ML20147E729

Application for Amend to License NPF-1,consisting of Rev 1 to License Change Application 124,revising Tech Specs Re Containment Isolation Valves

ML20147E729
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	03/01/1988
From:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
To:
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ML20147E724	List: ML20147E719 ML20147E729 ML20147E737
References
NUDOCS 8803070137
Download: ML20147E729 (12)

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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 124, Revision 1 This License Change Application requests modifications to Appendix A of Operating License NPF-1 for the Trojan Nuclear Plant regarding Containment isolation valves.

PORTLAND GENERAL ELECTRIC COMPANY D. W. ockfiefd Vic President Nuclear Subscribed and sworn to before me this 1st day of March 1988.

A wlc A k.

Notary Public of Oreg'on OMyCommission

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g3070137880301 p ADOCK 05000344 DCD

. LCA 124, Revision 1 Page 1 of 11 REASON FOR CHANGE This License Change Application (LCA) is the result of a systematic review of Containment penetrations at Trojan. Following this review, it ,

was determined that the Technical Specification changes discussed below '

were required to ensure consistency with the Final Safety Analysis Report (FSAR) and regulatory requirements.

DESCRIPTION OF CHANGE The following changes to Facility Operating License NPF-1 are requested (proposed replacement pages are provided as the attachment).

1. Page 3/4 6-1, Specification 4.6.1.1:

Part a.1 was revised to include those portions of penetrations inside Containment in the exception. This was done since verifica-tion every 31 days of these portions of penetrations (inside Con-tainment) would not be in the best interest of the radiation exposure As Low As Reasonably Achievable control program during critical operations. A new Surveillance Requirement 4.6.1.1.c was added to describe the necessary surveillance for those portions of penetrations inside Containment. This surveillance is similar to the Westinghouse Standard Technical Specifications (W-STS, NUREG-0452, Revision 4).

2. Pages 3/4 6-15, Surveillance Requirement 4.6.3.1:

Surveillance Requirement 4.6.3.1.1 was modified to recognize the fact that some Containment isolation valves do not have a required l isolation time (only automatic valves have required isolation times).

3. Pages 3/4 6-17 through 6-24 Table 3.6-1, Containment Isolation i Valves:

Each change made to this table is discussed below.

a. The steam generator sample and blowdown valves have been moved to Pages 3/4 6-22 and 6-23 under the heading of "Steamline Isolation".

b. Footnote Y was added to Valve MO 8105 (normal charging isola-tion valve) to indicate that this valve closes on a safety injection signal. Upon a safety injection signal, Valve MO 8105 closes to isolate normal charging flow, to allow flow to be diverted to the boron injection tank. Surveillance for this valve is performed per Trojan Technical Specification (TTS) 4.5.2.e.l. j

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1 LCA 124, Revision 1 l Page 2 of 11 L

c. Normal Charging Isolation Valve MO 8106 was deleted from, and Normal Charging Check Valvc 03R1 ws9 added to, TTS Table 3.6-1.

As previously discussed in Portland General Electric Company (PGE) to Nuclear Regulatory Commission (NRC) letter of December 22, 1986, Check Valve 8381 inside Containment serves as the inner Containment isolation valve and Valve MO 8105 serves as the outer containment isolation valve,

d. Air Lock Test Line Valves SV 6991 and SV 6992 were added to TTS Table 3.6-1. These valves are the isolation valves for the 93-foot elevation Containment air lock test lines and serve as Containment isolation valves.

e. Component Cooling Water Valves MO 3291, 3292, 3346, and 3290 were moved to Page 3/4 6-20 under the heading "Non-Automatic Power Operated Isolation Valves".

f. Footnote (a) was changed to footnote 4 and was moved to the end of Page 3/4 6-24.

g. Footnote # was added to Containment Sump Valves MO 2069A and MO 2069B. These valves are the emergency sump recirculation valves inside Containment. Addition of the Note # will exclude these valves from Type C leak testing. These valves are normally open following a Loss-of-Coolant Accident (LOCA) to allow the emergency core cooling pumps to take suction from the sump. Therefore, leak testing of these valves is unnecessary.

h. The following manual valves were added to TTS Table 3.6-1:

• 10610A&B, 10611A&B - Integrated Leak Rate Test (ILRT) instrument line isolation valves.

LD001 and LD003 foot elevation air lock test line isolation valves.

i. Identifying numbers were added for the demineralized water and reactor coolant drain tank nitrogen supply Containment isolation valves.

