ML20133B249

Rev 1 to License Change Application 117,modifying Tech Specs to Rectify Inconsistencies W/Installed Instrumentation Not in Agreement W/Rev 4 to NUREG-0452 & to Remove Unnecessary Numerals from Spec Numbers

ML20133B249
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	09/23/1985
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:
Shared Package
ML20133B237	List: ML20133B233 ML20133B249 ML20133B254
References
RTR-NUREG-0452, RTR-NUREG-452 TAC-56816, NUDOCS 8510030112
Download: ML20133B249 (16)

Text

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4 PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY TROJAN NUCLEAR PLANT Operating License NPF-1 Docket 50-344 License Change Application 117 Revision 1 l

This License Change Application requests modification of the Technical '

Specification contained in Appendix A to Operating License NPF-1 to revise the Reactor Trip System and Engineered Safety Feature Actuation l l

System instrumentation requirements. l l

PORTLAND GENERAL ELECTRIC COMPANY By ,

• 1. _/

Bart D. Withers Vice President Nuclear Subscribedandsworntobeforemethis23rddayofSeptembof1985.

Ai d Nof.ary~Public of Qfhgon OMyCommission /

/d[ /[M '

8510030112 G50923 PDR P ADOCK 05000344 pg

4k LCA 117, Rev. 1 Page 1 of 15 i REASON FOR CHANGE:

Present Trojan Technical Specifications (TTS) have inconsistencies with the installed instrumentation and are not in agreement with NUREG-0452, Revision 4, (W-STS) requirements. This change makes the TTS agree more closely with the W-STS, and clarifies the requirements to ensure that they' agree with the specific instrumentation installed at Trojan. There are also numerous changes to instrumentation operability and surveillance, requirements similar to those proposed in WCAP-10271, " Evaluation of Surveillance Frequencies and Out of Service Times for.the Reactor Protection Instrumentation Systems".

Additlonal reasons fo" individual changes are discussed below.

DESCRIPTION OF CHANGE:

t The recommended changes are as shown on the attached annotated pages and I as. outlined below. References 1 and 2 used throughout the text are identified at the end of this LCA (following Scheduled Considerations).

A. Operating License Section 2.C(3) and Specifications 2.2.1 and 3/4.3.1:

Changes are made to remove unnecessary numerals from the Specifica-i tion numbers. The extra ".1" is not needed since there is not a Specification 3/4.3.1.2.

B. Specification 2.2.1 Bases:

4 1.- Power Range, Neutron Flux, High Rates:

i This is changed to list the two trips separately: one for high positive rate and one for high negative rate. This is done to

! clarify the bases since the positive rate is not assumed to

operate in the accioent analysis while the negative rate is. A j statement is added to the positive rate to state that the trip is not used in the accident analysis. This agrees with TTS Table 3.3-2 requirements and Updated FSAR, Chapter 15 accident analysis.

2. Intermediate and Source Range, Nuclear Flux:

Changes are made to remove an implication in the first two sentences that these trips are redundant (implying required for safety) and were used as such in the accident analysis. A l statement is also added indicating that another reason for their existence is to provide readout of core neutron flux levels during startup and shutdown conditions.

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LCA 117, Rev. 1 Page 2 of 15

3. Pressurizer Pressure ~and Pressurizer Water Level:

Changes are made to clarify that these trips only occur when

. above the P-7 interlock setpoint.

'4. Loss of Flow:

A change is made to clarify that the 10-pere,ent power level is in actuality the P-7 interlock. Minor rewording is also done for clarification..

5. Steam /Feedwater Flow Mismatch and Low Steam Generator Water Level:

, A minor change is made to remove the implication that this trip is redundant (implying required for safety) and is assumed to operate in the accident analysis.

The specified flow rate in 1bs/hr at which the trip is actuated is revised to correct the number currently listed. Instead of s.75 x 106the number should be 11 51 x 106 as outlined below.

From Updated FSAR Table 5.1-1, steam flew at full power is 15.07 x 106 lbs/hr, or 3.77 x 106 lbs/hr per steam generator. Therefore, the 40 percent setpoint for the instrument equates to a flow rate of (3.77 x 106 ) x (.40) or 1.51 x 106 lbs/hr.

