ML20247H957

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Safety Evaluation Supporting Amend 152 to License NPF-1
ML20247H957
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 05/15/1989
From:
Office of Nuclear Reactor Regulation
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ML20247H949 List:
References
NUDOCS 8905310375
Download: ML20247H957 (5)
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[;( g. NUCLEAR REGULATORY COMMISSION ] E :j. WASHINGTON, D. C,20555 

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1 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION-RELATED TO Ai4ENDNENT NO.152 TO FACILITY OPERATING LICENSE NO. NPF-1 

                                             ' PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE. OREGON PACIFIC POWER AND LIGHT COMPANY TROJAN NUCLEAR PLANT DOCKET NO. 50-344

1.0 INTRODUCTION

By letter dated September 30,.1986 as revised and supplemented November 16, 1987 and April 14, 1988, Portland General Electric Company (PGE) submitted proposedchanges(LCR-142)totheTrojanTechnicalSpecifications(TS) to resolve control room habitability issues raised during NRC inspections of January 28-30, 1986 and February 24-28, 1986. The findings of these inspections are contained in NRC Inspection Report No. 50-344/86-06. The issues related to control room habitability were resolved prior to restart from the 1986 refueling outage, and are cocumented in the staff's Safety Evaluation (SE) of June 16, 1986. A portion of the resolution was PGE's commitment to reevaluate the adequacy of the Trojan TS related to control room habitability. LCA-142 and its associated revisions.is PGE's response to that commitment. The changes proposed b; the September 30, 1986 submittal were noticed in the Federal Register on May 6,1987(52FR16951). 2.0 DISCUSSION T.S 3/4.3.3.6., " Chlorine Detection Systems" was proposed to be revised to be applicable in all modes of operation instead of just Modes 1 through 4. The reference to chlorine detector location in the air intake was deleted. In addition, performance of a Channel Functional Test once per 31 days was adoed to the Surveillance Requirements. TS 3/4.3.3.12 "SO, Detection Systems" was proposed to be deleted along with its associated Bases. This proposal was based upon a toxic gas analysis provided by PGE in a letter cated September 30, 1986. 8905310375 890515 gDR ADOCK 05000344 PNU L_ _ _ _ _ -- - 

   's TS 3/4.7.6.1,." Control Room Emergency Ventilation System," (CB-1) was proposed to be revised to:

(a) be applicable in all Modes rather than just Modes 1 through 4; (b) incorporate the Action Statement from the Westinghouse Standard TechnicalSpecifications(W-STS)toaddressoperationinModes 5 and 6 with one or both CREVS inoperable; (c) change the acceptance criteria for the in-place dioctyl phthalate. ' (DOP))and (HEPA filtersfreon tests of the and charcoal high-efficiency absorbers particulate respectively, air to 99.95% removal; (d) specify system flowrates to incorporate emergency makeup flow and emergency recirculation flow, as appropriate; 

                                                                                                               '(e) incorporate American Society for Testing and Materials (ASTM)

D-3803 test method for the laboratory test of charcoal, and performance of the test at 30*C/70% RH, with an acceptable penetration for methyl radiciodine of 1.0%; (f) demonstrate on a monthly basis that the control room envelope can be maintained at a positive pressure of at least 1/8 inch water gauge with respect to all adjacent areas while operating in the radiological emergency mode; j (g) demonstratethatonreceiptofasafetyinjection(SI) signal, that the CB-1 system automatically initiates and that systems CB-2, CB-3, CB-4, CB-5, CB-6 and CB-10 are shut off; and (h) or S0 signal, that the CB-2 demonstratethatonreceiptofaC1,loset$atsystemsCB-3,CB-4, system stops and isolation dampers c CB-5, CB-6 and CB-10 stop, and that CB-1 automatically starts. 3.0 EVALUATION Chlorine Detection System TS 3/4.3.3.6, " Chlorine Detection Systems," presently requires that the chlorine monitors be operable in Modes 1 through 4. However, the toxic gas challenge to the operators is a threat in all Modes. Therefore, PGE has proposed that this TS be applicable in all Modes. In addition, PGE has added as a part of its surveillance requirement that an Analog Channel Operational Test be performed at least once per 31 days. For clarification, reference to the location of the chlorine detectors in the control room duct is deleted. 1

g I s ." Since the proposed changes impose operational and surveillance requirements more restrictive than those currently in-place, and the proposed clari- 

                                     ~fication is editorial in nature, the staff finds the proposed changes to TS 3/4.3.3.6 to be acceptable.

