ML20235Q910

Application for Amend to License NPF-1,consisting of License Change Application 173,clarifying Surveillance Requirements for Containment Equipment Hatch

ML20235Q910
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/10/1989
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20235Q902	List: ML20235Q898 ML20235Q910 ML20235Q919
References
NUDOCS 8903030074
Download: ML20235Q910 (4)

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l PORTLAND CENERAL ELECTRIC COMPANY l EUCENE WATER & ELECTRIC BOARD l AND PACIFIC POWER & LIGHT COMPANY Operating License NPF-1 Docket 50-344 License Change Application 173 This License Change Application requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to clarify the surveillance requirements for the Containment equipment hatch.

PORTLAND CENERAL ELECTRIC COMPl.NY By D. W. Cock _ffeld Vice President Nuclear Subscribed and sworn to before me this 10th day of February 1989.

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4 Notary Public of Ore (gon OMyCommission 4.<_adev[ [ #[/

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LCA 173 l Attachment A l Page 1 of 3 j 1

Description of Chango j I

Trojan Technical Specification (TTS) 3/4.6.1, " Containment Integrity" is l revised to dolote the following sentence: 1 "2. All equipment hatches are closed and scalod."

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RenGon for Change  !

I Trojan Technical Specification Surveillance Requiromant 4.6.1.1 requires that primary Containment integrity shall bo demonstrated at least every j 31 days by verifying (1) that all penetrations (except those portions i located inside Containment) are closed except as provided in Specifica-tion 3.6.3.1, and (2) that all equipment hatches are closed and scaled. I Following each opening of the equipment hatch during cold shutdown and )

beforo returning to full-power operation, the equipment hatch is verified l closed and scaled per Maintenance Procedure (MP) 8-1, " Equipment Hatch l Removal and Installation", and Periodic Engineering Test (PET) 5-2,

" Containment Local Leak Rate Testing". Verification of closure and seal of the equipment hatch can only be accomplished from within the Contain-  !

ment by verifying the torque on the closure nuts and a leak-rate test. 1 To do so every 31 days would require that Plant personnel enter the Containment while the reactor is at full power with an attendant risk of increased exposure to radiation. The estimated radiation levels at the hatch are 300-400 mR/ hour neutron and 400-500 mR/ hour gamma. This change climinates the need to enter Containment and is consistent with As Low As Reasonably Achievable (ALARA) principles.

In addition, the equipment hatch, by virtue of design, is a penetration that qualifics for the exemption, "except those portions located inside ,

Containment", as provided in TTS 4.6.1.1.a.1, since the equipment hatch '

cover and seal are located within Containment.

This change is consistent with the Westinghouse Standard Technical Specifications (NUREG-0452, Revision 4).

Significant Hazards Consideration Determination In accordance with the requirements of Part 50.92 of Title 10 of the Code of Federal Regulations (10 CFR 50.92), this License Change Application (LCA) is judged te involvo no significant hazards based upon the following constdorations:

1. Does the proposed license amendment involve a significant increase in the probability or consequences of an accident?

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J LCA 173 Attachment t Page 2 of 3 Including the verification of closure and seal of the equipment hatch in the exclusion to TTS Surveillance Requirement 4.6.1.1.a.1 does not involve a significant increase in the probability or consequence of an accident because the hatch is closed, scaled, and verified por Mp 8-1 and leak testod per PET 5-2 to ensure that the requirements of 10 CFR 50, Appendix J are mot. There is no identifiable mechanism th9t would cause the nuts securing the hatch bolts to looson, thereby ,

causing leakage past the scal.

The proper method for verifying that any Containment penetration is

" sealed" is to perform a leak test. As discussed above, the equipment hatch is subject to leak tests por the requirements of 10 CFR 50, Appendix J. This chango doos not alter the loak testing frequency, method, or acceptanco critoria, but merely clarifies that thic verification of sealing and closure nood not be performed overy 31 days.

2. Does the proposed licenso amendment create the possibility of a new or different kind of accident from any previously evaluated?

The Containment mitigatos the consequences of an accident and ]

verification of its integrity is not related to accident creation. J l

The change proposed is an administrative chango that does not alter l the equipment hatch test frequency, test methods, or acceptance l critoria.

3. Does the proposed licenso amendment involve a significant reduction in a margin of safety?

In accordance with the TTS and 10 CFR 50, Appendix J, the equipment hatch is tested at the peak Containment internal pressure following a design basis event (60 psig). This test is performed annually during refueling. No change to this testing is proposed. Instead, the TTS are merely being clarified to doloto the implication that the equipment hatch scaling capability, i.e., leak rato, should be demonstrated overy 31 days. Since no change to equipment hatch testing is proposed, and because the current testing program complies with 10 CFR 50, Appendix J, no significant rodJction in a margin of safety is involved.

In the March 6, 1986 Federal Register, the NRC published a list of examples of amendments that are not likely to involve a significant hazards consideration. Example No. 1 from this list states:

"A purely administrative change to Technical Specifications, e.g.,

a change to achiovo consistency throughout the Technical Specifi-cations, correction of an error, or a change in nomenclatuco."

This examplo applies to the change proposed heroin.

Based on the above ovaluation, this change does not pose a significant hazard.

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LCA 173 l Attachment A l I

Pago 3 of 3 l

Safety / Environmental Evaluation Safety and environmental evaluations woro performed as required by Title 10, Codo of Federal Regulations, Part 50 and the TTS. This review determined that the proposed chango does not create an uncoviewed safety question, nor does it create an uncoviewed environmental question.

Scheduto Conalderation I i

I It is requestod that the offectivo dato of this amendment be upon issuance by the Nuclear Regulatory Commission.

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