ML20211K316

Safety Evaluation Supporting Amend 117 to License NPF-1

ML20211K316
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/20/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20211K306	List: ML20211K305 ML20211K311 ML20211K316
References
NUDOCS 8606270372
Download: ML20211K316 (3)

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 117 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 INTRODUCTION By letter dated June 9, 1986, the staff confirmed its telephone authorization given to Portland General Electric Company (the licensee) on June 8,1986 for an amendment to Facility Operating License NPF-1, Appendix A, the Trojan Nuclear Plant Technical Specifications (TS), as requested by telephone conversation with T. Chan on June 7, 1986, as confirmed in the licensee's letter dated June 9, 1986. The staff's letter also confirmed its discussion with Mr. Orser of the licensee's staff that Trojan will perform and meet the surveillance test requirements of the proposed change to TS 4.6.2.2.d regarding the Spray Additive System prior to criticality. The staff's Safety Evaluation is presented below.

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DISCUSSION AND EVALUATION By letter dated October 14, 1983, the licensee submitted a revised Containment Spray System spray additive tank flow rate test method (TS 4.6.2.2.d) to be compatible with the Standard Technical Specifications for Westinghouse Pressurized Water Reactors (Revision 4 of NUREG-0452). By letter dated March 20, 1984, the staff issued Amendment 87 to the Trojan TS approving the revised test.

During the 1986 refueling outage, while performing the spray additive flow rate test for the first time under the new TS, a flow rate considerably lower than that which was obtained during data acquisition testing to establish the revised TS surveillance flow requirement, was achieved. In retrospect, the licensee discovered that the testing done to establish the flow rate for the revised method was based on an inappropriate valve alignment configuration.

Furthermore, the licensee has determined that this test methodology does not accurately demonstrate the operability of the system.

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S Therefore, the licensee proposed to change the TS to revert to the original test method used during the first two surveillance tests conducted in 1975 and 1981, which has been proven to be a valid test for successfully demonstrating spray additive system operability. This test entails draining the sodium hydroxide from the spray additive tank, refilling it with water and measuring the gravity fed flow rate to the eductor, with the containment spray pump operating in a recirculation mode using the Refueling Water Storage Tank water.

The staff concurs with the licensee that the inability to meet current surveillance requirements does not mean the spray additive system is inoperable, but rather the TS is not adequate for determining system operability. Therefore, since the previous test method was adequate for demonstrating operability of the spray additive system, the licensee's proposal to change the surveillance requirement to the original surveillance requirement is acceptable to the staff.

However, to assure the operability of the spray additive system, the staff's acceptance is conditional upon the successful performance of the surveillance test requirements of the proposed TS 4.6.2.2.d prior to criticality.

EVALUATION OF SIGNIFICANT HAZARDS CONSIDERATION In accordance with the requirements of 10 CFR 50.92, the licensee submitted the following significant hazards consideration:

This change does not involve a significant increase in the probability or consequences of an accident since this change only proposes an alternate method for verifying operability of the spray additive system. Therefore, the proposed change does not alter the likelihood of supplying Na0H to the Containment spray water nor the amount of Na0H supplied.

This change does not create the possibility of a new or different kind of accident. Neither the design of the Containment Spray System nor the manner in which it would be operated in an accident are being altered.

The design basis of 34-40 gpm of spray additive flow is not being

- changed, only the method for verifying that flow is being changed. The proposed change to Surveillance Requirement 4.6.2.2.d is not related to accident creation.

This change does not involve a significant reduction in a margin of safety. Since no change is proposed to the Limiting Condition for Operation, the spray additive system will continue to ensure that:

(1) the iodine removal efficiency of the spray water is maintained, and (2) corrosion effects on components within Containment are minimized, to the same extent as assumed in the accident analysis.

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 Consider-ation. Example (ii) of that list applies to this change and states:

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"A change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, e.g.,'a more stringent surveillance requirement."

This example is judged to apply because the proposed change requires an operational test using the Containment spray pumps as opposed to the less restrictive gravity flow test through drain valves.

The staff has reviewed the licensee's significant hazards consideration and concurs with the licensee that the proposed change does not involve a

, significant hazards consideration.

FINDING ON EXISTENCE OF EMERGENCY SITUATION In its submittal of June 9,1986, the licensee explains that since the inadequacy of the test could not have been identified until the test was run, the need ,

for the emergency Technical Specification change could not have been averted.

The staff has reviewed the submittal and concludes that since the test was run during startup testing and its successful completion was required before the plant could proceed to Mode 4, Hot Shutdown, failure to act in a timely manner would result in an unnecessary delay of plant startup. For that reason the Comission issued this amendment under the provisions of 10 CFR 50.91(a)(5).

ENVIRONMENTAL CONSIDERATION This amendment involves a change in surveillance requirements and involves no

significant hazards consideration. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The amendment meets the eligibility criteria for categorical exculsion set forth in 10 CFR 951.22(c)(9). Pursuant to 10 CFR 951.22(b), no

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environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment, i CONCLUSION We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be i

endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Dated: June 20,1986 PRINCIPAL CONTRIBUTOR:

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