ML20154Q715

Safety Evaluation Supporting Amend 114 to License NPF-1

ML20154Q715
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/12/1986
From:	Office of Nuclear Reactor Regulation
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ML20154Q698	List: ML20154Q696 ML20154Q706 ML20154Q715
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NUDOCS 8603210266
Download: ML20154Q715 (10)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.114 TO FACILITY OPERATING LICENSE NO. NPF-1 PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE, OREGON PACIFIC POWER AND LIGHT COMPANY TROJAN NUCLEAR PLANT DOCKET NO. 50-344 4 I. INTRODUCTION A. DESCRIPTION OF PROPOSED ACTION The proposed action would amend various sections of Appendix A of the Technical Specifications for the Trojan Nuclear Plant (the facility) to correct or clarify the existing specifications and facilitate their use by the operating staff.

A Notice of Consideration of Issuance of Amendment to License and Proposed No Significant Hazards Consideration Determination and Opportunity for Hearing related to the requested action was published in the Federal Register on October 9, 1985 (50 FR 41255).

No comments or requests for hearing were received.

B. BACKCROUND INFORMATION By letter dated March 12, 1985, the Portland General Electric Company (the licensee) submitted License Change Application 118.

This application contained proposed revisions to various sections of the technical specifications including: Containment Integrity, Reactor Trip Instrumentation Setpoints, Borated Water Sources, Reactivity Control Systems, Power Distributions Limits, etc. The proposed changes are intended to correct errors in the present specifications, clarify the meaning of the specifications or make the specifications easier to use by restating operating limits in

' terms of equivalent parameters that are readily monitored by the plant operators.

By letter dated' August 22, 1985, the licensee reque'st'ed that tue portion of the March 12, 1985 amendment request related to the definition of Containment Integrity (Specification 1.8) be with-drawn. The change would have allowed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for restoration of air lock operability and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for restoration of isolation The staff valve operability instead of the current 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> limit.

has reviewed your August 22, 1985 request and has determined that since the current Technical Specification are more conservative withdrawal is acceptable.

B603210266 060312 PDR ADOCK 05000344 PDR p

C. SCOPE OF REVIEW .

This review has considered only the changes in the facility technical specifications requested by the licensee. It has not considered those portions of the technical specifications for which changes were not requested. In performing this review we have considered whether the changes would reduce any of the operational ,

or administrative requirements implemented at the facility. Whether or not such a reduction was proposed, we have evaluated whether the change would: (1) increase the probability or consequences of accidents considered in the FSAR, (2) create the possibility of an accident not considered in the FSAR, or (3) reduce the margin of safety as defined in the basis for any technical specification.

II. EVALUATION

a. Table 2.2-1, Item 15. This item specifies the required T' rip Setpoint and Allowable Value for undervoltage of the power supply for the reactor coolant pumps. The specification presently requires the Trip Setpoint to be equal to or greater than 68% for each bus and the Allowable Value to be equal to or greater than 67% for each bus. The licensee proposes to revise the specification by adding the specific voltage value corresponding to these percentage values.

Specifically, the licensee proposes to add a value of 8.48 kv in parentheres, following the 68% specification and a value of 8.35 kv in parentheses, following the 67% specification. The licensee states these voltage values are based on the bus design voltage of 12.47 kv as specified in Updated FSAR Section 8.3. We have ccr. firmed this is the design voltage of the bus used to power the reactor coolant pumps, as stated in Section 8.3 of the Updated FSAR, and we have confirmed the correctness of the proposed voltage values. We also note the Standard Technical Specifications for Westinghouse Pressurized Water Reactors (STS), NUREG-0452, Revision 4, express these limits in terms of voltage, rather than as a percent of design voltage. Accordingly, we conclude this is an editorial change, made for the purpose of clarification, and is acceptable.

b. Specification 3.1.2.7. This specification sets forth Limiting Conditions for Operation (LCOs) for Borated Water Sources when the reactor is in Operational Modes 5 and 6. The licensee proposes to reword paragraph 3.1.2.7.a to refer to a " boric acid storage system" rather than the present reference to a " boric acid storage tank".