J. Chemical and Volume Control System (CVCS) Letdown Relief Valve PSV 8117 and RHR Suction Relief Valve PSV 8708 were added ,

to TTS Table 3.6-1. Valve PSV 8117 is within the CVCS letdown '

line Containment penetration boundary. Valve PSV 8708 is within the Residual Heat Renoval System suction line Containment penetration boundary.

k. Safety Injection Test Line Valve CV 8843 was added to TTS Table 3.6-1. This valve is the safety injection test line isolation valve and serves as an inner Containment isolation

LCA 124, Revision 1 Page 3 of 11 valve for the boron injection tank discharge Containment penetration.

SIGNIFICANT HAZARDF CONSIDERATION DETERMINATION The proposed changes do not pose a significant hazard for the reasons discussed below.

1. Revising TTS 4.6.1.1.a to exclude those portions o penetrations inside Containment from being verified closed every 31 days does not:

a. Involve a significant increase in the probability or consequences of an accident.

This change is an administrative change which clarifies the TTS. As presently written, the TTS could be interpreted to require verification of valve position by making a containment entry and physically checking valve position every 31 days. This would result in unwarranted radiation exposure to personnel.

Instead, administrative controls have been established as an alternate means of controlling valve position without making a Containment entry. This is accomplished via Administrative Order (AO) 3-13, "Control of Locked Valves and Engineered Safety Features Equipment", which is used to control the manipulation and status of these valves, in lieu of physically verifying the status of these valves every 31 days. Excluding the valves inside Containment from being verified closed every 31 days as proposed will eliminate ambiguity in the present TTS wording.

No change to the administrative controls in use is proposed.

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the consequences of an accident. The surveillance on these valves is not relevant to accident creation.

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c. Involve a significant reduction in a margin of safety. '

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Since this change only clarifies the TTS as to what is presently l done, and does not propose an actual change in surveillance, there is no reduction in a margin of safety.

2. Adding a new TTS 4.6.1.1.c which describes the surveillance required for those portions of penetrations inside Containment does not:

a. Involve a significant increase in the probability or consequences of an accident.

This change requires that valves which are located inside Containment be verified as closed during each cold shutdown,

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. LCA 124, Revision 1 Page 4 of 11

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except that such verification need not be performed more often than once per 92 days. This change constitutes an additional restriction not presently included in che TTS, and will provide greater assurance that isolation valves inside containment are closed.

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the consequences of an accident. The additional surveillance on these valves is not relevant to accident creation.

c. Involve a significant reduction in a margin of safety.

Since this change constitutes an additional restriction not presently included in the TTS, a reduction in a margin of safety is not involved. This new surveillance is consistent with the W-STS, NUREG-0452, Revision 4.

3. The addition of the words "if applicable" to the verification of Containment isolation valve isolation time required by TTS 4.6.3.1.1 does not:

a. Involve a significant increase in the probability or consequences of an accident.

This change is an administrative change which clarifies the TTS. TTS Table 3.6-1 identifies several Containment isolation valves for which no isolation time is required. Therefore, the words "if applicable" were added to Surveillance Require-ment 4.6.3.1.1 in recognition that not all Containment isolation valves have a required isolation time. No change is proposed to the actual testing of isolation valves,

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the consequences of an accident. The surveillance on these valves is not relevant to accident creation.

c. Involve a significant reduction in a margin of safety.

Since this change only clarifies the TTS as to what is presently done, and does not propose an actual change in surveillance, there is no reduction in a margin of safety.

. LCA 124, Revision 1 Page 5 of 11

4. Moving the steam generator sample and blowdown valves in TTS Table 3.6-1 to the heading "Steamline Isolation" does not:

a. Involve a significant increase in the probability or consequences of an accident.

This change is merely administrative and will ensure that all steamline isolation valves are grouped into one portion of TTS Table 3.6-1.

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided for accident mitigation and are pot related to accident creation.

c. Involve a significant reduction in a margin of safety.

The relocation of valves in TTS Table 3.6-1 is done to improve readability and has no impact on safety margins.

5. The addition of footnote f to Valve MO 8105 does not:

a. Involve a significant increase in the probability or consequences of an accident.

l This change is an administrative change which clarifies the TTS. Valve MO 8105 closes on a safety injection signal to isolate normal charging flow, to allow flow to be diverted to the boron injection tank. However, TTS 4.6.3.1.2.a requires that this valve be tested on a Containment isolation test signal. The addition of footnote T will clarify that this valve is actually tested on a safety injection signal. No change is proposed to the actual testing of this valve.

