ML19318A584

Forwards Response to NRC Re Implementation of Five Addl TMI-2 Related Action Items

ML19318A584
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/16/1980
From:	Goodwin C PORTLAND GENERAL ELECTRIC CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
TASK-***, TASK-1.A.1.3, TASK-1.A.3.1, TASK-1.C.5, TASK-2.K.3.01, TASK-2.K.3.02, TASK-2.K.3.03, TASK-2.K.3.05, TASK-2.K.3.09, TASK-2.K.3.10, TASK-2.K.3.12, TASK-2.K.3.25, TASK-2.K.3.29, TASK-2.K.3.44, TASK-TM TAC-44132, TAC-45253, TAC-45299, TAC-45385, TAC-45416, TAC-45465, TAC-45495, TAC-45525, TAC-45672, TAC-45868, TAC-46486, TAC-47258, TAC-48209, TAC-48436, NUDOCS 8006230409
Download: ML19318A584 (5)

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3b June 16, 1980 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. D. G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.

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Dear Sir:

On May 7, 1980, you issued a letter to all operating nuclear plants regarding implementation of five additional TMI-2-related action items and requested our commitment to meet these requirements and associated schedules.

We have reviewed your request and its implication to Trojan and provide the attached information as a response to your letter. The attached information describes current Trojan plant design and constitutes a PGE commitment for implementation of the NRC requirements.

It is our understanding, through the Westinghouse Owner's Group, that Items II.K.3.25, II.K.3.29 ar.d II.K.3.44 are applicable only to BWR plants, although they were addressed to PWR plants in your May 7, 1980 letter.

Sincerely, C. Goodwin, Jr.

Assistant Vice President Thermal Plant Operation and Maintenance CG/KM/4sa5B9 1

Attachment c:

Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing U. S. Nuclear Regulatory Commission Mr. R. H. Engelken, Director p \\\\

U. S.-Nuclear Regulatory Commission h

Region V Mr. Lynn' Frank, Director State of Oregon Department of Energy 80062 3 0k

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i ATTACHMENT 1 i

PGE Response to the May 7, 1980 NRC Letter Regarding Five Additional TMI-2-Related Requirements Item I. A.1.3 - Shift Manning:

We are currently planning to comply with the new requirer.ent of shift i

manning. However, to date, we have not received the NRC letter of clarification on this item which was promised in the May 7,1980 NRC letter. _ Therefore, our commitment on this item will be provided as soon as necessary information on the NRC requirement is received and reviewed by PGE.

Item I. A.J.1 - Revise Scope and Criteria for Licensing Examinations:

A review of.the Trojan plant operator training program had been initiated to include the new examination criteria and scopes as requested in the NRC letters of March 28 and May 7, 1980.

It is expected that the NRC requirement will be implemented in accordance with the associated schedule.

4 Item I.C.S. - Procedure for Feedback of Operating i

Experience to Plant Staff:

Appropriate Trojan plant administrative procedures will be reviewed and revised to ensure that significant operating experience originating within and outside Trojan is provided to operators and other operations I

personnel.

It is anticipated that this action will be implemented by i

January 1, 1981.

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- Item II.K.3.1 - Automatic PORV Isolation System:

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At the present *.ime, we do not agree that an automatic PORV isolation system should be cmquired. The intensity of a number of plant transients is reduced by proper operation of the PORV system and this function could I

be impaired by a failure of the proposed automatic isolation system.

In addition, the TMI short-term actions already implemented on PORVs in accordance with NUREG-0578 will ensure that the intended function of the automatic ' isolation system will be effectively provided by operator action.

Furthermore, failure to isolate stuck-open PORVs has been 4

analyzed and documented in WCAP-9600 and no possible core uncovery was identified.

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However. in accordance with the requirement under Item II.K.3.2 below, we will continue to review the necessity of any improvement to decrease the probability of a small-break LOCA caused by a stuck-open PORV.

Item II.K.3.2 --PORY Failure Report:

A report on PORV. failure reduction will be submitted to the NRC by January-1, 1981 which is consistent with the NRC schedule.

It is cur-

. rently anticipated that this report will be in the form of a generic

- Westinghouse Owner's Group submittal.

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Item II.K.3.3

. Reporting Safety and Relief Valve Failures and Challenges:

We intend to implement the NRC requirement of reporting or documentation

-for future failure / challenge to the pressurizer relief and safety valves.

The implementation ~ of this action is expected to be by January 1,1981.

