ML20141M188
| ML20141M188 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 03/27/1992 |
| From: | Robinson W PORTLAND GENERAL ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20141M186 | List: |
| References | |
| GL-87-09, GL-87-9, NUDOCS 9204020077 | |
| Download: ML20141M188 (11) | |
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.s PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY i-t Operating License NPF-1 Docket 50-344 License Change Application 186, Revision 1 l
This License Change Application requests modifications to Operating I License NPF-1 for the Trojan Nuclear Plant to revise the Trojan Technical .
l Specifications-in response to the recommended changes contained ir. I l.- Generic Letter (GL).87-09, " Sections 3.0 and 4.0 of the Standard l Technical Specifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements". Also included !
are-several minor administrative changes. j
.i I, W. R. Robinson, being duly sworn, subscribe to and say that I'am the General Manager, Trojan Nuclear Plant for Portland General Electric !
Company. the-applicant herein; that I have full authority to execute this oath; that I have reviewed the foregoing; and that to the best of my knowledge, information, and belief the statemente made in it are true.
Date Q(19 _, 1992 l j) /
l-By __%).W Cl )(&$ w xu d W. R. Robinson Cencral Manager Trojan Nuclear Pinnt On this day personally appeared before me W. R. Robinson, to me known to
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l' be the individual who executed the foregoing instrument, and acknowledged
-that-he-signed the same as his free act.
GIVEN under my hand and seul this # th day of March 1992,
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LCA 186 Rev. 1 Attachment A Page 1 of 10 Reason _for_thn_ Change In June 1987, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 87-09, "Section 3.0 and 4.0 of thu Standard Technical Specifications (STS) on the Applicability of Limiting Conditione for
- Operation and Surveillance Requirements." The purpose of the GL was to provide licensees with guidance on revisions to STS 3.0.4, 4.0.3, and 4.0.4 which would- result in an improvement to the luchnical Spe Ificationc.
On November 30, 1989 Portland General Electric Company (PCE) submitted' ,
License Change Application (LCA) 186, recuesting amendment of Operating License NPF-1. This LCA contained proposed revisions to the Trojan Technical Specifications (TTS) in response to GL 87-09.
On August 7,1990 PGE received a Request for Additional Information (RAI) from the NRC regarding LCA 186. The RAI requested, among other things, that PGE af firm that remedial measures prescribed for action statements ,
- affected by the TTS 3.0.4 proposed revisions are consistent with the Trojan FSAR and supporting safety analyses. Additionally, the NRC '
expressed the position that Plunt start-up with important safety features inoperable should be the exception rather than the rule, irrespective of the exceptions granted in reoponse to applications under GL 87-09 and requested that PGE identify and affirm those administrative controls that !
have been established to limit the use of the Specification 3.0.4 exceptions grar.ted. . PGE's response to these issues are provided in Attachment C.
LCA 186, Revision 1 was submitted on June 28, 1991. This supplement to Revision 1 is being submitted-to incorporate some editorial corrections, technical clarifications and to correct a recognized def3ciency regarding the application of Specification 4.0.4 to power range, neutron flux and steam-driven auxiliary feedwater pump surveillance requirements.
Dendplion_oLChange The.following changes are proposed to the Trojan Technical Specifications (TTS):
- 1. TTS 4.0.3 is replaced by the 4.0.3 Specification provided in ,
GL 87-09 as shown in Attaciunent B. The existing 4.0.3 Specificatinn !
is stated in n positive sense that completion of reouired surveillances on schedule demonstrates compliance with the OPERABILITY requirements of the Limiting Condition for Operation (LCO). The new 4.0.3 Specification stetus negatively that failure to perform the required surveillances on schedule constitutes !
noncompliance with the OPERABILITY requirements of the LCO. The new ll 4.0.3 Specification goes on to state the ACTION statements must be l entered at the time of identification that a Surveillance j requirement has not been performed. Additionally, a 24-hour grace
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LCA 186, Rev. 1:
Attachment A
, Page 2 of 10 1
period'is provided when the allowed outage time of_the ACTION statement is <24 hours to allow completion of the missed surveillance.
