ML20155A501

Requests NRC Concurrence W/Util Interpretation of Tech Spec 4.6.1.1.a.1 That Only Valves in Main Flow Path Included in Verification on 31-day Frequency

ML20155A501
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/21/1986
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
References
TAC-61360, NUDOCS 8604090034
Download: ML20155A501 (3)

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Q March 21, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator, Region V Creekside Oaks Office Park 1450 Maria Lane, Suite 210 U.S. Nuclear Regulatory Commission Walnut Creek CA 94596-5368

Dear Mr. Martin:

Surveillance of Containment Penetration Test and Vent Valves Recept discussions with members of your staff have indicated a concern with our implementation of Trojan Technical Specification (TTS) 4.6.1.1.a.1.

This Technical Specification requires a verification every 31 days of the position of all non-aut s ~cally isolated Containment penetrations that are required to be closed during accident conditions. It has been the PGE position that only those valves in the main flow path are to be included in such verification on the 31-day frequency. All other valves are verified to be in their position on a less frequent basis. PGE has established this position based upon the following considerations:

1. TTS 4.6.1.1.a 1 specifically refers to all penetrations, and not all valves in the penetrations. Those penetrations " capable of being closed by operable Containment automatic isolation valves, and required to be closed during accident conditions" are specifically excluded from the 31-day surveillance requirement.

At Trojan, penetrations have always been understood to include the associated main flow path isolation valves, interconnecting piping, and test and vent connections. If test and vent connections and their associated valves are considered applicable under this specification, then there would be no penetrations that would be excluded from the definition of this Technical Specification since all penetrations are equipped with test and vent connections. There would be no application or reason to have this Technical Specification. On the other hand, inasmuch as many of those penetrations that are automatically isolated 9604090034Byh44 ADOCK O PDR PDR P

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Portlanc!Generci ElectricCoisva ry Mr. John B. Martin March 21, 1986 Page 2 and are required to be closed have test and vent connections and are excluded from the 31-day requirement, it logically follows that for the penetrations with manual isolation valves, the test and vent connec-tions are also excluded from the 31-day surveillance.

2. The test and vent coenections are in small lines, 1/2- to 3/4-in.-

diameter, and are not considered in the TTS or FSAR as Containment isolation valves. On.y the valves in the main flow path, whether manually or automatically actuated, are considered Containment isolation valves.

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3. TTS 4.6.1.1.a.1 refers to the valves in Table 3.6-1 of Specifica-tion 3.6.1, and implies that the valves listed therein are the ones that are subject to*~the periodic 31-day surveillance requirement.

None of the manual valves on the test and vent connections are listed in Table 3.6-1, and thus, are not considered subject to the 31-day surveillance.

4. Notwithstanding all of the above, it is felt that the intent of TTS 4.6.1.1.a.1 is to periodically verify the position of those valves that are frequently operated and therefore, have a greater probability of being mispositioned. The test and vent valves are not routinely cperated, are typically used only once a year upon the performance of an LLRT, and then are subsequently verified closed by procedure. Since these valves are typically not operated again until an LLRT is per-  ;

formed on that penetration, there is no reason to expect that they have been cycled or operated, and no reason to verify their position, since it has not changed since the last LLRT. Further, each of the test and vent connections outside Containment has a cap on the end of the con-nection and is less likely to be removed between surveillances than a valve being mispositioned.

This interpretation of TTS 4.6.1.1.a.1 was established in discussion with the NRC shortly after issuance of the Trojan Operating License. Thic TTS has not been revised and is consistent with the Trojan FSAR. PGE's position on this interpretation has not changed.

PGE feels that adequate controls have been established and are being main-tained to verify the position of these test and vent valves. The appropri-ate test procedures require restoration of these valves to their proper position following an LLRT and ILRT. Valve lineups are performed to ensure this position. PCE does not disagree with the importance of verifying the position of these valves, just in the frequency at which it is required.

Upon identification of this concern, a position verification of the test and vent valves outside containment was performed, and all test and vent connection valves were confirmed to be closed. PGE will continue to per-form a monthly verification of these valves until this issue is resolved.

, N h ElechicW Mr. John B. Martin March 21, 1986 Page 3 Interpreting this TTS to require monthly position checks of the test and vent valves is felt to result in imposing additional requirements which should be considered under 10 CFR 50.109.

Ycur concurrence with this interpretation will serve as a final resolution to this issue.

Sincerely, Bart D. Withers Vice President Nuclear c: Document Control Desk U.S. Nuclear Regulatory Commission Mr. Lynn Frank, Director State of Oregon Department of Energy