Item II.K.3.5 - Automatic Trip of Reactor Coolant Pumos During LOCA:

In the PGE response of August 29, 1979 to IE Bulletin 79-06C, we refer-enced the Westinghouse analysis of delayed RCP trip during a small-break LOCA documunted in WCAP-9584. This Westinghouse analysis is the basis for the Westinghouse Owner's Croup (WOG) position on RCP trip (i.e.,

sufficient time is available at a Westinghouse PRW for manual tripping of the RCPs). This philosophy has been incorporated in the Westinghouse emergency instruction guidelines which were reviewed and approved by the NRC Bulletins and Orders Task Force.

These NRC approved guidelines were subsequently used as a basis for preparation of the Trojan plant Emergency Operating Instructions.

Currently, the only continued analysis work in this area is the pretest predictions of the LOFT Test L3-6 which were discussed at the May 22, 1980 meeting between WOG and the NRC. The NRC has indicated that small-break tests at the semiscale and LOFT facilities as well as the WOG test predictions will aid in the NRC resolution on this issue. Therefore, we belicve that it is not appropriate to take any additional actions on this issue until the results of the NRC-sponsored testing (in particular, L3-1 and L3-6) and the WOG predictions are completed and the results evaluated.

While we agree with the WOG position that an automatic trip is not needed, we are actively exploring the feasibility of installing an interim desig.t for automatic RCP trip in the interest of providing additional assurance that the RCPs will be tripped before ICC conditions are approached.

It should also be noted that due to the NRC requirement in IE Bulletin 79-06C, we have had to add an additional man to the control room staff solely for the RCP trip function. We de not believe this represents effective usage of Plant Operations personnel, which provides further incentive to explore whether this function could be accomplished by an automatic RCP trip.

Item II.K.3.9 - Proportional Integral Derivative (PID)

Controller Modification:

In June 1979, as a response (LCA 54) to IE Bulletin 79-06A, the engi-neered safeguard features actuation logic in the pressurizer was modi-fied from the coincident low level and low pressure actuation to a two-out-of-three actuation on low pressure alone. This modification also included a removal of the derivative action from the PID controller and the revised PORV interlock bistable setpoint of 2350 psia which satisfy the Westinghouse-recommended change to the PID controller as described i

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T' in the NRC letter dated May 7, 1980.

Therefore, Trojan is already in compliance with Item II.K.3.9 and no additional action is required.

Item II.K.3.10 - Proposed Anticipatory Trip Modification:

Trojan neither has proposed nor is currently planning to increase the power level for the anticipatory reactor trip upon turbine trip.

This item, thus, is not applicable to Trojan and requires no action.

Item II.K.3.12 - Confirm Existence of Anticipatory Trip Upon Turbine Trip:

The Trojan plant design already incorporates an anticipatory reactor trip on turbine trip and is in conformance with the NRC requirements.

Thus, no action is required on this item.

Item II.K.3.17 - Report on Outage of ECC Systems:

We will review the outage history of ECC systems for the last 5 yr. and provide a report to the NRC by January 1, 1981 in accordance with the NRC requirements.

Items II.K.3 25 - Loss of AC Power on Pump Seals, II.K.3.29 - Performance of Isolation Condensers With Noncondensables II.K.3.44 - Anticipated Transients With Single Failure to Verify No Fuel Failure:

It has been confirmed with the NRC, through Westinghouse Owner's Group Chairman Cordell Reed, that these three items were addressed to BWR plants and that no action is necessary on PWR plants.

It is our under-standing that the NRC will issue a letter of clarification in this regard.

Item II.K.3.30 - Revised Small-Break LOCA Methods to Show Compliance With 10 CFR 50, Appendix K:

It is our belief that the present Westinghouse small-break evaluation model used to analyze the Trojan plant is in conformance with 10 CFR 50, Appendix K.

However, Westinghouse has indicated that they will,-nevertheless, address the specific NRC items contained in NUREG-0611 in a model change which is scheduled for completion by January 1, 1981.

Item II.K.3.31 - Plant-Specific Calculation to Show Compliance With 10 CFR 50.46:

The present Westinghouse small-break evaluation model and small-break LOCA analyses for the Trojan plant are in compliance with 10 CFR Part 50, Appendix K and 10 CFR 50.46.

As stated in the response to Item II.K.3.30, Westinghouse plans to submit a new small-break evaluation model to the NRC fo review by January 1, 1982.

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.o If the results of this new Westinghouse model (and subsequent review and approval) indicate that the present small-break LOCA analysis for the Trojan plant is not in conformance with 10 CFR 50.46, a new analysis utilizing the new and approved Westinghouse model will be submitted to the NRC in accordance with the NRC schedule.

Item III.D.3.4 - Control Room Habitability:

We will perform an evaluation of the control room habitability at the Trojan plant to identify appropriate modifications, if any, to meet the NRC requirements.

It is currently anticipated that the evaluation will be completed by January 1, 1981 in order to meet the NRC schedule of January 1983 for completion of the identified modifications.

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