S07 Detection Systems TS 3/4.3.3.12. "S0 gDetection Systems" was proposed to be deleted, based upon a revised toxic gas analysis. The staff's review of the toxic gas analysis is not yet complete. As such, this proposed change will not be addressed in this evaluation. Control Room Emergency Ventilation System (CB-1) i Revisions were' proposed for TS 3/4.7.6.1, " Control Room Emergency Ventilation System." PGE proposed changing the Applicability of this TS from Modes 1-4 to all Modes, which recognizes the potential for radio-logical and gas challenges in all Modes, and the need for adequate protection. With this change in Applicability, the associated Action Statements for Modes S and 6 must be added to the TS. PGE has proposed that when in these Modes if one control room emergency ventilation system is inoperable and not restored within a period of 7 days, then the OPERABLE system must be placed in operation in the recirculation mode. If both systems are inoperable or if the OPERABLE system is incapable of 

                                     .being powered by an OPERABLE emergency power source, then all operations involving core alterations or positive reactivity changes must ae           ;

suspended. Since this change is an imposition of a requirement more j stringent than that which is currently in the TS, we fine this change to be acceptable. PGE also proposed that the Action Statement for Modes 1-4 be modified to i indicate that, if the inoperability of both control room emergency ventila- I tion systems were due solely to the inability to maintain the control room envelope at a positive pressure greater than or equal to 1/8 inch water gauge relative to adjacent spaces, then a period of 72 hours sould be-allowed to restore at least one control room emergency ventilation system to an Operable status, provided the control room envelope could be main- l tained at a positive pressure of at least 1/16 inch water gauge relative j to adjacent spaces. , Since the proposed Action Statement would allow for ' more orderly and methodical troubleshooting, justified by the existence of a least 1/16 inch water gauge, positive pressure, the staff finds the proposed change to be acceptable. The 72 hour Action requirement is not applicable if the control room envelope can not be maintained at a positive pressure relative to adjacent areas of at least 1/16 inch water gauge. 1 Other revisions to TS 3/4.7.6.1 that were proposed are changes to 4 surveillance requirements associated with the control room emergency ventilation (CREV) system and related systems.

A change was proposed to demonstrate the operability of each control I room emergency ventilation system train on a monthly staggered test ) basis by initiating flow through the HEPA filter and charcoal absorber i train and verifying train operability for 15 minutes. During the review  ! period, the licensee reconsidered its request and decided to maintain i the monthly test requirement of 10 hours duration with the preheaters I on, as currently provided for in the Trojan TS. i I A change was proposed in the acceptance criteria for the in-place dioctyl phthalate (DOP) and Freon tests of the high efficiency particulate air-filter (HEPA) and charcoal absorbers, respectively, to a more effective efficiency level of 99.95 percent removal. j A change was proposed that would specify CREV system flowrate so as to I incorporate emergency makeup flow and emergency recirculation flow as appropriate depending on the operating mode of the CREV system. A change was proposed that would incorporate an American Society for Testing and Materials test method, ASTM D-3803, for the laboratory tests of filter charcoal material, and a requirement to perform the test at 30 C and 70 percent relative humidity with an acceptable penetration for methyl radiciodide of 1.0 percent. A change was proposed that would require a monthly demonstration that the control room atmospheric envelope can be maintained at a positive pressure of at least 1/8 inch of water with respect to all adjacent areas while the CREY system is operating in the radiological emergency mode. A change was proposed that would require a demonstration at least every 18 months of CREV response to receipt of a safety injection (SI) signal; 1.e., demonstration that CB-1 (control room emergency ventilation) system will automatically initiate, and those systems not required to operate following the SI signal, i.e., CB-2 (control room normal air conditioning system), lunchroomCB-3 (water exhaust), samp(ling CB-5 laboratory Control Building exhaust), supply), CB-4 (toi'let CB-6 (mechanical rooniand exhaust), and CB-10 (Control Building air conditioning supply) systems, are isolated, q A change was proposed that would require a demonstration at least every 18 months that, on receipt of a High Chlorine signal, or a High S0 2 signal, the CB-2 system will stop and isolation dampers will close that systems CB-3, CB-4, CB-5, CB-6, and CB-10 will stop, and that CB-1 will automatically start. Each of the above. changes was evaluated for incorporation into the Trojan technical specifications. The changes were found to be appropriate and consistent with direction given in NUREG-0737, Item III.D.3.4 concerning control room habitability. Each proposed change is conservative in that it requires a more stringent surveillance or adopts a more specific standard or criterton of acceptability than was previously specified by j technical specifications, and each is acceptable for incorporation into ' the technical specifications.

