ML20034A953

Requests Exemption from Testing Requirements of 10CFR50,App J,Section III.D.2.b(i) for Containment Air Lock Door Equalizing Valves.Completion of Review Requested by 900510 in Order to Test Valves

ML20034A953
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	04/18/1990
From:	Walt T PORTLAND GENERAL ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9004250116
Download: ML20034A953 (3)

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g Peruand GeneralEledricC0wpiniy April 18, 1990 Trojan Nuclear Plant Docket 50-344 License NPF-1 U.S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington DC 20555 Dear Sirst Appepdix J Exemption Request-The purpose of this letter is to request an exemption'to the testing.

requirements of Title 10, of the Code of' Federal ~ Regulations, Part 50, Appendix J Section III.D.2.b(i) for the Containment air lock door equalizing valves. Portland General Electric-(PCE) recently. discovered that these equalizing valves were not included in the air lock leakage tests required by Trojan Technical Specification (TTS) 3.6.1;3,.

" Containment Air Locks".

PGE has conservatively declared.the inner containment air lock door inoperable due to the unt'ested equalizing valves. Because of their design, these valves can not be tested per Appendix J requirements and PGE proposes an alternative method of testing these valves as described in the attached Appendix J Exemption Request'

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TTS 3.6.1.3 requires the air lock to be. tested and-declared operable at the

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end of the current refueling outage.

In order to test: the equalizing valves, and thus' declare the air lock operable, PGE requests that this, j

Appendix J Exemption Request be-reviewed by May 10,-1990, j

i sincerely, T. D. Walt, Acting Vice' President, Nuclear Attachment i

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Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission Mr. David Stewart-Smith State of Oregon Department of Energy

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l Mr. R. C. Barr I

NRC Resident Inspector Trojan Nuclear Plant 9004250116 90041G P

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Trojan Nuclear Plant Document Control Desk Docket 50-344 April 18,_1990 License NPF-1 -

1 Page l'of 2 APPENDIX J EKEMPTION REQUEST Current Requirement-Title 10, of the Code of Federal Regulations, Part 50 (10 CFR 50),

Appendix J, Sections III.D.2.b(1), states that air locks are subject to!

Type B testing (at an internal pressure not less than P ) at six month a

intervals, t

t Basis for Exemption Request During a recent review of the Containment air lock testing methodology, it_was determined that the Containment air lock inner door equalizing valve was not being leak tested. During the testing of the Containment air lock penetration, the inboard door equalizing valve was being clamped-t shut to prevent the valvo from opening at the 60 psig (Pa) test =

pressure. Due to the design of the equalizing valve (see Figure 1) it cannot be tested at a pressure-greater than the spring force which holds the valve closed (i.e., approximately 10 to 15 psig), nor can it'be tested in the direction of flow from accident conditions.

Portland f

General Electric Company (PGE) conservatively declared the inboard

-l Containment air lock door inoperable until a. testing methodology for-the equalizing valve can be determined and the test performed.

i Alternative Testing PGE proposes an alternative method for determining the amount of potential leakage from this valve.- PGE has classified this valve as t

subject to Type B testing requirements in that it is a part of the air-lock mechanism (but not part of the door seal). As such.-it would be subject to testing at P every six months per 10 CFR 50,-Appendix J,-

a Section III.D.2.b(i).

As discussed above, the design of this valve.

precludes testing at P.

The valve has a test port that would allow.

a testing of the valve soals.

PGE proposes that the equalizing. valve.be tested by pressurizing between the valve seals at a reduced pressure (i.e., 5 to 10 psig). The leakage mass would be ratioed to P and a

added to the leakage for the Containment air-lock barrel test.

The test pressure would be exerted in a direction opposite to that which would be exerted during accident conditions on the equalizing valve disk.

This methodology is more conservative since the. accident pressure would tend to close the valve rather than open the valve.

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