ML20127P512

Forwards Response to 850502 Generic Ltr 85-07 Requesting Completion of Survey on Implementation of Integrated Schedules for Plant Mods.Completed Survey Form Encl

ML20127P512
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	06/28/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Thompson H Office of Nuclear Reactor Regulation
References
GL-85-07, GL-85-7, NUDOCS 8507020437
Download: ML20127P512 (4)

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-E Bart D W4hers Vce Presdyt June 28, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. Hugh L. Thompson, Jr., Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Mr. Thompson:

Implementation of Integrated Schedules for Plant Modifications Generic Letter 85-07 Generic Letter 85-07 dated May 2, 1985 requested our completion of a survey on implementation of integrated schedules for Plant modifications provided as Enclosure 2 to that letter. Attached is our response to Generic Letter 85-07, the completed survey form, and its attachment.

We would like to emphasize that we appreciate the significance of long-term planning and scheduling, and that the integration of~ regulatory require-ments into our schedule for design modifications is an important aspect of our program. We appreciate the cooperation received from the NRC in sched-uling regulatory requirements in a manner that allows us to adequately integrate their implementation into our long-term plan.

Sincerely, Bart D. Withers Vice President Nuclear Attachment c: Lynn Frank, Director State of Oregon Department of Energy g7020437850628 p ADOCK 05000344 PDR

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121 S W Saon Street Potand, Oregon 97204

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• ENCLOSURE 2 RESPONSE FORMAT - GENERIC LETTER 85-07 PLANT NAME: Troj an Nuclear Plant UTILITY: Portland General Electric Company ,

t I. INTENTIONS A. Intend to work with the staff to develop an ILS B. Have reservations that must be resolved before developing ILS C. Do not presently intend to negotiate an ILS with the staff xx D. Plan to implement an infomal ILS only xx II. STATUS A. If you answered I.A above:

( Have you settled on a method for prioritizing 1.

the work at your plant (s)?

Circle One: Yes No If yes, select best description:

Engineering judgement Analytic Hiearchy process .

, Risk based analysis Cost-benefit analysis Other (please describe)

If no, provide estimated date for selecting a methodology:

Date or If not presently available, provide estimated date for scheduling the selection of a methodology:

2. What is your estimated date for making a

( submittal to the NRC-or If not presently available, planned date for scheduling a submittal to the NRC

B. If you answered I.B above: .

)

1. Please explain your reservations on separate sheet (s) '

or provide your schedule for supplying an explanation See separate sheet (s) or Separate submittal scheduled for (Date)

2. If available to meet with the staff to discuss your concerns, propose a time frame for such a meeting and provide a contact that can make arrangements Contact / Time Frame Phone Number C. If you answered I.C

1. Would you be willing to meet with the staff to discuss the development of an ILS for your facility (s)?

Circle One: Yes )

If yes, propose a time frame for such a meeting and provide a contact that can rake arrangements.

Contact Time Frame Phone Number If no, any constructive comments you have would be appreciated.

See attached page III. ADDITIONAL ITEMS

.Please make any suggestions you may have as to how a utility sponsored availability / reliability project might be credited for plant safety enhancement. Provide additional constructive comments as appropriate.

See response to II.C. on attached page L

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Attachment to Enclosure to NRC Generic Letter 85-07 INTECRATED SCHEDULES FOR PLANT MODIFICATIONS PGE has reviewed Amendment 91 to the Duane Arnold Energy Center (DAEC) operating license and has incorporated applicable concepts from Generic Letter 83-20 in our long-term plan. Although PGE has been scheduling modifications and changes to the Trojan Nuclear Plant since construc-tion, it is only recently that the plan has been extended to encompass five years. PGE prefers to keep this plan for design modifications to the Trojan Nuclear Plant informal and flexible. We feel it is important to have an internal long-range plan of this nature that permits optimum utilization of resources without further regulatory involvement.

Approximately 65 percent of the design modifications currently included in PGE's long-term plan are neither safety-related nor regulatory commit-ments. Therefore, they would not be subject to NRC review or considera-tion. It is felt inappropriate to separate those that are safety-related or commitments and subject to additional restrictions from those that are not, since manpower and financial planning processes require us to con-sider all of the design' modifications. Also, the prioritization system developed for the long-term plan is such that those modifications that have safety significance are performed in a timely manner.

Notwithstanding the above, we appreciate the cooperative effort that exists between the NRC and PGE in scheduling completion dates for NRC-required modifications. It is this cooperation that allows us to develop our long-term plan for design modifications and efficiently use our resources. We encourage the continuance of this cooperation.

GAZ/3kal 0944G.685