ML19354E597

Application for Amend to License NPF-1,consisting of License Change Application 190,deleting Table 3.6-1, Containment Isolation Valves, from Plant Tech Specs

ML19354E597
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/25/1990
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML19354E594	List: ML19354E593 ML19354E597 ML19354E600
References
GL-87-09, GL-87-9, NUDOCS 9001310436
Download: ML19354E597 (7)

Text

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o _. 7 i-PORTLAND CENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND-PACIFIC' POWER & LIGHT COMPANY Operating License:NPF-1 Docket 50-344 License Change Application 190 i

This License Change Application requests modifications to. Operating License NPF-1 for the Trojan Nuclear Plant to delete Table 3.6-1,

" Containment Isolation Valves", from the Trojan Technical Specifications, i

PORTLAND CENERAL ELECTRIC COMPANY l

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D. W. Cockfleid o

Vice-Pre [ident Nuclear Division Subscribed and sworn to before me this 25th day of January 1990.

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J Notary Public.of OR/gon 9MyCommissionE i

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LCA 190 f

Attachment'A i

Page 1 of 6 4

Description of Change

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The proposed change deletes Table : 3.6-1,~ " Containment Isolation Valves",

from Trojan Technical Specifications-(TTS) 3/4.6.3.. Proposed changes.to

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the Bases section of TTS 3/4.6.3 now reference Final Safety Analysis

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Report (FSAR) Table 6.2-1, " Containment Isolation Barriers", as the.

required listing for these valves and any changes to FSAR Table 6.2-1 are l

to be made in accordance with Title 10, Code of Federal Regulations,.

Part 50.59 (10 CFR 50.59).

References to Table 3.6-1 have also been deleted from TTS 1.8.lb, 3.6.1.2, and 3/4.6.3.

I A footnote has been added to TTS 3.6.3.lb and c, stating that the_

1 provisions of Specification 3'.0.4 are not applicable.- Additional.

clarification has been provided to note that these action statements are not applicable to inoperable isolation valves required to be open during a post-accident situation.

Footnotes taken from TTS Table 3.6-1 concerning the opening.of certain j

isolation valves under administrative control'have been incorporated in

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TTS 1.8.la and 4.6.1.la.1.

Also, the footnote from TTS Table 3.6-1,

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l which states that certain Containment purge supply and exhaust valves shall be made inoperable, has also been incorporated into TTS 4.6.1.la.1.

The following valves which are also under administrative control are not presently included in-TTS Table 3.6-1 but are included in FSAR' 4

Table 6.2-1:

LD001, LD003 SV6991, SV6992 These valves have been added to the list of valves which:may be opened on-an intermittent basis under administrative control in Section 4.6' 1.la.

~6 The words "if applicable" were added to Surveillance Requirement 4.6.3.1.1 l

when verifying isolation times. Also, the.words "less than or' equal to L

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the required isolation times", were added to TTS 3.6.3.1; Reason for Change s

FSAR Table 6.2-1 contains a listing of'all Containment penetration valves, including additional information not currently in TTS Table 3.6-1.

Having information in both tables is redundant.' Deleting Table 3.6-1 from the TTS will make the TTS more usable and less cumbersome without impacting our ability to control changes made-. to. thel list of Containment valves.

Changes to FSAR Table 6.2-1 will be controlled by the 10 CFR 50.59. review process.

Also, deletion of.this i

table is consistent with the recommendations of NUREG-1024, " Technical l

Specifications - Enhancing the Safety Impact", as a short-term improve-ment item, and the efforts by the Westinghouse Owners Group (WOG) and

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LCA 190 Attachment A-Page 2 of 6 Nuclear Management and Resources Council (NUMARC) Technical Specification upgrade initiatives to make the Technical Specifications a more clear and i

concise document.

I The proposed change (footnote added) to TTS 3.6.3.1b and c is made to allow reactor-mode changes with containment isolation valves inoperable, provided they are closed and secured.

Specification 3.0.4 ensures that d'

operation is not initiated with inoperable equipment.

