ML20236Q219

Application for Amend to License NPF-1,consisting of Rev 1 to License Change Application 142,resolving Control Room Habitability Issues by Changing Tech Spec Sections Re Chlorine Detection Sys & Control Emergency Ventilation Sys

ML20236Q219
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	11/16/1987
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20236Q207	List: ML20236Q205 ML20236Q219 ML20236Q227
References
NUDOCS 8711190246
Download: ML20236Q219 (11)

Text

.

1 PORTLAND CENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY I

Operating License NPF-1 Docket 50-344 License Chango Application 142, Revision 1 This License Change Application requests modifications to Appendix A of Operating License NPF-1 for the Trojan Nuclear Plant regarding control room habitability by proposing changes to Section 3/4.3.3.6, Chlorino Detection Systems, and Section 3/4.7.6.1, Control Room Emergency Ventilation System.

PORTLAND CENERAL ELECTRIC COMPANY B \C-D.f.Cdekfield Vice President '

Nuclear Subscribed and sworn to before me this 16th day of November 1987.

[6e $ A Notary Public of QEcgen 9MyCommission ce,a e /' // /[f/

v l[k1 DbN $4 P

l LCA 142, Revision 1 Page 1 of 10  ;

i l

DESCRIPTION OF CHANGE The f ollowing changes to the Trojan Technical Specifications (TTS) are proposed: {

1. TTS 3/4.3.3.6. Chlorine Detection Systems l This TTS is revised to be applicable in ALL MODES instead of MODES 1 through 4. Reference to the detectors being located in the control room duct is deleted. A CHANNEL FUNCTIONAL TEST to be performed at least once per 31 days is added to the SURVEILLANCE REQUIREMENTS.

2. TTS 3/4.7.6.1. Control Room Emergency Ventilation Systeu (CB-1)

This TTS is revised to: (a) be applicable in ALL MODES; (b) incorpo-rate the ACTION statement from the Standard Technical Specifications for Westinghouse Pressurized Water Reactors (W-STS (NUREG-0452, Revi-sion 4)); (c) include a provision in the ACTION statement for a limited period of operation if specified pressure cannot be main-tained in the control room; (d) reduce the frequency of the monthly cooling capability test to quarterly until completion of the 1988 refueling outage; (e) increase the HEPA and charcoal filter test efficiency to 199.95 percent from 1 99 percent; (f) specify a system flow rate of 3000 cfm and 525 cfm makeup flow; (g) incorporate the l Regulatory Guide 1.52 test guidelines and American Society for Test-ing and Materials (ASTM) D3803-79 testing methods for laboratory charcoal analysis; (h) perform testing overy month to demonstrate that a pressure of 11/8 inch water gauge (W.G.) can be maintained relative to adjacent spaces and to outside atmosphere; (i) specify expected automatic actions on Safety injection, High Radiation, High SO2 , and High Chlorine signals; and (j) add additional background information to the BASES.

The above changes are shown in Attachment C.

REASON FOR CHANGE In References 1 through 3, PGE committed to evaluate the TTS that affect control room habitability. This evaluation was committed to based on NRC inspections of Trojan in January and February 1986, and a series of dis-cussions and meetings held subsequent to these inspections. Our evalua-tion has concluded that changes to the TTS are needed as identified above and further described below. i l

9

1. TTS 3/4.3.3.6. Chlorine Detection Systems The change to make this TTS applicable in ALL MODES and to add a CHANNEL FUNCTIONAL TEST conforms with the W-STS (NUREG-0452, l

l i

i L

L l LCA 142, Revision 1 Page 2 of 10 Revision 4) and providos greater assurance of protection for the j control room operators from chlorino gas releases. The change i deleting reference to the chlorino detcetors as being in the intake ducts is done for consistency since the detectors are located immediately outside the normal intako location.

2. TTS 3/4.7.6.1 Control Room Emergency Ventilation System The change to make this TTS applicable in ALL MODES conforms with the E-STS (NUREG-0452, Revision 4) and provides greater assurance the control room will remain habitable. The change to incorporate the H-STS. ACTION is done to provide ACTION statements for MODES 5 and 6, for which thero previously were none, to be consistent with the above chango in APPLICABILITY to ALL MODES.

An allowance is added to the ACTION statement for a limited period of operation if control room pressure cannot bo maintained at its speci-fled value. This is to permit a reasonable time period to locate and correct system problems, provided the control room can be maintained at a reduced positivo pressure.  !

