ML20204F441
| ML20204F441 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 07/22/1986 |
| From: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| TAC-61405, TPT-175, NUDOCS 8608040188 | |
| Download: ML20204F441 (48) | |
Text
, .
t JNFORM ATION
' C0PY PORTLAND GENERAL ELECTRIC COMPANY TROJAN NUCLEAR PLANT July 18, 1986 QUALITY RELATED Revision 0 TEMPORARY PLANT TEST - TPT-175 RCS Thermal ansion Long-Teria Monitoring APPROVED BY: DATE: 9 F d PROJECTED TEST INTERVAL July 1986 to July 1988 or Five Heat-up/Cooldowns (Whichever Comes Sooner)
PURPOSE AND OBJECTIVES This temporary plant test provides instructions for data collection and evaluation to ensure that the Reactor Coolant System is not experiencing any undue restraint to free thermal expansion or contraction during heat-up, initial power operation, and cooldown. Execution of this test fulfills the NRC directive contained in their letter of June 16, 1986.
STATUS
- 1. Partially complete, distribute data as indicated below.
- 2. Test complete. Distribute data as indicated below.
- 3. All testing complete. Delete TPT from PON and distribute data as indicated below.
- 4. Corsnents:
Applicable Deviations:
Submit this page and all data to Technical Services Secretary Date Logged DISTRIBUTION - Completed:
Date/ Initial
- 1. Cognizant Engineer: M. W. Hoffmann
- 2. Planner / Scheduler (cover sheet only)
- 3. Procedure Clerk (cover sheet only)
- 4. Others (indicate work group): Nuclear Plant Engineering
- 5. Q-File 83.3c (original)
T0264b TPT-175 - Cover Page 1 of 2 Revision 0 e60sO401ee e60 m PDR ADOCK 05000344 /1 P PDR k/ \
s RCS THERMAL EXPANSION LONG-TERM MONITORING REFERENCES
- NRC Letter, Varga (NRR) to Withers (PGE) dated June 16, 1986.
= TPT-166, Reactor Coolant System Thermal Expansion Test (June 1986).
- See Section 12.0 for other references.
COGNIZANT SUPERVISOR The cognizant supervisor is the Nuclear Plant Engineering Branch Manager, Mechanical Engineering, or his designee. See Section 4.0.
PREREQUISITES See Section 5.0.
LIMITATIONS AND PRECAUTIONS See Section 5.0.
SPECIAL EQUIPMENT AND MATERIAL See Section 6.0 and Appendix B.
TEST METHOD AND INSTRUCTIONS See Section 7.0.
j ACCEPTANCE CRITERIA See Section 8.0.
DISPOSITION See Section 9.0 for data disposition and Section 10.0 'or reporting. The completed test, including data sheets, shall be forwarJed to the cognizant supervisor for review. Closeout of TPT-175 shall be in accordance with Section 11.0 of the procedure.
T0264b TPT-175 - Cover Page 2 of 2 Revision 0 i
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RCS THERMAL EXPANSION LONG-TERM MONITORING RCS THERMAL EXPANSION LONG-TERM MONITORING TPT-175 i
i TROJAN NUCLEAR PLANT i
I July 1986 I
l TPT-175, Rev. O Page 1 of 27
RCS THERMAL EXPANSION LONG-TERM MONITORING
- 1. PURPOSE AND OBJECTIVES
- 2. TEST INTERVAL
- 3. DISCUSSION
3.1 BACKGROUND
3.2 1986 REFUELING OUTAGE ACTIVITY 3.3 RESPONSIBILITIES 3.4 PROCEDURE PHILOSOPHY
- 4. PERSONNEL
- 5. PREREQUISITES, LIMITATIONS, AND PRECAUTIONS
- 6. SPECIAL EQUIPMENT AND MATERIALS
- 7. TEST METHODS AND INSTRUCTIONS
- 8. ACCEPTANCE CRITERIA
- 9. DISPOSITION i
l 10. REPORTING
- 11. PROCEDURE CLOSE-0UT
- 12. REFERENCES P
l APPENDIX A - NRC Letter Dated June 16, 1986 APPENDIX B - Description of Special Test Equipment, Materials, and Initial Verification Data for TPT-166 Monitoring Devices APPENDIX C - Data Sheets APPENDIX D - Data Evaluation Form l
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l TPT-175, Rev. O Page 2 of 27
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RCS THERMAL EXPANSION LONG-TERM NONITORING 1.0 PURPOSE AND OBJECTIVES This temporary plant test provides instructions for data collection and evaluation to ensure that the Reactor Coolant System is not experiencing any undue restraint to free thermal expansion or contraction during heat-up, initial power operation, and cooldown. Execution of this procedure fulfills the NRC directive contained in their letter of June 16, 1986.
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TPT-175, Rev. O Page 3 of 27 l
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RCS THERMAL EXPANSION LONG-TERM MONITORING 2.0 TEST INTERVAL i
a This test shall be conducted during any Reactor Coolant System cooldown, heat-up, and subsequent initial power operation unless collection of data is precluded when prudent action prior to a cooldown calls for less than five days response time or when access to Containment is unavailable.
The projected applicability period is from July 1986 through July 1988.
If five monitored Reactor Coolant System heat-ups/cooldowns occur sooner l than July 1988, closeout of this procedure may be considered at that I
time, i
l TPT-175, Rev. O Page 4 of 27
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RCS THERMAL EIPANSION c LONG-TERM NONITORING 3.0 DISCUSSION
3.1 Background
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During the 198S and 1986 Refueling Outages, several conditions were discovered which either suggested or confirmed that normal free thermal expansion of the Reactor Coolant System had been impeded.
Most noticeably:
i (a) Functional testing of the steam generator hydraulic snubbers demonstrated failure to meet established acceptance criteria 4
and it was postulated that their as-found condition, under I
certain circumstances the occurrence of which has never been confirmed, could prevent free therinal movement of the steam generators.
(b) Graphite shims in the RCS hot-les whip restraints were found crushed or in contact with the RCS pipe or both. Original construction criteria had called for a hot gap "not to exceed 1/10 in." The discovery of the damaged shims indicated (1) that the original gap may have been improperly set; and/or (2) that rotation (ie, tilting about the vertical axis) of the
- steam generators may have occurred due to restrained RCS l thermal expansion.
