ML20236N382

Application for Amend to License NPF-1,consisting of License Change Application 159,revising Tech Spec 3.9.9 to Resolve Inconsistencies within Tech Specs

ML20236N382
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/09/1987
From:	Cockfield D EUGENE WATER & ELECTRIC BOARD, PACIFICORP (FORMERLY PACIFIC POWER & LIGHT), PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20236N377	List: ML20236N373 ML20236N382 ML20236N386
References
NUDOCS 8711160140
Download: ML20236N382 (4)

Text

_ ._

. i.

i ti PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY Operating License NPF-1 ,

Docket 50-344 License Change Application 159 This License Change Application requests.a change to Section 3.9.9 of the  ;

Technical Specifications Appendix A to Operating License, NPF-1, for. the 4 Trojan Nuclear Plant to resolve inconsistencies within the Technical Specifications.

PORTLAND CENERAL ELECTRIC COMPANY By c h W C-D. W. Co,cicfield -

Vice Prbsident Nuclear  ;

l Subscribed and sworn to before me this 9th day of November 1987.

d4 s /, Y rf L Notary Public of Oregon

< meo-[ k 8 I/

O'MyCommission 4' B711160140 871109 i PDR ADOCK 05000344 \

P PDR

LCA 159 l Page 1 of 3 DESCRIPTION OF CHANGE {

l Trojan Technical Specification (TTS) 3.9.9 - Containment Ventilation Isolation System

- Applicability is changed from " MODS 6" to "During C0pE ALTERATIONS or movement of irradiated fuel within the containment".

- The Action statement is changed to specify closing Containment '

Ventilation penetrations providing direct access from the Contain-ment atmosphore to the outside atmosphere if the Containment Ven-tilation Isolation System (CVIS) is inoperable.

REASON FOR CHANCE The reasons.for the change to the Applicability are to resolve an in-consistency between TTS 3.9.9 (CVIS) and TTS 3.9.4 (Containment Building Penetrations) Limiting Conditions For Operation, and to resolve an incon-sistency between TTS 3.9.9 Applicability and Surveillance Requirements.

TTS 3.9.4 establishes closure requirements for Containment Building penetrations du?ing Refueling Operations when CORE ALTERATIONS or fuel movement is in progress inside the Containment. At other times in '

Mode 6, the Containment Building may be opened up, with the airlocks, equipment hatch and other penetrations open.

TTS 3.9.9 requires that each penetration providing direct access from the Containment atmosphere to the outside atmosphere be closed while in Mode 6 if the CVIS is inoperable. Since the Containment is normally open in Mode 6, as permitted by TTS 3.9.4, it is inconsistent to single out Containment Ventilation dampers for closure if CVIS operability is not maintained. In addition, the Surveillance Requirements of TTS 3.9.9 are

< required to be performed only before starting and while conducting CORE ALTERATIONS. No Surveillance Requirements for Mode 6 are specified if fuel movement or CORE ALTERATIONS are not in progress. The change, tnus, removes this inconsistency between TTS 3.9.9 Applicability and Surveil-lance Requirements.

The reason for the chage to the TTS 3.9.9 Action statement is to make it clear that only Containment Ventilation penetrations must be closed as a result of CVIS inoperability.

SIGNIFICANT MA2ARDS CONSIDERATION DETERMINATION This proposed change will revise the Applicability statement for the CVIS Refueling Operations Technical Specification. The CVIS is presently  !

required to be operable at all times in Mode 6. This change will revise

L LCA 159 Page 2 of 3 the CVIS Refueling Operations Technical Specification such that it is applicable during CORE ALTERATIONS.or movement of irradiated fuel within the Containment. Additionally, the Action statement is revised to spec-ify closing Containment Ventilation penetrations if CVIS is inoperable.

