ML20235Q919

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Proposed Tech Specs Re Limiting Conditions for Operation & Surveillance Requirements for Containment Integrity for Equipment Hatches
ML20235Q919
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 02/10/1989
From:
PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20235Q902 List:
References
NUDOCS 8903030077
Download: ML20235Q919 (14)


Text

._ -

j LCA 173 Attachment B

!. Page 1 of 1  ;

1 3/4.6 CONTAINMENT SYSTEM _S_

3/4.6.1 PRIMARY CONTAINMENT CONTAINMENT INTEGRITY

_ LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: MODES 1, 2, 3 and 4 ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

SURVEILLANCE REQUIREMENTS ,

l 4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that:

All penetrations (except those portions located inside Containment) not can ble of being closed by OPERABLE Containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Specification 3.6.3.1.

b. By verifying that each containment air lock is OPERABLE per Specification 3.6.1.3.
c. By verifying that valves, blind flanges, and deactivated automatic valves which are located inside the Containment are verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

TROJAN-UNIT 1 3/4 6-1 Amendment No. 147 July 11, 1988 g3((3902100500p[-[

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMM1,SSION 4

In the Matter of )

)

PORTLAND GENERAL ELECTRIC COMPANY, )- Docket 50-344 THE CITY OF EUGENE, ORGEON, AND ) Operating Licetse NPF-1 PACIFIC POWER & LIGHT COMPANY )

)

(TROJAN NUCLEAR PLANT) )

CERTIFICATE OF SERVICE  !

i I hereby cert.ify that copies of License Change Application 173 to-the Operating License'for Trojan Nuclear Plant, dated February 10, 1989, have been served on the following by hand delivery or by deposit in the United  ;

States mail, first class, this 10th day of February 1989:

]

d State of Oregon l

Department of Energy I 625 Marion St NE I Salem OR 97310 l l

Mr. Michael J. Sykes l Chairman of County Commissioners Columbia County Courthouse ]

St. IIelens OR 97051 ki o-S. A. Bauer, Manager Nuclear Regulation Branch Nuclear Safety & Regulation Subscribed and sworn to before me this 10th day of February 1989.

I id Y ebt Notary Public of Q egon d OMyCommission & au / I MM

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PORTLAND GENERAL ELECTR1C COMPANi EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LICllT COMPANY Operating Licenso NPF-1 Docket 50-344 Licenso Change Application 173 This License Chango Application roquests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to clarify the surveillance requirements for the containment equipment hatch.

PORTLAND GENEFAL ELECTRIC COMPANY By ,

D. W. Cocl<tiold l Vice Pres'ident Nuclear Subscribed and sworn to before me this 10th day of February 1989.

4Ade Y 4tWsk Notary Public of Ordson My Commission Expiros: 4 red I /k/'

/

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1

.i LCA 173 Attschment A Page 1 of 3 Description of Change I

Trojan Technical Specification (TTS) 3/4.6.1. " Containment Integrity" is revised to delete the following sentence:

"2. All equipment hatches are closed and sealed."

l Reason for Change Trojan Technical Specification Surveillance Requirement 4.6.1.1 requires that primary Containment integrity shall be demonstrated at least every 31 days by verifying (1) that all penetrations (except those. portions

~

located inside Containment) are closed except as provided in Specifica-tion 3.6.3.1, and (2) that all equipment hatches are closed and sealed.

Foliawing each opening of the equipment hatch during cold shutdown and bc . :e returning to full-power operation, the equipment hatch is verified closed and sealed per Maintenance Procedure (MP) 8-1, " Equipment Hatch 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.

To do so every 31 days woulA require that plant personnel enter the containment while the reretor is at full power with an attendant risk of increased exposure to radiation. The estimated radiation levels at the hetch are 300-400 mR/ hour neutron and 400-500 mR/ hour gamma. This change eliminates 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 qualifies 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).

Sir,nificant Hazards Consideration Determination In accordance with the requirements of Part 50.92 of Title 10 of the Code l of Federal Regulations (10 CFR 50.92), this License Change Application ]

(LCA) is judged to involve no significant hazards based upon the following .]

considerations:

l

1. Does the proposed license amendment involve a significant increase in ,

the probability or consequences of an accident? l ll j

I

', .v LCA 173 3

Attachment A 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 . sealed, and verified per MP 8-1 and leak tested per PET 5-2 to ensure that the requirements'o/

10 CFR 50, Appendix J are met. There is no identifiable mechanism that would cause the nuts securing the hatch bolts to loosen, thereby causing leakage.past the seal.

