ML20210G249
| ML20210G249 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 09/23/1986 |
| From: | Chan T Office of Nuclear Reactor Regulation |
| To: | Withers B PORTLAND GENERAL ELECTRIC CO. |
| References | |
| GL-85-09, GL-85-9, TAC-53201, TAC-55383, NUDOCS 8609250364 | |
| Download: ML20210G249 (6) | |
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S;ptemb:r 23, 1986 DISTRIBUTION Docket No. 50-344 Docket File:
J. Partloe NRC PDR N. Thompson Local PDR T. Chan T. Novak C. Vogan Mr. Bart D. Withers PD#3 Rdg.
ACRS (10)
Vice President S. Varga R. Ballard Portland General Electric Company OGC 121 S.W. Salmon Street E. Jordan Portland, Oregon 97204 B. Grimes
Dear Mr. Withers:
SUBJECT:
GENERIC LETTER 85-09 AND ITEM 4.3 0F GENERIC LETTER 83-28 By letter dated October 30, 1985, you stated that it was Portland General Electric (PGE's) intention to follow the Westinghouse Owners Group (WOG) recommendation with respect to Technical Specification (TS) requirements for reactor trip breaker maintenance and surveillance practices, and bypass breaker testing. More specifically, the WOG was proposing to:
1.
Not include bypass breaker testing in the Technical Specifications as recommended by NRC Generic Letter 85-09, 2.
Adopt the remaining Generic letter 85-09 surveillance test requirements and allowable outage times as interim test requirements, and 3.
Administratively control the interim requirements in 2., above, without Technical Specification changes until the requirements can be optimally determined by the trip breaker reliability model on which the WOG is now working.
The staff has reviewed the WOG recommendation, and concludes that they are unacceptable for the reasons cited in the Enclosure. Thus, we request that PGE propose changes to the Trojan TS consistent with those recommended in Generic Letter 85-09, and the staff positions noted in the Enclosure. We also request that within 60 days of receipt of this letter, you provide us with the proposed changes to the Technical Specifications, or provide an alternate schedule within 15 days.
The reporting and/or recordkeeping requirements of this letter affect fewer than ten respondents; therefore, OMB clearance is not required under PL 96-511.
8609250364 860723 PDR ADOCK 00000344 p
PDR k
n 2-By letter dated July 3, 1986, PGE submitted LCA 117 Rev. 2 regarding numerous changes to the : Trojan Reactor Trip System and Engineered Safety Feature Actuation System instrumentation Technical Specifications. LCA 117 Rev. 2 will be evaluated independent of the above requested TS changes.
Sincerely,
!'j f.
Terence'L. C an, Project Manager Project Directorate #3 Division of PWR Licensing-A
Enclosure:
As stated cc: See next page PD#3 y PD#3 CVogan TCha 9/p/86' 9/2y86 4
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- e hr Mr. Bart D. Withers Portland General Eletric Company Trojan Nuclear Plant cc:
Senior Resident Inspector U.S. Nuclear Regulatory Commission Trojan Nuclear Plant Post.0ffice 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
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GENERIC LETTER 85-09 AND ITEM 4.3 T.S. (MPA B-90) 0F GENERIC LtIIER 83-28 PROPOSED TECHNICAL SPECIFICATION CHANGES TROJAN NUCLEAR PLANT, UNIT I DOCKET NO. 50-344 Introduction Generic Letter 85-09 contains staff positions regarding proposed Technical Specification changes pertaining to reactor trip breaker (RTB) design changes (Item 4.3 of Generic Letter 83-28).
Generic Letter 85-09 concluded that Technical Specification changes should be proposed by licensees to explicitly require independent testing of the under-voltage and shunt trip attachments of the reactor trip breakers during power 8
operation, testing of bypass breakers prior to use, and independent testing of the control room manual switch contacts and wiring during each refueling outage.
Staff Positions You are requested to submit proposed Technical Specification changes, noting particularly the following positions of Generic Letter 85-09.
For Table 3.3-1:
1.
For the reactor trip breakers (RTBs) and for the automatic trip logic, different actions are specified for Modes 1 and 2 as compared to Modes 3*, 4*, and 5* (asterisk means with the reactor trip system breakers closed and the control rod drive system capable of rod withdrawal.).
Action 12 applies to Modes 1 and 2, whereas Action 13 applies to Modes 3*,
4*, and 5*.
0 P 2.
A different action is permitted (Action 14) if only one of the diverse trip features (i.e., shunt or undervoltage trip is inoperable).
For Table 4.3-1:
1.
The manual reactor trip tests at refueling intervals specify testing of the bypass breaker trip circuits as well as the RTB trip circuits.
Independent testing of the undervoltage (UV) and shunt trip attachment (STA) of each RTB is specified (Action 11).
2.
Each RTB is to be tested at,least every 62 days on a staggered basis (Action 7).
Independent testing of the UV and STA is specified (Action 12) as part of this RTB test.
l 3.
Each automatic trip logic train is to be tested at least every 62 days l
l on a staggered basis (Action 7).
l 4.
The reactor trip bypass breakers are to be manually tested prior to
(
i placing the breaker in service (Action 13). Also an automatic UV trip l
test is to be made during each refueling outage (Action 14).
Some licensees or applicants have declined to provide Technical Specification changes for testing of the bypass breaker prior to each time it is put into
').
service. The reason cited is that a study by Westinghouse for the Westinghouse Owners Group (WOG) has shown only marginal reliability improvement by such testing. The NRC staff finds this basis for not testing to be unacceptable.
When a reactor trip breaker (RTB) is tested, the reactor trip bypass breaker is put into service as a backup to the remaining RTB. The Generic Letter 85-09 Technical Specifications specify a manual trip test of the bypass breaker prior to putting it into service. This testing is a simple procedure and it is prudent to do this test before relying on this breaker as a backup to the remaining RTB.
Although the probabilistic rist analyses have shown that the testing of the bypass breaker only marginally imroves overall reliability, no claim is made that the reliability is decreased or that the bypass breaker is not safety related. Accordingly, the NRC staff concludes that this test should be made as specified in Generic Letter 85-09..
A few licensees have declined to submit any proposed Technical Specification changes in response to Generic Letter 85-09, stating that they plan to control the re-quirements administrative 1y until the requirements can be optimally determined.
This is not acceptable to the NRC staff. Licensees should submit the proposed Technical Specifications consistent with Generic letter 85-09.
If subsequent analysis shows that different or less frequent surveillance testing is justified, the staff will consider further revision of the Technical Specifications accordingly.
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