ML20137Y582

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Forwards Response to Encl 2 of Generic Ltr 85-02 Re Steam Generator Tube Integrity.Mod to Existing Steam Generator Integrity Tech Specs Re Category 2 Steam Generators Unnecessary
ML20137Y582
Person / Time
Site: Trojan File:Portland General Electric icon.png
Issue date: 10/02/1985
From: Withers B
PORTLAND GENERAL ELECTRIC CO.
To: Thompson H
Office of Nuclear Reactor Regulation
References
GL-85-02, GL-85-2, TAC-58097, NUDOCS 8510080041
Download: ML20137Y582 (3)


Text

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Portland General ElectricCompany

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Bart D Wens Vce Presdert October 2, 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:

Steam Generator Tube Integrity Generic Letter 85-02 Our letter of June 14, 1985 provided a partial response to Generic Letter 85-02.

Attached is our response to Enclosure 2 of the Generic Letter. This letter completes our response on this issue.

Sincerely, 2

1 Bart D. Withers Vice President Nuclear Attachment c:

Mr. Lynn Frank, Director State of Oregon Department of Energy 8[

8510080041 851002 PDR ADOCK 05000344

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tu Trojan Nuclear Plant Mr. Hugh L. Thompson Docket 50-344 October 2, 1985 License NPF-1 Attachment Page 1 of 2 REQUEST FOR INFORMATION CONCERNING CATEGORY C-2 NRC Request The enclosed draft NUREG-0844, Section 2.2.1.2 describes certain limita-tions which the staff believes to be inherent in the present Technical Specification steam generator ISI requirements pertaining to Category C-2 inspection results. Licensees and applicants are requested to provide description of their current policy and actions relative to this issue and any recommendations they have concerning how existing Technical Specification steam generator ISI requirements pertaining to Category C-2 inspection results could be improved to better ensure that adequate inspections will be performed. This description should include a 3'

response to the following questions:

1.

What factors do, or would, the licensee or applicant consider in determining:

(a) whether additional tubes should be inspected beyond what is required by the Technical Specifications, (b) whether all steam generators should be included in the inspection program, and (c) when the steam generator should be reinspected.

I 2.

To what extent do these factors include consideration of the degrada-tion mechanism itself and its potential for causing a tube to be vulnerable to rupture during severe transients or postulated acci-dents before rupture or leakage of the tube occurs during normal operation?

I PGE Response PGE dces not recommend any changes to the current Technical Specification requirements relative to actions to be taken if a steam generator is classified as Category C-2.

Technical Specifications need not be the motivating factor to ensure steam generator tube integrity is adequately monitored.

Economic considerations alone stand as the motivating factor for licensees to closely nonitor their steam generators.

PCE is currently performing inservice inspections of steam generator tubes at a rate far in excess of that required by the Technical Specif1-cations. These inspections are being performed because it is in our best interest to closely monitor steam generator tube integrity. Close monitoring of this integrity allows us to take timely action to avoid unnecessary shutdowns and to postpone or avoid steam generator replace-ment during the life of the Plant.

These inspections enable us to monitor the rate of change of indications in number and magnitude from previous examinations. Based on the number and nature of the indications, addi'lonal inspections and corrective

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Trojan Nuclear Plant Mr. Hugh L. Thompson Docket 50-344 October 2, 1985 License NPF-1 Attachment Page 2 of 2 actions are determined.

An inspection is not considered complete until there is good assurance that no significant problems remain undetected in any of the steam generators which would be vulnerable to rupture during severe transients or postulated accidents. For those reasons, PGE does not believe it is necessary to modify the existing steam generator integrity Technical Specifications regarding Category C-2 steam generators.

SAB/kal 0457W.1085