ML19353A906
| ML19353A906 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 11/30/1989 |
| From: | Cockfield D PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML19353A897 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 8912080065 | |
| Download: ML19353A906 (9) | |
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PORTLAND GENERAL ELECTRIC COFDANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY Operating License NPF-1 Docket 50-344 License Change Appilcation 186 t
This License Change Application requests modifications to Operating License NPF-1 for the Trojan Nuclear Plant to revise the Trojan Technical
' Specifications to incorporate the recommended changes contained in Generic Letter (CL) 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specification (STS) on the Applicability of Limiting Conditions for Operation and Surveillar.ce Requirements".
PORTLAND GENERAL ELECTRIC COMPANY B
D. W. 06ckfield Vice President Nuclear Subscribed and sworn to before me this 30th day of November 1989.
OMyCommission rd>~u W J d b >~.a O NoharyPublicofOregon NxW f,
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l UNITED STATES OF AMERICA NUCLEAR RECULATORY COMMISSION In the Matter of
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PORTL CENERAL ELECTRIC COMPANY,
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Docket 50-344 THE 0: N OF EUGENE, ORECON, AND
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Operating License NPF-1 i
PACIFIC POWER & LIGHT COMPANY
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(TROJ.*Ji NUCLEAR PLANT)
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CERTIFICATE 0F SERVICE I hereby certify that copies of License Change Application 186 to the Operating License for Trojan Nuclear Plant, dated November 30, 1989, have been served on the following by hand delivery or by deposit in the United States mail, first class, this 30th day of November 1989:
State of Oregon Department of Energy 625 Marion St NE Salem OR 97310 Mr. Michael J. Sykes Chairman of County Commissioners Columbia County Courthouse St. Helens OR 97051 l
S. A. Bauer, Manager Nuclear Regulation Branch Nuclear Safety & Regulation Subscribed and sworn to before me this 30th day of November 1989.
OMyCommission ALob 4 L Notary Pub'lic of Ore'on d
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LCA 186 Attachment A Page 1 of 7 Description of change The following changes are proposed to the Trojan Technical Specifications (TTS):
1.
TTS 3.0.4, Applicability, is replaced by the 3.0.4 specification provided in Generic Letter (GL) 87-09, " Sections 3.0 and 4.0 of the Standard Technicel Specifcations (STS) on the Applicability of Limiting Coriditions for Operation and Surveillance Requirements".
2.
TTS 4.0.3, Applicability, is replaced by the 4.0.3 specification provided in CL 87-09.
3.
The following sentence is added to TTS 4.0.4, Applicability, as provided in CL 87-09:
"This provision shall not prevent passage through or to OPERATIONAL MODES as required to comply with ACTION requirements".
4.
The following TTS are revised to delete the phrase "The provisions of Specification 3.0.4 are not applicable":
a.
3.2.4, Quadrant power Tilt Ratio b.
3.3.1, Reactor Trip System c.
3.3.2, Engineered Safety Feature Actuation System d.
3.3.3.1, Radiation Monitoring Instrumentation e.
3.3.3.2, Movable Incore Detectors f.
3.3.3.3, Seismic Instrumentation s.
3.3.3.4, Meteorological Instrumentation h.
3.3.3.6, Chlorine Detection Systems
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3.3.3.7, Fire Protection Instrumentation l
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3.3.3.8, Decouple Switches k.
3.3.3.9, Accident Monitoring Instrumentation 1.
3.3.3.10, Radioactive Liquid Effluent Instrumentation m.
3.3.3.11, Radioactive Gaseous process Effluent Radiation Monitoring System n.
3.3.3.12, Sulfur Dioxide Detection Systems
b LCA 186 Attachment A page 2 of 7 o.
3.4.1.1, Reactor Coolant System Normal Operation p.
3.7.8.1, Fire Suppression Water System q.
3.7.8.2, Spray, Sprinkler and/or Deluge Systems r.
3.7.8.3, Fire Hose Stations s.
3.7.9, penetration Fire Barriers 5.
The Bases for TTS 3.0.1 through 3.0.4, and TTS 4.0.1 through 4.0.5 are revised to include the wording provided in GL 87-09.
Reason for Chanae In June 1987, the Nuclear Regulatory Commission (NRC) issued CL 87-09.
The purpose of this CL was to provide licensees with guidance on revision to TTS 3.0.4, 4.0.3, and 4.0.4 which would result in en improvement to the Technical Specifications.
The specific reason for each change to the TTS is provided below.
1.
TTS 3.0.4 precludes entering a mode or specified condition if a Limiting Condition for Operation (LCO) is not met, even if the action requirements permit continued operation.
In general, the individual TTS that have action requirements which allow continued operation note that TTS 3.0.4 is not applicable. However, exceptions to TTS 3.0.4 have not been consistently applied and their bases are not well documented.