- 2. TTS 4.0.418 medified, as provided f or by GL 87-09. by _ adding the following sentence:
"This provision shall not provent passage through or to OPERATIONAL MODES as required to comply with ACTION '
requirements."
Refer to Attachment B.
Additionally, the second' paragraph of the existing 4.0.4 Specification is being deleted'as it is no longer applicable.
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- 3. : GL 87-09 identified and provided a solution to the problem of
. unnecessary restrictiona on mode changes. Specification 3.0.4 s wording was revised to provide general allowance for continued operation and mode changes when in-an ACTION statement which permits continued operation for en unlimited period of time. Specifically STS 3.0.4 was reworded to state:
" Entry.into'ar 0 TERAT 10NAL MODE or other specified condition shall not'bc n.ade when the conditions for the Limiting Conditions for Operation are not met and the associated ACTION requires a shutdown if they are not met within a specified time interval. Entry into an OPERATIONAL _ MODE or specified condition may be made in accordance with ACTION requirements when conf ormance to these permits continued operation of the facility for an unlimited period of tima."
' Currently Specification 3.0.4 prohibits changing MODES upward while in an ACTION statement of an LCO. To provide exceptions.to the 3.0.4 limitation, the statement "The-provisions of-Specification 3.0.4 are not applicable" has been added to certain
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specifications thus allowing MODE changes when in the ACTION statements for these specifications.
~The method for implementing the GL 87-09 change would be to replace
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the existing Specification 3.0.4 with the revised wording shown
- above-and then to remove the statement "The proviulons of
. Specification 3.0.4 are not applicable" from those Specifications'to.
which it has been added. The result woald be that Plant personnel L would be required to make a determination for each Specification as
? to how Specification 3.0.4 applien. In many cases, such a determination is not straightf orward.
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LCA 186, Rev. 1 Attachment A ,
Page 3 of 10 ,
As=a result PCE proposes to implement the NRC staff position l 1 regarding Specification 3.0.4 by leaving the words of Specif.ication 3.0.4 unchanged and adding the statement "The-provision of Specification 3.0.4 are not applicable" to each Specification as appropriate in keeping with the philosophy of the revisea Specification 3.0.4. This approach ma.intains the current -
practice used in the Technical Specifications making the change simpler to understand for the Operstions staff and precludes the possibility for misapplicat3on of-the new wording of Specification 3.0.4.
The following.TTSs are revised to add the statement "the provisions of Specifice. tion 3.0.4 are not applicable". These TTSs have remedial' actions that allow indefialte operation in certain '
OPERATIONAL MODES when out. side of the LIMITING CONDIT10N FOR OPERATION. These are new uxceptions granted under Gh 87-09:
Charging Pump - Shutdown i 3.1.2.3-3.1.2.5 Boric Acid Transfer Pumps - Shutdown 3.1.2.7 Borated Water Sources - Shutdova 3.1.3.2 Position Indicator Channels
- L 3.1 Reactor Trip System Instrumentat!<n. (Action 5) 3.3.2 Engineered Safety Feature Actuation System ,
Instriunentation (Actier.s 16 and 17) 3.4.2 Safety Valves - Shut down 3.4.6.2 Operational Leaknaa 3.4.7 Chemistry 3.4.8 Specific Activi+ , ,
3.7.3.2 Component Coo. nr Wa_er System 3.7.4.2 Service Water Syr tem i 3.7.8.1 Fire Suppenssion Watar System ,
3.8.1.2 Electrical Power S; stems - Shutdown 3.8.2.2 AC Dist'ribution - Ghutdown 3.8.2.4 DC Distribution - Shutdown 3.8.3.1 4 lo-kV Entergency bus Undervoltage Protection (Action 1)
Refer to Attachment B for page revisions.
- 4. TTS 3.1.3,1, Group fleight - In Paragraph 2.a of ACTION 4 a change l unrelated t- T 87-09 is being made to correct the zero power ejected rod 3- th f rom 30.98 percent Lk to 10.90 percent Ak. ,
The current safety analysis uses a value of 10.90 percent hk for the end of life zero power ejected rod worth ac shown in
= Table 15.4-3 of the Final Safety Analysis Report.