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 per the requirements of 10 CFR 50, Appendix J. This change does not alter the leak testing frequency, method, or acceptance criteria, but merely clarifies that this verification of sealing and closure need not be performed every 31 days.

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

The Containment mitigates the consequences of an accident and verification of its integrity is not related to accident creation.

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

3. Does the proposed license 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 delete the implication that the equipment hatch sealing capability, i.e., leak rate, should be demonstrated every 31 days. Since no change to equipment hatch testing is proposed, and because the current testing program complies j with 10 CFR 50, Appendix J, no significant reduction in 2 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 j hazards consideration. Example No. I from this list states: l "A purely administrative change to Technical Specifications, e.g.,

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

1 This example applies to the change proposed herein.

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

LCA 173 Attschmsnt A Page 3 of 3 1

Safety / Environmental Evaluation }

l Safety end environmental evaluations were performed as required by Title 10, Code of Federal Regulations, Part 50 and the TTS. This review determined that the proposed change does not create an unreviewed safety question, nor does it create an unreviewed environmental question.

Schedule consideration It is requested that the effective date of this amendment be upon issuance by the Nuclear Regulatory Commission.

1 I

l TDW/KAH/mi 2816W.0289 l

' LCA 173

- Attachment B Page 1 of 1 ,

\

3/4.6 CONTAINMENT SYSTEMS j l

3/4.6.1 PRIMARY CONTAINMENT l f

CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONTAINMENT INTEGRITY within one hour or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

SURVEILLANCE REQUIREMENTS 4 . 6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

a. At least once per 31 days by verifying that:

All penetrations (except those portions located inside Containment) not capable of being closed by OPERABLE Containtnent automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Specification 3.6.3.1.

b. By verifying that each containment air lock is OPERABLE per Specification 3.6.1.3.
c. By verifying that valves, blind flanges, and deactivated automatic valves which are located inside the Containment are verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

TROJAN-UNIl 1 3/46-1 Amendment No. 147 July 11, 1988

", i '.

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PORTLAND GENERAL ELECTRIC COMPANY, ) Docket 50-344 THE CITY OF EUGENE, ORGEON, AND ) Operating License NPF-1 PACIFIC POWER & LIGHT COMPANY )

)

(TROJAN NUCLEAR PLANT) )

CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 173 to the Operating License for Trojan Nuclear Plant, dated February 10, 1989, have  ;

been served on the following by hand delivery or by deposit in the United States mail, first class, this loth day of February 1989:

State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes Chairman of County Commissioners Columbia County Courthouse St. Helens OR 97051 k k, im -

S. A. Bauer, Manager Nuclear Regulation Branch Nuclear Safety & Regulation l

Subscribed and sworn to before me this 10th day of February 1989, Od M7L Notary Public of 96egon GMyCommission u am # I /I[/

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PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD 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 equipsnont hatch.

PORTLAND GENERAL ELECTRIC COMPANY By /

D. W. Cockfield Vice President Nuclear Subscribed and sworn to before me this 10th day of February 1989.

d4 Y 4slA Notary Public of Ordgon OMyCommission c_#gf #/ /((/

o 1

v .s LCA 173

- Attcchment A Page 1 of 3 Description of Change Trojan Technical Specification (TTS) 3/4.6.1, " Containment Integrity" is revised to delete the following sentence:

"2. All equipment hatches are closed and sealed." ,

1 l

1 Reason for Change Trojan Technical Specification Surveillance Requirement 4.6.1.1 requires ,

that primary Containment integrity shall be demonstrated at least every 31 days by verifying (1) that all penetrations (except those portions located inside Containment) are closed except as provided in Specifica-tion 3.6.3.1, and (2) that all equipment hatches are closed and sealed.

Following each opening of the equipment hatch during cold shutdown and before returning to full-power operation, the equipment hatch is verified ,

closed and sealed per Maintenance Procedure (MP) 8-1, " Equipment Hatch l Removal and Installation", and Periodic Engineering Test (PET) 5-2,

" Containment Local Leck 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.

