ML20011D942

Proposed Tech Specs Re Instrumentation for Chlorine Detection Sys & Control Room Ventilation Sys

ML20011D942
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	12/27/1989
From:	PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20011D937	List: ML20011D936 ML20011D941 ML20011D942
References
NUDOCS 9001030101
Download: ML20011D942 (13)

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INSTRUMENTATION a

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CHLORINE DETECTION SYSTEMS LIMITING CONDITION FOR OPERATION 3.3.3.6 Two independent chlorine detection systems, with their alarm / trip setpoints adjusted to actuate at a chlorine concentration of 1 5 ppe,

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shall be OPERABLE.

US APPLICA8!LITY:

ALL MODES.

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a.

With one chlorine detection system inoperable, restore the l

inoperable detection system to OPERABLE status within 7 days or within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> initiate and maintain operation of the control room emergency ventilation system in the recircula-1 tion mode of operation.

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b.

With both chlorine detec' tion systems inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation.h c.

The provisions of Specification 3.0.4 are not applicable.

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SURVEILLANCE REDUIREMENTS 4.3.3.6 Each chlorine detection system shall be verified energized at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and demonstrated OPERABLE by performance of a A

CHANNEL FUNCTIONAL TEST at least once per 31 days and a CHANNEL 4S2T CALIBRATION at least once per 10 months.

For the purpose of meeting Specification 4.7.6.1.b, or for 1

providing periodic air exchanges to maintain air quality in the control room, the outside dampers for the normal and/or emergency control room ventilation systems may be opened for up to one hour provided that appropriate compensatory measures are taken to isolate the control room if a toxic gas accident should occur.

This process is permitted until new chlorine detectors are made OPERABl.E. on approximately March 15. 1990.

t TROJAN-UNIT 1 3/4 3-47 Amendment No. 33152 May 15, 1989 l

9001030101 891227 PDR ADOCK 05000344 P

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LCA 189 Attachment B

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Page 1 of 1 Compensatory Measures to take when both trains of chlorine detectors are inoperable and when outside makeup air is being brought into the Control Room:

1.

Communications are established between the Control Room and an individual in observation of the railroad tracks adjacent to Trojan on the west of the plant to alert control room of passing trains, and, Outside air makeup dampers (CB-1 and/or CB-2) will be closed and the associated ventilation system stopped whenever a train approaches and passes Trojan on the railroad tracks west of the plant.

2.

An observer will be posted who can observe the railroad tracks east i

of Trojan on the Washington side of the Columbia River and report any train derailment, and, 1

Outside air makeup dampers (CB-1 and/or CB-2) will be closed and the associated ventilation system stopped whenever a train dera11s on the railroad tracks east of the plant on the Washington side of the Columbia River.

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Communications will be established between the control Room and an r

observer posted at the Intake Structure who can alert the Control Room when the odor of chlorine is detected, and Outside air makeup dampers (CB-1 and/or CB-2) will be closeo and the associated ventilation system stopped whenever the observer at the Intake Structure detects the odor of chlorine.

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3.

No evolutions / activity involving use of chlorine in the Chlorine Building are permitted, and No chlorine shipments may be received, and, Chlorine levels will be monitored in the chlorine Building.

4.

Upon notification of a chlorine release within five miles of Trojan, outside air makeup dampers (CB-1 and/or CB-2) will be closed and the associated ventilation system stopped until confirmation that the release is terminated and poses no hazard to Trojan.

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e Licensing Document Change Request for Trojan LCA 189 i

Technical Specification Bases Change Attachment C l

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Reason for Channe This change is needed to exit the ACTION statement of Trojan Technical Specification (TTS) 3.7.6.1, " Control Roon Emergency Ventilation Systen".

i Presently, both chlorine detectors are inoperable which causes the Plant to Laplement TTS 3.3.3.6, " Chlorine Detection System", ACTION b.

This requires the control roca emergency ventilation system (CB-1) to be placed i

in the recirculation mode of operation. TTS 3.7.6.1 states that both CB-1 trains must be capable of responding to a safety injection signal, i.e. in the "AUT0" position. When a train of CB-1 is not in the "AUT0" position, it cannot respond to a safety injection signal.

Thus, if both trains of 1

CB-1 were pisced in recirculation, and there was no actual chlorine rele?;9, the Plant would be in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> shutdown ACTION statement per TTS i

1 3.7.6.1.

