ML20041D871
| ML20041D871 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/03/1982 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20041D868 | List: |
| References | |
| NUDOCS 8203090385 | |
| Download: ML20041D871 (4) | |
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PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY TROJAN NUCLEAR PLANT Operating License NPF-1 Docket 50-344 License Change Application 84 This License Change Application is submitted to amend Table 3.6-1 of the Trojan Nuclear Plant Technical Specifications (Appendix A to Facility Operating License NPF-1) to delete the isolation time limit for six Con-tainment sump recirculation valves that are non-automatic power operated.
PORTLAND GENERAL ELECTRIC COMPANY By Bart D. Withers Vice President Nuclear Subscribed and sworn to before me this 3rd day of March 1982.
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LCA 84 Pag 2 1 of 3 LICENSE CHANGE APPLICATION 84 Table 3.6-1 (Page 3/4.6-22) of the Technical Specifications is revised to change the isolation time to N.A. for valves MO 2069A and B, MO 2052A and B, and MO 8811A and B.
A revised Page 3/4.6-22 is attached.
REASON FOR CHANGE As identified in Licensee Event Report No. 80-22, Section 6.d, Limitorque motor operator brakes have not been tested for continued operation in a high radiation environment in accordance with the criteria of IE Bulletin 79-01B. These brakes are currently installed on the Containment recirculation sump valves, MO 2069A and B and it is intended to remove the unqualified brake from each valve operator and operate each valve in the future without it.
The vendor, Limitorque, was consulted and did confirm that operation without a motor operator brake is acceptable provided that the valve stem speed is slowed slightly so that full valve travel requires a minimum operating time of 30 seconds.
Limitorque has determined that an operating time of less than 30 seconds could damage the valve internals.
To meet this minimum time limit, this License Change Application proposes to delete the requirement in Table 3.6-1 of the Technical Specifications for the individual valve isolation time to be 17 seconds.
A review of Table 3.6-1 has determined that the isolation time limit for valves MO 2052A and B and.M0 8811A and B should also be deleted. These valves are not automatically operated and therefore do not receive a Containment isolation signal or safety injection signal. They are normally shut with control power deenergized, and their operation depends on plant operators since they are manually energized. Setting an isola-tion time limit for these valves is not justified since the closure time is actually dependent on the Plant operator reaction time.
SAFETY / ENVIRONMENTAL EVALUATION Summary of Change As described above, this License Change Application proposes to eliminate the isolation time requirement for valves MO 2069A and B, the Containment recirculation sump valves; MO 2052A and B, the Containment Spray System recirculation sump suction valves; and MO 8811A and B, the Residual Heat Removal System recirculation sump suction valves.
Effect on Technical Specifications and the Bases for the Technical Specifications Table 3.6-1 charts the maximum closure times for valves MO 2069A and B, MO 2052A and B, and MO 8811A and B.
The Bases for Technical Specifi-cation 3.6.3.1, Containment Isolation Valves, states the following:
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l The OPERABILITY of the Containment isolation valves ensures that the Containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the Containment. Containment isolation within the time limits specified ensures that the release of radioactive material to the environment will be consistent with the assumptions used in the analyses for a LOCA.
The proposed revision to Table 3.6-1, in which the specified closure i
times are to be deleted, ressins consistent with the Bases for Technical i
Specification 3.6.3.1.
Valves MO 2052 and MO 2069 are shown in FSAR Figure 6.4-1, and Valves MO 8811 are shown in FSAR Figure 5.5-7.
The normal system lineup consists of valves MO 2069A and B open and isolated by NO 2052A and B and NO 8811A and B, which are normally shut with control power deenergized. These valves are part of the system to provide recirculation ability during long-term core and Containment cooling following a design basis loss-of-coolant accident and would not be needed for a minimum of 25 minutes according to FSAR Section 6.4.3.1.
These valves are all shut or isolated and are not automatically operated.
They do not receive an automatic Containment isolation signal or safety injection signal. These valves are manually energized, and an isolation time limit for manually energized valves is not meaningful since the actual closure time is dependent on the Plant operator reaction time rather than an automatically initiated signal. The OPERABILITY of these valves will continue to be verified by testing performed under Technical Specification 4.6.3.1.1.
Technical Specification 6.13, Environmental Qualification, should also be considered for valves MO 2069A and B.
It states, in part, the i
following:
By no later than June 30, 1982, all safety-related electrical equipment in the facility shall be qualified in accordance with the provisions of:
Division of Operating Reactors
" Guidelines for Evaluating Environmental Qualification of l-Class IE Electrical Equipment in Operating Reactors" (DOR Guidelines); or NUREG-0588 " Interim Staff Positlan on Environmental Qualification of Safety-Related Ele:trical Equipment", December 1979.
Since radiation qualification testing has not been documented for the MO 2069A and B Limitorque motor operator brakes, they must be removed; however, this removal requires that the valve closure time be set at a l
minimum of 30 seconds to avoid internal damage during operation which is in conflict with Table 3.6-1.
As described above, deletion of the isolation time limit is consistent with the Bases for the Technical j
Specifications.
This proposed change to Technical Specifications Table 3.6-1 does not con-j stitute an unreviewed safety question. This revision does not involve a decrease in any safety margins and the health and safety of the public will not be endangered due to operation in this proposed manner.
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LCA 84 Peg 2 3 of 3 Effect on FSAR Section 6.2.4.1 describes the various types of Containment penetrations.
The lines associated with these valves are Type IV penetrations; fluid lines that must remain in service after a design basis accident.
In lines of this type, isolation valves are not automatically closed.
No changes to this section are necessary.
Sections 6.2, 6.4, 5.5.7 and 15.4.6 describe the design criteria for l
the valves.
No changes to these sections are necessary.
Environmental Effect The proposed change does not affect the environmental analyses in the FSAR, Environmental Report or the final Environmental Impact Statement.
No unreviewed environmental question exists and there is no significant adverse effect to the environment.
Schedule Considerations This License Change Application is submitted to support equipment modifi-cations necessary to comply with the Trojan Technical Specifications.
To allow adequate time to complete the maintenance by the required date i
of June 30, 1982, approval of this License Change Application is requested by June 1, 1982.
Basis for Determination of Amendment Class This License Change Application has been determined to result in a Class III amendment in accordance with 10 CFR 170.22 since it involves a single issue and does not involve a significant hazard consideration.
The fee for a Class III amendment is $4,000.
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