ML20028F068
| ML20028F068 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 01/21/1983 |
| From: | Broehl D PORTLAND GENERAL ELECTRIC CO. |
| To: | Clark R Office of Nuclear Reactor Regulation |
| References | |
| TAC-42502, NUDOCS 8301310086 | |
| Download: ML20028F068 (7) | |
Text
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um amme Portland Geners sechiccompany I
1 Donald J. Broehl Assistant Vce President January 21, 1983 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington DC 20555
Dear Mr. Clark:
Safety Evaluation Report for Environmental Oualification of Safety-Related Electrical Equipment Your letter of December 17, 1982 transmitted the Safety Evaluation Report (SER) for the environmental qualification of safety-related electrical i
equipment at the Trojan Nuclear Plant. We were requested to:
1.
Review the enclosed Technical Evaluation Report (TER) by Franklin Research Center and notify the NRC within seven days of receipt of the SER whether any portion of the identified pages still require proprietary protection.
2.
Reaffirm the justification for continued operation and, within 30 days of receipt of the SER, submit information for items in NRC Categories I.B, II.A, and II.B in the TER for which justification for continued operation was not previously submitted to the NRC.
3.
Provide plans for qualification or replacement of the equipment in NRC Categories I.B II.A, and II.B and the schedule for accomplishing proposed corrective actions within 90 days of receipt of the SER.
Item 1 was responded to in our December 30, 1982 and January 14, 1983 letters.
A detailed response to Item 2 is presented as an attachment to this letter. Resolution of the discrepancies noted in Section 5 of the TER are also addressed in the attachment.
8301310086 830121 PDR ADOCK 05000344 P
PDRw a vv can vi teet Pocand, Oregon 97204
W W BBCiricC0ff4MN1y Mr. Robert A. Clark January 21, 1983 q
Page two A response to Item 3 will be provided by March 18, 1983.
Included in this response will be resolution of the major qualification deficiencies identified in Tables 4-1 through 4-4 of the TER.
Sincerely, l //[(c 4
Attachment c:
Mr. Lynn Frank, Director State of Oregon Department of Energy i
l
i Trojan Nucleer Plcnt Robert A. Cicrk
'l Dockst 50-344 Jcnunry 21,_1983 License NPF-1 Attachment Page 1 of 3_
PORTLAND GENERAL ELECTRIC COMPANY'S 30-DAY RESPONSE TO THE NRC'S~ SAFETY EVALUATION REPORT OF DECEMBER 17,-1982 ON ENVIRONMENTAL QUALIFICATION OF SAFETY-RELATED ELECTRICAL EQUIPMENT The following information is provided in response to the NRC letter of' December 17, 1982, and the Safety Evaluation Report (SER) and Technical Evaluation Report (TER) attached thereto, which requested submittal of certain information within 30 days of receipt of the letter. Also pro-vided is resolution of the discrepancies noted in Section 5 of the TER.
A.
Reaffirmation of Justification for Continued Operation In a letter to PGE dated March 26, 1981, the NRC transmitted an Equipment Evaluation Report (EER) which documented the preliminary results of their review of environmental qualification-of safety-related electrical equipment at the Trojan Nuclear Plant. This letter requested a written statement supporting.the safe operation of the Plant, taking into account the NRC Staff's preliminary list of deficiencies.
In a letter dated April 6, 1981, PGE affirmed the continued safe operation of the Trojan Nuclear Plant based on:
(1) A review of the identified deficiencies in the EER and the ramifications of the deficiencies; (2) The previous PGE submittals of September 5, 1980, and January 13, 1980, which provided technical evaluations supporting' continued operation pending qualification, by June 30, 1982, of all open items identified by the licensee; and (3) Licensee Event Report 80-22 of October 31, 1980.
A detailed justification for continued operation was also provided in PGE's response of August 26, 1981, to the NRC's SER'of May'27, 1981.
The TER by Franklin Research Center (FRC), attached to the NRC's SER of December 17, 1982, has been reviewed. Notwithstanding the defi-ciencies identified in the TER, and based on the aforementioned submittals, the continued operation of the Trojan Nuclear Plant is renffirmed to be safe.
B.
Justification for Continued Operation for Items Not Previously_
Submitted to the NRC PGE has reviewed the items in Categories I.B, II.A, and II.B of the TER to determine those items. for which a justification for continued operation was not previously submitted to the NRC. Of the items in
Trojan Nuclesr Plant R:bert A. Clark Docket 50-344 Janu:ry 21, 1983 Licenza NPF-1 Attichment.
Page 2 of 3 these categories, only those listed below were explicitly identified in the TER as not having a justification for interim operation pro-vided by the licensee.