The licensee states this makes the specification consistent with the STS, which address a "boration system" rather than a single tank.

Because the facility is equipped with two Boric Acid tanks supplying a common header, and because the change is consistent with the STS, we conclude this is an editorial change and is acceptable.

The licensee also proposes to increase the required minimum contained volume of Boric Acid from 9,235 gallons to 10,000 gallons.

The license states this is necessary to account for the 741 gallon minimum indication level of the second tank when this specification is revised to cover both tanks. (We note this specification was revised by Amendment 95 to account for the minimum indication level of one tank). With this addition, the resulting valu'e would be 3,976 gallons; however, the licensee has rounded this upward to 2

10,000 gallens. Because the prcposed revision is acre restrictive then the present specification, in order to account for the minimum indication level of a second storage tank, we conclude the proposed revision is acceptable.

The licensee has proposed revisions to the Bases for this specification to reflect the proposed changes described above. Our review indicates the proposed revisions are appropriate for the

• proposed changes in the specifications, and do not reduc,e the present margin of safety. Accordingly, we conclude the proposed changes in the Bases for this specification are acceptable. We have also corrected a typographical error in the licensee's submittal.

c. Specification 3.1.2.8. This specification sets forth LCOs for Borated Water Sources when the reactor is in Operational Modes 1 through 4 The licensee proposes to revise this specification by increasing the volume of borated water that must be availhble in the Boric Acid storage system f rom 15,159 ~ gallons to 15,900 gallons. As in the case of specification 3.1.2.7, this increase is proposed to account for the minimum indication level of the second storage tank.

Because the proposed revision is more restrictive than the present specification, in order to account for this minimum indication level in a second storage tank, we conclude the proposed revision is acceptable.

As in the case of specification 3.1.2.7, the licensee has proposed changes to the Bases which correspond to the proposed revisions to .

this specification. We find the proposed revised Bases appropriate and acceptable.

d. Specification 3/4.1.3.2.

This specification sets forth operability -

requirements for the control rod position indicating systems. The licensee proposes to revise the wording of this specification to eliminate reference to rod position indicator " channels". In support of this change, the licensee notes the rod position indicating system for each control rod consists of two position data channels, A and B, either of which alone can measure rod position within the required accuracy. Because of this design, the use of the term " channel" in the present specification, lends itself to mis-interpretation. For example, one of the data channels for a given control rod could be inoperable, but the position indication system for that rod could still be operable. Nevertheless, because of the present wording, such a condition might be interpreted as a position indicator channel being inoperable.

Our review of the STS indicates the revised wording,p,roposed by the licensee conforms more closely to the STS wording. We also note the STS requires all rod position indicating systems to be operable, but does not require the individual Data Channels comprising the system to be operable if that does not af fect system operability, Based on the above, we conclude the proposed revision clarifies the requirement of the specification in conformance with the intent as expressed in the STS. Accordingly, we conclude the proposed change is acceptable.

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e. Specification 4.2.1.1.b. This specification sets forth the requirements for monitoring the reactor Axial Flux Difference at times when the Axial Flux Difference Monitor Alarm is inoperable.

The specification presently requires the monitoring and logging of the Axial Flux Difference for each operable excore flux channel at least once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the Axial Flux Difference .

Monitor Alarm is inoperable, and once per 30 minutes the,reaf ter.

The licensee proposes to revise the specification to require monitoring the Axial Flux Difference every 30 minutes whenever the Alarm is inoperable; i.e. climinate the one hour allowance during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee notes this change is more restrictive, but requests it nevertheless, in the belief it will ,

enhance safety and preclude potential violations of the technical specifications. This latter consideration derives from specification 3.2.1.a.2(a)(1), which limits operation with the Axial Flux Difference outside the Target Band to one hour cumulative in the preceding 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. By monitoring the Axial Flux Difference more frequently, the licensee expects an improved capability to conform to this LCO.