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b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the consequences of an accident. The surveillance on this valve is not relevant to accident creation.

c. Involve a significant reduction in a margin of safety.

Since this change only clarifies the TTS as to what is presently done, and does not propose an actual change in surveillance, there is no reduction in a margin of safety.

. LCA 124, Revision 1 Page 6 of 11

6. Revising TTS Table 3.6-1 to delete Valve MO 8106 and add Check Valve 8381 does not:

a. Involve a significant increase in the probability or consequences of accident.

General Design Criterion (GDC) 56 of Title 10, Code of Federal Regulations, Part 50 (10 CFR 50), Appendix A provides acceptable containment isolation configurations. One of these configura-tions is an automatic isolation valve inside Containment and an automatic isolation valve outside Containment. Final Safety Analysis Report (FSAR) Table 6.2-1, Penetration P-8, lists a check valve (8381) as the inner valve, but lists two valves (MO 8105 and 8106) as the outer valves. Two valves outside containment exceed the requirements of GDC 56 and, therefore, Valve MO 8106 is being deleted from the TTS. Valve 8381 is being added to the TTS not only for consistency with the FSAR, but also to satisfy the requirements of GDC 56. Since this change results in two valves still being identified as containment isolation valves in the TTS, but in a configuration that complies with GDC 56, there is no significant increase in the probability or consequences of an accident involved.

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided for accident mitigation and are not related to accident creation.

c. Involve a significant reduction in a margin of safety.

This change deletes a valve from the TTS that is not required by GDC 56 to be a containment isolation valve. In addition, it adds Valve 8381 which is listed in the FSAR as a Containment I isolation valve, but was not listed in the TTS. Since this change merely corrects an inconsistency, a reduction in a margin of safety is not involved.

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7. The addition of Valves SV 6991 and SV 6992 to TTS Table 3.6-1 does  !

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a. Involve a significant increase in the probability or consequences of an accident. .

l This change corrects the TTS to identify two Containment isola-tion valves which were not listed in Table 3.6-1. This change constitutes an additional restriction not presently included in the TTS, and will ensure that the TTS are consistent with regulatory requirements.

. LCA 124, Revision 1 Page 7 of 11

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the consequences of an accident. Adding two Containment isolation valves to TTS Table 3.6-1 which are already in the design is not relevant to accident creation.

c. Involve a significant reduction in a margin of safety.

Since this change constitutes an additional restriction not presently included in the TTS, a reduction in a margin of safety is not involved.

8. Moving the component cooling water (CCW) valves in TTS Table 3.6-1 to the heading "Non-Automatic Power Operated Isolation Valves" does not:

a. Involve a significant increase in the probability or consequences of an accident.

This change is merely administrative and will ensure that all non-automatic power operated isolation valves are grouped into one portion of TTS Table 3.6-1.

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided for accident mitigation and are not related to accident creation.

c. Involve a significant reduction in a margin of safety.

The relocation of valves in TTS Table 3.6-1 is done to improve readability and has no impact on safety margins.

9. Changing footnote (a) to footnote 4, and moving it to the end of ,

TTS Table 3.6-1 does not: l

a. Involve a significant increase in the probability or  !

consequences of an accident.

This change is merely administrative and will ensure that all footnotes are grouped into one portion of TTS Table 3.6-1.

b. Create the pcssibility of a new or different kind of accident.

Containment isolution valves are provided for accident mitigation and, therefore, moving a footnote associated with these valves is not related to accident creation.

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- LCA 124, Revision 1 Page 8 of 11

c. Involve a significant reduction in a margin of safety.

The relocation of this footnote in TTS Table 3.6-1 is done to improve readability and has no impact on safety margins.

10. Addition of footnote # to Containment Sump Valves MO 2069A and 2069B does not:

a. Involve a significant increase in the probability or consequences of an accident.

Footnote # excludes these valves from local leak testing.

Valves MO 2069A&B would be open following a LOCA for operation in the recirculation mode. Since these valves would be open, local leak testing is irrelevant. In addition, since the penetrations associated with these valves would be filled with water following a LOCA, these penetrations would not provide a Containment atmosphere leak path,

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided for accident mitiga-tion. Therefore, excluding Valves MO 2069A&B from leak testing is irrelevant to accident creation.

c. Involve a significant reduction in a margin of safety.