Therefore, TTS 3.0.4 is revised to accomplish two things.
- First, TTS 3.0.4 will only apply if both the LCO is not met and the ACTION requires a shutdown.
Secondly, an entry into an OPERATIONAL MODE can be made with reliance on the ACTION as long as the ACTION permits unlimited operation.
2.
TTS 4.0.3 states that performance of a surveillance within the specified time interval constitutes demonstration of OPERABILITY.
Therefore, failure to perform a surveillance within the specified time interval constitutes a f ailure to demonstrate operability.
In general, the ACTION for a TTS includes an allowable outage time limit of sufficient duration to permit performance of a missed surveillance without initiating a plant shutdown.
However, some TTS have ACTIONS with an insufficient time limit for the completion of a missed surveillance.
Review of this issue resulted in a determination by the NRC that 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is an acceptable time for completing a missed surveillance.
Therefore, TTS 4.0.3 is revised to include this 24-hour delay in implementing the TTS ACTION, upon discovery of a missed surveillance.
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LCA 186 Attachment A page 3 of 7 3.
TTS 4.0.4 prohibits entry into an OPERATIONAL NODE or other condition when the surveillance requirements have not been performed within the specified interval.
The Plant could be in NODE 1, and be required to go to MODE 3 as a result of a shutdown ACTION. A surveillance may be required in MODE 3 that is not required in NODE 1.
It is not the intent of TTS 4.b.4 to prevent compliance with a shutdown ACTION.
However, to perform a shutdown it may be necessary to enter a MODE without having performed the required surveillance. Therefore, TTS 4.0.4 is modified to note that it does not prevent passage through or to OPERATIONAL MODES to comply with an ACTION.
4.
Because of the proposed revision to TTS 3.0.4 described above, individual TTS with ACTIONS permitting continued operation no longer l
need to indicate that TTS 3.0.4 does not apply. A review of the TTS i
was performed, and for each TTS where the ACTION permits continued operation, reference to TTS 3.0.4 was deleted.
5.
In CL 87-09, the NRC provided revised Bases which reflected the modifications proposed above and also included improved Bases for other sections of the Technical Specifications, e.g., TTS 3.0.3.
Because these revised Bases provide useful information to support understanding of the TTS, they have been included as part of this TTS revision.
Significant Hazards Consideration Determination j
The proposed changes do not pose a significant hazard for the reasons i
discussed below.
4 1.
The change to replace TTS 3.0.4 with the 3.0.4 specification provided in GL 87-09 does not:
a.
Involve a significant increase in the probability or consequences l'
of an accident previously evaluated.
The proposed revision to TTS 3.0.4 does not change any LCO or I
associated ACTION in a manner that would allow more equipment to l
be out-of-service, nor does the change allow equipment to be out-of-service for a longer period of time.
l TTS 3.0.4 as presently written unduly restricts f acility l
operation because it does not allow entry into an OPERATIONAL MODE or other specified condition, unless the LCO is met without reliance on provisions of the associated ACTION. Conformance with an ACTION provides an acceptable level of safety when it permits continued operation. Therefore, for an LCO that has an ACTION permitting continued operation, entry into the MODE or condition for which that ACTION governs can be permitted without posing a significant increase in the probability or consequences of an accident.
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LCA 186 Attachment A
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Page 4 of 7 i
b.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
4 The proposed change is not related to accident creation because j
the TTS ACTIONS remain unchanged from the standpoint of allowed J
out-of-service times and components allowed to be iroperable.
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c.
Involve a significant reduction in a margin of safety.
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As previously stated, the proposed change to TTS 3.0.4 cenforms
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with the change recommended in GL 87-09.
This change does not revise any ACTION that would result in less restrictive operation j
of the Plant when operating in an applicable MODE or specified condition. The change merely allows the applicable MODE or j
specified condition to be entered when the ACTION permits continued operation, and at that time, the associated ACTION is to be invoked if the LCO is not met.
t 2.
The change to replace TTS 4.0.3 with the 4.0.3 specification provided in GL 87-09 does not:
a.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change to TTS 4.0.3 does not change any surveillance requirements or the frequency in which they are performed. The change is administrative in that up;n discovery of a missed surveillance, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> will be allowed to perform the surveillance. The 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is based on an NRC determination in GL 87-09 that this is an acceptable time limit for completing a missed surveillance when the allowable outage times of the ACTION are <24 hours.
If a Plant shutdown is required before a missed surveillance is completed, it is likely that it would be conducted when the Plant is being shut down because completion of a missed surveillance would terminate the shutdown requirement. This is undesirable since it increases the risk to the Plant and public safety for two reasons.
