ML20197J950
| ML20197J950 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 05/16/1986 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| TAC-60618, NUDOCS 8605200218 | |
| Download: ML20197J950 (4) | |
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Bart D Wens Vcc Presoxt May 16, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN:
Mr. Steven A. Varga Director, PWR-A Project Directorate No. 3 U.S. Nuclear Regulatory Commission Washington DC 20555
Dear Sir:
License Change Application 135 Pursuant to discussions with members of your staff (reference telephone conversation between Terence Chan and C. A. Zimmerman of April 16, 1986),
attached are revised pages for LCA 135 dealing with miscellaneous modifications to Technical Specifications 4.0.2, 4.4.6.1, 3.4.9.3, and Table 3.6-1.
As discussed in the telephone conversation, we have revised the Reason for Change and the Significant Hazards Considerations concerning the revision to Table 3.6-1 and the footnote to be applied to valve MD-059, Demineralized Water Washdown (Fire Water to the Containment). We trust these changes will assist your review and approval of this LCA.
Sincerely,
=+) w Bart D. Withers Vice President Nuclear Attachments c:
Mr. Lynn Frank, Director State of Oregon Department of Energy Mr. Michael J. Sykes Chairman of County Commissioners
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LCA 135 Page 1 of 3 DESCRIPTION OF CHANGE The following changes are proposed to the Trojan Technical Specifications (TTS) as discussed below and shown in Attachment 1.
REASON FOR CHANGE Page 3/4 0 TTS 4.0.2.b is revised to correct a typographical error.
Pane 3/4 4 TTS 4.4.6.1.b is revised to correct an editorial error.
" CALIBRATION TEST" is changed to " CHANNEL CALIBRATION". CALIBRATION TEST is not a defined term in TTS 1.0, whereas CHANNEL CALIBRATION is defined and cotsectly describes the surveillance performed.
Page 3/4 4-28a - TTS 3.4.9.3 is revised to correct an editorial error.
The correct Reactor Coolant System vent size is 3.40 square inches, not 3 square inches.
Panes 3/4 6-22 through 24 - TTS Table 3.6-1 is revised to delete valve CV-8825.
This valve is the RHR hot leg recirculation valve inside Containment. This valve was inadvertently not deleted from Table 3.6-1 in LCA 124 when Table 3.6-1 underwent a general revision. The basis for not including this valve is that this piping penetration is Type IV.
Type IV penetrations are required for post-Design Basis Event operation.
-By definition, Type IV penetrations only require one barrier. This barrier is provided by valve MO-8703 (RNR hot leg recirculation outside Containment), Which is still included in Table 3.6-1.
TTS Table 3.6-1 is also revised to allow manual valve MD-059 (demineral-ized water washdown) to be periodically opened under administrative control. This is accomplished by referencing the new footnote in Table 3.6-1 which is denoted by ##.
Valve MD-059 is opened to provide water to the Containment for fire protection when activities are occur-ring inside Containment which pose a fire hazard. The availability of the water is required per TTS 3.7.8.3, " Fire Hose Stations".
Administra-tively controlling the opening of valve MD-059 will allow TTS 3.6.1.1, 3.6.3.1, and 3.7.8.3 to be satisfied. A new footnote is added because the single asterisk footnote is not specific enough and because of the difference in intentions of the words " intermittent" and " temporary" as used here.
I SIGNIFICANT RAZARDS CONSIDERATION DETERMINATION The proposed changes do not increase the probability or consequences of i
an accident becauso:
i 1.
The changes to TTS 4.0.2.b, 4.4.6.1.b. and 3.4.9.3 are adminis-trative in that they correct typographical errors and make i-editorial improvements.
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i LCA 135 page 2.of 3 2.
The' change to TTS Table 3.6-1 which deletes CV-8825 is also a correction since.it deletes a valve which was inadvertently not deleted from LCA 124. Valve CV-8825 (RHR hot leg recirculation to SIS test line - inside containment) is associated with a piping penetration which is Type IV.
As discussed in FSAR Section 6.2.4.1, Type IV penetrations are those fluid lines which-must remain in service subsequent to a design basis event.
Type IV penetrations are required to have one Containment isola-4 tion valve. Valve MD-8703 (RHR hot leg recirculation - outside Containment) is the Containment isolation valve, not CV-8825, 3.
The change to TTS Table 3.6-1 is administrative since it resolves a conflict between TTS 3.6.1.1, Containment Isolation Valves, and l
TTS 3.7.8.3, Fire Hose Stations.
An example of when the conflict-may arise is when the plant is in Mode 4 and work is occurring inside containment for which the availability of water for fire i.
protection is required. Valve MD-059 would be opened to make domineralized water available for fire protection inside Contain-ment. However, since TTS 3.6.1.1 requires that this valve be i
closed from a Containment integrity standpoint, administrative controls would be established for this valve to ensure it was 4
closed once the work inside Containment was completed. These administrative controls include, but are not limited to, inclu-sion on the valve checkoff sheet for plant operational mode changes. Allowing valve MD-059 to be opened under administrative control will allow TTS 3.7.8.3 to be met, while also satisfying TTS 3.6.1.1.
A swing check valve is available inside Containment to isolate Containment and valve MD-059 could be immediately closed if necessary. Although this LCA would allow valve MD-059 to be opened in Modes 1, 2, or 3, the most likely mode is 4.
The proposed changes do not create a new or different kind of accident because:
1.
The changes to TTS 4.0.2.b, 4.4.6.1.b, and 3.4.9.3 are adminis-trative in that they correct typographical errors and make editorial improvements.
2.
The changes to TTS Table 3.6-1 are not related to creating a new or different kind of accident, but rather, deal with accident mitigation as related to Containment integrity. As previously discussed Containment integrity is not compromised by this change.
The proposed chr7ges do not result in a reduction in a margin of a safety because:
1.
The changes to TTS 4.0.2.b, 4.4.6.1.b, and 3.4.9.3 are adminis-trative in that thay correct typographical errors and make editorial improvements.
a LCA 135 Page 3 of 3 2.
The changes to TTS Table 3.6-1 do not compromise Containment
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integrity.
Therefore, no reduction in the safety provided by the Containment is proposed. From a fire protection standpoint, as related to valve MD-059, with this valve open the availability of fire water inside Containment is assured and, therefore, safety is enhanced.
In the April 6, 1983 Federal Register, the NRC published a list of examples of amendments that are not likely to involve a significant hazards consideration.
Example No. 1 of that list applies to the changes proposed herein and states:
"A purely administrative change to the technical specifications:
for erample, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature."
Since the above example is judged to apply to the proposed changes, the proposed changes are deemed not to pose a significant hazard.
SAFETY / ENVIRONMENTAL EVALUATION Safety and environmental evaluations were performed as required by 10 CFR 50 and the TTS.
This review determined that the proposed changes do not create an unreviewed safety question.
BLK/djh 0535W.586
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