6.. Undervoltage and Underfrequency - Reactor Coolant Pump Buses:

A change is made to clarify that this trip occurs only when above the P-7' interlock setpoint. Also the nominal values of voltage and frequency'are added for information.

7. Turbine Trip:

Only minor rewording is done to have the wording agree with the other trips. i l

8. Auto Safety Injection Input:

The title is reworded to agree with the change made in D.12 below.

9. Reactor. Coolant Pump Breaker Position Trip:

2 This trip is only interlocked by P-7 and not P-8 as the present wording states. Changes are made to have the wording agree with the design.

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..e-LCA 117. Rev. 1 i Page 3 of 15 i

? C. Specification 3.0.3:

-This section is reworded'to agree with the M-STS requirements.

D. Table 3.3-1, Reactor Trip System Instrumentation:

1

-1. Manual Reactor Trip:

The changes concerning Modes 3, 4, and 5 with the reactor trip breakers shut are made to make the TTS agree with the M-STS.

'2. Power Range Neutron Flux Trips, FUNCTIONAL UNITS 2 through 4: ,

l The provisions of Specification 3.0.4 are made not applicable to agree with the M-STS. FUNCTIONAL UNIT 2 is expanded to identify

' the'high and low setpoints separately to agree with the M-STS.

3. Intermediate Range Neutron Flux:

$ ~ The APPLICABLg MODgS column is revised to have applicability only in Modes 1 (when below P-10) and 2, as stated in the M-STS.

4. -Source Range Neutron Flux:

The APPLICABLg MODgS for startup is revised to have applicability only in Mode 2 (When below P-6), as stated in the M-STS. The new section for shutdown conditions with the reactor trip breakers closed is added to agree with the M-STS.

5. Overtemperature AT and.0verpower AT:

The applicable ACTION Statements are revised to agree with the

, M-STS requirements. The provisions of Specification 3.0.4 are made not applicable in four loop operation to agree with the j M-STS.

! 6. Pressuriser Fressure-Low and Pressurizer Water Level-High Trips:

The changes shown (except for the addition of note 9) are made

, to make the TTS agree with the M-STS. Requiring the trip to be applicable only above P-7 (note $), prevents having to meet the trip surveillance requirements at power levels where the trips are not needed and when in fact they can be bypassed and are therefore effectively nonexistent.

.7. Pressurizer Pressure-High:

l The provisions of Specification 3.0.4 are made not applicable to j agree with the M-STS.

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er LCA 117, Rev. 1 Page 4 of 15

8. Loss of Flow - Single Loop /Two Loops:

The provisions of Specification 3.0.4 are made not applicable to s agree with the W-STS.

9. Steam Generator Water Level - Low Low and Steam /Feedwater Flow Mismatch Coincident with Low Steam Generator Water Level:

The provisions of Specification 3.0.4 are made not applicable to agree with the W-STS.

10. Undervoltage-RCP and Underfrequency-RCP Trit'c:

The exclusion to Specification 3.0.4 is addeu to agree with the W-STS. The note t is added for the reasons outlined in D.6 above. In the CHANNELS TO TRIP column, the words "for each bus" are added to clarify that the trip occurs only when both busses have the underfrequency or undervoltage condition. In the MINIMUM CHANNELS OPERABLE column, the number "3" is changed to a "1/ bus" to be consistent with the above change to the CHANNELS TO TRIP column.

11. Turbine Trip and RCP Breaker Position Trip:

The note 9 is added for the reasons outlined in D.6 above.

With the addition of this note, ACTION Statement 8 becomes the same as the revised No. 7. Therefore, ACTION Statement No. 8 is deleted and Statements 9, 10, and 11 are renumbered 8, 9, and 10.

Turbine Trip-Turbine stop Valve closure is modified to describe the channels as "4-1/ valve" rather than "4" for clarification.

The exclusion to Specification 3.0.4 is added to agree with the W-STS.

NOTE: The change in trip logic at P-8 shown in the W-STS for the RCP Breaker Position Trip does not occur at Trojan per Drawings M-1-T-13, Sheet 5 (Updated FSAR Figure 7.2-1).

12. Auto Safety Injection Input:

This FUNCTIONAL UNIT title is revised to " Auto Safety Injection Input" to clarify that this is from the engineered safety feature automatic actuation circuitry as shown on

- Drawing M-1-T-13, Sheet 8 (Updated FSAR Figure 7.2-1. Sheet 8).