l-This chango does not involve a significant increase in the probabil4.ty or ,:

consequences of an accident. Status of the CVIS does not affect accident probability, because this system functions to isolate Containment Venti-lation penetrations after an accident has occurred. Operability of the CVIS enables automatic isolation of the Containment Ventilation penotra-tions. Containment Building penetration closure, while in Mode 6, is relied upon only while CORE ALTERATIONS or movement of irradiated fuel within the Containment is in progress per.TTS 3.9.4. This Technical Specification requires the Containment equipment door be closed, one door  ;

in each air lock be closed, and each penetration from Containment atmos-phere to outsido atmosphere be either closed or capablo of being closed by a Containment, Ventilation isolation valve. These operating and clo-sure restrictions on Containment Building penetrations are suff!.cient to restrict radioactive material release from a fuel element rupture while in the Refueling modo. As a result of this change, the same Applica-bility requirements will apply to CVIS as apply to Containment Building

. penetrations. The CVIS will be required to be operable to support Con-tainment Building penetration closure requirements. The change to the Action statement is an administrative change to provide clarification that only valves which rely on CVIS for automatic closure are required to be closed should CVIS become inoperable. The consequences of an accident are, thus, not increased, since this change does not involve a substan- I tive change to the condition of the containment Building in Mode 6.

This chango does not create the possibility of a new or different kind of accident from any previously evaluated. The operability of CVIS is not relevant to accident creation, since CVIS functions to mitigate the con-  ;

sequences of an accident after it has occurred. l J

This change does not involve a significant reduction in a margin of safety. The requirements for CVIS operability will match those for Con- l tainment Building penetration closure during Refueling Operations, and 1 affected Containment Ventilation valves will be closed should CVIS becomo inoperable. Penetration closure and CVIS operability will be required during CORE ALTERATIONS and fuel movement in Containment. Relaxation of CVIS operability requirements will bo permitted only when these evolu-tions are not in progress. The required status of the containment Build- )

ing will not be materially affected during Mode 6. j 1

In the April 6,1983 Federal Register, the IIRC published a list of exam- l ples of amendments that are not likely to involve significant hazards concerns. The following example from that list applies to this proposed 1

)

l l

l 4

_ _ _ - - - - - - J

j l .

l :* ,

LCA 159 Page 3 of 3 l- ,

j L change, demonstrating why this amendment is not considered likely to involve a significant hazards consideration:

"A purely administrative change to Technical Specifi-cations, og, a change to achieve consistency through-out the Technical Specifications, correction of an error, or a chante in nomenclature."

This change is-administrative in nature to achieve consistency throughout the Technical Specifications. Additionally, the change is consistent with the regulatory guidance of NUREG-0452. Revision 4, Standard Techni-cal Specifications for Westinghouse Pressurized Water Reactors (W-STS).

TTS 3.9.4 and 3.9.9 presently have different Applicability and Action statemente for very similar and interrelated Limiting Conditions For Operation (LCO). This change will make these two specifications consis-tent with each other. Additionally, the Surveillance Requirements for LCO 3.9.9 are keyed to the commencement of CORE ALTERATIONS. Therefore, this change would make Technical Specification 3.9.9 Applicability and Action consistent with its Surveillance' Requirements.

^ W-STS 3.9.9'for Containment purge and exhaust isolation system (equiva-lent to TTS 3.9.9) is applicable during CORE ALTERATIONS or movement of irradiated fuel within the Containment. Its Action statement requires purge and exhaust penetrations providing direct access from the Contain-ment atmosphere to outside atmosphere be cicsed when the isolation system is inoperable. The requirements of this propo-sed license change neo thus equivalent to that of regulatory guidance per W-STS.

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

SAFETY / ENVIRONMENTAL EVALUATION Safety and environmental evaluations were performed as required by f Title 10. Code of Federal Regulations, Part 50 and the TTS. This review I l

determined that the proposed change does not create an unreviewed safety question since it is administrative in nature to achieve consistency throughout the TTS.

I i

4 LAH/ maw 1605P 1

L '_ _._.._______.______9