Presently, and with NRC concurrence, one train of CB 1 is in j

i "AUT0" and the other train of CB-1 is in recirculation. This current lineup maintains one train of CB-1 capable of responding to a safety i

injection signal and also meets the requirements of TTS 3.3.3.6 ACTION b.

However, this does make the other train of CB-1 incapable of responding to a safety injection signal and therefore, inoperable per TTS 3.7.6.1.

This puts the Plant in a seven-day shutdown ACTION statement per TTS 3.7.6.1 i

which began on December 12, 1989.

The intent of TTS 3.3.3.6 ACTION b is to conservatively isolate the control room ventilation systems because both chlorine detectors are inoperable.

Stopping the operation of the normal control room ventilation system (CB-2) closes the outside dampers and isolates the control roca ventilation systems.

Starting and operating the CB-1 fans in recirculation per TTS 3.3.3.6 ACTION b when no chlorine accident has occurred does not add any

" extra isolation" capability and only forces the Plant into the ACTION statement of TTS 3.7.6.1.

The ACTION statement in TTS 3.3.3.6 was intentionally worded to require operation of CB-1 in recirculation so that some air movement and cooling would be available in the Control Room.

This is no longer necessary due to j

the existence of CB-16 which is the CB-1 supplementary cooling system.

This allows CB-1 to remain in "AUT0" with the air cooling function provided by CB-16 during normal operations. In the event that CB-16 is not available, the CB-1 fans could be turned on, with the outside air makeup i

dampers closed, to provide control room cooling.

This change would define in the BASES for TTS 3.3.3.6 and TTS 3.7.6.1 that the phrase " recirculation mode of operation" found in TTS 3.3.3.6 ACTION b means stop operation of CB-2 and maintain both trains of CB-1 in a lineup espable of responding to a safety injection signal.

This does not preclude operating the CB-1 fans with the outside air askeup dampers closed and/or performing the other actions required La the event of an actual chlorine release.

This mode of operation is consistent with the assumptions made in the toxic gas analysis.

For consistency purposes, the proposed addition to the BASES for TTS 3.3.3.6 are also being added to the BASES for TTS 3.3.3.12. "S02 Detection Systems".

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LCA 189 I

Attachment C Page 2 of 9 t

Safety Evaluation l

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Will the probability of occurrence or consequences of an accident, or j

of a malfunction of equipment Laportant to safety, previously evaluated i

in the FSAR be increased?

This change does not increase the probability or consequences of an accident. The toxic gas analysis assumes isolation of the control roon ventilation systems.

Stopping the operation of CB-2. isolates the

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control room.

This change leaves CB-1 in auto, capable of responding i

to an SI signal.

Therefore, rewording the ACTION statement from

"... initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation." to "...stop operation of the control room normal ventilation system (CB-2)."

changes neither the consequences nor the probability of an accident since control room ventilation isolation results from both actions.

operation of the control room emergency ventilation system in accordance with the proposed change is consistent with that assumed in the FSAR and the toxic gas analysis.

l The probability of occurrence or consequences of an accident or a i

malfunction of equipment due to the loss of cooling function of CB-1 does not change.

The ACTION statement in TTS 3.3.3.6 was worded to i

require operation of CB-1 in recirculation so that cooling would be I

l available in the Control Room.

This is no longer necessary due to the j

availability of CB-16, which is the CB-1 supplementary cooling system.

This allows CB-1 to remain in " AUTO" with the air cooling function provided by CB-16 during normal operations.

2.

Will the possibility of a new or different kind of accident from any previously evaluated in the FSAR, or the possibility of a malfunction of equipment important to safety of a different type than any previously evaluated in the FSAR, be created?

I This change does not create the possibility of a new or different kind of accident because isolation of the Control Room is not relevant to accident creation.

The isolation of the Control Room functions to aitigate the consequences of an accident after it has occurred.

Isolation of the Control Room is a function that has already been evaluated in responding to a toxic gas. accident.

This change still operates equipment within the assumptions of the toxic gas analysis.

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LCA 189 Attachment C I

Page 3 of 9 h

l safety Evaluation (cont.)