The staff has considered this proposed revision and concludes it is more restrictive than present specifications with respect to the requirements for monitoring and logging the Axial Flux Dif ference, and does not reduce any other current requirements. Accordingly, we find the proposed revision acceptable. _

f. Specification 3.4.1.4 This specification sets forth limits on the startup, and operation of reactor coolant pumps. The limits are imposed to prevent low temperature over-pressurization events. The licensee proposes to revise the wording of sub-paragraph b of this specification from:

"The secondary side temperature of each steam generator is less than 50*F greater than each of the RCS cold leg '

temperatures...."

to:

"The secondary side temperature of each steam generator is less than 50*F above each of the RCS cold leg temperatures (ie T'q g <

TC+ 0*F)...."

The licensee states this proposed revision, including the equation.

is intended to clarify the meaning of the specification. Our review indicates the proposed revision does clarify the requirement and does not reduce any of the present requirements. Accordingly, we conclude this is an editorial change and is acceptable.

g. Specification 4.5.2.a. This specification lists a number of valves associated with the operation of the Emergency Core Cooling System (ECCS) and states the valve pusition must be verified to be correct each 31 days. The licensee proposes to change the humb'er of the valve appearing as Item d in this list (SIS Hot Leg Injection) from MO 8002-A to MO 8802-A. The licensee states the present number is a 1

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typsgraphicel error. We have revi(wed the applicable facility

. drawing (M-206) tnd ccnfirmed the designations of the SIS Hot Leg Injection valves are NO 8802-A and MO 8802-B.

Accordingly, we agree 1 that the present designation is incorrect and the proposed revision is appropriate and acceptable.  !

h. Specification 4.5.3.1. This specification defines the surveillance ,

requirements for the ECCS when the reactor is in the liot Shutdown Operating Mode (350 F > T >200*F). At present this specifteation states "The ECCS subsystem"Ehall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2." The licensee proposes to revise this specification to explicitly state which surveillance requirements (of 4.5.2) are applicabic in this Mode Specification 4.5.2 lists nine areas of Surveillance Requirements --

designated 'a' through 'i' Among these areas, the licensee proposes the following be defined as applicable to speci(ication 4.5.3.1: c, d.1, d.2, d.3.a, e.1, e.2.a. e.2.c, e.3, f.1, g.1, h, i.1, and i.3. The surveillances the licensec considers not applicable to this specification are discussed below.

As for a reas 'a' and 'b', which the licensee proposes to define as "not applicable", these surveillances involve periodic verification of the valve alignment necessary for automatic initiatton of the ECCS. The licensee states these surveillances are not necessary for the Mode covered by this specification (Mode 4) because the existing Limiting Conditions for Operation (LCOs) for this Mode explicitly permit manual valve realignment. Our review of the existing -

specifications confirms the LCOs for Mode 4 permit manual realignment of ECCS valves. Accordingly, we agree the surveillances necessary to provide an OPERABLE flow path for auto-initiation of the ECCS in Modes 1, 2 and 3 are not required in Mode 4. We also note, however, Mode 4 is a transitory condition - usually lasting no more than a few hours during plant startup and shutdown. The surveillances in question, however, are only required once every 31 days (125%). Thus, since the plant is normally in Mode 4 only for short periods of time, we see no need to explicitly waive the requirements for these surveillances while in Mode 4 Further, we believe such an explicit waiver could be misinterpreted to justify not performing a surveillance that was due because the plant was in Mode 4. Finally, the present specification (which follows the wording of the STS) allows the licensee to determine which surveillance requirements are applicable in Mode 4, and these determinations are subject to review by the NRC inspection program.

Based on these considerations, we conclude the licensee has not demonstrated a significant need for this proposed revision, and that the proposed revision could confuse, rather than clarify, present requirements. Accordingly, we conclude this proposed revision is not acceptable and have not included it in this amen,dment.