.s-t LCA 117, Rev. 1 Page 5 of 15

13. Reactor Trip Breakers and Automatic Trip Logic:

The~ change splits the requirements for Modes 3, 4, and 5 (with

-the reactor trip breakers closed and capable of rod withdrawal) from the requirements in Modes 1 and 2 to agree with the M-STS.

14. The ACTION Statements in the TTS are revised to be identical (except for the individual numbers) with those in the M-STS except for:

a. TTS ACTION 5 does not list Specification 3.1.1.2 since this Specification was deleted per Amendment 64.

b. TTS ACTION 3 does not limit operation in the power range as does M-STS ACTION 3. This is done for the following reason.

As stated in the Bases for Specification 2.2.1, the Inter-mediate Range Neutron Flux Trip is not assumed to operate in any accident analysis. Therefore, there is no safety basis to have this Trip operable other than to provide backups to other trips (which are redundant in themselves). Since the Intermediate Range Trip is normally bypassed above P-10 (which means the Trip is essentially nonexistent), a safety concern does not exist for limiting power range operation to less than P-10. Increasing power from the Intermediate Range to the Power Range, when one Intermediate Range

. channel is inoperable, will enhance the reliability of the Reactor Protection System because of the backup trip capability available in the Power Range. In other words, with one Intermediate Range Channel out of service, it is not logical to vary power level (<P-10) where there is only one backup Trip (normally there are two Intermediate Range Channels) when you can go to a power level (>P-10) where the Intermediate Range Trip is not utilized to provide backup.

l Additionally, a statement is added to ensure that the power level is expeditiously taken out of the Intermediate Range when only one channel is available to provide power level i indication to the Plant operators.

i These changes are discussed further in the Significant l Hazards Consideration Determination. l

c. TTS ACTION Statements 1, 2, 6, and 8 are revised to allow surveillance testing per Specification 4.3.1.1 for up to four hours instead of the currently allowed two hours. This is done in accordance with Reference 1 as discussed in the Significant Hazards Consideration D9 termination. i

m- m, LCA 117, Rev. 1 Page 6 of 15

d. TTS ACTION Statements 2 and 6 are revised to allow an inoperable channel to be taken out of the tripped condition for repairs for the same period of time that a channel may be placed in test for surveillance testing (four hours).

Additionally, these ACTION Statements are revised to allow surveillance testing when an inoperable channel is taken out of the tripped condition. These changes are made ir accor-dance with Reference 1, as discussed in the Significa A Hazards Consideration Determination,

e. TTS ACTION Statements 2, 6, 7, and 9 revised the time within which an inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This is done in accor-dance with Reference 1, as discussed in the Significant Hazards Consideration Determination.

15. Added a description of the P-13 interlock for consistency.

R.. Table 3.3-2, Reactor Trip System Instrumentation Response Times:

This table is changed to consolidate all Not Applicable trips into the new note and remove them from the body of the table. This is done to condense the table such that only the Trips for which the surveillance testing is applicable are listed.

In addition, the response time for Overtemperature AT was revised from 16 seconds to 14 seconds. The 6-second time delay includes 2 seconds of lag associated with the RTDs thermal capacity and RTD bypass loops flow which is not measured in the response time test.

This change is consistent with FSAR Table 15.0-3.

F. Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements is revised to change the CHANNEL FUNCTIONAL TEST from monthly to quarterly.per Reference 1. In addition, the following changes are made:

1. Manual Reactor Trip:

The CHANNEL FUNCTIONAL TEST is changed to an R requirement, and the MODES IN WHICH SURVEILLANCE REQUIRED is revised to "1, 2, 3*, 4*, 5*" to agree with the M-STS.

2. Power Range Neutron Flux and Rates:

The new Note 4 (excluding the detectors from all CHANNEL CALIBRATION requirements) is added to agree with the M-STS.

FUNCTIONAL UNIT 2 is expanded to identify the high and low setpoints separately and associated surveillance requirements per the M-STS.