The footnoto added to Surveillance Requirement 4.7.6.1.a allows the cooling capability test to be performed at reduced frequency. This change proposes to reduce the test frequency from monthly to quar-terly. Operating experience has shown that cooling capability does not chango dramatically over short intervals. A quarterly test is deemed adequato to determine if the cooling capability of CB-1 has degraded. Also, since the test will be run on a staggered test basic, one system will be tested overy 46 days. If degradation is found in the testod system, the other system would be thoroughly evaluated.

The change to specify a total flow rate for CB-1 of 3000 cfm ensures that the residence timo for radioactivity in the filter units is 2025 seconds as assumod in the control room dose calculations.

Specification of a maximum makeup flow rato providos assurance that the filtered makeup flow rato is $525 cfm as determined in the control room dose calculations.

The change to increase the HEPA filter and charcoal filter test removal officiency to 99.95 percent conforms with the M-STS (NUREG-0452, Revision 4) and Regulatory Guide 1.52. In addition, this will make the TTS consistent with the assumptions in the control room dose calculations.

The change to incorporate the Regulatory Guido 1.52 test requirements for laboratory charcoal analysis into the TTS is consistent with the W-STS (EUREC-0452, Revision 4). In addition, this will make the TTS consistent with the assumptions in the control room dose calculations.

i t

LCA 142, Revision 1 Page 3 of 10 Frequency of the test to demonstrate that the control room can be maintained at a positive pressure is changed from every 18 months to monthly. This increased test frequency of control room pressuriza- l tion capability will provide greater assurance that integrity of the control room envelopo is being maintained. Additionally, a demon- '

stration of control room positivo pressure 11/8 inch W.G. relative to adjacent spaces, as well as to outside atmosphoro, will be required.

This will provido assuranco that unfiltered inleakago into the con- ,

trol room is minimized, consistent with the control room doso I calculations.

The change to specify individual testing requirements for Safety Injection, High Radiation, and High Toxic Cas signals is to provido clarity as to what actions are expected on cach signal.

The change to the TTS Bases adds background information to clarify different modes of system operation and to identify additional bases for system operability.

SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TTS 3.3.3.6. Chlorine Detection Systems - Detectors OPERABLE in ALL MODES.

This change does not involve a significant increase in the probability or consequences of an accident because the change is a more restrictive limitation not presently included in the TTS. Requiring the chlorino detectors to be OPERABLE in ALL MODES does not change the probability of an accident. However, it does reduce the probability of the detectors being inoperabic when needed to respond to a chlorino release because the proposed change requires OPERABILITY in ALL MODES instead of just MODES 1 through 4. This in turn reduces the consequences of a chlorino release accident because the detectors will be OPERABLE to respond in MODES 5 and 6, when previously they were not required to be OPERABLE.

This chango does not create the possibility of a new or different kind of accident because OPERABII.ITY of the chlorino detectors is not relevant to accident creation since they function to mitigate the consequences of an j accident after it has occurred. i This chango does not involvo a significant reduction in a margin of safety because requiring the chlorine detectors to be OPERABLE in ALL MODES instead of only MODES 1 through 4 enhances safety.

TTS 3.3.3.6. Chlorine Detection Systems - Detectors located immediately >

outsido normal intake location, i

This change does not involvo a significant increase in the probability or consequences of an accident because it is an administrative change. The present TTS implies that the chlorino detector is physically located in the duct. In actuality, the detectors and sensor tubing inlet are located immediately outsido the normal makeup air intake location.

_ _ _ _ - _ _ -- _. _ . _ _ . _ _ _ _____ ----_-_ _____ __ _ = --_ - ___ ___ _-_

l l

LCA 142, Revision 1 Page'4 of 10 This change does not create the' possibility of.a new or different kind of accident because the location of the chlorino detectors is not relevant to accident. creation since they function.to mitigate the consequences of

.an accident after it'has occurred.

This change does not involve a significant reduction in a margin of safety because this. change is administrative.

TTS 4.3.3.6. Chlorine Detection Systems - Performance of a CHANNEL

' FUNCTIONAL TEST every 31 days.

'This change does not involvo a significant increase in the probability or consequences of an accident because the change is a more restrictive limitation not presently included in.the TTS. Requiring the performance of a CHANNEL FUNCTIONAL TEST does not change the probability of an acci-dent. However, it does reduce the probability of the detectors being inoperable when nooded to respond to a chlorine release because.the pro-posed change requires additional testing to verify operability. This in turn reduces the consequences of a chlorino release accident.