As for areas d.3.b, d.3.c, e.2.b, f.2, g.2, g.3 and i.2; these surveillances all refer to valves or pumps that are part of the Safety Injection System. The licensee proposes to delete these requirements from this specification on the basis the technical specifications do not require the Safety Injection System to be OPERABLE in Mode 4 5

i Regarding paragraphs d.3.b and d.3.c, these items require the position of certain ECCS manual throttle valves in the Safety Injection System be verified to be correct at least once every 18 months. As discussed above, because Mode 4 is typically a

• transitory condition, we question the need for such a wa_iver relative to a surveillance that is only required at 18 month (+ 25%)

intervals. Indeed, the only circumstance when such relief would be meaningful would be if the reactor were to remain in Mode 4 for a period in excess of 18 months. Even then, however, upon leaving Mode 4 the licensee would be obliged to promptly perform the surveillance as described under specification 4.5.2. Accordingly, because the licensee has not demonstrated a significant need for this change, and because the proposed revision could confuse rather than clarify the applicability of surveillance requirements, we do not find the portion of the proposed revision that would delete paragraphs d.3.b and d.3.c acceptable, and have not included it in this amendment.

Regarding paragraph e.2.b, this specification requires the testing of each Safety Injection Pump at least once per 18 months (+ 25%),

during shutdown, to verify it starts automatically upon receipt of a safety injection signal. As with the case discussed above, we find this to be an important long-term periodic surveillance that is not meaningfully related to transitory Operating Modes. Further, the _

fact the testing is to be performed when the reactor is shutdown (normally meaning Mode 5 - Cold Shutdown, or Mode 6 - Refueling),

suggests the surveillance is not performed in Mode 4. The proposed revision, therefore, app' ears to have little or no meaning or significance. In addition, as discussed above, the adoption of this revision could confuse, rather than clarify the intent of the specification. Accordingly, we do not find the portion of the proposed revision that would delete paragraph e.2.b acceptable, and have not included it in this amendment.

Regarding paragraph f.2, this specification requires the flow characteristics of Safety Injection cold leg piping be determined and adjusted during shutdown, following completion of modifications that would alter the flow characteristics of this piping. It is the staff's view this is a clearly prudent requirement that is not altered by the fact the plant does or does not require certain equipment during a particular Operating Mode. Accordingly, we find the licensee has not provided sufficient justification for waiver of this requirement during Mode 4 and conclude this portion of the proposed revision is not acceptable. This proposed revision, therefore, is not included in the present amendment.

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Regarding paragraphs g.2 and g.3, these items require verification of the correct positioning of specified ECCS manual throttle valves following stroking and or maintenance of the valves, when the associated ECCS system is required to be OPERABLE. Incorporation of the proposed revision to the technical specifications would waive this verification requirement for the Safety Injection System when the reactor was in Mode 4. The licensee's basis for requesting this change is that this system is not required to be OPERABLE in Mode 4.

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Since the present specification already makes allowance for Operability requirements, we conclude this proposed revision would duplicate existing provisions and is, therefore, unnecessary.

Because the licensee has provided no other basis for this proposed revision, we have not included it in the present amendment. ,

Regarding paragraph i.2, this item requires the licensee to verify the Safety Injection Pump meets or exceeds a specified minimum discharge pressure when tested pursuant to Specification 4.0.5 (In-Service Testing). The proposed revision would waive this requirement when the reaci.or was in Mode 4, based on the fact the Safety Injection System is not required to be OPERALLE in Mode 4.