Exclusion of Valves MO 2069A&B from local leak testing is con-sistent with the exclusions presently allowed for other penetra-tions with a similar function following a LOCA. Penetrations such as residual heat removal suction and discharge, and safety injection discharge are not subject to local leak testing because they are also required to be open to perform their post-accident function and are filled with water. Local leak testing of these types of penetrations would serve no useful purpose from the standpoint of Containment leak tightness since the isolation valves are open post-accident. Since Valves MO 2069A&B are located inside Containment, any leakage around the valve stems would remain inside containment.

11. Addition of Valves 10610A&B, 10611A&B, and LD001 and 003 do not:

a. Involve a significant increase in the probability or consequences of an accident.

This change is an administrative change in that it corrects the TTS to identify Containment isolation valves which were not listed in Table 3.6-1. This change constitutes an additional restriction not presently included in the TTS, and will ensure that the TTS are consistent with regulatory requirements.

LCA 124, Revision 1 Page 9 of 11

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the conse-quences of an accident. Adding Containment isolation valves to TTS Table 3.6-1 which are already in the design is not relevant to accident creation,

c. Involve a significant reduction in a margin of safety.

Since this change constitutes an additional restriction not presently included in the TTS, a reduction in a margin of safety is not involved.

12. Adding identifying numbers for the demineralized water and reactor coolent drain tank nitrogen supply valves does not;

a. Involve a significant increase in the probability or consequences of an accident.

This change is merely administrative and will ensure that the demineralized water and reactor coolant drain tank nitrogen supply valves are correctly identified.

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the consequences of an accident. The addition of identifying numbers for these valves is not relevant to accident creation,

c. Involve a significant reduction in a margin of safety.

The addition of identifying numbers to these valves in TTS Table 3.6-1 is done to improve readability and has no impact on safety margins.

13. Addition of Relief Valves PSV 8117 and PSV 8708 does not:

a. Involve a significant increase in the probability or consequences of an accident.

This change is an administrative change in that it corrects the TTS to identify Containment isolation valves which were not listed in Table 3.6-1. This change constitutes an additional restriction not presently included in the TTS, and will ensure that the TTS are consistent with regulatory requirements,

b. Create the possibility of a new or different kind of accident.

Containment isolation valves are provided to mitigate the conse-quences of an accident. Adding Containment isolation valves to s_____ _ __ _ .

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. LCA 124, Revision 1 -

Page 10 of 11 1 i

TTS Table 3.6-1 which are already in the design is not relevant 1 to accident creation, j

c. Involve a significant reduction in a margin of safety.

i Since this change constitutes an additional restriction not presently included in the TTS, a reduction in a margin of safety is not involved.

14. Addition of Valve CV 8843 to TTS Table 3.6-1 does not:

a. Involve a significant increase in the probability or consequences of an accident. I This change is an administrative change in that it corrects the TTS to identify a Containment isolation valve which was not listed in Table 3.6-1. This change constitutes an additional restriction not presently included in the TTS, and will ensure that the TTS are consistent with regulatory requirements.

b. Create the possibility of a t.aw or different kind of accident. 1 Containment isolation valves are provided to mitigate the l consequences of an accident. Adding a Containment isolation valve to TTS Table 3.6-1 which is already in the design is not relevant to accident creation,

c. Involve a significant reduction in a margin of safety.

I Since this change constitutes an additional restriction not

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presently included in the TTS, a reduction in a margin of safety )

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1 In the March 6, 1986 Federal Register, the NRC provided certain examples i of amendments that are considered not likely to involve significant hazards considerations. Example (i) is a purely administrative change to Technical Specifications, for example, a change to achieve consistency throughout the Technical Specifications, correction of an error, or a change in nomenclature. Example (ii) is a change that constitutes an additional limitation, restriction, or control not presently included in the Technical Specifications, eg, a more stringent surveillance require-ment. The changes proposed within fall within these examples.

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

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LCA 124, Revision 1 Page 11 of 11 SAFETY / ENVIRONMENTAL EVALUATION Safety and environmental evaluations were performed as required by 10 CFR 50 and the TTS. This review determined that an unreviewed safety question does not exist since Plant operations remain consistent with the FSAR, adequate surveillance is maintained, and there is no conceivable impact upon the environment.

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BLK/kal 6075k.288 I

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