W3P88-1286, Application for Amend to License NPF-38,deleting motor-operated Valve Actuator compartment-heater Circuit Breakers from Table 3.8-1.Fee Paid

Application for Amend to License NPF-38,deleting motor-operated Valve Actuator compartment-heater Circuit Breakers from Table 3.8-1.Fee Paid

ML20196E854
Person / Time
Site:	Waterford
Issue date:	12/06/1988
From:	Dewease J LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20196E858	List: ML20196E874 W3P88-1286, Application for Amend to License NPF-38,deleting motor-operated Valve Actuator compartment-heater Circuit Breakers from Table 3.8-1.Fee Paid
References
W3P88-1286, NUDOCS 8812120105
Download: ML20196E854 (7)

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N LOUISIANA 317 BARONNE STREET e P. O. BOX 60340 POWER & LlGHT ! NEW ORLEANS, LOUl5lANA 70160 . (504) 595 2781

$SEsbsN J. G. DEWE ASE sewet a s nnsotur NUCL E A S OM B A TaCWs December 6, 1988 W3P88-1286 A4.05 QA U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555

Subject:

Waterford 3 sES Docket No. 50-382 License No. NPF-38 Technical Specificat! Change Request NPF-38-91 Gentlemen:

Waterford SES Unit 3 responds to 16E's Information Notice 86-71, "Recent Identified Problems with Limitorque Motor Operators", in part with this Technical Specification Change Request, NPF-38-91. The proposed change deletes motor-operated-valve actuator compartment-heater circuit breakers from Table 3.8-1. NPF-38-89, sent on October 31, 1988, requests reformatting Tabic 3.8-1 and Attachments "A" and "B" follow the new format.

The enclosed safety r.nalysis rests on two fundamentals. Limitorque motor operators come wit.h internal compartment heaters to maintain operator reliability during long storage times and infrequent maintenance while in storage. Electrical penetrations do not need overcurrent protection from disconnected heater circuits.

Should you have any questions or coments on this matter, please feel free to contact Steven Farkas at (504) 464-3383.

Very truly yours,

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J, . C . evea e Senior Vice President -

()tuelearOperations Attachments: NPF-38-91 Filing Fee, LP6L check - $150.00 cc: R.D. Martin, J.A. Calvo, D.L. Wigginton, NRC Resident Inspectors

ffice, E.L. Blake, W.M. Stevenson, Administrator Nuclear Energy Divinknr(State of Louisiana), American Nuclear Insurers 6312120105 801206 O'/ M PDR P

ADOCK 01000102 F DC. ,

/[O "AN EQUAL OPPORTUNITY EMPLOYER" $ 8 7~ gg,

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of )

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Louisiana Power & Light Company ) Docket No. 50-382 k'aterford 3 Steam Electric Station )

AFFIDAVIT l J.G. Dewease, being duly sworn, hereby deposes and says that he is Senior Vice President-Nuclear Operations of Louisiana Power & Light Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the cttached Technical Specificction Change Request NPF-38-91; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief, r

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.G. Devease enior Vice President-Nuclear Operations STATE OF LOUISIANA)

) ss PARISH OF ORLEANS )

Subscribedandsworntobeforeme,aNotaryPubleinandfortheParish and State above named this [3 M~

day of S gmt te.J.V ,

1988.

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' Notary Pub 1f~c My Commission expires .

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'J DESCRIPTION AND SAFETY ANALYSIS OF PROPOSED CHANGE NPF-38-91 This document justifier a revision to Technical Specification Table 3.8-1, "Containment Penetration Conductor Overcurrent Protective Devices -- 120 Volts Control Power from PDPs or MCCs," items 83, 85, 95, and 97. Part of the program to disconnect all safety-related MOV compartment heater circuits, pursuant to Information Notice 86-71, "Recent Identified Problems with Limitorque Motor Operators", includes this change.

Existing Specifications See Attachment A, extracted from Attacheent B of NPF-38-89.

Proposed Specifications See Attachment B, which uses the new format proposed in NPF-38-89.

Description Inspectica & Enforcement Information Notice 86-71, "Recent Identified Problems with Limitorque Motor Operators," identifies an unintended wire burning design feature in the motor operator. The NRC told the industry of a problem uncovered at Vogtle. Personnel found burned Limitorque installed internal wires located in the operator limit switch compartment. The wires were near, or in contact with, the installed limit switch compartment electric heater element or heater bracket. The wiring was neither properly routed, nor restrained from contacting the heater or heater bracket.

Although the heater is not seismically or environmentally qualified (in the traditional manner) and is intended only for storage, heater use in Vogtle caused serious environmentally-qualified internal wire degradation. In 1986 Waterford inspected all "EQ'd" Limitorque motor operators' internal wires. The inspection found no evidence of burn damage.

Motor operated valve actuators generally have condensation protection heaters (one for the switch compartnent, one for the rotor conpactment).