In-Service Testing is required by the facility Technical Specifications and 10 CFR 50.55a (g), and is not conditigned on Operational Modes except where a written request for relief, based on impracticality, has granted. Inasmuch as no relief based on impracticality has been requested in this case, we conclude the proposed revision is not acceptable and it is not included in the present amendment.

i. Specifications 3.7.3.2 and 4.7.3.2. These are new technical specifications proposed to be added by the licensee. The proposed specifications address the LCOs and Surveillance Requirements applicable to the Component Cooling Water (CCW) system when the reactor is in Operating Modes 5 and 6. In requesting these .

additions, the licensee notes that although the present LCOs for the CCW system are applicable only in Modes 1-4, the CCW system is also needed in Modes 5 and 6 to support systems required to be OPERABLE in these Modes, e.g. the Residual Heat Removal Pumps and Heat Exchangers. The licensee also notes the definition of OPERABLE includes the requirement that supporting systems, such as cooling water systems, also be OPERABLE, but that this requirement is not addressed explicitly in the technical specifications.

To remedy this condition, the licensee has proposed these additional technical specifications. The proposed Limiting Condition for Operation would require the operability in Modes 5 and 6 of at least one component cooling water train capable of supplying cooling water to equipment required to be OPERABLI in Modes 5 and 6. The associated ACTION statement would be that if this LCO could not be met, the supported equipment would be required to be declared INOPERABLE. As a surveillance requirement, the licensee proposes the portion of the system necessary to support equipment required to be OPERABLE in Modes 5 and 6, be verified OPERABLE by testing in accordance with Specification 4.0.5 (In-Service Testing).

Based on our review of the proposed additions to the technical specifications, we find they provide clarification of, but do not reduce any present requirements. Accordingly, we conclude the incorporation of the proposed additional specifications will not reduce the safety of operations, and such incorporation,is acceptable.

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j. Specifications 3.7.4.2 and 4.7.4.2. These are new technical specifications proposed to be added by the licensee to address the LCOs and Surveillance Requirements applicable to the Service Water system when the reactor is in Operating Modes 5 and 6. As with the CCW system discussed above, the licensee notes that although the .

present LCOs for the Service Water system are applicable,only in Modes 1-4, this system is also needed in Modes 5 and 6 to support systems required to be OPERABLE in these Modes, e.g. the CCW system and Diesel Generators.

Accordingly, the licensee has proposed specifications for the Service Water system that are basically similar to those proposed for the Component Cooling Water system. For the same reasons stated for that system, se find the additional specifications proposed by the licensee for the Service Water system to be acceptabfe.

k. Basis - Specification 3/4.1.1.4. This specification sets forth LCOs and Surveillance Requirements for the Moderator Temperature Coefficient (MTC). The licensee proposes to revise the Basis for this specification to be consistent with the actual requirements of the specification. At present, the Basis refers to "... measurement of the MTC at the beginning, middle and near the end of each fuel cycle...." The licensee states this is inconsistent with the actual specification which only requires the HTC to be measured near the

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beginning of the fuel cycle and again, near the end. The licensee, _

therefore, proposes to correct this inconsistency by deleting the word " middle" from the Basis. In support of this proposed change, the licensee states the revised wording would also be consistent with that given in NUREG-0452, Revision 4 (Standard Technical Specifications for Westinghouse Pressurized Water Reactors).

We have reviewed the current wording of this specification and its related Basis. We have alao reviewed the Standard Technical Specifications referenced by the licensee. Based on this review, we conclude the proposed change would provide consistency with the present requirements of the technical specifications and with the Standard Technical Specifications. Accordingly, we find the proposed change acceptable.

1. Bat is - Specification 3/4.2.1. This specification sets forth the LCOs and Surveillance Requirements for Axial Flux Difference (AFD).

The licensee proposes to revise the associated Basis section to correct a typographical error. The error involves the number of detectors that must indicate the AFD is outside the target band in order to initiate an alarm. The Basis presently sthtes an alarm message will be generated if 3 of 4 or 2 of 3 OPERABLE excore channels are outside the target band; while the specification states the indicated AFD shall be coosidered out of its target band when at least 2 of 4 or 2 of 3 OPERABLF channels are indicating the AFD is outside the target band.

