ML20154J080

Forwards Request for Addl Info Re Occupational Radiation Exposure.Comments Re 850517 Proposed Tech Spec Change on Replacement of MSIV Bypass Valve Actuators & FSAR Changes in Amend 56 Also Encl

ML20154J080
Person / Time
Site:	Comanche Peak
Issue date:	02/28/1986
From:	Noonan V Office of Nuclear Reactor Regulation
To:	Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 8603100470
Download: ML20154J080 (8)

Text

._____ ____ ________

RB 2 8 M Docket Nos.: 50-445 and 50-446 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L. B. 81 Dallas, Texas 75201

SUBJECT:

REQUEST FOR CHANGE TO CPSES TECHNICAL SPECIFICATIONS CONCERNING REPLACEMENT OF MSIV BYPASS VALVE ACTURATORS By letter dated May 17, 1985, Texas Utilities requested changes to the Comanche Peak technical specifications to allow the use of manual operators on the main steam isolation valve (MSIV) bypass valves. In addition, by letter dated July 10, 1985, Texas Utilities submitted an evaluation performed to determine the impact of the MSIV bypass valve actuator replacement on plant safety. The staff has reviewed your request and safety evaluation and has prepared the enclosed request for additional information with regard to impact on occupational radiation exposure. In addition, the staff has provided consnents on your proposed changes to the technical specification as marked in your May 17, 1985, submittal and FSAR changes provided in Amendment 56. Should you have any questions concerning the enclosed request, contact Annette Vietti-Cook, Project Manager on telephone number (301) 492 8083.

Vincent S. Noonan, Director PWR Project Directorate #5 Division of PWR Licensing-A

Enclosure:

As stated cc: See next page Distribution: g

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FEB 9 719Q6 Docket Nos.: 50-445 and 50-446 Mr. W. G. Counsil Executive Vice President Texas Utilities Generating Company 400 North Olive Street, L. B. 81 Dallas, Texas 75201

SUBJECT:

REQUEST FOR CHANGE TO CPSES TECHNICAL SPECIFICATIONS CONCERNING REPLACEMENT OF MSIV BYPASS VALVE ACTURATORS By letter dated May 17, 1985, Texas Utilities requested changes to the Comancht Peak technical specifications to allow the use of manual operators on the main steam isolation valve (MSIV) bypass valves. In addition, by letter dated July 10, 1985, Texas Utilities submitted an evaluation performed to determine the impact of the MSIV bypass valve actuator replacement on plant safety. The staff has reviewed your request and safety evaluation and has prepared the enclosed request for additional infonnation with regard to impact on occupational radiation exposure. In addition, the staff has provided coments on your proposed changes to the technical specification as marked in your May 17, 1985, submittal and FSAR changes provided in Amendment 56. Should you have any questions concerning the enclosed request, contact Annette Vietti-Cook, Project nager on telephone number (301) 492-8083. g _

. on n, Director fW Projec Dire torate #5 Division o PWR Licensing-A

Enclosure:

As stated cc: See next page

s W. G. Counsil Comanche Peak Steam Electric Station Texas Utilities Generating Company Units 1 and 2 cc:

Nicholas S. Reynolds, Esq. Resident inspector / Comanche Peak Bishop, Liberman, Cook, Nuclear Power Station Purcell & Reynolds c/o U. S. Nuclear Regulatroy Commission 1200 Seventeenth Street, N. W. P. O. Box 38 Washington, D. C. 20036 Glen Rose, Texas 76043 Robert A. Wooldridge, Esq. Regional Administrator, Region IV Worsham, Forsythe, Sampels & U. S. Nuclear Regulatory Commission Wooldridge 611 Ryan Plaza Drive Suite 1000 2001 Bryan Tower, Suite 2500 Arlington, Texas 76011 Dallas, Texas Mr. Robert E. Ballard, Jr. Lanny A. Sinkin Director of Projects Christic Institute Gibbs and Hill, Inc. 1324 North Capitol Street 11 Pen Plaza Washington, D. C. 20002 New York, New York 10001 Mr. R. S. Howard Ms. Billie Pirner Garde Westinghouse Electirc Corporation Citizens Clinic Director P.O. Box 355 Government Accountability Project Pittsburgh, Pennsylvania 15230 1901 Que Street, N. W.

Washington, D. C. 20009 Renea Hicks, Esq. David R. Pigott, Esq.

Assistant Attorney General Orrick, Herrington, A Sutcliffe Environmental Protection Division 600 Montgomery Street P.O. Box 12548, Capitol Station San Francisco, California 94111 -

Austin, Texas 78711 Mrs. Juanita Ellis, President Anthony Z. Roisman, Esq.

Citizens Association for Sound Energy Trial Lawyers for Public Justice 1426 South Polk 2000 P Street, N. W.

Dallas, Texas 75224 Suite 611 4

Washington, D. C. 20036 Ms. Nancy H. Williams Nancy E. Wiegers CYGNA Spiegel & McDiarmed 101 California Street 1350 New York Avenue, N. W.

San Francisco, California 94111 Washington, D. C. 20005-4798 Robert P. Lessy, Jr.

Morgan, Lewis & Bokius 1800 M Street, N. W.

Suite 700, North Tower Washington, D. C. 20036

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r e Texas Utilities Electric Company Comanche Peak Electric Station Units 1 and 2 cc:

Resident Inspector - Comanche Peak c/o U. S. Nuclear Regulatory Commission P.O. Box 1029 Granbury, Texas 76048 Mr. John W. Beck Vice President Texas Utilities Electric Company Skyway Tower 400 North Olive Street, L. B. 81 Dallas, Texas 75201 Mr. Jack Redding Licensing Texas Utilities Ge .erating Company 4901 Fairmont Avenue Bethesda, Maryland 20814 William A. Burchette, Esq.