(c) Cold gaps at various RCS supports and restraints were I determined on the basis of physical measurement to be inadequate for accomr.odating system normal thermal expansion, j In particular, gaps at the steam generator upper support ring ;
j guides and lower support ring guides and bumpers were a
i determined to be undersized.
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'l TPT-175, Rev. O Page 5 of 27 I
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RCS THERMAL EXPANSION LONG-TERM MONITORING i
i (d) An engineering analysis performed in an attempt to determine the cause of unexpected pressurizer surge line motion showed that locked steam generator snubbers or unusual restraint at the upper support ring may have occurred.
1 These issues were addressed by PGE Nuclear Plant Engineering and its various consultants during the 1986 Refueling Outage. In a June 16, 1986 letter (see Appendix A) acknowledging that matters had been satisfactorily addressed to permit plant startup, the Nuclear Regulatory Commission (NRC) imposed several requirements including the following:
I "The future monitoring activities [ie, following completion of work during the 1986 Outage under TPT-166]
will be an extension of the ongoing RCS monitoring program, and will verify the expected movements and behavior of the RCS, and the adequacy of the corrective measures applied. . . . Provide NRR and Region V with I
periodic reports of the results of the monitoring program during startups, power operations, and cooldowns. In j addition, prior to termination of the monitoring program, i PGE will advise NRR and Region V of its proposed decision
- and their reasons thereof."
This temporary plant test is intended to ensure that these requirements are met.
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j 3.2 1986 Refueling Outage Activity After corrective action was taken to repair / modify the steam generator hydraulic snubbers and to reset gaps for RCS restraints.
Temporary Plant Test TPT-166 was prepared to confirm that undue restriction to RCS free thermal expansion was not occurring during TPT-175, Rev. O J
Page 6 of 27 i
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9 RCS THERMAL EXPANSION LONG-TERM MONITORING the initial heat-up and return to power. Most test activity involved manual measurements. However, remote reading instruments were installed at several locations to permit measurements to be taken during power operation. These included:
(a) Linear variable differential transformers (LVDTs) were mounted under the RCS hot leg on the hot-les whip restraint. One LVDT was installed per loop. These devices measured the vertical displacement of the pipe during heat-up and were used to ensure that the pipe did not come into co~ tact during any mode of operation with the hot-les whip restraint.
(b) Linear potentiometers (LPs) were mounted on the steam generator upper support ring. Two LPs were installed per generator - one to measure the vertical displacement and one to measure horizontal displacement. Both are physically located between the two upper snubbers and the two lower snubbers such that there is a direct correlation between LP indication and snubber movement. For TPT-175, only the LPs which measure horizontal displacement will be used.
Recording devices were temporarily installed in the Containment i Building. Device power supplies were connected and calibrated before data was taken. They were not left inside Containment because high temperature conditions for extended periods could result in equipment deterioration.
3.3 Responsibilities
[ 3.3.1 The Nuclear Plant Engineering Branch (NPE) Manager, On-Site Engineering, is responsible for data collection and initial data evaluation. He is also responsible for forwarding TPT-175, Rev. O Page 7 of 27 l
RCS THERMAL EXPANSION LONG-TERM MONITORING data to the NPE Branch Manager, Mechanical Engineering. He is designated as the " cognizant engineer" for this TPT as noted in Paragraph 4.2.
3.3.2 The NPE Branch Manager, Mechanical Engineering, is responsible for final disposition of all data and initiation of corrective action in the event of an unacceptable condition. He or his designee also has
" cognizant supervisor" responsibility for this TPT as noted in Paragraph 4.1.
3.3.3 The Manager, Operations and Maintenance, or his designee has the responsibility to give at least five days' notice to the NPE Branch Manager, On-Site Engineering, for any plant cooldown, heat-up, and initial power operation.
3.3.4 The Manager, Nuclear Safety and Regulation Department, or his designee has the responsibility to provide reports to the NRC of the results of this monitoring program (refer to Paragraph 10.3).
3.4 Procedure Philosophy Only the steam generator hydraulle snubbers can degrade in such a way so as to result in unacceptable conditions during Reactor Coolant System thermal expansion or contraction. Settings for restraint gaps cannot change, and their acceptability was confirmed during the execution of TPT-166 in June 1986. Therefore, only data which would indicate that the snubbers failed to function properly will be collected and evaluated in accordance with this TPT.
TPT-175, Rev. O Page 8 of 27
RCS THERMAL EXPANSION LONG-TERM NONITORING 4.0 PERSONNEL 4.1 The cognizant supervisor is the NPE Branch Manager, Mechanical Engineering, or his designee. As of the date of Revision 0 of this TPT, these individuals are:
Name Office Phone Home Phone
, Branch Manager Bob Fowler 220-3253 293-1547 1st Designee Rodger Wehage 226-8039 282-2069
- 2nd Designee Chris Dieterle 226-8041 644-7322 4.2 The cognizant engineer is the NPE Branch Manager, On-Site Engineering, or his designee. As of the date of Revision 0 of this TPT, these individuals are
Name Office Phone Home Phone Branch Manager Mark Hoffmann 345 543-6224 1st Designee (To be provided later) 4.3 The cognizant engineer and his designee shall be certified as l
I Level II Testers in accordance with QAP-11-2.
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- TPT-175, Rev. 0 Page 9 of 27
RCS THERMAL EXPANSION LONG-TERM MONITORING 5.0 PREREQUISITES LIMITATIONS. AND PRECAUTIONS 5.1 Before any heat-up and subsequent return to power operation prior to which personnel activities were conducted in the vicinity of the LVDTs or LPs, visually inspect the LVDTs and LPs to ensure no apparent damage has occurred during the current outage. This inspection should be performed after personnel activity has been completed in that area, but early enough to make repsirs without impacting plant startup.
5.2 Data collection may require a Containment entry during RCS heat-up and/or power operation. Secure the necessary approvals, notify operations personnel, and take the usual precautions for Containment entry.
5.3 If required, obtain radiation work permit (RWP) prior to Containment entry.
5.4 In the event that an LVDT or LP fails, manual naasurements shall be taken using the reference tabs installed for TPT-166. Instructions are provided in Paragraph 7.4.8. Provisions of Paragraph 6.6 also apply.
5.5 When heating up or cooling down the plant, data shall be collected at 340*F i 10*F. Also, during heatup, data is collected at hot standby (557'F i 10*F). The RCS temperature shall be held at these points until the data has been evaluated and approval given by the cognizant engineer or cognizant supervisor to proceed. See Section 9.0.