The possibility of a new or different kind of accident from any previously evaluated in the FSAR or the possibility of a malfunction of equipment bsportant to safety of a different type than any previously i

evaluated in the FSAR due to the loss of cooling function of CB-1 is

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not created.

The ACTION statement in TTs 3.3.3.6 was worded to require operation of C3-1 in recirculation so that cooling would be available in the Control Room.

This is no longer necessary due to the availability of CB-16, which is the CS-1 supplementary cooling system.

This allova CB 1 to remain in " AUTO" with the air cooling function provided by CB 16 during normal operations.

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Vill the margin of safety, as defined in the basis of any Technical Specification, be reduced?

This change does not involve a reduction in a margin of safety because the change is within the assumptions used in the toxic gas analysis (the toxic gas analysis assumes ventilation system isolation, not recirculation).

There is no reduction in the margin of safety due to the loss of cooling function of CB-1 since CB-16 is available to l

provide the required cooling during non accident conditions.

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I Descrint!.on of Channe r

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1.

Add the following paragraph to the BASES for TTS 3.3.3.6 and 3.3.3.12:

"The recirculation mode of operation is defined as stopping the control I

room normal ventilation system and maintaining the emergency control room ventilation system in a lineup capable of responding to a safety injection signal. This does not preclude operating the CB 1 fans with the outside air askeup dampers closed and/or performing the other required actions Ln the event of an actual chlorine release."

2.

Change the following paragraph in the BASES for TTS 3.7.6.1 from:

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" Recirculation mode of operation is defined as operation of the control i

room emergency ventilation system with the outside air dampers closed."

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The recirculation mode of operation is defined as stopping the control i

room normal ventilation system and maintaining the emergency control room ventilation system in a lineup capable of responding to a safety injection signal. This does not preclude operating the CB-1 fans with the outside air askeup dampers closed and/or performing the other required actions in the event of an actual chlorine release."

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i LCA 189 INCLM.WATION Attachtaent C Page 4 of 9 y.3 s

i 3/s.3.3.5 Ch' LOR!NE OETECICM SYSTh5 J

The CFDASILITT sf the 21erine detection systas ensuns dat sufficient ca;dfif ty is available ts ;ner:1y detact and initiata protactive action in ce event of an ac=idantal 21crine nieue. This upability is required ta ;retect==ntral recs persennel and is censistant with 2e rec =enendations I

of Regulatsry Guide !.25,, 'Pretaction of Muclear Power Plant Contal Acom l

Operators Against an Acetdantal Chierine Aalease,' February 1975.

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3/4.2. 7. 7.rTRE 0 :t.snCN DS?RUMUTATION t

i 0FDA8ILITY of 2a fire detaction instnnantation ensuns that adequata l

i" worntny cacability is avatTahie for the prompt detection of fins. This t

i casaAf'ity fs neuired in ordar :s detect and locata fires in 2eir early N;

stages. Promet detection af fires will recuca 2e ;ctantial for dacage ts aug ;

refety relatat souipment and is an integral element in the overall facility fire protaction prtgram.

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In the event dat a portten of the fin detection instrumentation is inc;ernt.le, the estan11shment of frequent fire patrols in the affected areas -

ts nguired ta pnvice detaction capabiltty until the insperable instr: san-tatten ts rest: red to CFEV2ILITf.

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3/A.3.3.8 OtCOUPLE !ETTCNIT 0FDARIL.TP of es dec: cele swtt= hee in the. cable spreading roca (CER) anacres that the centr:1 caties passfag 2nuta ce CER ta cartain equi: ment l

required ' e safa sactdown of 2e Plant wit 1 to isolatad'and local ocenti:..

l cf the equi; tent =an te acniaved. Pn the event eat a portion 3f te dec=u:le swits?.es tec:.ses inocentle, a fire wat:n will be estatiisted in i

the CIR until me incienble equipment is restored ts 0FD.'JILITY, 3/4.3.3.3 AC:::DC' '*CMITCADE 'M5 2UPCf?A !0M l

The CFDAEIL.T/ sf ce ac:itant :enit:rf ag inst.nentation ensures :Ma:

sufdt:fsa: inf=r:s:1:n is ava11aste en selectas plant ;aneetart := monit:r s

i and assess dese variabies curing ard fellowing an acrisant. This ca 1:11-fty is ::nsistant with the rec =smancation of NUKEE 4578, 'T.MI4 Lassans Learned Task Ferca !tatus Aacer. anc Ihort.Ters Rec==enndations' anc

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1URE5-G727, *0iarification :1 ;;i! Action Plan Kaguirements.*

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4 TRcJAN-ct!