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LCA 117. Rev. 1 Page 7 of 15

3. Intermediate Range Neutron Flux:

The new CHANNEL CALIBRATION requirement (R(4)I] is added to make the TTS agree more closely with the M-STS. In the

" NODES. .. " column the changes are made to make the TTS agree with the M-STS and the revised Table 3.3-1. "

4. Source Range Neutron Flux:

4 The new CHANNEL CHECK and CHANNEL CALIBRATION requirements (S.

R(4,5)} are added to agree with the M-STS. In the " NODES. . . "

column, the changes are made to agree with the M-STS and revised Table 3.3-1. Reference to Note (9) is made to help ensure that the requirements of Technical Specification 4.9.2 are not overlooked.

5. Pressurizer Pressure-Low through Underfrequency-Reactor Coolant Pumps:

These changes are made to make Table 4.3-1 consistent with the revised Table 3.3-1.

Turbine Trip:

6.

These changes are made to make Table 4.3-1 consistent with revised Table 3.3-1 and agree more closely with the N-STS.

7. Auto Safety Injection: ,

The CHANNEL FUNCTIONAL TEST is revised from N(4) to R to agree with the M-STS. The title is revised to " Auto Safety Injection Input" to agree with revised Table 3.3-1.

8. Reactor Coolant Pump Breaker Position Trip:

The change to the required NODES from NA to 19 is made to make Table 4.3-1 consistent with the revised Table 3.3-1.

9. Reactor Trip Breaker and Automatic Trip Logic:

The change to the required NODES from 1, 2*, to 1, 2, 3*, 4*, 5*

is made to agree with the M-STS. The addition of Note (10) to the monthly testing of the reactor trip breakers is made to clarify that the trip input is from the automatic trip logic.

10. Notation:

The changes to Notes (1) through (8) and the addition of Note #

(M-STS Note 5) are made to make Table 4.3-1 consistent with the M-STS. Note (9) is added to ensure Specification 3.9.2 is

\

LCA 117, Rev. 1 Page 8 of 15 properly bmplemented. Note (10) is added to remove the con-fusion concerning Which trip signal should be used for the monthly survelliance testing.

The new Notes ##, ###, and $ are added to make Table 4.3-1 consistent with the revised Table 3.3-1.

G. _ Technical Specification 3/4.3.2:

This Specification is revised to delete the extra .1 in the Specifi-cation number, which is not needed since there is not a Technical Specification 3/4.3.2.2. i H. Pages 3/4 3-14 through 3-30, General Comments:

The M-STS is written to account for plants that have logic / coincidence circuitry between the manual initiation switches and the " Automatic" Actuation Logic. Since Trojan does not have this feature, the tables are reformatted to specify requirements for the Actuation Logic (the word " Automatic" is deleted) first, followed by the inputs to the logic.

I. Pages 3/4 3-14 through 3-21, Table 3.3-3 General Comments:

The ACTION statements are reworded (and three added) to be more in agreement with the N-STS, and editorial changes are made to improve readability.

Notes # and ## are reworded to clarify their effect on the APPLICABLg ,

MODgS column. This' rewording removes the confusion about when the ACTION statements are applicable in MODS 3.

A note is added to the safety Injection (SI) function showing the other actions that occur on an SI.. For individual features that have input from the SI function, FUNCTIONAL UNIT 1 (SI) is referenced instead of specifying duplicate requirements. Another note is added stating that Specification 3.0.4 is not applicable to some features as allowed by the M-STS.

The 2-hour allowance in ACTION statements 13, 15, 16, and 19 to per-form surveillance testing per Technical Specification 4.3.2.1 is revised to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The 1-hour allowance in ACTION Statement 14 within which an inoperable channel must be placed in the tripped con-dition is revised to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. These changes are the same as those made to the reactor trip' system and are further discussed in the Significant Hazards Consideration Determination.

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LCA 117 Rev. 1 Page 9 of 15 In addition to the above, the following specific changes (listed by function) are made:

1. Safety Injection: Referenced the new note stating Specifica-tion 3.0.4 is not applicable for inputs e, d, e (4 loops operating), and f (4 1 cops operating) as allowed by the M-STS.

Added NODE 4 to Item c for consistency with TTS 3.6.3.1.

2. In part a. of the Containment isolation functional unit, the title is revised by adding the word " Signal". This removes confusion *en which circuits the requirements apply to.

3. Containment Spray: Added MODE 4 to Item c for consistency with TTS 3.6.2.1.

4. Containment Ventilation Isolation: Deleted the manual testing requirements for Containment Ventilation Isolation since none exist exclusively for Ventilation Isolation. Added actuation inputs from SI, Manual Containment Spray, and Manual Containment Isolation.

