ML20027D257
| ML20027D257 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 10/07/1982 |
| From: | Clark R Office of Nuclear Reactor Regulation |
| To: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| References | |
| TAC-48653, NUDOCS 8211030456 | |
| Download: ML20027D257 (4) | |
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4 OCT 7 1982 tATocket File NRC PDR.'
L PDR NSIC ORBf3 Rdg Docket No. 50-344 DEisenhut JHeltemes OELD ELJordan Mr. Bart D. Withers JMTaylor Vice President Nuclear ACRS-10 Portland General Electric Company RAClark 121 S.W. Salmon Street PMKreutzer-3 Portland, Oregon 97204 CTrammell Gray File
Dear Mr. Withers:
GZwetzig - Region V PSTam, A-14 In conducting our review of your Inservice Testing Relief requests as delineated in your letter of July 23, 1982, as revised on August 18, 1982, for the Trojan Nuclear Plant, we have detennined that we will need the additional information identified in the enclosure to complete our review.
In order for us to maintain our review schedule, your response is re-quested within 45 days of your receipt of this letter.
The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.
Please contact us if you have any questions concerning this request.
Sincerely, Original signed by Robert A. Clark
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Robert A. Clark, Chief Operating Reactors Branch #3
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Division of Licensing
Enclosure:
Request for Additional Information cc w/ enclosure:
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NRC FORM 318 0080) NRCMDNO OFFICIAL RECORD COPY uso i ei-sweeo
Portland General Electric Company cc: Multnomah County Library Social Science and Science Department 801 S.W. 10th Avenue Portland, Oregon 97205 Michael Malmros, Resident Inspector U. S. Nuclear Regulatory Commission Trojan Nuclear Plant P. O. Box 0 Rainier, Oregon 97048 Robert M. Hunt, Chairman Board of County Commissioners Columbia County St. Helens, Oregon 97501 Donald W. Godard, Supervisor Siting and Regulation Oregon Department of Energy Labor and Industries Building Room 111 Salem, Oregon 97310 Regional Administrator Nuclear Regulatory Commission, Region V Office of Executive Director for Operations 1450 Maria Lane, Suite 210 Walnut Creek, California 94596
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Request for Additional Information Inservice Testing Program Relief Requests--
Trojan Nuclear Plant Docket No. 50-344 Note:
Unless otherwise indicated, paragraph reference are keyed to the attachment to the PGE letter of July 23, 1982 as revised August 18, 1982.
1.
Para.3.2: Please verify the accuracy of or correct the formula for pump inlet pressure.
As written, it appears that increasing
" Intake Structure Level" would reduce the pump inlet pressure.
2.
Paras. 3.2.2, 3.2.3, 3.2.4 and 3.2.5: The basis for granting
. relief from a test requirement is that the requirement is impractical.
The fact that flow measurement instrumentation is not presently installed does not, by itself, make flow measurements impractical.
Accordingly, please comit to including flow measurements in accordance with IWP-3100; or supplement the discussion of alternate testing provided in the PGE letters of July 23 and August 18, 1982, to demonstrate how the measured test parameters (together with any other test provisions, such as a fixed resistance flow path, or matching a point on a head-flow curve, etc.) will detect significant (per Table IWP-3100-2) degradation in flow capability, so that necessary corrective actions can be implemented.
3.
Para. 4.2: This section does not request relief for the 3 inch check valve located at elevation 83 ft. 11 inch in the spent fuel pool (SFP).
It appears that depending upon the elevation of the break, failure of line 10"-HCC-54 combined with failure of this check valve to open could cause draining of the SFP.
It also appears that inservice testing of this valve in accordance with IWV-3520 might be difficult.
Accordingly, the question arises as to why relief has not been requested and/or alternate testing proposed.
In reviewing FSAR Figure 9.1-4, we note that the.SFP cooling system, including this check valve, is designated Quality Group 4A.
- Hence, one might consider the check valve not subject to IWV-3520. We believe, however, this is incorrect because the SFP cooling system is.not designed to Seismic Category I s,tandards, and' because it is not, FSAR Section 9.1.3.3 takes credit for operation of this check valve to prevent draining of the SFP.
Therefore, based on this argument, it appears that periodic testing to verify the operability of the check valve is prudent.
Please address this concern.
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2-4.
Paras. 4.2.3.1, 4.2.4.1 and 4.2.4.2.
These requests for relief appear to be based on the assumption that full-stroke testing can only be accomplished by flow testing.
IWV-3522, however, specifies other methods for performing full stroke testing, including visual observation, electrical position indication, observation of pressure differences and use of mechanical exerciser.
Please consider these other techniques in determining if full stroke testing is impractical.
If, after considering these other techniques, it is still concluded that full stroke testing of these valves impractical, please explain the bases for your conclusions.
5.
Para. 4.2.5.3.
Please describe how the valves (3-EBD-CK) will be
" exercised to verify operability in the closed position..."
- 6.. Para. 4.28.
The basis given for requesting relief from the Section XI leakage rate measurement is that the Category A containment isolation valves are currently tested under the provisions of Appendix J to 10 CFR 50. While the tests performed to Appendix J are acceptable for satisfying the requirements of Section XI, IWV-3420 Valve Leak Rate Test, Appendix J does not provide for the analysis of leakage rates as specified in IWV-3426. Accordingly, please modify your request for relief to indicate that the analysis required by IWV-3426 and the corrective action required by IWV-3427 will be performed.
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