ML20214V694

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Comments on Tech Spec 4.6.1.1.a.1 Surveillance Requirement Re Applicability to Containment Penetration Test & Vent Valves Per Region V 860422 Request.Surveillance of Penetration Test & Valves Should Be Once Per Every 31 Days
ML20214V694
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 06/05/1987
From: Jocelyn Craig
Office of Nuclear Reactor Regulation
To: Knighton G
Office of Nuclear Reactor Regulation
Shared Package
ML20214V698 List:
References
TAC-61360, NUDOCS 8706120249
Download: ML20214V694 (2)


Text

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'o, UNITED STATES 4

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j NUCLEAR REGULATORY COMMISSION r.

l WASHINo TON, D. C. 20666 k **.e p'#

June 5, 1987 l

Docket No. 50-344 MEMORANDUM FOR: George W. Knighton, Director Project Directorate - V Division of Reactor Projects III, IV and V FROM:

John W. Craig, Acting Chief P1 ant Systems Branch Division of Engineering and Systems Technology

SUBJECT:

CLARIFICATION OF TROJAN TS 4.6.1.1.a.1 CONCERNING THE SURVEILLANCE OF CONTAINMENT. PENETRATION TEST AND. VENT CONNECTION VALVES (TAC NO. 61360)

Plant Name:

Trojan Nuclear Plant Licensee:

Portland General Electric Company Docket No.:

50-344-Review Status:

Complete l

By memorandum dated April 22, 1986, Region V requested that NRR review the requirements of the Trojan Nuclear Plant Technical Specification (TS)

Farveillance Requirement (SR) in Section 4.6.1.1.a.1 with regard to its applicability to containment penetration test and vent valves. The wording of Trojan TS SR 4.6.1.1.a.1 explicitly requires a verification every 31 days that "all penetrations... not capable of being closed by OPERABLE containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flenges, or deactivated automatic valves secured in their positions." The licensee's position is that this 31 day verification requirement applies to "only those valves in the main flow path

[and not to the] test and vent connections and their associated valves." We disagree with the licensee's. position as discussed below.

We have considered the regulatory basis for the specific TS on containment isolation and note the following. The test and vent connections are located between the cain flow path containment isolation barriers (valves) and the containment wall.

Thus, they are part of the containment boundary and are, therefore, governed by the GDC concerning containment isolation.

Further, the j

guidelines in SRP Section 6.2.6, Containment Leakage Testing, state that test and vent connection valves should be subject to periodic surveillance to verify the effectiveness of administrative controls for ensuring their proper position.

Further, it has been a long standing staff practice regarding TS interpretation s,ould be ta.n,t the TS requirements are explicit, the that to the exten nd intent ite,al,,.

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Based on the above, we conclude that compliance with Trojan TS SR 4.6.1.1.a.1 would require regular surveillance of the containment penetration test and vont connection valves. The surveillance should be at least once per 31 days en.ept where the staff has approved a change to a lesser frequency such as for valves located inside containment (e.g., memorandum from C. Rossi to T. Chan dated January 7, 1987).

/ John W. Craig, Acting Ch f Plant Systems Branch Division of Engineering and Systems Technology 1

CC:

E. Butcher T. Chan D. Langford i

R. Barr, R:V M. Mendoca, R:V S. Richards, R:V CONTACT:

C. Li X79414 l

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