1 3 3/4 3 3 Asentment No. H. H. f fepanner 3,1$.

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' I LCA 189 Attachment C Page 5 of 9

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Add the following paragraph :o the BASES for TTS 3.3.3.6 "The recirculation mode of openstion is defined as 6toppird the control room normal ventilation systaa and maintaining the energency control room ventilation system in a lineup capable of responding to a safety injection signal. This does not preclude operating the CB-1 fans with l

the outside air makeup dampers closed and/or performing the other

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required actions in the event of an actual chlorine release."

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LCA 189

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et. ANT SYSTEMS Page 6 of 9 i

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3 /4. 7. 5 CONTROL ROOM VENTil ATION SYsitM i

The OPERA 8!LITY of the control roos ventilation systes ensures that'

1) the ambient air temperature does not sxceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled i

by this systes and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPtAA41LITY of this sytes in conjunction with control reos design pro-s visions is based on limiting the radiation exposure to personnel i

occupying the control room to 5 rea or less whole body, er its equivalent.

l This Itaitation is consistent with the requirements of General Design criteria 19 of Appendix 'A',10 CFA 50. System operability can be affected l'

by ICC3 recirculation leakage and Containment leakage should the conditions assumed in F3AA Section 15,.6.5.6 be exceeded.

i The OPERA 31LITY of this system in conjunction with control room design provisions is also based on liatting the toxic gas exposure to control 1

room personnel consistent with the FSAA design basis and Regulatory Guide 1.95.

[c# ecirculation mode of operation is defined as operation of the R

ontrol room emerenney ventilation system with the outside air d t

\\ closed _.fTn the event of 4.rasianon release while operating the systes

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in the recirculation mode of operation, the system is operated in the

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pressurization ande of operation by opening the outside air damper:.

Operation of the system in this manner meets the intent of this specification and satisfies the F3AA design basis and requirements of GDC 19.

t 3/a 7.7 SEAlt0 SOURCf CONTANINaTION Vf The limitations on sealed source removable contamination ensure that the total body or individual organ irradiation does not exceed allowable fW- ;

limits in the event of ingestion or inhalation of the source material.

The limitations on removable contamination for sources, requiring leak

• b *d"d testing, including alpha esitters,1s based on 10 CFR 70.3f(c) limits for l

plutonium.

Leakege of sources..escluded from the requirements of this specification represent less than one maximum periaissible body burden g

for total body irradiation if the source asterial is inhaled or ingested.

i 3/4.7.9 eter sueegtssf0N SYSTEMS The OPEAASILITY of the fire suppression systans ensures that adequate t

fire suppression capability is available ta confine and estinguish fires occurring in any portion of the facility where safety related eosiement is located. The fire suspression systas consists of the water systas.

sprinklers and fin hose stations. The cellective casability of the fire suppression systems is adeguata ta sinisite potential daanse to safety related equipment and is a anjor element in the facility fire protection -

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7to.1AN-UNIT 1 3 3/4 7-5 Amendment Me. 75. ZI 152 May 13, 1989

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LCA 189 l

Attachment C Page 7 of 9 l

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Insert the following sentence where indicated in the BASES for TTS 3.7.6.1:

"The recirculation mode of operation is defined as stopping the control room normal ventilation system and maintaining the emergency control room ventilation system in a lineup capable of responding to a safety injection signal. This does not preclude operating the C5-1 fans with the outside air askeup dampers closed and/or performing the other i

required actions in the event of an actual chlorine release."

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o LCA 189 l

,.3 Attachment C Page 8 of 9 INSTRUMENTATION BMES 3/a.3.3.10 RA0f0AcTtyt t.10Ut0 EFFLUENT INSTRUMETATION The radioactive liquid effluent instrumentation is provided to monitor and control, as spplicable, the releases of radioactive materials in liquid effluents dudng actual or potential releases. The alam/ trip setpoints for these instruments shall' be calculated in accordance with the 00CM to ensure that the alam/ trip will occur prior te exceeding the limits of 10 CR Part 20.