Based on this discrepancy and the fact a 2 of 4 requirement is more restrictive than a 3 of 4 requirement, we conclude the proposed 8

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change is a proper correctioa, does not reduce the present level of safety and is, therefore, acceptable.

m. Basis - Specification 3]4.4.3.2. This specification sets forth ,

Operability and Surveillance Requirements for the pressurizer Power Operated Relief Valves (FORVs) and the associated Block Valves. The Basis for this specification presently states the PORVs have remotely operated block valves to provide a positive shutoff capability "should a relief valve become inoperable". The licensee states this wording may be misleading because there are situations, other than PORV inoperability, when it is necessary or desirable to close the Block Valve. These include situations when the PCRV has a minor leak, or when it is necessary to perform surveillance testing.

The licensee therefore proposes to revise the wceding in the Basis to state the Block Valve can be closed "when necessary".

Based on our review, we agree the present wording in the Basis section is subject to mis-interpretation. We also agree there are conditions other than PORV inoperability when i* is necessary or desirable to close the Block Valve. We turther note Specification 3.4.3.2 imposes no limitations on closure of the Block Valves - only on valve operability. According!y, based on the foregoing considerations, we conclude the proposed change to this Basis

. Section is acceptable.

n. Basis - Specification 3/4.4.4. This specification addresses the Operability and Surveillance Requirements associated with the Pressurizer. One of the operability requirements is the pressurizer shall be OPERABLE with at least 150 kw of pressurizer heaters. The licensee proposes to revise the Basis section for this specification by adding a sentence stating that a minimum of seven pressurizer heaters (23 kw each) are needed to meet this power requirement. We conclude this is an editorial revision and that it is acceptable.

o. Basis - Specifications 3/4.5.2. and 3/4.5.3.1. These specifications set forth the Operability and Surveillance Requirements for ECCS subsystems. Specification 3.5.2 applies in Modes 1-3 and requires two independent ECCS subsystems to be OPERABII in these Modes.

Specification 3.5.3.1 applies in Mode 4 and requires only one ECCS subsystem to be OPERABLE. These requirements are essentially identical to those stated in the Standard Technical Specifications for Westinghouse reactors. The licensee proposes to add to the Basis for these specifications an explanation of why only one ECCS subsystem is needed in Mode 4 (RCS temperature < 350*F). The proposed explanation is virtually identical to that presented in the Standard Technical Specifications.

Inasmuch as the proposed revision merely explains the Basis for existitig requirements and does not reduce any present requirements or limitations, and because the proposed Basis is substantially identical with that presented in the Standard Technical.

Specifications for Westinghouse reactors, we conclude the proposed revision is acceptable.

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[ p. Figure 6.2-2, Facility Organization. This Figure shows the administrative organizational structure at the facility and among i other information, indicates those in the organization that are members of the Plant Review Board. The licensee states the revision of this .Tigure issued by Amendment 86 was in error because it

] indicated Assistant Shift Supervisors were members of the Plant Review Board, and this is not consistent with Specification 6.5.1.2.

The licensee therefore proposes to correct the error by revising the

) Figure as necessary to be consistent with Specification 6.5.1.2. We j

conclude this is an editorial change and is acceptable.

j III. CONCLUSIONS Environmental Consideration i This amendment involves a change in the installatten or use of a facility component located within the restricted area as defined in 10 CFR Part 20, changes in surveillance requirements and a change in administrative requirements. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, j of any effluents that may be released offsite, and that there is no sionificant increase in individual or cumulative occupational radiation exposure. The Commission has previously published a proposed finding that the j . amendment involves no significant hazards consideration and there has been no l public comment on such finding. Accordingly, the amendment meets the -

i eligibility criteria for categorical exclusion set forth in 10 CFR 531.22(c)(9) and (10). Pursuant to 10 CFR 551.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the J

issuance of the amendment.

1 Conclusion l

We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public i

will not be endangered by operation in the proposed manner, and (2) such

, activities will be conducted in compliance with the Commission's i

4 regulations, and the issuance of the amendment will not be inimical to common defense and security or to the health and safety of the public.

! Date: March 12, 1986

, Principal Contributor:

G. Zwetzig.

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