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 ganea. This change eliminates 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 qualifies for the exemption, "except those portions located inside j 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 (NUREC-0452, Revision 4).

Significant Hazards Consideration Determination i

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 to involve no significant hazards based upon the following l considerations: ]

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

t l

l

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l 4

l

l

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LCA 173 Attechment A Page 2 of 3 Including the verification of closure and seal of the equipnent 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, sealed, and verified per MP 8-1 and leak tested per PET 5-2 to ensure that the requirements of 10 CFR 50, Appendix J are met. There is no identifiable mechanism that would cause the nuts securing the hatch bolts to loosen, thereby causing leakage past the seal.

The proper method for verifying that any Containment penetration is i

" sealed" is to perform a leak test. As discussed above, the equipment hatch is subject to leak tests per the requirements of 10 CFR 50, Appendix J. This change does not alter the leak testing frequency, method, or acceptance criteria, but merely clarifies that this verification of sealing and closure need not be performed every 31 days.

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

The Containment mitigates the consequences of an accident and verification of its integrity is not related to accident creation.

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

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

In accordance with the TTS and 10 CFR 50, Appendix J, the equipment i 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 delete the implication that the equipment hatch sealing capability, i.e., leak rate, should be demonstrated every 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 reduction 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. Exangle No. I from this list states:

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

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

This example applies to the change proposed herein.

Based on the above evaluation, this change does not pose a significant hazard L _________________

v . . .

LCA 173 l

- Attschmsnt A Page 3 of 3 l

l Safety /Envirownental Evaluation Safety and environmental evaluations were performed as required by Title 10, Code of Federal Regulations, Part 50 and the TTS. This review )

determined that the proposed change does not create an unreviewed safety I question, nor does it create an unreviewed environmental question.

Schedule Consideration i i

It is requested that the effective date of this amendment be upon f issuance by the Nuclear Regulatory Commission, j O

i i

i I

l l

l TDW/KAH/ml 2816W.0289 l

l

1 y ..e.

LCA 173 l

- Attachment B {

Page 1 of 1

^

i 3/4.6 CONTAINMENT SYSTEMS I

3/4.6.1 PRIMARY CONTAINMENT CONTAINMENT INTEGRITY LIMITING CONDITION FOR OPERATION 3.6.1.1 Primary CONTAINMENT INTEGRITY shall be maintained.

i APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

Without primary CONTAINMENT INTEGRITY, restore CONT AINMENT INTEGRITY within one hour or be in COLD SHUTDOWN within the next 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

SURVEILLANCE REQUIREMENTS __

4.6.1.1 Primary CONTAINMENT INTEGRITY shall be demonstrated:

1

a. At least once per 31 days by verifying that:  !

All penetrations (except those portions located inside l Containment) not capable of being closed by OPERABLE Containment automatic isolation valves and required to be closed during accident conditions are closed by valves, blind flanges, or deactivated automatic valves secured in their positions, except as provided in Specification 3.6.3.1.

I

b. By verifying that each containment air lock is OPERABLE per Specification 3.6.1.3.
c. By verifying that valves, blind flanges, and deactivated automatic valves which are located inside the Containment are verified closed during each COLD SHUTDOWN except that such verification need not be performed more often than once per 92 days.

i TROJAN-UNll 1 3/46-1 Amendment No. 147  !

July 11, 1988 1

v ~

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

)

PORTLAND GENERAL ELECTRIC COMPANY, ) Docket 50-344 THE CITY OF EUGENE, ORGEON, AND ) Operating License NPF-1 PACIFIC PCWER & LICHT COMPANY )

)

(TROJAN NUCLEAR PLANT) )

CERTIFICATE OF SERVICE I hereby certify that copies of License Change Application 173 to the Operating License for Trojan Nuclear Plant, dated February 10, 1989, have been served on the following by hand delivery or by deposit in the United States mail, first class, this 10th day of February 1989:

State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes Chairman of County Commissioners Columbia County Courthouse St. Helens OR 97051 k

S. A. Bauer, Manager n

Nuclear Regulation Branch Nuclear Safety & Regulation 4

Subscribed and sworn to before me this 10th day of February 1989.

l bu / bat Notary Public of 9degon Ge/CommissionE a am, # [ /I[/

p '

I l

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