4.0 CONTACT WITH STATE OFFICIAL The NRC staff has notified the Oregon Department of Energy of the proposed issuance of this_ amendment along with the proposed determination of no significant hazards consideration. No comments were received.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment involves a change in surveillance requirements and in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in inoividual or cumulative occupational radiation exposure. The Commission has previously published a proposed finding that the dmendment involves no significant hazards consideration and there has been-no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuantto10CFR51.22(b),noenvironmentalimpactstatementorenvironmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

Wehaveconcluded,basedontheconsiderationsdiscussedabove,that(1) there is reasonable assurance that the health and safety of the will. not be endangered by operation in the proposed manner, such(2) public activities will be conducted in compliance with the Commission's regu-lations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. PRINCIPAL CONTRIBUTORS: J. Hayes T. Chan R. Bevan Dated: May 15, 1989

L May 15, 1989 q, . - i. Docket No. 50-344 DISTRIBUTION Docket File n. WJones NRC & Local PDRs JCalvo MVirgilio ACRS(10) j Mr. David W. Cockfield JLee- GPA/PA l Vice President, Nuclear RBevan. ARM /LFMB l 

        .                                                     Portland General Electric Company                        OGC                                                    PDS Plant File                                         I 121 S.W. Salmon Street                                   DHagan Portland, Oregon 97204                                   EJordan BGrimes

Dear Mr. Cockfield:

TMeek (4)

SUBJECT:

ISSUANCE OF' AMENDMENT N0.152 TO FACILITY OPERATING LICENSE N0. NPF-1, TROJAN NUCLEAR PLANT (TAC NO. 73157) l l The Commission has issued the enclosed Amendment No.152 to Facility Operating l License No. NPF-1 for the Trojan Nuclear Plant. The ar,endment consists of changes to the Technical Specifications in response to your application (LCA-142)datedSeptember 30, 1986, as revised and supplemented November 16, 1987 and. April 14, 1988. 

                                                                                                                                                                                                                                     ]

The amendment revises Trojan Technical Specifications (TS) Sections 3/4.3.3.6, 

                                                             " Chlorine Detection Systems" and TS 3/4.7.6.1, " Control Room Emergency Ventilation Systems."

A copy of the related Safety Evaluation is also enclosed. The notice of issuance will be included in the Commission's next regular bi-weekly Federal Register notice. Sincerely, original signed by Roby B. Bevan, Project Manager , Project Directorate V Division of Reactor Projects III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

1. Amendment No.152 to NPF-1
      ~
2. Safety Evaluation cc w/ enclosures:

See next page 

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[ .g NUCLEAR REGULATORY COMMISSION 

                        .'        5             'j                           WASHINGTON, D. C. 20555 y,                                     .....                                            May 15, 1989 Docket No. 50-344
                                      'Mr. David W. Cockfield Vice President, Nuclear-Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204

Dear Hr. Cockfield:

SUBJECT:

ISSUANCE OF AMENDMENT N0.152 TO FACILITY OPERATING LICENSE N0. NPF-1, TROJAN NUCLEAR PLANT (TAC NO. 63157) The Commission has issued the enclosed Amendment No. 152 to Facility Operating License No. NPF-1 for the Trojan Nuclear Plant. The amendment consists of changes to the Technical Specifications in response to your application (LCA-142)datedSeptember 30, 1986, as revised and supplemented November 16, 1987 and April 14, 1988. Theamendmentrevises1rojanTechnicalSpecifications(TS) Sections 3/4.3.3.6, 

                                        " Chlorine Detection Systems" and TS 3/4.7.6.1, " Control Room Emergency Ventilation Systems."