Heron, Burchette, Ruckert & Rothwell Suite 700 1025 Thomas Jefferson Street, N. W.

Washington, D. C. 20007 Mr. James McGaughy Southern Engineering Company of Georgia 1800 Peachtree Street, N. W.

Atlanta, Georgia 30367-8301 Administrative Judge Peter Bloch U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Elizabeth B. Johnson Administrative Judge Oak Ridge National Laboratory P.O. Box X, Ruilding 3500 Oak Ridge, Tennesse 37830 Dr. Kenneth A. McCollom, Dean Division of Engineering, Architecture and Technology Oklahoma State University Stillwater, Oklahoma 74074 Dr. Walter H. Jordan 881 Outer Drive Oak Ridge, Tennesse 37830 1

. Request For Additional Information (1) Address the operation of the MSIV bypass valve by " handwheel" manual actuation and provide information on operator radiation exposure based on its location, dose rate in the area that must be accessed and occupied for its actuation, the time spent in the area, and the frequency of need to actuate, maintain, service, etc., the valve under normal and emergency plant conditions.

(2) Describe the occupational radiation exposure in terms of man-rem that will be received as compared to that which would have been received under the previously installed automatic operating conditions.

(3) During Mode 2, if a Steam Generator Tube Rupture event were to occur, would the environment, e.g., radiation level / temperature, permit an operator to manually close the valve without exceeding part 10 CFR 20 guidelines?

(4) Assuming fuel failure before or during the tube rupture described in 3 above, what is the maximum time available to complete valve closure before radiation exposure becomes excessive per 10 CFR part 20 and/or offsite doses becomes excessive per 10 CFR Part 1007

O y Comments On Mark Up To Technical Specifications Page

1. 3/4 6-21 Refer to Table 3.6-1; Containment Isolation Valves;

4. Manual Valves; Insert A. Valve numbers marked 1HV imply power operated 1HV should be changed to IMS.

2. 3/4 6-26 Refer to Table 3.6-1; Containment Isolation Valves;

7. Steam Line Isolation Signal; Valve 1HV-2323 A; under Line or Service. Currer.tly this reads " Main Steam From Generator #1". This should read, " Main Steam From Steam Generator #1".

3. 3/4 6-27 Refer to Table 3.6-1; Containment Isolation Valves; 7.SteamLineIsolationSignal(Continued); Valve IHV-2411; under Line or Service. Currently this reads " Main Steam From Steam Generator #3. This should read, " Drain From Main Steam Line #3".

4. 3/4 6-30 Refer to Table 3.6-1; Table Notations Note 11.

Should read, "All four MSIV Bypass Valves are .

locked closed in Mode 1. During Modes 2, 3 and 4 one MSIV Bypass Valve may be opened provided the other three MSIV Bypass Valves are locked closed and thair associated MSIVs are closed."

r Consnents On FSAR Amendment 56 V

FSAR Section 3.98 Mechanical Systems and Components

1. Refer to Table 3.98-8; Sheet 5; ASME Code Class 2 and Class 3.

Active and Inactive Pumps and Valves; Main Steam Reheat and Steam Dump System. Are b and e the same now? Should b be deleted?

2. There is a conflict between Table 3.9B-8; sheet 5, and Table 3.9B-10 sheet 1 of 12. HV-2333B, HV-2334B, HV-23358 HV-2336B should be deleted from the Active Valve list.

FSAR Section 6.2 Containment Systems

3. Assuming Table 6.2.4-2 Sheet 1 of 10 is for both Active and Inactive valves, the "HV" designator should be changed on the MSIV bypasses and the primary method of actuation should be " Local Manual" to clearly differentiate from the remote manual actuators.

4. On Table 6.2.4-3 Sheets 1 and 2 of 14, the containment isolation signal for items 2, 7,11, and 15 should be deleted since they no longer receive a containment isolation signal.

5. Figure 6.2.4-1; Sheet 5 of 10; Valve arrangement 17; Outside Containment; should indicate locked closed.

3 FSAR Section 10.3 1

! 6. In Section 10.3.2.3.1, justify the elimination of the need for main steam

! isolation valves to stop flow from either direction within 10 seconds l after a steam line break to prevent uncontrolled steam releases from more that one steam generator (Page 10.3-7 and 10.3-9 Amendment 56).

7. Thewords"anintegral"shouldberemovedandreplacedwit$"amanual" (Page10.3-7 Amendment 56).

8. Should the bypass valve be locked closed during " power operation" or when i " containment integrity" is required (Page 10.3-7 Amendment 56)?

r

9. The following sentence should be deleted; "Each MSIV bypass valve also l has a two train module, open, close and auto switch on the control board." (Page 10.3-8 Amendment 56).

l 10. The following sentence should be deleted; "There is no provision for testing the bypass valves." (Page 10.3-9 Amendment 56).

11. Refer to Section 10.3.2.4; Main Steam Isolation Bypass Valves. This paragraph should clearly explain that all four MSIV bypass valves are locked closed in Mode 1. During Modes 2, 3, and 4 one MSIV bypass valve may be opened provided the other three MSIV bypass valves are locked closed and their associated MSIVs are closed.

12. Refer to Figure 10.3-1; Sheet 1. Designation HV should be replaced with MS for the subject valves.

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