ML20211C722

Forwards Addl Info on Actions Taken & Actions Planned Re Generic Ltr 83-28,Items 3.1.3 & 3.2.3

ML20211C722
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/13/1986
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
GL-83-28, TAC-53052, TAC-53891, NUDOCS 8610220009
Download: ML20211C722 (3)

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~se PDitliMid Gelieral M h But O Wohcts Vce Presdent October 13, 1986 Trojan Nuclear Plant Docket 50-344 License NPF-1 Director of Nuclear Reactor Regulation ATTN: Mr. Steven A. Varga Director PWR-A Project Directorate No. 3 U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Sir:

PGE Response to Request for Additional Information Relating to Generic Letter 83-28 In response to recent concerns verbally expressed by the NRC staff, additional information is provided concerning Generic Letter 83-28 (Required Actions Based on Generic Implications of Salem ATWS). Attachment A provides information on actions PGE has taken. or is planning to take, pertaining to NRC Positions 3.1.3 and 3.2.3.

Sincerely, y ,2 _

Bart D. Withers Vice President Nuclear Attachment subscribed and sworn to before me this 13th day of October 1986.

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. Tr@jtn Nuclcze Plant Mr. Stavrn A. Vcrgs Dockst 50-344 Octcbar 13, 1986 License NPF-1 Attachment A Page 1 of 2 PGE ACTIONS RELATED TO NRC GENERIC LETTER 83-28 POSITIONS 3.1.3 AND 3.2.3 Generic Letter 83-28, Positions 3.1.3 (Reactor Trip System) and 3.2.3 (All Other Safety-Related Components) states, " Licensees and applicants shall identify, if applicable, any post-maintenance test requirements in existing Technical Specifications which are perceived to degrade rather than enhance safety. Appropriate changes to these test requirements, with supporting justification, shall be submitted for staff approval."

The NRC staff has requested additional information in regard to specific action being taken by PGE related to this issue.

In a PGE letter dated November 4, 1983 (B. D. Withers to D. G. Eisenhut),

no changes to Technical Specifications were proposed. PGE indicated its participation in the Westinghouse Owners Group (WOG) efforts and our support of J. M. Sniezek's Task Force and their work. Subsequently, we have determined that, while identifying testing that degrades rather than enhances safety is an important issue, it exists as a subtask of an overall Technical Specification Improvement Program (TSIP). PGE is actively involved in the AIF, various Owners Groups, and NRC efforts in this area. PCE has performed a systematic revies of the Trojan Technical Specifications and identified several areas in which improvements could be made. The criteria of Positions 3.1.3 and 3.2.3 are considered when proposing Technical Specification changes. Examples of Technical Specification amendments received, and License Change Applications.(LCAs) either submitted to the NRC, or being processed internally, or planned for the future, are as follows:

Amendments Received i 104 - Clarified Channel Functional Test to ensure pressurizer PORVs are properly tested.

l 107 - Reduced the frequency of diesel generator testing and allow the engine to be warmed up for most tests before increasing speed.

! 115 - Increased allowed outage time to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for diagnosis and I repair, for the case where one or more control rods are electrically inoperable.

LCAs Submitted i 117, Revision 2 - Reduces the frequency of Reactor Protection System I surveillance from monthly to quarterly.

l 142 - Reduces the frequency of Control Room Emergency Ventilation System l

(CB-1) testing.

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. TrajIn Nuclerr Plant Mr. Stavin A. Virgs Dock 3t 50-344 Octob r 13, 1986 License NPF-1 Attachment A Page 1 of 2 LCAs in Progress 1 - Proposes Containment isolation valve testing in modes other than 5 or 6 to eliminate duplicate testing.

2 - Increases pressurizer and main steam safety valve tolerance to preclude testing all the valves when one valve fails to meet current lift tolerance.

LCAs Planned 1 - Reduces the frequency of Emergency Safety Features Actuation System surveillance from monthly to quarterly.

As can be seen, PGE is actively involved in the improvement of Trojan Technical Specifications and is considering surveillance requirements '

that degrade safety as a major factor in the process. It is believed these actions satisfy the requirements of Positions 3.1.3 and 3.2.3.

DRP/kal 0811P.1086

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