A copy of the related Safety Evaluation is also enclosed. The notice of issuance will be included in the Concission's next regular bi-weekly Federal Reoister notice. Sincerely, Uc<s(A Roby B. Bevan, Project Manager Project Directorate V Division of Reactor Projects III, IV, Y and Special Projects Office of Nuclear Reactor Regulation

Enclosures:

1. Amendment No.152 to NPF-1
2. Safety Evaluation cc w/ enclosures:

See next page _ _ _ _ _ - - _ - - - - . - - _ - - - - 0

Mr. David W. Cockfield ',. Portland General Electric Company Trojan Nuclear Plant ec:? Senior Resident Inspector U.S. Nuclear Regulatory Commission Trojan Nuclear Plant Post Office Box 0 Rainier, Oregon 97048 Mr. Michael J. Sykes, Chairman Board of County Commissioners Columbia County St. Helens, Oregon 97501 Mr. William T. Dixon Oregon Departnent of Energy-Salem, Oregon 97310' Regional Administrator, Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 L- --_____- --_ - - 

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UNITED STATES [ 

            'E             1j NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20S$5 .

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PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE, OREGON PACIFIC POWER AND LIGHT COMPANY DOCKET NO. 50-344 TROJAN NUCLEAR PLANT AMENNIENT TO FACILITY OPERATING LICENSE Amendment No.152 License No. NPF-1

1. The Nuclear Regulatory Comission (the Comission) has found that:

A. The application for amendment by. Portland General Electric Company, etal.,(thelicensec)datedSeptember 30, 1986, as revised and TupPementedNovember 16, 1987 and April 14, 1966, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations set forth in 10 CFR Chapter-I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Comission; C. Thereisreasonableassurance(1)thattheactivitiesauthorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations; D. The issuance of this amendment will not be inimical to the comon defense and security or to the health and safety of the public; and E. The issuance of this anendment is in accordance with 10 CFP Par + 51 of the Commission's regulations ano all applicable requir ...ents have been satisfiec. 

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t. 2. Accordingly, the license is amended by changes to the Technical i

Specifications as indicated in the attachment to this license , l amendment, and paragraph 2.C.(2) of Facility Operating Lhense l l No. NPF-1 is hereby amended to read as follo'>s: (2) Technical Specifications l The _ Technical Specifications contained in Appendices A i i and B, as revised through Amendment No.152 , are hereby incorporated in the license. The licensee shall operate the facility in'accordance with the Technical Specifica-tions, except where otherwise stated in specific license conditions.

3. This license amendment is effective as of the date of its issuance.

FOR THE NUCLEAR REGULATORY COMMISSION e46

  • George E' Knighton, 1 rector Project Directorate V Division of Reactor Projects III, IV, V and Special Projects

Attachment:

Changes tu the Technical Specifications Date of Issuance: May 15, 1989 4 F _ _ _ _ _ _ _ _ _ _ _ _ _ _ l 

     ~.+   .,

ATTACHMENT TO LICENSE AMENDMENT !!0.152 . TO FACILITY OPERATING LICENSE NO. NPF-1 DOCKET NO. 50-344 Revise Appendix A as follows: Remove Pages Insert Pages 3/4 3-47 3/4 3-47 3/4 7-18 3/4 7-18 3/4 7-19 3/4 7-19 3/4 7-20 3/4 7-20 B3/4 7-5 B3/4 7-5 B3/4 7 Sa l ____._---D

i 1 INSTRUMENTATION I CHLORINE DETECTION SYSTEMS - LIMITING CONDITION FOR OPERATION 3.3.3.6 Two independent chlorine detection systems, with their alarm / trip setpoints adjusted to actuate at a chlorine concentration of 5 5 ppm, shall be OPERABLE. APPLICABILITY: ALL MODES. ACTION: ,

a. With one chlorine detection system inoperable, restore the inoperable detection system to OPERABLE status within 7 days or within the next 6 hours initiate and maintain operation of the control room emergency ventilation system in the recircula-tion mode of operation.
b. With both chlorine detection systems inoperable, within 1 hour initiate and maintain operation of the control room emergency ventilation system in the recirculation mode of operation,
c. The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE RE0VIREMENTS 4.3.3.6 Each chlorine detection system shall be verified energized at least once per 12 hours and demonstrated OPERABLE by performance of a CHANNEL FUNCTIONAL TEST at least once per 31 days and a CHANNEL CALIBRATION at least once per 18 months. e TROJAN-UNIT 1 3/4 3-47 Amendment No. f3152 i 