This change does not create the possibility of a new or different kind of  ;

accident because OPERABILITY of the chlorino detectors is not relevant to '

accident creation since they function to mitigate the consequences of an accident after.it has occurred.

This change does not involvo a significant reduction in a margin of safety.because requiring this additional testing enhances safety.

TTS 3.7.6.1. Control Room Emergency Ventilation System - CB-1 OPERABLE in ALL MODES.

This change does not involvo a significant increase in the probability or consequences of an accident because the change is a more restrictive limitation not presently included in the TTS. Requiring CB-1 to be OPERABLE in ALL MODES does not chango the probability of an accident.

However, it does reduce the probability of CB-1 being inoperable when needed to respond to an accident because the proposed change requires OPERABILITY in ALL MODES instead of just MODES 1 through 4. This in turn reduces the consequences of an accident because CB-1 will be OPERABLE to respond in MODES 5 and 6, when previously it was not required to be OPERABLE.

This change does not create the possibility of a new or different kind of accident because OPERABILITY of CB-1 is not relevant to accident creation

.since it functions to mitigate the consequences of an accident after it has occurred.

This change does not involvo a significant reduction in a margin of safety because requiring CB-1 to be OPERABLE in ALL MODES instead of only MODES 1 through 4 enhances safety.

l

l LCA 142, Revision 1 Pago 5 of 10 l.

TTS 3.7.6.1. Control Room Emergency Ventilation System - Revise ACTION statements.

This change (1) incorporates actions from W-CTS (NUREC-0452, Revision 4)

ACTION statement, and (2) incorporates a provision to permit operation up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the control room at a positive pressure of 11/16 inch W.C., but less than its specified value of 1/8 inch W.C. This change does not involve a significant increase in the probability or conso-quences of an accident. The incorporation of W-STS as modified is a more restrictive limitation not presently included in the TTS. Presently, there are no ACTION statements for this TTS in MODES 5 and 6 because OPERABILITY is only required in MOUES 1 through 4. However, to be con-sistent with the change above which requires OPERABILITY in ALL MODES, the additional ACTION statements for MODES 5 and 6 are proposed. The addition of an ACTION to allow operation up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the control room at a positivo pressure of 1/16 inch but less than required by SUR-VEILLANCE REQUIREMENTS will provido a period of continued operation commensurate with that required to locate and correct deficiencies pro-venting these requirements from being mot. This ACTION maintains the requirement for reactor shutdown if control room pressure cannot be promptly restored to its specified value. It also requires the control room continue to be maintained at a measurable positive pressure to provido assurance that radioactivity in outsido atmosphere or which may enter adjacent spaces is prevented from entering the control room. An additional SURVEILLANCE REQUIREMENT is being added to require the system to maintain the control room at a pressure 11/8 inch W.C. relative to adjacent spaces, and control room pressurization test frequency in to be increased from every 18 months to monthly. Incorporation of this 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO provides reasonabic operational ficxibility commensurate with the additional constraints of the increased testing requirements. The not effect of these changes is to be more restrictive than present TTS limitations.

This change does not create the possibility of a new or different kind of accident because OPERABILITY of CB-1 is not rolovant to accident creation since CB-1 functions to mitigate the consequences of an accident after it has occurred.

This change does not involve a significant reduction in a margin of safety. Providing the additional ACTION statements for MODES 5 and 6 enhances safety since thoro previously was no action required in these MODES. Addition of the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LCO is more than adequately compensated for by the added testing requirements to be incorporated.

TTS 4.7.6.1. Control Room Emergency Ventilation System - Reduction in CB-1 cooling test frequency.

This change does not involvo a significant increase in the probability or consequences of an accident. The surveillance performed on CB-1 to demonstrate system OPERABILITY does not affect accident probability 1

_ _ _ _ . _ _ __ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____._______________J

p l .

LCA 142, Revision 1 page 6 of 10 becauso CB-1 functions to mitigate the consequences of an accident after it has occurred. The consequences of an accident could be affceted if I CB-1 was unabic to maintain the design basis temperature. Thereforo, i testing to demonstrate that CB-1 can maintain the control room 1110*F is prudent. However,'the current TTS requiring a monthly cooling test I instead of the proposed quarterly test is considered to be an excessivo  !

test frequency for the following reasons:

1. The current monthly testing contributes to control room equipment aging. CB-1 was not designed to keep the control room at 75*F like the normal control room ventilation system (CB-2). The elevated control room temperature experienced during tecting of CB-1, while well within design limits, is considered more detrimental to control room habitability than the marginal increase in confidence in CB-l's cooling ability provided by fecquent monthly testing.