5.6 Before data is collected, verify that all required equipment calibrations have been performed in accordance with Paragraph 6.7.
I TPT-175. Rev. O Page 10 of 27
RCS THERMAL EXPANSION LONG-TERM MONITORING 6.0 SPECIAL EQUIPMENT AND MATERIALS 6.1 Linear variable differential transformers (LVDTs) (see Appendix B).
6.2 Linear potentiometers (LPs) (see Appendix B).
6.3 Data recorders (see Appendix B).
6.4 Digital Calipers If manual measurements at the system generator upper ring tabs or the hot-leg whip restraint tabs are to be taken (see Paragraph 7.4.8), digital calipers shall be used. Approved devices i are: Mitutoyo, Model No. 500-115 or Mitutoyo, Model No. 505-637.
Alternate devices may be used if approved by the cognizant engineer
- or nognizant supervisor.
6.5 Tem orary Modifications 6.5.1 TM-060 was used to install the LVDTs and LPs as well as j metal reference tabs on the steam generator upper rings and
! the hot-leg whip restraints used for manual measurements.
6.5.2 TM-063 was used to install the power supply for the data recorders.
l 6.6 Equipment Failures i
j If any instrument (ie, LVDT or LP) fails while in service, the condition shall be documented on the Appendix C data sheet, and the device shall be repaired during the next scheduled refueling
! TPT-175. Rev. O Page 11 of 27 i
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RCS THERMAL EXPANSION LONG-TERM MONITORING outage. See Paragraph 5.4 for alternative data collection requirements and Paragraph 7.4.8 for alternative data collection instructions.
6.7 Calibration Checks 6.7.1 Calibration checks shall be performed annually during the refueling outage prior to the start of heat-up.
6.7.2 Digital Calipers The digital calipers shall be calculated in accordance with Procedure MP-3-1, 6.7.3 LVDTs The LVDT calibration check shall be performed by inserting a metal slip of known thickness (approximately 100-mils thickness recommended) between the probe roller and the RCS pipe. Recorder output shall be within i 5 mils of the slip thickness.
CAUTION: If the LVDT is removed or physically disturbed, recalibration of the secondary slug positioning shall be performed in acccedance with Schaevitz Engineering Instruction Manual ATA-101.
6.7.4 LPs l The LP calibration check shall be performed by displacing the lanyard a known distance and comparing with the recorder indication. Indication shall be within 15 percent of the displacement.
TPT-175. Rev. O Page 12 of 27
RCS THERMAL EXPANSION LONG-TERM MONITORING 7.0 TEST METHODS AND INSTRUCTIONS 7.1 The Manager, Operations and Maintenance, or the shift supervisor shall contact the NPE Branch Manager, On-Site Engineering, at least five days in advance of any plant cooldown, heat-up, and initial power operation, unless access to Containment is unavailable. If either five days' notice cannot be given or Containment access is unavailable (see Paragraph 7.4.8), the NPE Branch Manager, On-Site Engineering, shall be informed by phone (or in person) and he shall document this condition by telecon or memo, copy to the NPE Branch Manager, Mechanical Engineering.
7.2 Upon proper " prior" notification, the NPE Branch Manager, On-Site Engineering, shall assign an electrical engineer or technician from the NPE On-Site Branch (herein referred to as the " data collector")
to collect data remotely from the LVDTs and LPs. If an individual within the on-site NPE Engineering Branch is unavailable, an alternate who has been instructed in the use of the recording devices may also be used as follows: (a) Electrical engineer or technician from NPEEB; or (b) nonelectrical engineer or technician from NPE.
7.3 The cognizant engineer shall easure that the recording devices have been installed inside Containment and properly connected.
7.4 Using data sheets contained in Appendix C, the following information shall be recorded:
7.4.1 Date and time of data collection.
7.4.2 Name and title of the data collector.
TPT-175, Rev. O Page 13 of 27
s RCS THERMAL EXPANSION LONG-TERM MONITORING 7.4.3 Plant condition (ie, cooldown, heat-up, or initial plant operation).
7.4.4 Circumstances for the change in plant condition (eg, forced outage or normal refueling. outage). If a forced outage, the nature of the problem shall be recorded.
7.4.5 For plant cooldown:
s (a) At power operation or hot standby condition:
3 (1) LVDT readings (all four loops).
(2) LP readings (horizontal device only for all four 4
loops).
(3) Plant conditions /RCS temperature (for power operation - record Tg,Teold' "" ave I for hot standby - record only T,y,).
(b) At RCS T,y, = 340*F i 10*F:
f (1) LVDT readings (all four loops).
l (2) LP readings (horizontal device only for all four loops).
l j (3) RCS temperature (T,y,).
(c) At cold conditions (within three days of reaching cold l conditions, but no sooner than three hours after reaching a stable temperature):
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(1) LVDT readings (all four loops).
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l TPT-175, Rev. O l
Page 14 of 27
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x s RCS THERMAL EXPANSION
- LONG-TERM MONITORING (2) LP readings (horizontal device only for all four loops).
-(3) RCS temperature (T,y,).
7.4.6 For plant heat-up:
4 (a) At cold conditions (as close before start of heat-up as reasonable).
(1) LVDT readings (all four loops).
(2) LP readings (horizontal device only for all four i
loops).
(3) RCS temperature (T,y,).
1 (b) At RCS T,y, = 340*F 10*F:
(1) LVDT readings (all four loops).
4 (2) LP readings (horizontal device only for all four loops).
(3) RCS temperature (T,y,).
(c) At hot standby conditions (no sooner than one hour after reaching T,y, which equals 557'F i 10*F).
s (1) LVDT readings (all four loops).
i (2) LP readings (horizontal device only for all four loops),
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! TPT-175, Rev. O Page 15 of 27
RCS THERMAL EXPANSION I
LONG-TERM MONITORING (3) RCS temperature (T, ,).
7.4.7 For initial power operation:
(a) " Initial power cperation" is defined herein as no later than the first 15-day period after power operation has commenced from a cold shutdown.