                                                                                                       -- ------- 'J

O PLANT SYSTEMS 3/4.7.6 CONTROL ROOM EMERGENCY VENTILATION SYSTEM LIMITING CONDITION FOR OPERATION 3.7.6.1 Two independent control room emergency ventilation systems l shall be OPERABLE. APPLICABILITY: ALL MODES. ACTION: MODES 1, 2, 3, and 4.- , With one control room emergency ventilation system inoperable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. l With both control room emergency ventilation systems inoperable [where inoperability of one or both systems is due solely to  ! failure of +.he system (s) to maintain the control room at a posi-tive pressure of 21/8 ihch WG relative to outside atmosphere or to adjacent spaces, but able to maintain the control room at a positive pressure of 11/16 inch WG), restore at least one system to operable status within 72 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTOOWN within the following 30 hours. MODES 5 and 6:

a. With one control room emergency ventilation system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the remaining OPERABLE
                     ,                                         control room emergency ventilation system in the recirculation mode of operation.
b. With both control room emergency ventilation s'ystems inoperable, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.7.6.1 Each control room emergency ventilation system shall be demon-strated OPERABLE:

a. At least once per 31 days on a STAGGERED TEST BASIS by initiating flow through the HEPA filter and charcoal adsorber train and verifying that the train operates for at least 10 hours with the TROJAN-UNIT 1 3/4 7-18 Amendment No. 77, 28 ,152

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ . B 

          .    .                                                             LCA 142, Revision 1 l   ,,
, Attachment
         ,.                                                                  Page 3 of 6 PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) preheaters on and maintains the control room air temperature 5 110*F.
b. At least once per 31 days by verifying that the system maintains )

the control room at a positive pressure of 21/8 in. WG relative j to the outside atmosphere and to other adjacent spaces during i system operation.

c. At least once per 18 months <,r (1) af ter any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:
1. Verifying that the charcoal adsorbers remove ? 99.95% of l a halogenated hydrocarbon ref rigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the ventilation system at a flow rate of 3000 cfm i 10%. l
                              ?. Verifying that the HEPA filter banks remove 199.95% of the         j 00P when they are tested in ple:e in accordance with ANSI N510-1975 while operating the ventilation system at a flow rate of 3000 cfm 10%.                                         l
3. Verifying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, demonstrates a pene-tration of 5 1.0 percent when tested in accordance with ASTM D3803-79 Methyl Iodide Penetration Test Methods at 30'C and 70 percer,t relative humidity.
4. Verifying a system flow rate of 3000 cfm i 10% (of which makeup flow is 5 525 cfm) during system operation in the pressurization mode _of operation when tested in accordance with ANSI N510-1975.
d. Af ter every 720 hours of charcoal adsorber operation by veri-fying within 31 days after removal that a laboratory analysis of a representative carbon sample obtained in accordance with l

l TROJAN-UNIT 1 3/4 7-19 Amendment No. yg 152 j l ii l I i; 

      . . . "9'
                        ' PLANT SYSTEMS
                      ~                                                                                 ~

SURVEII. LANCE REQUIREMENTS (Continued) Regulatory Position C.6.b of R'egulatory Guide 1.52, Revision 2, 

                                                                ~

March 197B, demonstrates a penetration of 51.0 percent when tested in accordance with ASTM D3B03-79 Methyl Iodide Penetra-tion Test Methods at:30'c and 70 percent relative humidity.

e. At least once per 1B months by:

1 .- Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is < 6 inches Water Gauge while operating the ventilation system at a flow rate of 3000 cfm 10%.

2. Verifying that on a Safety Injection signal, the control room normal air conditioning system (CB-2) stops and isolation dampers close to automatically isolate the control room within 3 seconds; the CB-3 (water sampling laboratory exhaust), CB-4 (toilet and lunch room exhaust), CB-5 (Control Building supply),

CB-6 (mechanicc1 room exhaust), and CB-10 (Control Building air conditioning supply) systems step; and that CB-1 (control room emergency ventilation system) automatically starts.

3. Verifying that on a High Radiation signal, the control room normal air conditioning system (CB-2) stops and isolation dampers close to automatically isolate the control room within 3 seconds; and the CB-3 (water sampling laboratory exhaust), CB-4 (toilet and lunch room exhaust), CB-5 (Control Building supply), CB-6 (mechanical room exhaust), and _CB-10 (Control Building air conditioning supply) systems stop.
4. Verifying that on a High Chlorine signal and Figh.502 signal the control room normal air conditioning system (CB-2) stops and isolation dampers close to automatically isolate the con-trol room within 3 seconds; and the CB-3 (water sampling laboratory exhaust), CB-4 (toilet and lunch room exhaust),

CB-5 (Control Building supply), CB-6 (mechanical room exhaust), 'and CB-10 (Control Building air conditioning supply) systems stop. l 

                  ?           f. After each complete or partial replacement of HEFA filter banks by verifying that the HEPA filter banks remove 1 99.95% of the DOP when they are tested in-place in accordance with ANSI N510-1975 while operating the filter train at a flow rate of 3000 1 10%.
g. After each complete .or partial replacement of a charcoal adsorber bank by verifying that the charcoal adsorbers remove 199.95% of a halogenated hydrocarbon refrigerant test gas when they are tested in-place in accordance with ANSI N510-1975 while operating the filter train at a flow rate of 3000 cfm ! 10%.