The heater does not preclude periodic inspection or maintenance. Ebasco's specifications require heaters and drains in both the notor and limit / torque switch and terminal block compartments. These options do not add to the initial cost of the actuator and prove useful during long term storage of the equipment during construction of the plant -- after installing the equipment, but while exposed to uncontrolled environments --

and during long periods of plant shutdown. Linitorque provides space heaters for storage purposes only, and only when specified (re: Limitorque to Anchor Darling, dated November 17, 1983).

For Class lE applications, actaators are environmentally qualified without the benefit of operable heaters. The heaters are, therefore, not considered essential for the actuators' safety function.

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'J The limit / torque switch and terminal box compartment heaters consist of an inorganic ceramic core with a wire wound or film reristive element ecmpletely encapsulated by a ceramic glaze. The failure mode of such a device results in an open circuit and does not short its power supply.

This type of heater, after simulated seismic acceleration of up to 12G, had no structural damage.

Waterford motor heaters are not necessarily the same as the switch and terminal compartment heaters. The motor heaters might fail in the short circuit mode, possibly resulting in the de-energizing of the control circuit. The motor heaters were not subjected to any seismic testing; however, by virtue of their configuration and mounting method, they should withstand a "6G" acceleration without failing. The plant AE reconfirmed this "6G" position with the vendor who assured that it applied to all the various heater types provided to Waterferd 3 (re: LW3-1035-84, dated August 27, 1984).

A recent station modification disconnected the power to these heaters at the actuator. The Table 3.8-1 revision deletes circuit protection listed for valves SI-331A, SI-331B, SI-332A, and SI-332B. Specification 3/4.8.4 and its associated Table 3.8-1 lists circuits whose failure could cause safety-related electrical containment penetrations to become inoperable.

Specification 3/4.8.4 intends to protect containment electrical penetration conductors (separate from cable conductors run-to and run-from the penetration) from overcurrent by either de-energizing unnecessary circuits, or providing primary and backup overcurrent protection circuit breakers.

Revised Tabic 3.8-1 elininates the motor operated compartment heater circuits from the population of protective circuit breakers to test.

Stopping the use MOV heaters precludes the problem documented in Information Notice 86-71.

NPF-38-89, cubmitted on October 31, 1988, proposed reformatting all of Table 3.8-1 to prevent recurrence of an event reported in LER 88-019. The attachments to this request are consistent with the proposed change requested in Attachment B of NPF-38-89.

Safety Analysis The proposed change described above shall be deemed to involve a significant hazards consideratici. if there is a positive finding in any of the following areas:

1. Will operation of the f acility in accordance with this proposed change involve a signifiennt increase in the probability or consequences of any accident previously evaluated?

Response No.

The heatern play no functional roic in Limitorque actuator operation. ,

Because disconnecting compartment heatera does not change any MOV safety role, the probability and consequences of all accidents remains as before.

Therefore, the proposed change will not involve a significant increase in the probability or consequences of any accident previously evaluated.

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2. Will operation of the facility in accordance with this proposed change  ;

create the possibility of a new or different kind of accident from any l accident previously evaluated?  !

Response: No.

The MOV compartment hes .rs protect the internals from condensation during storage in uncontrolled atmospheres and extended periods of no maintenance or inspection. Valves and their operators installed in various plant systems receive regular maintenance. Disconnecting in-service valve operator heaters eliminates a failure mode identified at plant Vogtle. Limitorque clearly states that the motor operator i IEEE qualification tests were successful without using heaters.

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Therefore, the proposed change will not create the possibility of a i new or different kind of accident from any accident previously evaluated.

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3. Will operation of the facility in accordance with this proposed change involve a significant reduction in a margin of safety?

Response: No.

Specification 3/4.8.4 intends to limit potential damage to conductors internal to electrical penetration assemblies. The role of SI-331A, SI-331B, SI-332A, and SI-332B remain unchanged by disconnecting compartment heaters. The heater usefulness manifests only during i valve storage. LCO 3.8.4.1 allows de-energized circuits instead of -t primary and backup overcurrent protection.

Therefore, the proposed change will not involve a significant reduction in a margin of safety.

The Commission has provided guidance concerning the application of ,

standards for determining whether a significant hazards consideration exists by providing certain examples (48 FR 14870) of amendments that are considered not likely to involve significant hazards considerations.  ;

(vii) A change to make a license conform to change in the regulations, I where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

Disconnecting MOV compartment heaters addresses an NRC concern raised in Inforeation Notice 86-71. A disconnected circuit legitimately protects the conductors of electrical penetrations (re LCO 3.8.4.1). Furthermore, the qualification of the Limitorque operators did not credit heater operation.

The heaters provide no safety-related functions; they do not help to open, close, or maintain control of the associated valve. The regulatory intent for protected electrical penetrations and qualified valve operators remains unchanged.

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j Safety and Significant Hazards Determination Based on the above Safety Analysis, it is concluded that: (1) tbt proposed change does not constitute a aignificant hazards consideration as defined by 10CFR50.92: and (2) there is a reasonable assurance that the health and safety of the public will not be endangered by the proposed change; and (3) t'-Is actica will not result in a condition which significantly alters the impact cf the station on the environment as described in the NRC Final Environmental Statement.

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