(b) With the plant in initial power operation period:
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(1) IVDTs (all four loops)
(2) LP readings (horizontal device only for all four loops)
(3) Reactor power level (4) RCS temperature: 7 ,T cold' ave' 7.4.8 If data cannot be collected using the LVDTs and LPs, the following action shall be taken:
(a) For plant cooldown for which lesi'than five days' notice could be given because prudent action called for less response time and there is simply insufficient time to install the necessary recorders and power supplies, (1) Manual measurements shall be taken (at suberitical conditions only) at the reference tabs on the steam generator upper support rings and at the reference tabs (vertical direction only) on the HLPWRs mounted next to the LVDTs installed for TPT-166; and TPT-175, Rev. O Page 16 of 27 i
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RCS THERMAL EXPANSION LONG-TERM MONITORING (2) Data shall be taken in accordance with 7.4.5(C) and shall be compared with the last available corresponding LVDT and LP data. The time limitation of 7.4.5(C) may be waived if equipment repair and/or recalibration is necessary.
(b) For plant cooldowns when Containment access is unavailable, data shall be collected in accordance with Paragraph 7.4.8(a)(2) above.
(c) For times when LVDTs or LPs are inoperable and the reactor is suberitical, substitute data in lieu of LVDT and LP readings shall be taken in accordance with Paragraph 7.4.8(a) above.
7.5 Once data has been collected, action shall be taken in accordance with Sections 9.0 and 10.0.
TPT-175 Rev. O Page 17 of 27
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RCS THERMAL EXPANSION LONG-TERM MONITORIdG !
t 8.0 ACCEPTANCE CRITERIA l l i
8.1 LVDTs on the Hot-Leg Whip Restraints l
A. The movement from cold to 340*F i 10*F (or vice versa) shall fall within the below range:
- 1. Loop A: 90 i 40 mils
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- 2. Loop B: 90 40 mils l l
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- 3. Loop C: 90 t 40 mils I
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- 4. Loop D: 100 1 40 mils B. The movement from 340*F i 10*F to hot standby conditions (or vice versa) shall fall within the below range:
1 j 1. Loop A: 80 1 40 mils I
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- 2. Loop B: 80 i 40 mils 1
- 3. Loop C: 80 t 40 mils
- 4. Loop D: 90 t 40 mils C. The movement from cold to hot standby conditions (or vice versa) shall fall within the below ranges:
- 1. Loop A: 170 i 40 mils.
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- 2. Loop B: 170 i 40 mils.
TPT-175, Rev. 0 ,
Page 18 of 27 i
RCS THERMAL EXPANSION LONG-TERM MONITORING j
l 3. Loop C: 170 1 40 mils.
- 4. Loop D: 190 1 40 mils.
D. The movement from cold conditions to power operation (or vice j versa) shall fall within the below ranges:
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- 1. Loop A: 185 i 40 mils.
- 2. Loop B: 185 + 45/-65 mils.
- 3. Loop C: 185 i 65 mils.
- 4. Loop D
- 210 + 20/-90 mils.
l 8.2 LPs on the Upper Steam Generator Support Ring A. The movement from cold to 340*F i 10*F (or vice versa) shall fall within the below range:
l 1. Loop A: 0.4 t 0.3 in.
- 2. Loop B: 0.5 i 0.3 in.
- 3. Loop C: 0.6 1 0.3 in..
- 4. Loop D: 0.4 1 0.3 in.
B. The movement from 340*F 10*F to hot standby conditions (or vise versa) shall fall with the below range:
- 1. Loop A: 0.9 i 0.3 in.
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TPT-175 Rev. O Page 19 of 27 l
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e l RCS THERMAL EXPANSION
! LONG-TERM MONITORING l
l 2. Loop B: 1.0 i 0.3 in.
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! 3. Loop C: 0.9 1 0.3 in..
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f 4. Loop D: 0.9 i 0.3 in.
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l j C. The movement from cold to hot standby conditions (or vice
! versa) shall fall within the below ranges:
f 1. Loop A: 1.3 i 0.3 in.
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! 2. Loop B: 1.5 1 0.3 in.
j 3. Loop C: 1.5 i 0.3 in.
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j 4. Loop D: 1.3 1 0.3 in.
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l D. The movement from cold condition to power operation (or vice versa) shall fall within the below range:
- 1. Loop A: 1.4 1 0.3 in.
- 2. Loop B: 1.7 1 0.3 in.
- 3. Loop C: 1.7 i 0.3 in.
- 4. Loop D: 1.5 i 0.3 in.
TPT-175, Rev. O Page 20 of 27
RCS THERMAL EXPANSION i LONG-TERM MONITORING 8.3 General Notes 8.3.1 Hot-leg whip restraint LVDTs.
l 8.3.1.1 Data for measured gap clearances under cold conditions and pipe movemer.t data from TPT-166 were used to establish an allowable movement
! range. Readings from Shim 11 to Shim 30 were used since this is the most relevant region. The range is intended to ensure the hot-leg whip restraint gap stays in the Westinghouse-specified range of 0 in to 0.13 in, during power operation.
8.3.1.2 Plus tolerances are based on movement that would nominally indicate that contact is starting to occur somewhere between Shims 11 to 30.
Observations made in June 1986 indicate incipient contact at Shim 12 on Loop D. This is not considered significant since it is not in direct l line with the direction of' pipe movement.
There. fore, an additional 20 mils for this LVDT above what otherwise might be indicated by the l
Shim 12 gap has been allowed.
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h-I 8.3.1.3 Minus tolerances are based on readings which would indicate that the maximum allowable gap of 0.13 in, at 100 percent power had been closed.
Based on review of the data for measured gap clearances, it has been determined that the average effective gap is approximately 0.25 in.
between Shims 11 through 30 on all four loops.
Tolerances established herein permit a maximum TPT-175, Rev. O I Page 21 of 27
_,,,-7,., ,_.----y , , _ , - - - - _ , , , , - - _ - _ . , _ _ . , , - - -
RCS THERMAL EXPANSION LONG-TERM MONITORING pipe displacement of: Loop A - 0.225 in.; {
Loop B - 0.230 in.; Loop C - 0.250 in.; and Loop D - 0.230 in.
8.3.2 Steam Generator LPs i
4 8.3.2.1 Only the horizontal direction LPs will be monitored. This is sufficient to verify that the snubbers are operating properly.
8.3.2.2 Readings that fall within the indicated tolerances warrant no further action. Readings falling outside of indicated tolerances are not necessarily unacceptable, but do warrant further evaluation (see Far. tion 9.0).
I 8.3.2.3 Variations in readings should not be unexpected.
Steam generator diameter variations occur due to changes in pressure and temperature, which affect j the position of the steam generator within the I support ring. This can affect the position of the ring and, thereby, the potentiometer readings.