2. Modes of possible failure of the CB-1 service water coolers, such as fouling do not occur rapidly enough to justify testing on a monthly basis. Quarterly testing is considered adequato to detect any l decrease in the capacity of the service water coolers. In addition, since testing is proposed on a STAGGERED TEST BASIS, at least one train of CB-1 will be tested cycry 1-1/2 months. Therefore, any l significant degradation in the cooling capability of one train would result in investigations boing performed on the other train. Since it is unlikely that significant degradation in the cooling capability of one train, e.g., fouling, would occur without also occurring in the other train, the effectivo surveillance frequency is equivalent to every 1-1/2 months.

3. CB-1 has never failed to maintain temperature within design condi-tions during all testing performed to date. Test results show that the control room temperature has never exceeded approximately 87*F during sumc.or conditions. This is significantly less than the design basis of 110*F and indicates that gradual degradation of the CB-1 cooling capability between tests could be accommodated with available margin.

This change does not create the possibility of a new or different kind of accident because the surveillance performed on CB-1 to demonstrate OPERABILITY is not relevant to accident croation since CB-1 functions to mitigate the consequences of an accident aftec it has occurred.

This change does not involve a significant reduction in a margin of safety because no change to the Limiting Condition for Operation nor  :

control room design basic temperature is proposed. l l

Based on the above, this change does not pose a significant hacard. (

i

_______________a

l l

V LCA 142, Revision 1 Page 7 of 10 TTS 4.7.6.1. Control Room Emergency Ventilation System - Reduction in CB-1 flow rate to 3000 cfm with 5 5 25 cfm makeup flow.

This change does not involvo a significant increase in the probability or consequences of an accident. The surveillance performed on CB-1 to demonstrate system OPERABILITY does not affect accident probability because CB-1 functions to mitigato the consequences of an accident after it has occurred. The consequences of an accident are not significantly increased because the reduction in CB-1 flow rate to 3000 cfm ensures that the residence time for radioactivity in the filter units is

>0.25 seconds as assumed in the control room doso calculations. Specify-ing makeup flow 15 25 cfm provides assuranco that filtered makeup flow rate is within the acceptabic rango determined in the control room dose 3 calculations. '

This change does not create the possibility of a new or different kind of accident because the surveillance performed on CB-1 to demonstrate OPERABILITY is not relevant to accident creation since CB-1 functions to mitigate the consequences of an accident after it has occurred.

This change does not involve a significant reduction in a margin of safety because flow will still be established through CB-1 in the same manner and at the satte frequency as the existing TTS, albeit at a slightly lower flow rate. Based upon past measurements, flow rates have actually been about 3000 cfm. Thereforo, the lower specified flow rate of 3000 cfm is no different than actual performance of CB-1.

Specification of the makeup flow rate provides additional assurance that the system operates as assumed in dose rate calculations.

TTS 4.7.6.1 Control Room Emergency Ventilation System - Increased HEPA and charcoal filter test officiency.

This change does not involve a significant increase in the probability or i consequences of an accident because this change is a more restrictive limitation not presently included in the TTS. This change imposes more restrictive requirements on the removal of particulate by the HEPA and charcoal filters.

]

This change does not create the possibility of a new or different kind

'of accident because the surveillance performed on CB-1 to demonstrate OPERABILITY is not relevant to accident creation sinco CB-1 functions to mitigate the consequences of an accident af ter it hac occu'rred.

This change does not involve a significant reduction in a margin of safety because testing the HEPA and charcoal filters to demonstrate a greater officiency in the removal of particulate increases the margin between the as-tested and as-analyzed performance of the filters.

i 1

LCA 142, RevisAon 1 Page 8 of 10 TTS 4.7.6.1. Control Room Emergency Ventilation System - Revised laboratory charcoal analysis.

This change does not involve a significant increase in the probability or s

consequences of an accident because this change is a more re'trictivo limitation not presently included in the TTS. This chango imposes more restrictive requirements on the removal officiency of radioiodino by the charcoal adsorbers and also imposes more restrictive test conditions.

This chango does not create the possibility of a new or different kind of accident because the surveillance performed on CB-1 to demonstrate _

OPERABILITY is not relevant to accident creation since CB-1 functions to mitigate the consequences of an accident after it has occurred.

This change does not involvo a significant reduction in a margin of safety boeause subjecting the charcoal adsorbers to more restrictive test conditions and operating efficiencies increases the margin between the as-testod and as-analyzed performance of the filters.

