability; l

3.

the appropriateness of TS 3.9.4 and proposed TS 3.9.9 during Mode 6 operations (not core alterations), in light of Trojan's loose fuel particle / contamination experience, and the need for containment isolation capability; and 4.

the inconsistency of TS 3.9.4 with respect to TS 3.9.9 vice the reverse.

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