Other variations in readings can occur depending on whether the steam generator is pushing outward, pulling inward, or centered within the ring at the moment readings are taken and whether or not any rocking or position shifting has occurred due to contact between the ring girder and lateral supports.
6 TPT-175, Rev. O Page 22 of 27
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RCS THERMAL EXPANSION I LONG-TERM MONITORING 8.3.3 Temperature Considerations l t
j Acceptance criteria have been established based on actual measurements taken during June 1986 under TPT-166. Obviously, these " baseline" measurements l are directly related to the RCS temperature at the time the data was collected. It is understood that, due to plant operational considerations, l
collection of data in the future will not i
necessarily be at exactly the same temperature as before, especially for " cold" conditions (ie, cold
! RCS conditions may be anywhere from 80*F to 200*F). The acceptance criteria tolerances hopefully will accommodate this variation.
However, it should be understood that further i adjustments may be necessary during data evaluation to account for higher or lower than
! anticipated temperatures. These " adjustments" will be documented using the Appendix D form in accordance with Section 9.0.
k TPT-175, Rev. O Page 23 of 27
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RCS THERNAL EXPANSION LONG-TERN NONITORING 9.0 DISPOSITION 1
9.1 Cognizant Engineer Evaluation i
i The cognizant engineer shall review the data and compare it with the Section 8.0 acceptance criteria, using the Appendix D form to document the evaluation. The original of the completed form shall be sent to the cognizant supervisor for further action.
, 9.2 Apparently Unacceptable Data l
i If any data falls outside the range of acceptability, the matter shall immediately bo referred (ie, by telephone and/or telecopy) to the cognizant supervisor for disposition. If the initial data review indicates that an unacceptable plant condition exists, the I
cognizant supervisor shall take action in accordance with Nuclear Division procedures. Plant Procedure A0-6-3 may be used for i
guidance.
9.3 HOLDS During Heatup and Cooldown Operations personnel shall hold RCS temperature at 340*F i 10*F for either heatup or cooldown and at 557*F i 10*F for heatup until approval is given to proceed. This approval shall be conununicated to the shift supervisor by the cognizant engineer if data falls within the Section 8.0 range of acceptability or by the cognizant supervisor if apparently unacceptable data (see Paragraph 9.2 above) is identified.
9.4 Completion of Data Evaluation The cognizant supervisor shall complete the d:t evaluation form and process the form in accordance with Section 10.0.
TPT-175 Rev. O Page 24 of 27
RCS THERMAL EXPANSION LONG-TERM MONITORING 10.0 REPORTING 10.1 General Completed data sheets and data evaluation forms shall be processed in accordance with A0-3-15.
10.2 Unacceptable Conditions If an unacceptable plant condition is identified, it shall be documented, reported, and dispositioned in accordance with applicable Nuclear Division Procedures. A0-6-3 may be used for guidance.
10.3 Long-Term Reporting As required by NRC Letter of June 16, 1986 (see Appendix A),
periodic reports of the results of the monitoring program shall be filed with the NRC. The reports shall be sent promptly (ie, within 30 days) if an unacceptable plant condition is identified.
Otherwise, reports shall be sent no less frequently than once per year.
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( TPT-175, Rev. O Page 25 of 27
4 RCS THERMAL EXPANSION LONG-TERM MONITORING 11.0 PROCEDURE CLOSEOUT 11.1 This procedure shall not be closed until:
11.1.1 The General Manager, Trojan, and the General Manager, Technical Functions, agree that an adequate track record has been established which demonstrates that past problems causing limitatieis in the free RCS thermal expansion have been resolved; and 11.1.2 PGE advises NRR and Region V of its intent to terminate the Monitoring Program and the reasons why PGE is justified in such termination; and 11.1.3 PGE receives concurrence from the NRC that the Monitoring Program may be terminated.
11.2 Final procedure disposition shall be in accordance with A0-3-15.
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i TPT-175, Rev. O Page 26 of 27 i
RCS THERMAL EXPANSION LONG-TERM MONITORING
12.0 REFERENCES
12.1 TPT-166 Reactor Coolant System Thermal Expansion Test (June 1986).
12.2 NRC Letter, Varga (NRR) to Withers (PGE) dated June 16, 1986 (see Appendix A).
12.3 A0-3-15. Temporary Procedures.
12.4 A0-6-3, Anomalous Indication During Periodic Surveillance.
12.5 QAP-11-2, Qualification of Testing Personnel.
12.6 MP-3-1, Calibration of Maintenance Equipment.
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TPT-175, Rev. O Page 27 of 27 i
RCS THERMAL EXPANSION LONG-TERM MONITORING APPENDIX A NRC Letter Dated June 16, 1986 i
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TPT-175, Rev. O Page 1 of 4
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- k UNITED STATES
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- June 16, 1986 .'i.'.'! l 91985 Route To: -
Docket No. 50-344 Mr. Bart D. Withers Vice President Nuclear Portland General Electric Company 121 S.W. Salmon Street Portland, Oregon 97204
Dear Mr. Withers:
By letter dated June 5, 1986, the staff concluded that adequate assurance regarding the integrity of the Reactor Coolant System (RCS) had been demonstrated to permit Trojan to proceed to Mode 3, Hot Standby. The staff also requested that affimation by the Bechtel Corporation of the general conclusions of the RCS stress analyses, certification by PGE that the results of the thermal expansion monitoring program are acceptable, and submission of the actual monitoring results, be submitted to the staff prior to criticality.
This information was provided to us by letters dated June 6, 13 and 16, 1986.
We have completed our review of the Impell analysis and the Bechtel Corporation's Interim Report of the Independent Review, and have received PGE's certification of the monitoring program results. We conclude that PGE has adequately addressed the technical and programmatic aspects of the cause and effects of restrained thermal growth of the RCS, the necessary corrective actions, and future monitoring activities to verify resolution of this issue.
The future monitoring activities will be an extension of the ongoing RCS monitoring program, and will verify the expected movements and behavior of the RCS, and the adequacy of the corrective measures applied. To enhance your monitoring program however, the staff requests that four considerations be incorporated:
! (1) Provide an assessment of the impact of using carbon steels shims in lieu of graphite shims. The assessment shall consider the potential impact of the shims on the RCS pressure boundary in the event of future contact l
between the shims and the hot leg.