Exceptions-to Specification 3.0.4 are provided in other sections of the TTS:when startup with inoperable equipment would not affect Plant safety. The isolation valves' intended function of ensuring that the Containment atmosphere is isolated from the outside environment during an accident-can either be met by an operable automatic isolation valve or by a= closed.

valve (or otherwise isolated line), fPlant' safety is thus not degraded by

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an inoperable valve-provided that the valve is in its closed' position.

Under these circumstances, the provision of Technical. Specification 3.0.4 is not necessary. Generic Letter-(GL) 87-09 states " Specification 3.0-4 unduly restricts facility operation when conformance to the Action 6

Requirement provides an acceptable level of safety for-continued '

operation. For an LCO that has Action Requirements permitting continued' operation for an unlimited period of time,' entry into an operational mode or other specified condition of operation should be permitted in j

accordance with those Action Requirements. This is consistent with NRC l

regulating requirements for an LCO."

Since closed isolation valves satisfy the intended safety function and are permitted for an unlimited period of time, our proposed change is consistent with the intent of-changes endorsed by GL 87-09.

We will, however, make all effort to-maintain these valves in operable condition regardless of the proposed change.

i The additional sentence added to the footnotes of TTS 3.6.3.1b and c-

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provides needed clarification. This clarification williprevent the possible isolation of Type IV fluid lines which must remain in service subsequent to a Derign Basis Event, such as lines serving the Engineered i

Safety Feature (ESP) system.

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'i The footnotes from TTS Table 3.6-1 are retained and incorporated into other sections since ti.e footnotes allow for the necessary testing.

i Oaintenance, and other activities to be performed on specified valves during Modes 1 through 4.

Administrative control of specified valves is I

necessary to be able to rapidly close them under accident conditions:and, f

as such, future changes to this list will remain under the control of the license amendment process. Also, the requirement to make-inoperable certain containment purge supply and exhaust valves has been retained and incorporated into TTS 4.6.1.la.1.

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a LCA 190 Attachment A.

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Valves LD001, LD003, SV6991 and SV6992 were added to the footnote contained in Section 4.6.1.la because they may'be opened on an intermittent basis under administrative control.

- Surveillance Requirement 4.6.3.1.1 was modified ' to recognize -the f act that some containment isolation valves do not have required isolation.

times-(only automatic valves have required isolation times).

1 Clarification was made to TTS 3.6.3.1 to recognize that valves may close j

f aster than the required isolation time and still be considered operable.

Determination of Sianificant Hazards Consideration In accordance with the requirements of. Title 10, Code of Federal Regulations, Part 50.92, this License Change Application (LCA)'is judged-to involve no significant hazards based upon the following information:

1.

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

The removal of. Table 3.6-1 'from TTS: and replacing-it with a I

reference to FSAR Table 6.2-1 in.the-Bases section~does not reduce the effectiveness of the TTS.- In addition, there'are no proposed changes to the Limiting Conditions for Operation (LCOs) and-l Surveillance Requirements (SR) other than discussed below; so.

l consequently, no changes in operability of the isolation valves will-

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occur. Accordingly, there will be no effect on previous 1'y analyzed accidents.

-i Making Specification 3.0.4' not applicable - to TTS 3.6.3.lb and c -

allows Plant startup with isolation valves closed and deenergized or the penetration isolated with a closed manual' valve or a blind flange.

This provides at least the same level of assurance that the affected penetrations will be isolated when required.

Since the ability to isolate the containment is not adversely affected, there can be no adverso impact on the consequences or probability of any accident.

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1 The clarification that TTS 3.6.3.lb and c will not apply.to those 1

isolation valves required for post-accident operation.is more restrictive than the present TTS and will thus enhance safety.

Again, there will be no adverse impact on the consequences or probability of any accident.

We have retained in the TTS the requirements for keeping certain valves under administrative control and for making'others>

inoperable. These valves and their requirements remain the same as t

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LCA 190 pp

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l7 the current TTS.

Thus, because'only the location of the requirement 6

within the TTS has changed, there can be no impact upon any accident.

l analysis.

