ML20207P883

Forwards Change to Significant Hazards Consideration of License Change Application 144,expanding Description of Acceptability of Testing Containment Isolation Valves During Operation

ML20207P883
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/14/1987
From:	Lentsch J, Lindblad W PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
TAC-63445, NUDOCS 8701200367
Download: ML20207P883 (3)

Text

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PORTLAND GENERAL ELECTRIC COMPANY 121 S.W. S ALM ON STR EET WILLIAM J. LIN DBLAD PoRTLAN D, OR EGO N 97204 (503)226-8875 January 14, 1987 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555

Dear Sir:

License Change Application 144 Pursuant to our discussion with your staff concerning LCA 144, attached is our change to the Significant Hazards Consideration for this LCA. This change expands the description of the acceptability of testing Containment isolation valves during operation.

Sincerely,

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c: Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. Gary Kellund Resident Inspector 4 Trojan Nuclear Plant Mr. David Kish, Acting Director State of Oregon Department of Energy Mr. Michael J. Sykes Chairman of County Commissioners N

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I 8701200367 870114 PDR ADOCK 05000344 )

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LCA 144 Page 1 of 2 DESCRIPTION OF CHANGE Trojan Technical Specification (TTS) 4.6.3.1.2 provides surveillance requirements for Containment isolation valve testing. -This change revises this TTS to allow containment isolation valve testing during any MODE rather than only MODES 5 or 6.

REASON FOR CHANGE TTS 4.6.3.1.2' requires that Containment isolation valves be stroke-tested during only MODES'S or 6. However, selected isolation valves can be tested in other MODES to satisfy this surveillance _ requirement. An-example is valve MD-8105. This is a Containment isolation valve which also functions as an ECCS valve to isolate charging to the RCS. Per TTS 4.5.2.e.1, this valve is stroke-tested once every 18 months. This testing is typically performed during MODE 4 in accordance with Periodic Operating Test 25-2b,

" Safeguards Test Panel Actuating Test", as part of ECCS valve testing.

This testing also satisfies the requirements of TTS 4.6.3.1.2, but since it is performed in MODE 4, does not meet the prescriptive requirements of this -

, TTS because it is not performed in MODES S or 6. To avoid performing this stroke-testing twice, but in different MODES, the change shown in Attachment A is proposed. .

SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION This change does not involve a significant increase in the probability or consequences of an accident. No change is proposed in the test frequency or the valves to be tested. This change merely gives credit for testing performed in MODES other than 5 or 6 for satisfying TTS 4.6.3.1.2. TTS Table 3.6-1 identifies those valves which are testable during operation.

In addition, FSAR Section 7.3.2.1.5 describes the online testing capability of the Engineered Safety Features Actuation System. As discussed in the FSAR, ". . . the operator in the main control room assures that Plant con-ditions will permit operation of the equipment that will be actuated . . ."

The online testing capability, which is part of the existing design basis, in combination with operator control of actual testing, provides assurance ~~~

that this testing is adequately controlled. Testing of containment isolation valves in modes other than 5 or 6, ie, online testing, has also been considered in the safety analysis with regard to single-failure criteria. As discussed in FSAR Section 6.2.4.3, the Containment isolation design is based.on the concept of two barriers. The two barriers ensure

. that a single failure of a containment isolation valve to close can be accommodated because a second barrier is available. The failure of an isolation valve to open during testing is accommodated either by: (1) the availability of a redundant train, or (2) the valve is not tested online because its failure to open may adversely affect the normal operation of the Plant as indicated in Table 3.6-1. Based on the above, this change does not involve a significant increase in the probability or consequences of an accident.

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-i LCA 144 Page 2 of'2 This change does not create a new or different kind of accident. Stroke-testing of Containment isolation valves is not relevant to accident cre-ation since.the-containment isolation valves are designed to mitigate the consequences of an accident after it has occurred. Valves which have both a Containment isolation function and a process function are tested only in NODES which do not adversely affect the functioning of the system, as discussed above. No' change is proposed to the design of the Plant.

This change does not involve a significant reduction in a margin of safety because this is an administrative change designed to achieve consistency

.throughout the TTS. This change proposes that stroke-testing still be per-formed in the same manner as is currently done. The acceptance criteria for this testing remains unchanged. The proposed change simply allows greater flexibility in the scheduling of this testing and eliminates duplicate testing.

This change is identical to a change proposed by Brunswick on August 29, 1986 which was given a preliminary notice of no significant hazards consideration by the NRC in the October 6, 1986 Federal Remister.

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 con-sideration. Example No. 1 of that list applies to the change proposed herein and states:

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

This change is considered administrative since it will achieve consistency

, throughout the TTS. Presently, TTS Table 3.6-1 lists numerous valves that l are testable during operation. However, TTS 4.6.3.1.2 only allows testing l of these valves during shutdown. The proposed change will eliminate this inconsistency.

! Based on the above evaluation, the proposed change is deemed not to pose a

! significant hazard.

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