- (2) Provide NRR and Region V with periodic reports of results of the
! monitoring program during startups, power operations, and cooldowns. In addition, prior to termination of the monitoring program, PGE will advise NRR and Region V of its proposed decision and their reasons thereof.
(3) During the next cycle, perform the surveillance in Trojan Technical Specification 4.4.6.2.1.a & b, RCS leakage monitoring of containment atmosphere particulate radioactivity and containment sump inventory and discharge, at least twice a shift as committed to by your letter dated June 13, 1986.
Copies to: Withers, Yundt, Lentsch, Orser, Steele, E. Burton, E. Jordan, A. Holm, LIS, C. A. Olmstead, S. Hoag, S. Sautter, TNP: GOV REL F:NRC CHRONO, S. Bauer, i G. Zimmerman, R. Fosse (Bechtel), W. Bak (Impell), R. Wehage, J. Misko (West)
PGE Action - R. L. Steele Items 1, 2, 4 Item 1 Due 9/20/86 Item 3 Due 6/13/86 R. P. Schmitt Item 3 Item 2 Due 7/20/96 Item 4 Due 7/1/87
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(4) During the next refueling outage, perform additional examinations of the RCS Loop B hot leg elbow to ensure that small cracks have not been initiated in the interior surface.
Our Safety Evaluation regarding restrained thermal growth is enclosed as Attachment 1.
We have also completed our review of the revised control room habitability (III.D.3.4) analysis dated June 4, 1986, and conclude that the doses calculated utilizing the Trojan plant specific assumptions of the control room ventilation system's operational configuration and parameters, meet the acceptance criteria of General Design Criterion 19, and that PGE has embarked upon a program which will sianificantly improve the quality of the Trojan control room ventilation system and the control room envelope. We will continue to monitor the progress of PGE commitments toward the completion of NUREG-0737 TMI Action Plan Item III.D.3.4, Control Room Habitability. Our Safety Evaluation on this topic is ,
enclosed as Attachment 2.
Based on the above, we conclude that the issues of restrained thermal growth of the RCS, and control room habitability have been adequately addressed.
Thus, Trojan may proceed to Mode 1, Power Operatit .
I n . brg;t c PWR Project Direct 3 Division of PWR Lice g-A, NRR l
Enclosures:
j
! As stated 9
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i TPT-17f
Mr. Bart D. Withers Portland General Eletric Company Trojan Nuclear Plant ec:
Senior Resident Inspector U.S. Nuclear Regulatory Commission Trojan Nuclear Plant Post Office Box 0 Rainier, Oregon 97048 Robert M. Hunt, Chairman Board of County Commissioners Columbia County St. Helens, Oregon 97501 William T. Dixon Oregon Department of Energy Labor and Industries Building Room 111 Salem, Oregon 97310 Regional Administrator, Region V U.S. Nuclear Regulatory Commission Office of Executive Director for Operations 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 4
TFT-175
RCS THERMAL EXPANSION LONG-TERM MONITORING l
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I APPENDIX B !
SPECIAL TEST EQUIPMENT, MATERIALS l ,
! AND, INITIAL VERIFICATION DATA FOR TPT-166 MONITORING DEVICES I
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NOTE: This Appendix is not intended to be a calibration procedure.
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I l TPT-175, Rev. 0 l Page 1 of 8 i
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RCS THERMAL EXPANSION LONG-TERM MONITORING I. Linear Potentiometers (LPs)
A. Vendor Calibration Factor SGA - Vert 185.87 mV/V/in. Model PT101 0005 111-1110 SGA - Horiz 187.96 mV/V/in. Model PT101 0005 111-1110 SGA - VerL 188.50 mV/V/in. Model PT101 SA SGA - Horiz 191.26 mV/V/in. Model PT101 SA SGA - Vert 187.62 mV/V/in. Model PT101 0005 111-1110 SGA - Horiz 189.26 mV/V/in. Model PT101 5A SGA - Vert 188.12 mV/V/in. Model PT101 SA SGA - Horiz 189.88 mV/V/in. Model PT101 0005 111-1110 NOTE: Difference in model number is due to new stock / inventory identification scheme recently implemented by vendor (Celesco Transducer Products, Inc.) for computer compatibility.
B. Power Supply (PS) Data Output voltage as measured with Fluke meter, PGE No. 8805, calibrated February 13, 1986 during initial calibration:
SG A-V: 12.08 Vdc SG C-V: 12.09 Vdc SG A-H: 12.08 Vdc SG C-H: 12.10 Vdc SG B-V: 12.06 Vdc SG D-V: 12.10 Vdc SG B-H: 12.08 Vdc SG D-H: 12.04 Vdc All power supplies are factory set with 0.5 percent regulation. All LPs are calibrated at the factory to l 0.5 percent accuracy for measuring 0-in. to 5-in. linear i
displacement. This vendor calibration is sufficient for purposes of this installation.
l C. Initial Calibration Check Procedure and Results Span: 0-in. to 5-in, displacement to correspond to 0-Vps (Calibration factor) volts or approximately 0 to 12 V.
A spare potentiometer transducer and power supply were used to
) verify accuracy.
Calibration factor: 188.18 mV/V/in.
Displacement: 5 in.
PS voltage: 12.08 Vde, 0.5 percent regulation TPT-175 Rev. 0 Page 2 of 8 l
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l RCS THERMAL EXPANSION LONG-TERM MONITORING C. Initial Calibration Check Procedure and Results (continued) 0 in. = 0 V 5 in. = 5(12.08)(.18818) = 11.37 Vdc l
' Using a standard tape measure to measure displacement, the following was observed:
Displacement Voltate Difference Measured Calculated AV %
0 in. 0.006 0.000 +0.006 0.6 1 in. 2.261 2.273 -0.012 0.53 i
2 in. 4.540 4.546 -0.006 0.13 3 in. 6.890 6.820 +0.070 1.03 4 in. 9.200 9.093 +0.117 1.29 5 in. 11.540 11.366 +0.174 1.53 5.25 in. 12.090 11.934 +0.026 0.22 (Max)
' Maximum deviation observed was 1.53 percent. This is greater than the factory specification for the LP only. However, it is acceptable as the method used to complete this verification had inherent inaccuracies (eg, inaccurate use of a standard tape measure, power supply inaccuracies, and fluke reading inaccuracies). Thus, the observed results were acceptable since they were a calibration check to verify proper operation only.
