ML20059L668
| ML20059L668 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/21/1990 |
| From: | Cross J PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20059L666 | List: |
| References | |
| NUDOCS 9009270249 | |
| Download: ML20059L668 (4) | |
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Operating License NPF11
. Docket 50-344 License Change Application 203, Revision'1 9:i-This License Change-Application requests modifications to Operating
- License NPF-1 for the Trojan Nuclear Plant to change Trojan Technical
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Specification Table 3.6-1, " Containment Isolation Valves".
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PORTLAND GENERAL ELECTRIC-COMPANY t
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Subscribed and' sworn to before me this 21st day,of September 1990.
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,LCA 203, Revision 1
-Attachment A
,Page 1 of 3 y
Reason for Channe and Justification of Emergency Circinna t ances -
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<The original Trojan Technical Specification (TTS) 3/4.6.3,:" Containment
. Isolation-Valves"J included a requirement in the surveillance section for:
valve (cycling at least once per 92 days. The column dTestable During c
Plant Operation" of TTS Table 3.6-1 delineated which of the valves could
- beLso tested.while the Plant was operating.
On June 10, 1982, Paragraph 4.6.3.1.1.a was removed from the Technical Specification by Amendment 174 and was replacad by a, requirement to perform theitesting in accordance with TTS 4.0.5 li.e., the Inservice Testing (IST) Progran.l.
Since the IST program delineates which valves can be tested at power and which cannot,-the " Testable During Plant Operation" column should have
- been deleted as part of Amendment 74 as well, but was not.
As discussed with the Nuclear Regulatory Commission (NRC) staff on
. September 7,1990,' it has been recognised that a conflict.c.xists in that -
TTS 4.7.1.2.1, " Auxiliary Feedwater System", requires periodic testing of
. the auxiliary feedwater _(AW) turbine-driven pump, but Table 3.6-1 prohibits. cycling of-the steam supply valves to the turbine during Plant operation. To alleviate the; conflict, it is requested in accordance with Title 10 of:the Code of Federal Regulations, Part 50, Paragraph 91(a)(5)
'[10 CFR-50.91(a)(5)], " Emergency Circumstances", that this License Change Application (LCA) be processed on an emergency basis to support the next scheduled surveillance test. The AW turbine-driven pump, which is on
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increased surveillance frequency, is scheduled for testing October 1, 1990. The test date can be extended further under the provisions of TTS 4.0.2, but this is' not desirable because of the pump's increased monitoring status. A functional problem = affecting the AW turbine-driven a
pump requiring 4 the pump to be run within'72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in order to return it E
_to service could arise at anytime.
7 The TTS conflict has existed since the TTSs were issued' On September 6, 1990, it was determintd that strict compliance with both Table 3.6-1.and TTS 4.7.1.2.1 could not be achieved. The NRC was contacted the following morning and later told that an LCA would be' submitted.
The time period for, resolution of the conflict is as discussed above. Technical Ljustification to.show that the Plant can be safely operated under the existing conditions is.provided under "Determinatican of Significant Hazards. Consideration". Cycling the AW turbine-driven pump steam supply valves improves their reliability because the air-driv,.n operators are of f
a lubricated cylinder' design. The Trojan Plant is prese?tly operating in Mode 1 " Power Operation", but would have to be shut down if the AW turbine-driven pump could not be tested as required by TTS S.7.1.2.1.
l The stroking of the AW turbine-driven pump steam supply valvos that has occutred 'while conducting past pump testo during Plant operatun, will be the subject of a forthcoming licensee event report. The licenice event report will niso inclufe reporting that under the IST program, the safety injection (5?) pump disebarge valves outside containment have been tested during Plant operation, which is also prohibited by Table 3.6-1.
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t c7, LCA 203, Revision 1 Attachment A'
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Page 2 of 3
- t This LCA makes-the necessary. changes to resc1ve the conflict of testiing the AW: turbine-driven pump and to correct. the numbers of - the AW turbine-driven pump steam s,upply valves, which were changed from l
' motor-driven to air-ope ated to make their operation independent of alternating current power.
Description of Changt-1.
The "no" designations.are changed to "yes" in the TTS Table 3.6-1 column entitled " Testable ~During Plant Operation" for the main ateam-If to AW' pump turbine-driver supply valves.
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The numbers'of-main steam to A W pump turbine o iver supply valves.
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' listed in TTS Table 3.6-1 are corrected as followst. M0-2218 becomes l
l' CV-1451, MO-2228 becomes CV-1452, MO-2238 becomes 07-1453, and MO-2248 becomes CV-1454.
.' Determination of Sinnificant Hazards Consideration In accordance with the requirements of 10'CFR 50.92, " Issuance of Amendment, this LCA is judged to involve no significant. hazards' based e
upon the following information:
- 1.,Does the. proposed' license change involve a significant increase in p
the probabill',y or consequences,of = an accident'l' 1
K The.immediate effect of approval of the proposed changes to TTS Table ~ 3.6-l' will be that the. AW turbine-driven pump steam' supply
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valves'will-continue to be. tested during Plant operation, but that testing will.now be in compliance with the TTS.: The AW turbine-driven pump steam supply valves have been required to be cycled during Plant operation throughout Plant life in satisfying testing requirements of TTS 4.7.1.2.1.
Testing of the valves concurrent with the' pump-test does not' increase the probability or
, consequences of aC accident since running!the pump test places the V
valves. in-their accident position (open) and cycling valves closed s
for valve testing does not inhibit pump. operation..
i Tba changes to the valve numbers are administrative and have no effect on_ increasing the probability or consequences of an accident.
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- 2..Does the proposed license change create the-possibility of a new or l1
~different kind of accident from any accident previously analyzed?
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Testing,of the AW turbine-driven pump steam supply valves does not
' create,the possibility of a new or different kind of accident since running the pump. test places ~the valves in their accident position
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.(open) and cycling valves closed for valve testing does not inhibit L
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- pump operation.
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i LCA-203,' Revision;1' l
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The changesito the valve numbers 're administrative and have no a
1 effection tha accident analyses.
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3.. Does the proposed license change involve a significent reduction in-a rargin of safetyt Testing of t?e AFW turbine-driven pump steam supply. valves does not-1 reduce 'he margin of-safety, since opening ofLthese normally: closed valves.mu es than to their accident ponition.:
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-The' changes to valve numbers correct the' identification of-valves' which have_already been incorporated into the' design, and as such,'
it is an administrative change with no affect-on safety margin.
In the March 6, 1986 Federal Register, the NRC publish'ed a list of.
examples of amendments that are not likely to involve a significant
-hazards consideration. ' Examples (i) and (vii) from this list state:
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-(1). A purely administrative change to technical specifications:
for example a change to achieve-consistency-throughout the technical specifications., correction of an error, or a change in nomenclature.
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(vil) A change to conform a license to changes'in the j
regulations, where the license change results in very minor changes to facility operations clearly n
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in keeping:with the regulations.
1 The changes to valve numbers are similar to Example (1).
The'additionalL testing of valves: during Loperation is similar to Example- (vii).
It is-1 noted'that the TTS Table 3.6-1 column entitled " Testable During Plant
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Operation" is not included'~in NUREG-0452, " Standard Technical' Specifications for Westinghouse Pressurized Water Reactors".
Safetv/ Environmental-Evaluation Safe'ty and environmental evaluations were performed as required by
-10 CFR-50.59 and the TTS. The review determined that'the proposed change 1
does not create an unreviewed safety question,;nor~does it create an-t 4tnreviewed environmental question.
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