TROJAN-UNIT 1 3/4 7-20 Amendment No. 77, 705, 152 ________ l

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1 .. o , PLANT SYSTEMS 8ASES . 3/4.7.6 CONTROL ROOM VENTILATION SYSTEM The OPERABILITY of the control room ventilation system ensures that

1) the ambient air temperature does not exceed the allowable temperature for continuous duty rating for the equipment and instrumentation cooled by this system and 2) the control room will remain habitable for operations personnel during and following all credible accident conditions. The OPERABILITY of this system in conjunction with control room design pro-visions is based on limiting the radiation exposure to personnel occupying the control room to 5 rem or less whole body, or its equivalent.

This limitation is consistent with the requirements of General Design Criteria 19 of Appendix 'A",10 CFR 50. System operability can be affected by ECCS recirculation leakage and Containment leakage should the conditions assumed in FSAR Section 15.6.5.6 be exceeded. The OPERABILITY of this system in conjunction with control room design provisions is also based on limiting the toxic gas exposure to control room personnel consistent with the FSAR design basis and Regulatory Guide 1.95. Recirculation mode of oper.' tion is defined as operation of the control room emergency ventilation system with the outside air dampers closed. In the event of a radiation release while operating the system in the recirculation mode of operation, the system is operated in the pressurization mode of operation by opening the outside air dampers. ' Operation of the system in this manner meets the intent of this specification and satisfies the FSAR design basis and requirements of GDC 19. 3/4.7.7 SEALED SOURCE CONTAMINATION The limitations on sealed source removable contamination ensure that the total body or individual organ irradiation does not exceed allowable limits in the event of ingestion or inhalation of the source material. The limitations on removable contamination for sources . requiring leak  ; testing, including alpha emitters, is based on 10 CFR 70.39(c) limits for  ! plutonium. Leakage of sources excluded from the requirements of this 

    .              specification represent less than one maximum permissible body burden
          ,      ; for total body irradiation if the source material is inhaled or ingested.

3/4.7.8 FIRE SUPPRESSION SYSTEMS The OPERABILITY of the fire suppression systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment  ! is located. The fire suppression system consists of the water system, sprinklers and fire hose stations. The collective capability of the fire suppression systems is adequate to minimize potential damage to safety related equipment and is a major element in the facility fire protection program. TROJAN-UNIT 1 8 3/4 7-5 Amendment No. 78, 28 ,152 i lI

L. .- . 

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PLANT SYSTEMS BASES (Continued) - In the event that portions of the fire suppression systems are inoperable, alternate backup fire fighting equipment is required to be made available in the affected areas until the inoperable equipment is restored to service. 1 a 4

  • t TROJAN-UNIT 1 B 3/4 7-Sa Amendment No. 78, 26, 152 l

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               %                     9p, .                                  UNITED $TATES
                                     .g                  NUCLEAR REGULATORY COMMISSION.

, " J9 *Y rn 'j WASHINGYON, D. C. 20535 S, . l SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDNENT N0.152 TO FACIcITY OPERATING LICENSE NO. NPF-1 PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE. 04EGON ' PACIFIC POWER AND LIGHT COMPANY TROJAN NUCLEAR PLANT DOCKET NO. 50-344 1.0.' INTRODUCTION 

                                    .By letter dated September 30,,1986 as revised and supplemented November 16, 1987.and April 14 1988, Portland General Electric Company (PGE) submitted proposeachanges[LCR-142)totheTrojanTechnicalSpecifications(TS) to resolve control room habitability issues raised during NRC inspections of January 28-30, 1986 and February 24-28, 1986. The findings of these-inspections are contained in NRC Inspection Report No. 50-344/86-06.