First, the Plant would be in a transient state involving changing Plant conditions that offer the potential for an upset that could Icad to a demand for the system or component being tested. This would occur when the system or component is either out-of-service to allow performance of the surveillance test or there is a lower level of confidence in its OPERABILITY because the normal surveillance interval was exceeded.
If the surveillance did demonstrate that the system or component was inoperable, it usually would be preferable to restore it to OPERABLE status before making a major change in Plant operating conditions.
Second, a shutdown would increase the pressure on
1 LCA 186 Attachment A page 5 of 7 the plant staff to chpeditiously complete the required survell-
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lance so that the plant could be returned to power operation.
This would further increase the potential for a Plant upset when both the shutdown and surveillance activities place a demand on the plant operators.
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- b. ' Create the possibility of a new or different kind of accident f rom any accident previously evaluated, i
The propose 6 change is not related to accident creation because the TTS surveillance requirements remain unchanged in that neither what is to be performed, nor the frequency at which it is performed, is modified, c.
Involve a significant reduction in a margin of safety.
As previously stated, the proposed change to TTS 4.0.3 conforms with the change recommended in GL 87-09.
This change does not relax any surveillance requirement or change the frequency at which surveillances are perfermed. The change merely allows for missed surveillances to be performed without resulting in a plant shutdown.
It is overly conservative to assume that systems or components are inoperabl9 when a surveillance requirement has not been performed. The opposite is in fact the case. The vast majority of surveillances demonstrate that systems or components in fact are OPERABLE. When a surveillance is missed, it is primarily a question of OPERABILITY that has not been verified by the performance of the required surveillance. Because the allowable outage time limits of some ACTIONS do not provide an appropriate time limit for performing a missed surveillance before shutdown requirements may apply, the TTS should include a time limit that would allow a delay of the required actions to permit the performance of the missed survelliance. The 24-hour time limit balances the risks associated with an allowance for completing the surveillance within this period against the risks associated with the potential for a plant upset and challenge to safety systems when the alternative is a shutdown to comply with ACTIONS before the surveillance can be completed.
3.
The change to revise TTS 4.0.4 to include the provisions of CL 87-09 does not:
a.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change to TTS 4.0.4 does not change any surveillance requirements or the frequency in which they are performed.
This change is administrative in that it merely clarifles that passage through or to an OPERATIONAL MODE is allowed to comply with the ACTION of an LCO.
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LCA 186 Attachment A page 6 of 7
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b.
Create the possibility of a new or different kind of accident f rom any accident previously evaluated.
The proposed change is not related to accident creation because the TTS surveillance requirements remain unchanged in that j
neither what is to be performed, nor the frequency at which it is performed, is modified.
c.
Involve a significant reduction in a margin of safety.
I As previously stated, the proposed change to TTS 4.0.4 conforms with the change recommended in GL 87-09.
This change does not relax any surveillance requirement or change the frequency at j
which surveillances are perfomed.
This change merely clarifles j
that passage through or to an OPERATIONAL MODE is allowed to comply with the ACTION of an LCO.
j 4.
Deleting reference to TTS 3.0.4 in individual TTS with ACTIONS permitting continued operation does nots i
a.
Involve a significant increase in the probability or consequences of an accident previously evaluated.
This change is administrative in that with the revision to TTS 3.0.4 proposed herein, individual TTS with ACTIONS permitting continued operation no longer need to indicate that TTS 3.0.4 does not apply, b.
Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed change is not related to accident creation. This change is administrative in that with the revision to TTS 3.0.4 proposed herein, individual TTS with ACTIONS permitting continued operation no longer need to indicate that TTS 3.0.4.
does not apply, c.
Involve a significant reduction in a margin of safety.
The proposed change is not related to safety margins. 'this change is administrative in that with the revision to TTS 3.0.4 proposed herein, individual TTS with ACTIONS permitting continued operation no longer need to indicate that TTS 3.0.4 does not apply.
In the March 6, 1986 federal Register, the NRC published a list of examples of amendments that are not likely to involve a significant hazards consideration.
Example No. 7 from this list states:
"A change to make a license conform to changes in the regulations, where the license change results in very minor changes to facility operations cicarly in keeping with the regulations."
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LCA 186 i
i Attachment A I
_Page 7 of 7 f
The changes proposed in this LCA are a result of GL 87-09.
While this GL-is not a change in regulations per se, it is a change in regulatory I
guidance as provided in the Westinghouse Standard Technical l
Specifications (NUREG-0452). Therefore, the above example is deemed to apply to the proposed change.
I safety / Environmental Evalugtion l
Safety and environmental evaluations were performed as required by Title 10, Code of Federal Regulations, Part 50, and the TTS.
This review determined that the proposed changes do not create an unreviewed safety question, nor do they create an unreviewed environmental question.
I Schedule Consideration It is requested that the effective date of the amendment be the date of.
issuance by the NRC, i
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