ML20234C810
| ML20234C810 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/02/1987 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TAC-64533, NUDOCS 8707060675 | |
| Download: ML20234C810 (4) | |
Text
N ammums s!!g Portlaixi General Elechic Coiripraiy David W. Cockfield Vice President, Nuclear July 2, 1987 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555
Dear Sir:
Replacement Pages to Licenno Change Application 150 Pursuant to telephone conversations with your staff, attached are replace-ment pages to License Change Application (LCA) 150 requesting amendment of Operating License NPF-l.
This LCA revises surveillance requirements for safety injection accumulator isolation valves. The replacement pages pro-vido additional discussion supporting a proposed determination that the I
change involves no significant hazards consideratione as defined in Title 10, Code of Federal Regulations, Part 50.92.
Sincerely, Attachments l
c:
Mr. John B. Martin Regional Administrator, Region V U.S. Nucicar Regulatory Commission Mr. R. C. Barr Resident Inspector Trojan Nuclear Plant Mr. David Kish, Director State of Oregon Department of Energy Mr. Michael J. Sykes Chairman of County Commissioners
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I LCA 150 page 1 of 3 Description of Change Delete the words "... by removal of the breaker from the circuit" from Technical Specification 4.5.1.c.
Reason for Change Technical Specification Surveillance Requirement 4.5.1.c for accumulator isolation valves M08808A, B, C and D requires disconnecting power from the valve operators by removal of the breaker from the circuit Whenever RCS pressure exceeds 2000 psig. This results in loss of valve position indi-cation (VpI) in the control room and necessitates racking in the breaker to regain remote operation capability.
The requirement to remove the breaker is unnecessarily restrictive and inconsistent with other Technical Specifications. With the installation of a lockout feature on the accumulator isolation valve control room switches, control power to the valve operators could be disconnected remotely While retaining VpI.
A change to the Technical Specification is necessary to allow use of this preferred method to satisfy the curveillance requirement.
Significant Hazards Consideration Determination In accordance with the requirements of 10 CFR 50.92, this LCA is judged to involve no significant hazards based upon the following information:
1.
Does the proposed license change involve a significant increase in the probability or consequences of an accident?
This proposed change does not involve a significant increase in the probability or consequences of an accident.
The surveillance requirement for the safety injection accumulator isointion valves ensures the operability of the accumulators in the event of an accident. As part of the Emergency Core Cooling System, the function of the accumulators is to mitigate the consequences of an accident. Thus, the operability of the accumulators does not affect the probability of an accident.
The accumulators mitigate the consequences of an accident by deliver-ing a specified volume of borated water into the Reactor Coolent System. As long as the volume of water delivered to the Reactor Coolant Systen is unchanged and the time for delivery is not increased, then the consequences of an accident are not affected.
Surveillance Requirement 4.5.1.c prevents the undesired mechanical motion of the accumulator isolation valves by disconnecting power to the electrical control system for the valve operators while in Modes 1, 2 or 3*.
This action ensures the availability of a flowpath from the
- pressurizer pressure above 1000 psig.
r 4
LCA 150 page 2 of 3 accumulators to the Reactor Coolant System and conforms with guidance provided in Branch Technical position Instrumentation and Control Systems Branch (ICSB) 18 (power Systems Branch (pSB)), " Application of the Single Failure Criterion to Manually Controlled Electrically Operated Valves".
The proposed change to Technical Specifica-tion 4.5.1.c does not alter this requirement for disconnecting power, only the requirement that this be accomplished by removal of the l
breaker from the circuit.
An alternative method is to disconnect power to the valve operator control circuit through a lockout feature on the control switch.
Lockout is achieved by pulling out on the switch handle while in the
" normal" (12 o' clock) position.
In this position, all rotary action of the switch is inhibited, and both the hot and neutral leads of the control circuit are opened. This halts any valvo action in progress and precludes any manual or automatic valve actuation.
Inadvertent pushing of the handle is prevented ty placing a blocking collar over the switch operating shaft when it is pulled out.
i Use of a lockout feature on the control switch of these valves does not affect the operation of any other system. Similarly, none of the exieting interlocks, cetpoints, alarms, or operating parameters associated with the valves are changed. Conformance with guidance provided in Branch Technical position ICSB-4 (pSB), " Requirements on Motor-Operated Valves in the ECCS Accumulator Lines" remains unchanged.
2.
Does the proposed license change create the possibility of a new or different kind of accident from any accident previously evaluated?
Changing this surveillance requirement for accumulator isolation valves to allow use of the lockout feature does not create the possi-bility of a new or different kind of accident. Demonstration of operability for each accumulator remains a requirement.
The control / lockout switches are fully qualified for Nuclear Class IE applications and preclude any manual or automatic actuation of the valves when placed in lockout. No other system is affected by the change.
3.
Does the proposed amendment involve a significant reduction in a margin of safety?
Since the requirement to demonstrate operability of each accumulator remains, there is no significant reduction in the margin of safety.
Use of the lockout feature may actually increase the margin of safety since VPI is retained and remote valve control can be returned more expeditiously. The volume of water provided by the accumulators and the time for delivery is not affected by this change.
R f-LCA 150 Page 3 of 3 i
.)
i In the' April 6, 1983 Federal Rer,ister, the NRC published a list of examples of amendments that are not likely to involve a significant hazards concern. Although none of the examples apply directly, this change is bounded by conditions described in Example (vi) Which states:
"A change Which either may' result in some increase to the probability or consequences of a previously analyzed. accident or may reduce in some way a safety margin, but where the'results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan, eg, a change result-ing from the application of a small refinement of a previously used calculational model or design method."-
l Safety / Environmental Evaluation
' Safety and environmental evaluations were performed as required by Title 10, Code of Federal Regulations, Part 50 and the Trojan Technical Specifications. This review determined that an unreviewed safety question does not exist since Plant operations remain consistent with the Updated FSAR, adequate surveillance is maintained, and there is no conceivable impact upon the environment.
DLN/kal 5989k.687