The OPERA 8!Lm and use of this instrumentation is consistent with the require-ments of General Design Critaria 60, 63, and 64 of Appendix A to 10 CFR Part 50.

3/4.3.3.11 RA0f0AC?tVE GA$t005 PROC!!$ AND EFTLUENT INSTRUMENTAft0N The radioactivt gaseous process and affluent instrumentation is provided to (1) monitor and control, as applicable, the releases of radioactive materials in gaseous affluents during actual or potentiel releases. (2) pro-vice automatic isolation of 'dG07 discharges prior to exceeding the limits of 10 CFR Part 20. (3) to provide automatic isolation of Containment ventilation at two times Containment background readings in Modes 1, 2, 3, 4 and 6; I

however, in no case will the Itaits of 10 CFR Part 20 he exceeded. (4) to provide containment activity levels for RCS leakage detection. (5) to monitor A

potentially explosive mixtures in the Gaseous Radwasta System, and (6) to M

monitor post. accident release levels. The alarm / trip setpoints for these fastruments shall be calculated in accordance with the 00CM. The OPERA 81LM and use of this instrumentation is consistent with the requirements of General '

Design Criteria 60 and 64 of Appendix A to 10 CFR Part 50.

The process and affluent radiological monitors for the Containment.

Auxiliary Builoing and condenser air ejector effluents are equipped with an extended range designed to function during accident conditions. Additionally, noble gas activity monitors have been installed on the main steam lines to monitor potential releases of activity through the main steam relief valves.

These monitoring capabilities are consistent with the requirements in NUREG-0737. " Clarification of TMI Action Plan Requirements.'

3/4.3.3.12 302 DETICTION SYSTEMS The OPERA 8!1.ITY of the sulfur dioxide detection system ensures that sufficient caoatility is available to promotly detect and initiate protective

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action in the event of an accidental sulfur dioxide release. This capatt11ty f

is required to protect control room personnel in accareance with Regulatory Suide 1.78. "Assumotions for Evaluating the Habitability of a Muclear Power Plant Control Room Ouring a Postulated Hazareous Chemical Release," June 1974 and is consistent with the requirements of General Design Criterion 19 of Appendix A to 10 CFR Part 50.

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TRtWAN-UNIT 1 3 3/4 3-4 Amenennent No. $9,105 1

April 4,1945 4(e)

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LCA 189 Attachment C Page 9 of 9 l

Add the following paragraph to the MSES for TTS 3.3.3.12:

The recireslation mode of operation is defined as stopping the control room normal ventilation system and maintaining the emergency control room ventilation system in a lineup capable of responding to a safety injection signal. This does not preclude operattag the CB-1 fans with the outside air makeup dampers closed and/or performing the other required actions in the event of an actual chlorine release."

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v LCA 189 Attachment D i

Page 1 of 1 Scheduled Milestones for Testing and Installation of New Trojan Chlorine Detectors J

December 20, 1989 Issued Purchase Requisition for Chlorine Detectors j

December 27, 1989 Issue Purchase Order for Chlorine Detectors j

January 8, 1990 Ship Detectors to Wyle Labs for Qualification Testing January 29, 1990 Complete Laboratory Testing; Begin Laboratory Report and Commence Installation on-Site February 28, 1990 Complete Laboratory Report and On-Site Installation J

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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PORTLAND GENERAL ELECTRIC COMPANY,

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Docket 50-344 THE CITY OF EUGENE, OREGON, AND

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Operating License NPF-1 PACIFIC POWER & LIGHT COMPANY

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j (TROJAN NUCLEAR PLANT)

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CERTIFICATE OF SERVICE I

I hereby certify that copies of License Change Application 189, to the Operating License for Trojan Nuclear Plant, dated December 27, 1989, have j

been served on the following by hand delivery or by deposit in the United l

States mail, first class, this 27th day of December, 1989:

State of Oregon Department of Energy J

625 Marion St NE-Salem OR 97310 i

Mr. Michael J. Sykes l

Chairman of County Commissioners Columbia County Courthouse St. Helens OR 97051 a n. L i

S.

A. Bauer, Manager l

Nuclear Regulation Branch Nuclear Safety & Regulation l

i tubscribed and sworn to before me this 27th day of December, 1989.

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Notar Publig/of Oregon My Commission Expires:

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