- 5. TTS 3.1.3.3, Rod Drop Time - The footnote at the bottom of the page l is no longer applicable and in being deleted. ACTION Paragraph b. I is-also being deleted because rod drop times cannot be determined l l
- An editorial change was also made to change the word "with" to "within" in the LCO.
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l LCA 186, Rev. 1 Attachment A Page 4 of 10 i
with less thun four reactor coolant pumps operating.- Rod drop tlines l are determined in MODE 3 and TTS 3.4.1.2 requires all four reactor coolant pumpsito be in operation in order to energizo any control I rod drive mechanism (CRDM). With only three reactor coolant pumps- l in operation, all CRDMs must -be deenergized. l
- 6. TTS Table 4.3-1, Page 3/4 3 The TTS require three-CllANNEL- ;
CALIBRATION surveillances to be performed on the Power Range Neutron Flux instruments. These surveillances can only be performed with l the reactor critical. The current notes in Table 4.3-1 do not contain a provision to exempt TTS 4.0.4 to allow entry into MODES 2 or 1 to perform the surveillances. Rev' '~n 5 of the Standard Technical-Specifications-for Westinghou.s Pressurized Water Reactors corrected this deficiency by adding nn exception to Specification 4.0.4 to the surveillance requirements. In like manner, Notes (2), (3), and (6) of Table 4.3-1 have been revised to include the necessary exception to Specification 4.0.4. ,
- 7. TTS 4.7.1.2.1.c Pages 3/4 7-5 and 7 Thia Specification requires ,
the steam-driven auxilinry feedwater pump to be tested to verify pump operability. The surveillance is required .to be current in MODES-1, 2, and-3. During Plant startup, the surveillance would be required to be performed in MODE 4 prior to entering the MODE where ,
the equipment is required to be OPERABLE in accordance with TTS 4.0.4.- In order to achieve sufficient steam pressure to test the pump, entry-into MODE 3 is required. The existing specification does not:contain an exception to Specification-4.0.4. Revision 5 of the _ Standard Technical- Specificatioos f or Westinghouse Pressurized Water Reactors corrected this deficiency by adding an. exception to Specification 4.0.4 to- this surveillance requirement.
In like manner, this exception to Specification 4.0.4 has been added to SpecificationL4.7.1.2.1.c.
- 8. The Bases for TTS 3.0.1 through 3.0.3, and TTS 4.0.1 through 4.0.5- I are revised to include the wording provided in GL B7-09.
The Bases for Specification 3.0.4 are modified slightly from that provided by GL 87-09.
Attachment l B shows the proposed wordir.g for the Bases.
1 NLSignif.iranLilatard s _ Cons id era t iottDe terminat ion
.In accordance with the requirements'of 10~CFR,50.92, these changes are judged to involve no significant haznrds based on the following ^
-information:
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- 1. _ The change to replace TTS 4.0.3 with the 4.0.3 npecifleation provided in- GL 87-09:
- a. Does the proposed 11' cense change involve a significant increase in the probability or consequencen nf an accident previously i evaluated?
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LCA 186, Rev. 1 Attachment A Page 5 of 10 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 upon 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 survalliance. 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 less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
If a Plant shutdown is required befcre a missed surveillence is ecmpleted, it is likely that the surveillance would be conducted while the Plant was being shut down because _
completion of the missed surveillance would terminate the shutdown requirement. This la undesirable for two reasons. 1 First, the Plant would be in a transient state involving changing Plant conditions that offer the potential for an upset that could lead 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 perf ormance 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 conditicas. Gecond, a shutdown would increase the pressure on the Plant staff to expeditiously complete the required surveillance 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.
In summary, accident probabilities or consequences will not be increased by thus proposed license change.
- b. Does tat proposed license change 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 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. Doce the proposed license change involve a significant reduction in a margin of safe!.y?