The addition of four valves not presently included in TTS

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Table 3.6-1 to the footnote of'TTS 4.6.1.la.1 constitutes additional J

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restrictions not presently included in the TTS..and will ensure consistency with regulatory requirements. :Thus,'it does not L

increase the probability or consequences of any accident.

l Modification of TTS-4.6.3.1'.1 was done for clarification only in recognition that not all containment isolation valves have required' l

1 solation times.. Likewise, the proposed change to TTS 3.6.3.1 clarifies that the required isolation time < represents a maximum time' F

for valve closure. Thus, there will be no ef fect on previously _

analyzed accidents.

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l 2.

Does the proposed license change. create the possibility of a new or

.different kind of accident from any accident previously analyzed?

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Because deletion of Table 3.6-1 does not change the way the Plant is-operated, the potential for an;unanalyzed_ accident is not created.

The footnote added to TTS 3.6.3.lb and c will not affect the Plant response in any way,iand no new failure modes are introduced which could create a new accident. The~ footnote-applies to valves which-have no safety function other than Containment isolation and-that safety function can-be met by meeting the conditions of TTS 3.6.3.1b:

or c.

The retention of administrative control over specific valves cannot create a new accident since the requirements remain the same.

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.Likewise, adding valves not presently' included-in TTS Table 3.6-1 presents more restrictions and ensures consistency with regulatory-.

p requirements and thus cannot create a new accident, a

Clarification =of TTS 4.6.3.1.1 and 3.6.3.1 does not create a new-accident since the change will enhance interpretations of-the TTS.

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Does the proposed license change-involve a significant reduction in-a margin of safetyt' Since the-deletion of Table 3.6-1 does not affect the consequences of any accident previously. analyzed, there is no. reduction in. the margin of safety.

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LCA 190 V4 Attachment'A l

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.t ff The proposed change to.TTS 3.6.3.lb and c will apply only when'the f[

inoperable Containment' isolation valve (s) are isolated by use of at least one deactivated automatic valve-secured in the closed position.

.f or by use of a closed manual' valve or' blind flange.

Because thes penetration is isolated, the proposed change does not have any l

l adverse impact on the Containment boundary. ' Accordingly, there will-l be no impact on safety margin.

. Keeping the same administrative'controis over. specific valves does-l not-affect sclety margins since the. requirements remain the same.3

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h Adding valves to the TTS provides additional restrictions and will-t not reduce the margin of safety.

i The enhancement of?TTS 4.6.3.1.-1 ana 3.6.3.1 provides needed i

clarification and thus, cannot reduce the safety margin.

i In the March 6, 1986 Federal Reaister, the NRC published a list of-l examples of amendments-that are not likely to-involve a significant hazards consideration.

Examples (1),f(11), and (vil)-from this list' l

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f (1) A purely administrative change to. technical specifications:

for example a: change to achieve i

I consistency throughout the technical specifications, correction of an error, or a-change in nomenclature.

(11) A change that constitutes an additional-I limitation, restriction, or control-not presently.

included in the technical specifications, e.g'.,

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more stringent surveillance requirement.

(vil) A change to conform a license to changes in the.

regulations, where the license change results in very minor changes to facility-operations-clearly l-in keeping with the regulations.

The clarification added to TTS 4.6.3.1.1cis=similar to Example (1).

The inclusion of additional valves into the =TTS is shallar to Example (ii) as L

18 the footnote to TTS 3.6.3.lb and c which clarifles that those action statements are not applicable-to inoperable isolation valves required to i

be open during post-accident conditions. The footnote concerning

l nonapplicablity of Specification 3.0.4 is similar to Example-(vil) in l-that it is consistent with changes endorsed by GL 87-09.

Removal of-Table 3.6-1 is not enveloped by any example, but is consistent with l

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j efforts by WOG and NUMARC to upgrade the Technical Specifications.

Accordingly, none of the proposed changes involve a significant hazards I

consideration.

Safety / Environmental Evaluation Safety and environmental evaluations were performed as required by.

10 CFR 50 and the TTS. The review determined that'the proposed change l does not create an unreviewed safety question, nor does it create an 1

unreviewed environmental-quest

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Schedule Considerations a

It is requested that the effective date of the amendment be thirty; days after. issuance by the NRC.

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