TTS 4.7.6.1. Control Room Emergency Ventilation System - Positivo pressure of >1/8 inch W.C. relative to adjacent spacco and to outside atmosphere to be tested monthly.

l This change does not involvo a significant increase in the probability or consequences of an accident because this change is a more restrictive limitation than that presently included in the TTS. The surveillance performed on CB-1 to demonstrate system OPERABILITY does not affect accident probability because CB-1 functions to mitigate the consequences of an accident after it has occurred. The consequences of an accident are not significantly increased because maintaining a control room posi-tive pressure relativo to adjacent spaces as oppocod to only outsido air provides greater assurance that unfiltered inloakage into the control room is minimized. Testing control room pressurization capability at increased frequency provides greater assurance that control room envelope integrity is maintained.

This change does not create the possibility of a new or different kind of accident because the surveillance performed on CB-1 to demonstrate OPERABILITY is not relevant te arcident creation since CB-1 functions to mitigate the consequences of an accident after it has occurred.

This change does not involve a significant reduction in a margin of safety, but rather involves an enhancement of safety sinco the proposed change requires a positivo pressure be maintained relative to adjacent spaces as opposed to the existing TTS which anly requires maintaining a '

positivo pressure relative to outside air. Maintaining a positivo pressure in the control room in relation to adjacent spaces provides assurance that radioactivity which may enter adjacent spaces following an accident is prevented from entering the control room.

LCA 142, Revision 1 page 9 of 10 TTS 4.7.6.1. Control Room Emergency Ventilation System - Specification of ACTIONS for Safety Injection, High Radiation, and High Toxic Gas signals.

This changes does not involvo a significant increase in the probability or consequences of an accident because it is an administrative change.

The procent TTS addresses the test requirements for all initiating signals in one sentenco. The chango clarifies expected system response by stating the test requirements for cach signal in a separate sentence

~

and in more detail than present TTS.

This change does not create the possibility of a new or different kind of accident becauso OPERABILITY of CB-1 is not relevant to accident creation since CB-1 functions to mitigate the consequences of an accident after it has occurred.

This chango does.not involve a significant reduction in a margin of safety because this change is administrative. t 1

TTS 3/4.7.6. Control Room Ventilation System - Bases This chango does not involve a significant increase in the probability or l consequences of an accident because it is an administrative change. l Additional information is being added to clarify the basis for control room emergency ventilation system operability and to better define system modes of operation referred to in the TTS.

This chango does not create the possibility of a new or different kind of  !

accident because OPERABILITY of CB-1 is not relevant to accident creation since CB-1 functions to mitigato the consequences of an accident after it has occurred.

This change does not involvo a significant reduction in a margin of safety because this change is administrative.

In the April 6, 1983 Federal Register, the NRC published a list of examples of amendments that are not likely to involvo a significant hazards consideration. Example No. 2 from this list states:

"A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, og, a more stringent surveillance requirement".

This example applies to the following proposed changes:

1. Incorporating a monthly chlorino detcetor CHANNEL FUNCTIONAL TEST,

2. Requiring the chlorine detectors to be OPERABLE in ALL MODES,

3. Requiring CB-1 to be OPERABLE in ALL MODES, 1

\'

LCA 142, Revision 1 Page 10.of 10

4. Implementing' ACTION statements for CB-1 in MODES 5 and 6,

5. Increasing the HEPA and charcoal filter test efficiency,

6. Specifying a CB-1 flow rato of 3000 cfm and makeup flow rate of 1525'efm,

7. Incorporating the Regulatory Guide 1.52 charcoal testing guidelines,

8. Maintaining a control room positive pressure relativo to adjacent spaces, and Increasing control room pressurization test frequency to monthly.

~

9.

Based on the abovo evaluation, these changes do not pose a significant hazard.

Example No. 1 from the above cited Federal Register listing states:

"A purely administrative change to technical specifications, eg, a change to achievo consistency throughout the technical specifica-tions, correction of an error, or a change in nomenclature."

This examplo applies to the following proposed changes:

1. Correction of the chlorino detector location,

2. Specification of expected automatic actions on Safety Injection, High Radiation, and High Toxic Gas signals, and

3. Inclusion of additional information in the Bases.

Based on the above evaluation, these changes do not pose a significant hazard.

REFERENCES

1. PGE to NRC letter regarding Control Room Habitability, May 19, 1986,

2. PGE to NRC letter regarding CB-1 Action Plan, June 4, 1986.

3. PGE to NRC letter regarding CB-1 Action Plan, June 13, 1986.

6038k

(

l E-__-----_--