The proposed' change to TTS 4.0.3 conforms with the change recommended in GL 87-09 except for the revision to the Bases
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1 LI l LCA 186, Rev. 1 i Attachment A Page 6 of 10 for Specification 4.0.3 as described above. This change does not- relax any surveillance requirement or change the frequency at which surveillances are perf ormed. 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 inoperable when -a surveillance requirement has not been performed. The vast majority of l 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 perforraance of the required sut 111ance.
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 '
surveillance. 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 potentini for a Plant upset and challenge to safety nystems when the alternative is a shutd =a to comply-with ACTIONS before the surveillance can be completed. Consequently, margins of safety are not reduced.
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- 2. The change to revise TTS 4.0.4 to include the provisions of GL 87-09:
- a. Does the proposed license change 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 survelliance requirements or the frequency in which they are performed. This change is administrative in that it merely clarifies that passage through or to an operational mode'is allowed to comply with the ACTION of an LCO. Accident probabilities or consequences are not increased.
- b. Does the proposed license change create the possibility of a new or dif ferent kind of accident from any accident previously evaluated?
The proposed 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 modifled.
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2 LCA 186, Rev.-1 Attachment A Page 7 of 10
- c. Does the proposed license change involve a significant reduction in a margin of safety? ,
As previously stated, the proposed change in 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 which surveillances are performed. This change merely clarifica that passage through_or to an operational mode is ;
allowed to comply with the ACTION of an LCO. '
- 3. -The proposed changes to modify individual TTSs to include references to TTS 3.0.4 as not being applicable:
- a. Does the proposed license change involve a significant increase in the probability or consequences of an accident previously evaluated?
I CL 87-09, in the proposed bases for TTS 3.0.4, states
" Compliance with ACTION reqairements that permit continued operation of the facility for an unlimited period of time provides an acceptable level of safety for continued operation without regard to the status of the Plant before or after a l
mode change. Thurefore, in this case, entry into an OPERATIONAL MODE or other specified condition may be made in accordance with the provisions of the ACTION requirements." '
! The individual TTSs for which revisions are proposed to add references to ITS 3.0.4 as being not appilcable meet the above criteria, i.e., they contain actions that allow continued operation for an unlimited period of time. Consequently, entry into these ACTIONS provides an - 9ptable level of safoty for continued operation, and do not . ult in a significant increase in the probability or consequences of an accident.
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Attachment C to this LCA contains- summary discussions- of the prepared individual TTS revision affirming that the remedial
- measures prescribed for the affected ACTION statements are L consistent with the updated Safety Analysis Report and its j supporting safety analyses.
l l b. Uces the proposed. License change create the possibility of a new or different kind ofiaccident from any ricident previously evaluated?
These changos result in the ability to change modes while In an ACTION that allows-continued, indefinite operation.
l! Jonsequently, no new equipment configurations or accident L scenarios are introduced.
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LCA 186, Rev. 1 Attachment A-Pagt 8 of 10
- c. -Does the proposed license change involve a significant reduction in a margin of safety?
Since the ACTIONS themselves associated with this set of specific TTSs already exist and are considered to provide adequate icvels of safety, entry into these actions should not cause.a reduction in a margin of safety.
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.4. The proposed change to TTS 3.1.3.1, Group ileight, to reflect the zaro power ejected rod worth value of 50.90 percent rather than 10;98-percent:-
- a. Does che proposed license change involve a significant increase in the probability or consequences of an accident previously evaluated?
This-change will achieve consistency between the TTS and the FSAR Accident Analyses. FSAR Table 15.4-3 lists the parameters used in the analysis of the RCCA ejection accident. Included 1s- a value of 0.90 percent AK for the zero, power, end of cycle.--ejected rod worth. This ejected rod worth value resulted from FSAR Amendment 11 which was generated to update the FSAR to reflect the Trojan Nucicar Plant fuel upgrade. .The resultant change in reactor characteristics represented by a calculated maximum ejected rod worth of 0.90 percent rather than.the previous value of 0.98. percent is al change in the
. positive safety direction. Consequently, this change will not increase the probability or consequences of an accident.
I b. Does the proposed license change create the possibility of a new-or different kind-of accident from any accident.previously evaluated?
The value of the ejected rod worth of 0.90 percent is the value used in1the Accident Analyses' represented.in the FSAR.
