ML20133H176

Provides Response & Schedule for Satisfying 10CFR50.62(d) Requirements Re Atws.Justification for Implementing Generic Design After Second Refueling Outage Given

ML20133H176
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/11/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Office of Nuclear Reactor Regulation
References
GL-85-06, GL-85-6, TAC-59152, NUDOCS 8510160299
Download: ML20133H176 (3)

Text

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r - Ell PortlandGeneralElectricCoiryniy Bart D Whys Vce Presaivt October 11, 1985 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Sir:

Response to 10 CFR 50.62(d)

Section 50.62(d) of the ATWS rule requires that each licensee develop and submit a proposed schedule for meeting the requirement of the rule within 180 days after issuance of the QA guidance for nonsafety-related ATWS equipment. The QA guidance was issued as Generic Letter 85-06 on Apell 16, 1985. This letter provides Portland General Electric Company's (PGE) response to the subject requirement.

The Trojan Nuclear Plant utilizes a Westinghouse pressurized water reactor and, as such, is required to meet Paragraph (c)(1) of 10 CFR 50.62. PGE is a member of the Westinghouse Owners Group (WOG) and a participant in the AMSAC Generic Design Program (AMSAC is an acronym for ATWS Mitigating System Actuation Circuitry). Accordingly, PGE proposes to implement the requirements of 10 CFR 50.62(c)(1) by implementing one of the three con-ceptual designs identified in WCAP-10858, "AMSAC Generic Design Package".

This design package was sent by the WOG to the NRC for its review and approval on July 25, 1985.

It is PGE's understanding that the NRC intends to issue generic design crl-teria for ATWS equipment in October of 1985 and a Safety Evaluation Report (SER) on the AMSAC Generic Design Package in November of 1985. On the basis of these dates and other factors discussed below, PGE proposes to implement A*e. SAC by December 31, 1987 in accordance with the attached schedule. As this date is later than the second refueling outage after July 26, 1984 (which would be July 1986 for Trojan), the following justifi-cation is provided per 10 CFR 50.62(d):

1. Detailed design of AMSAC cannot begin until after the NRC issues an SER on the AMSAC Generic Design Package (WCAP-10858). PGE will need to evaluate the impact of the SER on each of the designs described in WCAP-10858 in order to determine which logic is best suited for Trojan.

8510160299 851011 f-PDR ADOCK 05000344 0 P PINT i b g \

121 s W Sa' mon Street. Poord Oregon G 7204

PbrutuxiM BechicC0iiptaiy Director of Nuclear Reactor Regulation October 11, 1985 Page 2 Based on an SER being issued in November, detailed design cannot com-mence at least until January 1986 after the SER impact has been evalu-ated and a conceptual design selected. This date also assumes that NRC review comments do not invalidate preliminary design work to date.

2. Procurement lead time for AMSAC hardware requirements is estimated at 8 to 12 months. Because the procurement process cannot begin until the detailed design is developed, AN3AC implementation will not be possible to achieve during the April-July 1986 refueling outage.

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3. PGE estimates that 18 to 24 months is necessary to implement AMSAC.

This is based on the attached schedule which, in addition to reflecting the duration of design, procurement, and construction activities, i includes allowances for system startup testing and checkouts, procedure updating, and operator training. The schedule also depends on the conceptual design solected. For example, Logic 3 (in WCAP-10858) is estimated to take three to four months longer to implement than Logics 1 or 2 because of the additional design complexity and hardware required.

It should be noted that the attached schedule is predicated in part on

! receiving NRC approval of WCAP-10858 by the end of 1985. Any significant delay of NRC approval beyond that time will impact the attached schedule.

I PGE requests NRC concurrence with the proposed schedule for AMSAC imple-mentation at Trojan and will be pleased to discuss it with you as needed.

Sincerely, Bart D. Withers

! Vice President Nuclear c: Mr. Lynn Frank, Director State of Oregon 4 Department of Energy Mr. John B. Martin Regional Administrator, Region V U.S. Nuclear Regulatory Commission

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TROJAN NUCLEAR PLANT EaE S

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9/1/85 . . 1/1/86 . . 4/1/86 . . . . 1/1/87 . . 4/1/87 . . . 9/1/87 . . 12/1/87 Preliminary Engineering l l -

6 NRC Approval (SER Issued) l Evaluate SER Impact l l Detailed Engineering l l Material Procurement l l Construction l l Final Implementation Complete l 12/31/87 N R3 EoA

$ 5' S 8"8 E I2 o DRS/kal G 15 0490W $l*