FRC Item No.
TNP Equipment ID No.
29 M08700A 30 M08807B 36 M08806 39 M02052A&B,.2053A&B 40 M08809B 42 M08700B 43 M08811A 44-M010002, 10003 The equipment items listed above correspond to Limitorque motor operators with brakes. Justification for continued operation for these items was provided in PGE's August 26, 1981 submittal under the
" Resolution of Deficiency" column on Sheets 37, 40, and 43 of Table 3.
As noted therein, these operator brakes have not been qualified for the specified radiation environment; however, the operators perform their essential safety function before exposure to a severe radiation environment. This justification is consistent with the' clarification set forth in Item 8 of Generic Letter No. 82-09.
Further analyses have also confirmed that subsequent operator failure will not defeat the performance of essential safety functions.
C.
Resolution of Discrepancies Noted in Section 5 of the' TER Pages 5-1 and 5-2 of the TER identified various valve actuators that did not have System Component Evaluation Worksheets (SCEWs) provided, but did have both SER deficiencies and a licensee response to the deficiencies. Discrepancies were also noted for other valve actua-tors listed on Pages 5-3 and 5-4.
i
~
The resolution of the discrepancies noted for each valve ectuator listed in Section 5 of the TER is provided in Table 1.
On Page 5-1 of the TER, the following is stated:
"The cover letter of the NRC SER states that the SER was based on information supplied with cover letters dated March 7, 1980, April 25, 1980, May 19, 1980, September 5, 1
1980, and January 3, 1981. However, this Technical Evalu-ation Report is based on the March 7, 1980 submittal and the Licensee's response to the SER. This difference may account for some of the discrepancies noted in the follow-l ing list of motorized valve actuators...."
i i
Trojen Nucissr Plant Robert A. C1crk Decket 50-344 Jcnuary 21, 1983 Licanza NPF-1 Attcchment Page 3 of 3 This " difference" accounts for many of the discrepancies identified in Section 5 of the TER, as well as many of the deficiencies identi-fled in Section 4.
It should be clear that these later submittals by PGE represent revisions to, and updates of, previous submittals, and were prepared in order to provide the NRC with the most recent information available to base their review.-
DRS/4mawlA3 5
TABLE 1 Sheet 1 of 2 RESOLUTION OF DISCREPANCIES NOTED IN SECTION 5 0F THE TECHNICAL EVALUATION REPORT TNP TER ID No.
Discrepancy Resolution of Discrepancy MO 8716A No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 120)
MO 8716B No T.CEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page'121)
MO 8804A No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 122)
MO 8804B No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 123)
MO 8809A No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 124)
MO.8811B No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 127)
MO 112D' No SCEW provided SCEW was provided in 1/13/81 submi:tal (Enclosure 2, page 142)
MO 112E No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 143)
MO 8924 No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 150)-
MO 8807A No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 171)
MO 8802B Fo SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 167)
MO 5651B No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 287)
MO 5651D No SCEW provided' SCEW was provided in 1/13/81 submittal (Enclosure 2, page 289)
MO 8701 No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 117)
MO 8702 No SCEW provided The SCEW provided in 1/13/81 submittal was incomplete due to uncertainty about operator serial-number (see Enclosure 2, page 118). This operator has since been confirmed to be identical to MO 8701.- Therefore, the SCEW for MO 8701 (Enclosure 2, page 117) would be applicable for MO 8702.
TABLE 1 Sheet 2 of 2 TNP TER ID No.
Discrepancy Resolution of Discrepancy MO 8801B No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 165)
MO 8112 No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 149)
MO 8803B No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 169)
MO 112B No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 140)
MO 112C No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 141)
MO 8105 No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 145)
MO 8110 No SCEW provided SCEW was provided in 1/13/81 submittal (Enclosure 2, page 147)
MO 8923B Not addressed in SER SCEW was provided in 1/13/81 submittal (Enclosure 2, page 183)
MO 2808, 2810, Not addressed in SER These valve operators have been deleted from the Master List, 2812, 2813, and by license since they are located in a non-harsh environment..
6716, 6717, 6718, 6719 MO 2913 Not addressed in SER This plant ID No. is in error and has been deleted from the and by license Master List.
M0.4180 Unidentified Will address when identified; but, in any case, SCEW was pro-vided in 1/13/81 submittal (Enclosure 2, page 316)
MO 4181 No SCEW provided and-This plant ID No. is in error. The correct valve reference
.not addressed in SER should be CV 4181. The SCEW for the solenoid valve associated with this operator (SV 4181) was provided in 1/13/81 submittal (Enclosure 2, page 317).
DS/4s11A1