II. Linear Variable Differential Transformers (LVDTs)
A. Vendor Calibration Information Ser. Pri. Exc. Output Catalog Sens.
Location No. Voltate 0 0.5 in. mV/V/.001 in.
RCS Hot Les A 162 3.0 @ 2.5 kHz 699 mV 0.4 mV RCS Hot Leg B 165 3.0 @ 2.5 kHz 734 mV 0.4 mV RCS Hot Leg
- 157 3.0 0 2.5 kHz 710 mV 0.4 mV RCS Hot Les
- 159 3.0 @ 2.5 kHz 679 mV 0.4 mV TPT-175, Rev. O Page 3 of 8
RCS THERMAL EXPANSION LONG-TERM MONITORING A. Vendor Calibration Information (continued)
All units are nuclear /high-temperature devices manufactured by Schaevitz Engineering; Range 1 0.500 in., i 0.5% linearity, Model No. 500KS-ZTR.
- Loop on which Serial Nos. 157 and 159 were installed and not recorded.
B. LVDT Sianal Conditioner Schaevitz Model ATA-101 Primary Excitation - 3.5 Vrms, 9 2.5 kHz (Vps) for following ranges of secondary voltages: 500 mVrms - 4.5 Vrms (Internally adjustable 200 mVrms - 1.8 Vrms gain) 125 mVrms - 1.125 Vrms 50 mVrms - 0.45 Vrms Output Signal -10 Vdc to + 10 Vdc C. Calibration Each LVDT and signal conditioner set was calibrated as follows:
- Gain Selection - (.4 mV/V/.001 in.)(3.5Vps)(500) = 700 mV (per ATA-101 Therefore, factory setting usable.
installation (Catalogue sensitivity) (V (max manucl) displacement from 0 mils) pg) t l
. - Zero Adjustment -
1 Each LVDT was initially set up with its respective core in the approximate center of the LVDT. From this position, the signal conditioner was zero-adjusted, as outlined following the instructions in the ATA-101 Installation Manucl.
i Finer adjustment of each LVDT's null-point was then calculated according to the indicated readings.
Mechanical adjustments were made as necessary.
- Span and Phase -
[
' Span and phase adjustments were made from the front of the signal conditioner to optimize itsioutput and provide a scaled output between -10Vdc and +10Vdc. The ATA-101 TPT-175 Rev. O Page 4 of 8
- RCS THERMAL EXPANSION LONG-TERM MONITORING C. Calibration (continued) l Installation Manual was again utilized; 500 and 250 mil
. shims were used to aid this step.
Final calibration checks were made by temporarily I installing 500 mil and 105 mil shims between the RCS hot-leg pipe and the LVDT plunger.
The table below documents i.he final zero points for the i four LVDTs and indicates the final calibration checks.
All values reflect final signal scaling necessary to
! indicate actual displacement (ie, in mils).
! Zero LVDT Initial With 105 mil Shim Error Final Repeatability Zero Point Cale. Indicated (Note 1) Zero Point (Note 2)
I RCS-A 44 mils 149 rlls 147 mils 0.4% 42 mils 0.4%
RCS-B -2 mils 103 mils 99 mils 0.8% -1 mils 0.2%
l RCS-C -2 mils 103 mils 102 mils 0.2% 0 mils 0.4%
RCS-D 71 mils 176 mils 176 mils 0.0% 69 mils 0.6%
NOTE 1: Error is calculated by subtracting indicated measurement i from the esiculated measurement and dividing by the l maxinuun scale, ie, d -d l eale ind 500 mils NOIE 2: Drift in the zero repeatability is attributed to machining tolerances in the LVDT plunger mechanism and imperfection in the RCS piping surface. These are very minor with respect to actual physical sizes and the measurements to be obtained.
Each input signal is individually progranned to provide individualized signal scaling necessary to display each channel in actual engineering units. In addition, the zone of the chart in which any signal appears is progranmed to be proportional to the engineering units. See Section III.C of the appendix for more j information.
I TPT-175. Rev. O !
Page 5 of 8
4 RCS THERMAL EXPANSION LONG-TERM MONITORING III. 30 Pin Chart Recorder A. Vendor Calibration Data 30-channel, rack-mount hybrid recorder, Yokogawa Model 4081, display in six-color pins.
Inputs - t 20 mVdc to i 50 Vdc.
B. Calibration Setup
- 1. Channel Assianment Steam Generator A - Vertical Displacement - CH 01 (Purple)
Upper Support Ring - Horizontal Displacement - CH 02 (Red)
Steam Generator B - Vertical Displacement - CH 03 (Green)
Upper Support Ring - Horizontal Displacement - CH 04 (Blue)
Steam Generator C - Vertical Displacement - CH 05 (Brown)
Upper Support Ring - Horizontal Displacement - CH 06 (Black)
Steam Generator D - Vertical Displacement - CH 07 (Purple) l Upper Support Ring - Horizontal Displacement - CH 08 (Red)
I RCS Hot-Leg Whip - Vertical Displacement - CH 09 (Green)
Restraint Loop A RCS Hot-Leg Whip - Vertical Displacement - CH 10 (Blue)
Restraint Loop B t
RCS Hot-Leg Whip - Vertical Displacement - CH 11 (Brown)
- Restraint Loop C f
RCS Hot-Leg Whip - Vertical Displacement - CH 12 (Black)
} Restraint Loop D I
- 2. Channel Calibration i
Power supplies for the LPs are rated at + 12 Vde; signal conditioners for the LVDTs have an output of t 10 Vdc.
Therefore, all channels are set on the i 20-V range (ie, the smallest inclusive range), with provision for scaling.
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I TPT-175, Rev. O Page 6 of 8 I
l__._...,.,__,,_._,_.-,_.. , , _ . . , _ , _ . . _ . _ _ . , _ - , , _ _ . _ _ . _ _ - - ,
RCS THERMAL EXPANSION l
LONG-TERM MONITORING l Channels 1 through 12 are scaled as follows:
CHANNEL SCALE Ranze For Input Voltage (Notes 1. 2) 1 0-5 in. 0 - 11.225 V 2 0-5 in. 0 - 11.355 V
, 3 0-5 in. 0 - 11.365 V 4 0-5 in. 0 - 11.550 V 1
5 0-5 in. 0 - 11.340 V 6 0-5 in. 0 - 11.450 V F 7 0-5 in. 0 - 11.380 V 8 0-5 in. 0 - 11.430 V 9 -500 - +500 mils -10V - +10V 10 -500 - +500 mils -10V - +10V 11 -500 - +500 mils -10V - +10V 12 -500 - +500 mils -10V - +10V 1
n NOTE 1: Maximum voltage for Channels 1 - 8 is derived by multiplying the LP calibration factor times power supply voltage times the maximum LP displacement or:
l' (Kcal)(Vps)(5 in.) = Vscale (See Section III.I for more information.)