5. Steam Line Isolation: Deleted applicability in Mode 4 for inputs a. and b., and referenced new ACTION statements 19 and 20 to agree with the M-STS. Deleted reference to note "##" (bypassed below P-12) since the bypass from these instnanents affects only the SI. feature. Referenced the new note stating Specifica-tion 3.0.4 is not 6pplicable for input d. (4 loops operating) as allowed by the M-STS. -Under CHANNELS TO TRIP for input d., clari-fled that the trip occurs on a trip from any two steam lines or loops.

6. Turbine Trip and Feedwater Isolation: Added an input to the actuation logic from SI. Deleted applicability in Mode 3 for input b., and referenced the new note stating Specification 3.0.4 is not applicable as allowed by the M-STS.

7. Auxiliary Feedwater Pumps Start: For input a., the new ACTION Statement 21 is referenced. This ACTION statement invokes Technical Specification 3.7.1.2 since the failure of the manual initiation circuitry only affects the auxiliary feedwater pumps.

For input c., the applicable ACTION statement is changed from 18 to 14 to agree with the M-STS,'and a reference to the new note stating Specification 3.0.4 is not applicable is added as allowed by the M-STS.

8. ESF Interlocks, P-12: Deleted 3 of 4 coincidence statement to avoid confusion. Actual logic operates on a 2 of 4 coincidence logic.

LCA 117,' Rev. 1 Page 10 of 15-

9. Added a description of the P-4 and P-14 interlocks for consistency.

J. ~Pages 3/4 3-22 through 3-24, Table 3.3-4:

1. The mention of requirements (both not applicable) for Manual Initiation and the Actuation Logic are deleted, and the Note

• is added explaining this change. This is done to condense the table and remove extraneous wording.

2. ' The inputs for each FUNCTIONAL UNIT are revised as needed to agree with the revised Table 3.3-3.

K. Pages 3/4 3-25 through 3-27, Table 3.3-5:

i EItem 1 is consolidated into a single "Not Applicable" statement to simplify the table. All other "Not Applicable" trips are removed to condense the table and remove extraneous wording. A note outlining the handling of "Not Applicable" trips is added as shown.

L. Pages 3/4 3-28 through 3-30, Table 4.3-2:

1. Testing of the Manual Initiation is changed from M(1) to R, and Note 1 is deleted as allowed by the M-STS (NOTE: The 31-day test referenced in the former Note 1 is for plants having coincidence circuits between the manual switches and the rest of the actua-

- tion circuitry. Trojan does not have this configuration; there-fore, the note is not applicable).

2. The CHANNEL FUNCTIONAL TEST surveillance frequency is changed from monthly to quarterly. This change makes Note 2 not applicable and it is deleted.

3. Note 3 is deleted as allowed by the M-STS.

4. The requirement for the SI input to the various Functional Units is consolidated into Note

• to simplify the table.

5. The various inputs are revised as needed to agree with revised Table 3.3-3.

6. The Modes in which surveillance is required are revised to agree with'the M-STS and the revised Table 3.3-3. This includes the

! addition of the two new NOTES # and ##,

-SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION:

The majority of the revisions made by this change fall into one of three

~

3 categories: (1) editorial changes or minor rewording made to correct errors or improve readability and that do not change the intent or requirements, (2) changes made to make the Technical Specifications agree 4

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LCA 117, Rev. 1 Page 11 of 15 I more closely with the M-STS, which have been previously approved by the NRC, or (3) make additional limitations or restrictions not presently included. The revisions that fall into these three categories do not impose a significant hazard because they either: (1) do not make substantive changes to the Technical Specifications, (2). clearly fall within existing regulatory guidance (NURgG-0452, Revision 4), or (3) are more restrictive-than existing requirements.

Revisions made by this change that do not fall into the above three categories are evaluated below.

.A. Addition of Note $ to Tables 3.3-1 and 4.3-1 esses the restrictions on APPLICABLE MODgS given in the M-STS. For example, the Pressurizer

' Pressure-Low Trip is applicable in Mode 1 only when above the P-7 setpoint (Note $).

The M-STS lists this Trip as applicable'when in Mode 1 at any power level. However, this Trip is blocked by the P-7 interlock when below the P-7 setpoint effectively making the Trip nonexistent below P-7.