Consequently, no newlor different accident scenarios are introduced.
- c. Does the proposed license change involve a significant reduction in a margin of safety?
No. The margin of safeti involved Jn a rod ejection accident is enhanced by-the lowering of the ejected rod worth.
- 5. The proposed change to TTS 3.1.3.3, Rod Drop Time, to delete the footnote and Action b.:
- a. Does the proposed license change involve a significant increase in the' probability or consequences of an accident previously evaluaced?
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4 LCA 186, Rev. 1 F Attachment A h Page 9 of 10 The deletion of the footnote is an administratise change only.
This footnote only had applicability until April 11, 1980. .
The deletion of Action b. does not adversely affect the probability or consequences of an accident. Given other TTS restraints, rod drop times are not determined with -three coolant pumps operating.
- b. Does the proposed license change create the possibility of a new or different kind of accident from any accident previously evaluated?
No. Deletion of the footnote is administrative. Deletion of the Action b. assures that rod drop time will be determined with four reactor coolant pumps operating, which is the preferred and safer situation. ,
- c. Does the proposed license change involve a significant reduction in a margin of safety?
No. Deletion of the footnote is administrative. Deletion of Action b. assures that rod drop times will be determined with four reactor coolant pumps operating. This is more accurate and results in better defined safety margins.
- 6. The proposed changes to TTS Table 4.3-1, power range neutron flux surveillance notations, and TTS 4.7.1.2.1.c, steam driven auxiliary feedwater pump surveillance,: to add exceptions to Specification 4.0.4:
- a. Does the proposed license change involve a significant increase -
in the probability or consequences of an accident previously evaluated?
No. The proposed change to add an exception to Specification 4.0.4 allows entry into the MODE where it is possible to perfo>m the required surveillances. Verifying operability of the Power Range Nuclear Instruments and the Steam-Driven Auxiliary Feedwater Pump provides assurance that equipment required to detect abnormal conditions and initiate protective action or to mitigate the causequences of an accident will perform their intended function,
- b. Does the proposed license change create the possibility of a new or different kind of accident from any accident previously evaluated?
No. Providing an exceptinn to TTS 4.0.4 is an administrative change and, as such, does nct introduce any chandes to Plant systema, struct ures, or componente or methods of Plant operation which could create the possibility of a new or different kind of accident.
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INA 186, Rev. 1 Attachment A Prge 10 of 10 ,
- c. Does the preposed license change, luvolve n significant l
teduction in a margin of afe'y? a No. Providing an e xcept ion tn TTS 4.0.4 As an administ r ative change and does not involve a significant reduction in a inatgin of safe,y. The chm se recognizes that for the l' owe r Range Nuclear Instrument calibrations to be perf ormed, the t eactor snus t be c rit ical ant
- in the MODP where the instruments are reyulted to be OPEkAHLE. Likewise, to test the steam-driven auxiliary f eedwater pur, p. the Finnt must be in a MODE shcre adequcte steam preunure exists to perform the test. *lbe safety functions of the equipment remain unaffcett1.
in the tiarch 6, 1Yb6 h;deral Register, the NPS pubilbhed a list al 9
examples of amendments that are not likely to involve a si.nificant 6 horords consideration. Example No. 7 from this list states:
"A :hange to make a license conform to changes in the regulations, where the licenso eaange resulta in very minor chang;en to faellity ,
operations clearly in keeping with the regulations."
The changes proposed herein are a result of GL 87-n9 f or the most part.
While this GL in act a change in regulations per se, it is a change in x regulatory guidance as provided in the Westinghouse Standard Technical Specifications (NUREG-0452). Therefore, the above exttmple is deemed to apply to those changes which are bnsed on GL 87-09.
Saf e ty_ Etivironmentallvaluativu A safety evaluation of the type described in 10 CFR 50.59 was performed.
Additionally, an environmental evaluation was performed in accordance with the " '. This revtew deteilnined that the proposed changen do not create an eviewed safety question, nor do they create an unreviewed environme, question.
Schedule. Consideration It is requested snat 30 days be provided for afaendment implementation.
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