NOTE 2: Voltage limits for Channels 9 through 12 wee adjusted during the calibration of the LVDTs, signal conditioners, and recorders as listed in Section II of this apper. dix and in Vendor Manual ATA-101.
C. Analom Data Presentation l
Each pin can be programmed to print it analog data in any predetermined zone on the chart. ,
The chart is 10-in. wide (250 mm). For this application, the l following zones are used.
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TPT-175 Rev. O Page 7 of 8 l
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l GENERAL CHART RECORDER DEF:
CHANNEL DISPLAY ZONE SIZE AREA ACTUAL MVT l 01 0-5 in. (127m) Left Half 1:1 02 0-5 in. (127m) Left Half 1:1 03- 0-5 in. (127m) Left Half 1:1 04 0-5 in. (127m) Left Half 1:1 05 5-10 in. (127m) Right Half 1:1 06 5-10 in. (127m) Right Half 1:1 07 5-10 in. (127m) Right Half 1:1 08 5-10 in. (127m) Right Half 1:1 09 0-10 in. (250m) Full Chart 10:1 10 0-10 in. (250m) Full Chart 10:1 11 0-10 in. (250m) Full Chart 10:1 12 0-10 in. (250m) Full Chart 10:1 l
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RJW/MGCmr 2648C TPT-175, Rev. O Page 8 of 8
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RCS THERMAL EXPANSION LONG-TERM MONITORING .
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APPENDIX C Data Sheets i
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TPT-175, Rev. O Page 1 of 3
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RCS THERMAL EXPANSION LONG-TERM MONITORING APPENDIX C DATA COLLECTION LOG i Data Collection Plant i Sequence Number Condition Description of Circumstances i
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i NOTE: Sequence number shall be in "86-1-A" format where "86" is the year, "1" is the heatup/cooldown event and "A" is the data collection point.
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TPT-175-DS-1 TPT-175, Rev. O f Page 2 of 3
RCS THERMAL EXPANSION _
LONG-TERM MONITORING Sequence No. APPENDIX C DATA COLLECTION SHEET Date/ Time /
Name/ Title /
of Data Print Collector __ ,s Signature ;
Plant Condition:
l__l Cooldown l__l Heatup l__l Initial Power Operatio.1 Circumstances for change in plant condition:
\
l__l Forced Outage l_l Refueling Outage l_l Other Explanation i
Plant Status l((l Operating (PowerLevel %) l"[lHotStandby l((l340*Fi10*F l(([l Cold RCS Temperature i i
THot *F TCold *F TAve *F L
Instrument Readings l__l OR Manual Measurementes l__l l l
LOOP LVDT (mils)* (inches)* (inches)**
A B
C l D I
- If instruments are unavailable, substitute manual tab measurements per TPT-175, Paragraph 7.4.8. Record digital j caliper Serial No. .
- LP (VERT) readings are for REFERENCE ONLY.
TPT-175-DS-2 TPT-175, Rev. O Page 3 of 3
\
't RCS THERMAL EXPANSION LONG-TERM MONITORING
\- Sequence No. APPENDIX C DATA COLLECTION SHEET Date/ Time /
Name/ Title /
of Data Print Collector
' Signature l Plant Condition:
l__l Cooldown l__l Heatup l__l Initial Power Operation l
Circumstances for change in plant condition:
l l Forced Outage l_l Refueling Outage l[lOther j Explanation Plant Status l((l Operating (PowerLevel %) l((lHotStandby l((l340*Fi10*F l((l Cold RCS Temperature THot *F TCold *F TAve *F Instrument Readings l__l OR Manual Measurementes l__l LP (HOR) LP (VER)
LOOP LVDT (mils)* (inches)* (inches)**
l B C
D
- If instruments are unavailable, substitute manual tab measurements per TPT-175, Paragraph 7.4.8. Record digital caliper Serial No. .
- LP (VERT) readings are for REFERENCE ONLY.
i TPT-175-DS-2 TPT-175. Rev. O Page 3 of 3
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LONG-TERM MONITORING
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l APPENDIX D Data Evaluation Form l
TPT-175, Rev. O Page 1 of 2
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LONG-TERM MONITORING APPENDIX D f.
- Sequence No.
DATA EVALUATION SHEET I. Cognizant Engineer Evaluation Does the collected data fall within the range of acceptability listed in Section 8.0 of TPT-175?
YES l l For Paragraph 9.3 HOLD points, notify shift supervisor.
Person Notified Date/ Time NO l[l If NO, data out of range:
If NO, inform the Cognizant Supervisor as soon as possible:
Person Notified Date/ Time BY:
l Cognizant Engin er / /
Print Signature Date II. Cognizant Supervisor Evaluation Does the collected data fall within the range of acceptability listed in Section 8.0 of TPT-175?
YESl[l NO l[l If NO, data out of range:
Evaluation Final Disposition: Acceptable l[l Unacceptable l[l Action Taken BY:
Cognizant Supervisor / /
Print Signature Date TPT-175-DS-3 TPT-175. Rev. O Page 2 of 2
_ _ _ _ _ _ _ _ l
e dCENED icO
- muumm M
-- E, isas r 24 m 1:rm Bart D Wahers Vce Presdert July 22, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. John B. Martin Regional Administrator Region V 1450 Maria Lane, Suite 210 Creekside Oaks Office Park
( U.S. Nuclear Regulatory Commission l
Walnut Creek CA 94596-5368
Dear Mr. Martin:
TROJAN NUCLEAR PLANT Reactor Coolant System Thermal Expansion Monitoring Our letter of June 26, 1986 indicated the continuing thermal monitoring program for the Reactor Coolant System was in the development process.
The procedure is now complete and a copy is attached for your infccmation.
Sincerely, Bart . Withers Vice President Nuclear l Attachment c: Mr. Steven A. Varga Director, PWR-A Project Directorate No. 3 Mr. Lynn Frank, Director State of Oregon Department of Energy JE O/
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121 SW Sa! mon Street. Port'and. Oregon 97204 L
.