Therefore, not making this Trip applicable when below P-7 does not increase the probability or consequences of an accident, doas not create the possibility of a new or different kind of accident, and does not decrease a margin of safety since the Trip is already blocked and is not in use. Therefore, a significant hazard is not created with these revisions.

B. In Table 3.3-1. ACTION 3 is revised to allow unrestricted operation when above the P-6 interlock setpoint. This change does not increase the probability or consequences of an accident, does not create the possibility of a new or different kind of accident, nor does it reduce a margin of safety for the reasons discussed below:

1. As stated in the Bases for Specification 2.2.1, the Intermediate Range Neutron Flux Trip is not assumed to operate in any acci-dent analysis. Therefore, there is not a safety basis to have this trip OPERABLE.

2. Increasing power from the Intermediate Range to the Power Range, when one Intermediate Range channel is inoperable, will enhance the reliability of the Reactor Protection System because of the backup trip capability available in the Power Range.

3. The current TTS allow an approximate 5 decade power increase (P-6 to 5 percent power) with only a single Intermediate Range channel available. Allowing a power increase of this magnitude, with only one channel available, but not' allowing a power increase of only a few percent to the Power Range where four channels are available, is inconsistent and unreasonable.

LCA 117, Rev. 1 Page 12 of 15 4

4. Reference 2 states that changes in OPERATIONAL MODES, eg, increasing power above 5 percent (MODE 2 to MODE 1), with selected equipment inoperable, is acceptable on a case basis if adequately justified. Consistent with the NRC guidance supplied in Reference 2, the necessary justification is provided in Items'1 through 3 above. i Based on the above, this change does not pose a significant hazard.

C. Table 3.3-1 ACTION Statements 1, 2, 6, and 8 are revised to allow 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing instead of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Table 4.3-1 is revised to change the frequency of the CHANNEL FUNCTIONAL TEST from monthly to. quarterly. In addition Table 3.3-1 ACTION Statements 2 and 6 are revised to: (1) allow an inoperable channel to be removed j- from the tripped condition for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for troubleshooting and repair, (2) allow surveillance testing when an inoperable channel is taken out of the tripped condition, and (3) increase the time within Which an inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ACTION Statements 7 and 9 in Table 3.3-1 are

'also revised to increase the time within which an-inoperable channel 1

must be placed in the tripped condition from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

l These changes are consistent with WCAP-10271, " Evaluation of Surveil-

, lance Frequencies and Out of Service Times for the Reactor Protection Instrumentation Systems", and the associated NRC Safety Evaluation Report (Reference 1) accepting this WCAP.

These changes do not involve a significant increase in the probabil-ity or consequences of an accident, do not create a new or different

, kind of accident, and do not significantly reduce a margin of safety for the reasons given below.

This change is expected to increase the Reactor Protection System unavailability a small amount, with a consequent increase of similar magnitude in the probability of an Anticipated Transient Without Trip (ATWT), and-in the probability of core melt resulting from an ATWT.

However, this change is expected to result in a significant reduction '

in the probability of core melt from inadvertent reactor trips. This is a result of a reduction in the number of inadvertent reactor trips l occurring during testing of Reactor Protection System instrumenta-l tion. This reduction is primarily attributable to testing in bypass and less frequent surveillance. This reduction in inadvertent core l

melt probability offsets the increase in ATWT core melt probability, resulting in a negligible change in core melt probability. In addi-

.tlon, this change does not increase the consequences of an accident since it does not alter the manner in which protection is afforded nor the manner in which limiting criteria are established, i

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LCA 117, Rev. 1 Page 13 of 15 The proposed change does not modify the manner in which the Reactor Protection System provides Plant protection. The proposed change

-does not involve hardware changes except those necessary to implement testing in bypass. Some existing instrumentation is designed to be tested in bypass and current Technical Specifications allow testing

, .in bypass. Testing in bypass is also recognized by IEEE Standards. j Therefore, testing in bypass has been previously approved and imple- i mentation of.the proposed changes for testing in bypass does not create the possibility of a new or different kind of accident from any previously evaluated. Furthermore, since the other proposed

! ' changes do not alter the functioning of the Reactor Protection System, the possibility of a new or different kind of accident from any previously evaluated has not been created.