The issues related to control room habitability were resolved prior to restart from the 1986. refueling outage, and are cocumented in the staff's Safety Evaluation (SE) of June 16, 1986. A portion of the resolution was DGE's commitment to reev61uate the adequacy of the Trojan TS related to citrol room habitability. LCA-142 and its associated revisions is PGE's ts ionse to that comitment. The changes proposed by the September 30, 1986 submittal were noticed in the Federal Register on May 6,1987(52FR16951). 

      .                      2.0 DISCUSSION T.S 3/4.3.3.6., " Chlorine Detection Systems" was proposed to be revised to be applicable in all modes of operation instead of just Modes 1 through 4 The reference to chlorine detector location in the air intake was deleted.

In addition, pe.-formance of a Channel Functional Test once per 31 days was added to the Surveillance Requirements. TS 3/4.3.3.12. "50, Detection Systems" was proposed to be deleted along  ! with its associated Bases. This proposal was based upon a toxic 5es analysis provided by PGE in a letter cated September 30, 1986. l 

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1 TS 3/4.7.6.1, _" Control Room Emergency Ventilation System," (CB-1) was l proposed to be revised to: (a) be applicable in all Modes rather than just Modes 1 through 4; (b) incorporate the Action Statement from the Westinghouse Standard Technical Specifications (W-STS) to address operation in Modes - f and 6 with one or both CREVS inoperable; (c) change the acceptance criteria for the in-place dioctyl phthalate (D0P))and (HEPA filtersfreon and tests of the charcoal high-efficiency absorbers particulate respectively, air to 99.95% q removal; . (d) specify system flowrates to incorporate emergency makeup flow and emergency recirculation flow, as appropriate; (e) incorporate Ararican. Society for Testing and Materials -(ASTM). D-3803 test' method for the laboratory test of charcoal, and performance of the test at 30*C/70% RH, with an acceptable penetration for methyl radiciodine of 1.0%;- (f)' demonstrate on a monthly basis that the control room envelope can be maintained at a positive pressure of at least 1/8 inch water gauge with respect to all adjacent areas while operating in the radiological emergency mode;  ! (g) demonstrate that on receipt of a safety injection (SI) signal, that the CB-1 system autor.atically initiates and that systems CB-2, CB-3, CB-4, CB-5, CB-6 and CB-10 are shut off; and or 50, signal, that the CB-2 (h) demonstrate system stcps that and on receipt isolation of a C1, dampers c lose that systems CB-3, CB-4, CB-5, CB-6 and CB-10 stop, and that CB-1 automatically starts. 3.0 EVALUATION Chlorine Detection System TS 3/4.3.3.6, " Chlorine Detection Systems," presently requires that the chlorine monitors be operable in Modes I through 4. However, the toxic gas challenge to the operators is a threat in all Modes. Therefore, PGE l has proposed that this TS be applicable in all Modes. In addition, PGE l has added as a part of its surveillance requirement that an Analog Channel Operational Test be performed at least once per 31_ days. For clarification, reference to the location of the chlorine detectors in the control room duct is deleted. . _ _ _ - - _ - I4

an, e Since the proposed changes impose operational and surveillance requirements more restrictive than those currently in-place, and the proposed clari-fication is editorial in nature, the. staff finds the proposed changes to TS 3/4.3.3.6 to be acceptable. S02 . Detection Systems TS 3/4.3.3.12. "50 Detection' Systems" was proposed to be deleted, based upon a revised toxic gas analysis. The staff s review of the toxic gas analysis is n- yet complete. As such, this proposed change will not be addressed fr . sis evaluation. Control Rwm Emergency Ventilation System (CB-1) Revisions.were proposed for TS 3/4.7.6.1, " Control Room Emergency Vent 11stion System." PGE proposed changing the Applicability of this TS from. Modes 1-4 to all. Modes, which recognizes the potential for radio-logical and gas challenges in all Modes, and the need for adequate protection. With this change in Applicability, the associated Action Statements for Modes 5 and 6 must be added to the TS. PGE has proposed that when in these Modes if one control room emergency ventilation system is inoperable and not restored within a period of 7 days, then the OPERABLE system must be placed in operation in the recirculation mode. If both systems are inoperable or if the OPERABLE system is incapable of being powered by an OPERABLE emergency power source, then all operations involving core alterations or positive reactivity changes must be 

                                              -suspended. Since this change is an imposition of a requirement more stringent than that which is currently in the TS, we fino this change to be acceptable.

