ML20214C799

License Change Application 137 to License NPF-1,revising Tech Specs Re Max Pressurizer Spray Water Temp Differential

ML20214C799
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	02/18/1986
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20214C792	List: ML20214C789 ML20214C799 ML20214C812
References
TAC-60781, NUDOCS 8602210275
Download: ML20214C799 (4)

Text

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. 9 PORTLAND GENERAL ELECTRIC COMPANY i l

EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY Operating Licet.se NPF-1 Docket 50-344 License Change Application 137 This License Change Appl cation requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to revise the maximum pressurizer spray water temperature differential.

PORTLAND CENERAL ELECTRIC COMPANY By Bart D. Withers j Vice President Nuclear Subscribed and sworn to before me this 18th day of February 1986.

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LCA 137 Page 1 of 3 l

j DESCRIPTION OF CHANGE

1. The maximum spray water temperature differential (AT) allowed in Trojan Technical Specification (TTS) 3.4.9.2.c is increased from 320*F to 560*F. The following is added: "[ Note: Spray actuations with a temperature differential >320*F and 1560*F are limited in accordance with Table 5.9-1.)".

2. The surveillance requirement TTS 4.4.9.2 is separated into 4.4.9.2.1 (heatup and cooldown), and 4.4.9.2.2 (spray operation). The pres-surizer spray surveillance is changed to require that the AT be I determined during " spray operation" instead of " steady-state opera-tion". The requirement that spray operation with a AT >320*F be i recorded for evaluation is added.

3. In Table 5.9-1 of the TTS, the following changes are made to the auxiliary spray actuation cyclic limit:

- The words " inadvertent auylliary" are deleted.

- An upper bound of 560*F is added to the spray water temperature 4

differential transient definition. The transient or cycle is now J

stated as " Spray water temperature diffee9ntial >320*F and 1560*F".

i REASONS FOu CHANGES

1. TTS 3.4.9.2 limits the pressurizer spray AT to 320*F. If the limit is exceeded, the action required includes performing an analysis to I determine the effects on the fracture toughness properties of the pressurizer. This specification is unnecessarily restrictive.

The design of the Trojan pressurizer considers various ASME operating conditions (discussed in Trojan UFSAR, Section 3.9). Included are normal operating transients (Plant heatup/cooldown) and upset condi-tions (abnormal incidents not resulting in mechanical damage).

Analysis assumptions for normal heatup/cooldown include a 320*F AT 4

limit at the spray nozzle. A maximum spray AT of 560*F is used for the upset condition caused by inadvertent actuation of auxiliary

+ spray. Table 5.9-1 recognizes this fact and allows 10 inadvertent cycles with a AT >320*F.

Increasing the maximum spray AT from 320*F to 560*F in TTS 3.4.9.2.c corrects the apparent inconsistency with Table 5.9-1, and more accurately reflects the pressurizer design basis analyses. The change also removes an unnecessary license restriction preventing the l discretionary use (within the cyclic limits of Table 5.9-1) of auxil-l iary spray during certain accident scenarios. One of the operational problems identified by INPO in its evaluation of the 1982 Cinna steam generator tube rupture event was the existence of administrative con-trols prohibiting the use of auxiliary spray when the nozzle AT exceeded 320*F. The basis for these controls was an unnecessarily

! restrictive Technical Specification. This change to the TTS allows

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the option of directing, through approved emergency instructions, the i

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4 LCA 137 Pcge 2 cf 3 limited use of this pressure control method while remaining in com-pliance with the Technical Specificationn.

The added " Note" to TTS 3.4.9.2.c provides a reference to the cyclic limit associated with the use of spray when the temperature differen-tial exceeds 320*F.

2. TTS 4.4.9.2 requires that the spray water AT be determined at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady-state operation.. This specification j requires clarification.

4 The surveillance requirement for pressurizer spray should apply when-ever spray is in operation (normal or auxiliary) and not be limited to steady-state operation. The requirement that the actuation of spray with a AT >320*F be recorded is added to allow future cal-culation of actual effects on the material integrity of the nozzle.

Accounting for the fact that operation with a lower AT has a lesser effect than operation with a higher AT, the remaining number of available cycles could then be determined.

3. Table 5.9-1, Component Cyclic or Transient Limits, allows 10 inadver-tent auxiliary spray actuation cycles with a spray water AT >320*F.

This limit requires clarification.

It is irrelevant to the issue of material integrity of the spray nozzle whether the spray actuation is auxiliary or normal spray and whether it is intentional or inadvertent. The words " inadvertent auxiliary" are deleted. Additionally, it is important to define an i upper temperature bound of 560*F, reflecting the maximum design value analyzed.

SIGNIFICANT HAZARDS DgTERMINATION

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

The change to TTS 3.4.9.2 increases the pressurizer spray AT from an unnecessarily restrictive limit of 320*F to a previously analyzed design value of 560*F and, therefore, does not involve an increase in

the probability or consequences of an accident previously evaluated.

l Changes to TTS 4.4.9.2 do not affect accident probabilities or conse-quences, but more specifically require surveillance during any period of spray operation rather than during steady-state operation only.

i An administrative data recording requirement is also added. The

! changes to the cyclic limit in Table 5.9-1 expand the applicability of the limit to all spray actuations rather than inadvertent auxil-inry spray actuations only. An upper bound of 560*F is also added thereby making the limit more restrictive to reflect the maximum analyzed spray temperature differential.

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LCA 137 P go 3 of 3

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

The possibility of a new kind of accident is not created since the l changes to the pressurizer spray AT limits remain within design transient analyses values. No new accident considerations result from the clarification in surveillance requirements nor in making the spray actuation cyclic limit more restrictive.

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

The margin of safety is not affected since the change in the pressurizer spray AT limit remains within the pressurizer design basis analyses. The clarification to the surveillance requirement does not involve a safety margin in any way. The cyclic limit changes are actually more restrictive and, therefore, do not reduce a margin of safety.

In the April 6, 1983 Federal Register, the NRC published a list of examples of amendments that are not likely to involve a significant hazards concern. Example (ii) of that list applies to the changes made to TTS 4.4.9.2 and Table 5.9-1 and states:

"A change that constitutes an additions 1 limitation, restric-tion, or control not presently included in the Technical Specifications: for example, a more stringent surveillance requirement."

Example (vi) of that list applies to the changes to TTS 3.4.9.2.c and states:

"A change which either may result in some increase to the probability or consequences of a previously-analyzed accident or may reduce in some way a safety margin, but Where the results of the change are clearly within all acceptable criteria with respect to the system or component specified in the Standard Review Plan: for example, a change resulting from the applica-tion of a small refinement of a previously used calculational model or de:ign method."

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 Updated FSAR, adequate surveillsnee is maintained, and there is no l

conceivable impact upon the environment.

DLN/kal/5716k.286

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