The proposed change does not alter the manner in which safety limits, t <

limiting safety system settings, or limiting conditions for operation 1 are determined. The impact of reduced testing other than as addressed above is to allow a longer time interval over which instrument uncer-tainties, eg, drift, may act. Experience at two Westinghouse plants with extended surveillance intervals has shown the initial uncertainty assumptions to be valid for reduced testing. The proposed change in expected to result in an overall improvement in safety by: (1) fewer inadvertent reactor trips due to less. frequent testing and testing in typass which minimizes the time spent in a partial trip condition, (2) higher quality repairs leading to improved equipment reliability ,

due to longer allowed repair times, and (3) improvements in the

' effectiveness of the operating staff in monitoring and controlling j Plant operation due to less frequent distraction of the operator and shift supervisor to attend to instrumentation testing.

Based on the above, this change does not pose a significant hazard.

D. Table 3.3-3 ACTION Statements 13, 15, 16, and 19 are revised to allow 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing instead of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Table 4.3-2 is revised to change the frequency of the CHANNEL FUNCTIONAL TEST from monthly to quarterly. In addition, Table 3.3-3 ACTION Statement 14 is revised to increase the time within which an inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

These changes are similar to those discussed in Item c. above. These changes do not involve a significant increase in the probability or  !

consequences of an accident, do not create a new or different kind of accident, and do not significantly reduce a margin of safety for the reasons given as follows:

1. This change does not modify the manner in which the ESFAS functions.

2. This change does not alter the manner in which safety limits,

. limiting safety system settings, or limiting conditions for operation are determined. '

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LCA 117, Rev. 1 Page 14 of 15

3. This change reduces the time when ESFAS channels are in a 4

degraded state due to testing and, therefore, reduces the potential for unnecessary Plant transients and challenges to protection and safety systems.

4. Constant cycling of equipment for testing purposes can shorten component lifetime and contribute to premature failure. This is of greatest concern if the premature failure occurs at a time when a bona fide safety signal exists.

5. Significant manpower resources are used to perform and administer these tests. This poses not only an economic burden, but also precludes using these resources for other efforts to assure safe Plant operation while still maintaining a highly reliable ESFAS system, 6..~This change allows personnel to perform troubleshooting and repair in a less hurried manner which will result in higher quality repairs and consequent improved equipment reliability.

i Based on th'e above, this change does not pose a significant hazard.

E. NUREG-0452, Revision 4 Table 4.3-2 presently requires Surveillance Testing of the Pressurizer Pressure-Low, Differential Pressure Between Steam Lines-High, and Steam Flow in Two Steam Lines-High Coincident With etc, trips during Plant conditions when these inputs are not required to provide ESF actuation.

The Pressurizer Pressure-Low input can be bypassed below the P-11 setpoint. The Differential Pressure Between Steam Lines-High and Steam Flow in Two Steam Lines-High Coincident With etc. inputs can be bypassed below the P-12 setpoint. Deleting the Surveillance Require-ments below the P-11 or P-12 setpoints does not increase the i

probability or consequences of an accident, does not create the possibility of a new or different kind of accident, and does not reduce a margin of safety.

If the inputs were required to provide ESF actuation below P-11 or P-12 then the capability to bypass these inputs below P-11 or P-12

[ would not exist. The fact that these inputs can be bypassed below P-11 or P-12_(and effectively made nonexistent) demonstrates that they are not needed for ESF actuation below P-11 or P-12. Therefore, removal of the requirement for surveillance below P-11 or P-12 is not l considered a significant hazard.

SAFETY / ENVIRONMENTAL EVALUATION Safety and environmental evaluations were performed as required by 10 CFR 50 and the Trojan Technical Specifications. This review determined that the proposed changes do not create an unreviewed safety I

question.

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LCA 117 Rev. 1 Page 15 of 15 SCHEDULE CONSIDERATION It is requested that the effective date of this amendment be 30 days after receipt by PGE.

REFERENCES i

1. Letter from C. O. Thomas (NRC) to J. J. Sheppard (WOG) providing NRC Safety Evaluation (and approval) of WCAP-10271, dated February 21, 1985.

2. Letter from J. R. Miller (NRC) to B. D. Withers (PGE) regarding Trajan License Change Application 114, dated March 8, 1985.

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