PGE also proposed that the Action Statement for Modes 1-4 be modified to K indicate that, if the inoperability of both control room emergency ventila-tion systems were due solely to the inability to maintain the control room envelope at a positive pressure greater than or equal to 1/8 inch water gauge relative to adjacent spaces, then a period cf 72 hours sould be allowed to restore at least one control room emergency ventilation system to an Operable status, provided the control room envelope could be main-tained at a positive pressure of at least 1/16 inch water gauge relative 

      .                                        to adjacent spaces. Since the proposed Action Statement would allow for more orderly and methodical troubleshooting, justified by the existence of a least 1/16 inch water gauge, positive pressure, the staff finds the proposed change to be acceptable. The 72 h.ur Actior. requirement is not applicable if the control room envelope can not be maintained at a positive pressure relative to adjacent areas of at least 1/16 inch water gauge.

1 Other revisions to TS 3/4.7.6.1 that were proposed are changes to ' surveillance requirements associated with the control room emergency l ventilt. tion (CREV) system and related systems. 4 

  .. e* s l,   :s-A change was proposed to demonstrate the operability of each control                                                            i room emergency ventilation system train on a monthly staggered test                                                             '
               ' basis by initiating flow through the HEPA filter and charcoal absorber train and verifying train operability for 15 minutes. During the review
period, the licensee reconsidered its request and decided to maintain the monthly test requirement of 10 hours duration with the preheaters on, as currently provided for in the Trojan TS. ,

A change.was p:)oposed phthalate(DOP and Freonintests the acceptance of the high criteria for particulate efficiency the in-placeair- dioctyl [ filter (HEPA) and charcoal absorbers, respectively, to a more effective efficiency level of 99.95 percent removal. A change was proposed that would specify CREV system flowrate so as to ! incorporate emergency makeup flow and emergency recirculation flow as appropriate depending on the operating mode of the CREV system. 

              'A change was proposed that would incorporate an American Society for Testing and Materials test method, ASTM D-3803, for the laboratory tests of filter charcoal material, and a requirement to perform the test at 30*C'and 70 percent relative humidity with an acceptable penetration for methyl radiciodide of 1.0 percent.

A change was proposed that would require a monthly demonstration that the 

              ' control room atmospheric envelope can be maintained at a positive pressure of at least 1/8 inch of water with respect to all adjacent areas while the CREV system is operating in the radiological emergency mode A change was proposed that would require a demonstration at least every                                                         ,

18 months of CREV response to receipt of a safety injection (SI) signal, i.e., demonstration that CB-1 (control room emergency ventilation) system will automatically initiate, and those systems not required to operate following the SI signal, i.e., CB-2 (control room normal air conditioning system), lunchroomexhaust),CB-5 CB-3 (water samp(ling laboratory exhaust), CB-4 (toilet andControlB 

              - exhaust), and CB-10 (Control Building air conditioning supply) systems,                                                          ;

are isolated. A change was proposed that would require a demonstration at least every 18 months that, on receipt of a High Chlorine signal, or a.High S0 2 signal, the CB-2 system will stop and isolation dampers will close that systems CB-3, CB-4, CB-5, CB-6, and CB-10 will stop, and that CB-1 will automatically start.  ; Each of the above. changes was evaluated for incorporation into the Trojan -; technical specifications. The changes were found to be appropriate and consistent with direction given in NUREG-0737, Item III.D.3.4 concerning control room habitability. Each proposed change is conservative in that it requires a more stringent surveillance or adopts a more specific standard or criterion of acceptability than was previously specified by technical specifications, and each is acceptable for incorporation into the technical specifications. l 

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4.0 CONTACT WITH STATE OFFICIAL The NRC staff has notified the Oregon Department of Energy of the proposed issuance of this amendment along with the proposed determination of no significant hazards consideration. No comments were received.

5.0 ENVIRONMENTAL CONSIDERATION

                                                           )

This amendment involves a change in_ surveillance requirements and in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that'the amendment involves no significant increase in the amounts,_and no significant ci;ange in' u the types, of any effluents that may be released offsite, and that there is no significant increase in incividual or cumulative occupational radiation exposure. The Counission has previously published a proposed finding that the amendment involves no significant hazards consideration and there has been' no public comment on such finding. Accordingly, the amendment meets the eligibility criteria for. categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the blic 

                                                . will.not be endangered by operation in the-proposed manner, (2) such pu activities will be conducted in compliance with the Commission's regu-lations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

P_RINCIPAL CONTRIBUTORS: J. Hayes T. Chan P Bevan Dated: tiay 15, 1989 1 li}}

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