ML20209D962

Safety Evaluation Supporting Amend 131 to License NPF-1

ML20209D962
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	04/22/1987
From:	Office of Nuclear Reactor Regulation
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ML20209D912	List: ML20209D908 ML20209D940 ML20209D962
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NUDOCS 8704290403
Download: ML20209D962 (10)

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SAFETY EVALUATION RY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.131 TO FACILITY OPERATING LICENSE NO. NPF-1 I, PORTLAND GENERAL ELECTRIC COMPANY THE CITY OF EUGENE, OREGON PACIFIC POWER AND LIGHT COMPANY

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TROJAN NUCLEAR PLANT i

i DOCKET NO. 50-344 l .

I INTRODUCTION By letter dated January 30, 1985, with revisions dated September 23, 1985, July 3, 1986, August 22, 1986, and October 17, 1986, Portland General Electric l Company (PGE), the licensee for the Trojan Nuclear Plant, reouested various f changes to the plant's Technical Specifications. These changes included i editorial changes intended to clarify the Technical Specifications and ensure agreement with-the actual installed instrumentation. Changes were requested to bring the plant's Technical Specifications into closer agreement in some i

areas with the Westinghouse Standard Technical Specifications (NUREG-0452, l Revision 4). Changes were also proposed to increase surveillance intervals

and out-of-service times for Reactor Trip System analog instrument channels '

based on the Westinghouse Technical Specification Optimization Program set forth in WCAP-10271, " Evaluation of Surveillance Frequencies and Out-of-Service i

Times for the Reactor Protection Instrumentation System," and Supplement 1 l

thereto. By letter dated March 23, 1987, PGE withdrew its request for proposed t change D.14.b. as originally identified in the January 30, 1985 application.

I The staff has reviewed the requested changes and finds them acceptable.

l The change number convention as used by the staff is that which PGE used in their submittals. i i

In the staff's November 19, 1986 Federal Register Notice (51 FP 41864) of l

Consideration of Issuance of Amendment To Facility Operating License And

j. Proposed No Significant Hazards Determination And Opportunity For A Hearing, l j the January 30, 1985 application was incorrectly referenced as January 30, 1984 The staff has concluded that the date discrepancy between the licensee's cover letter and its attached application was a typographical error, and does not alter the substance of the submittal. We have also concluded that the March 23,

1987 withdrawal of proposed change D.14.b does not alter the staff's original detennination of the application's no significant hazards consideration.

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DISCUSSION AND EVALUATION A. The licensee proposed the following editorial changes which we find acceptable on the basis that they add clarification, brevity and conciseness to the plant's Technical Specifications:

Change A - Under " ACTION" on page 2-4 and under " LIMITING CONDITION FOR OPERATION" on page 3/4 3-1, renumber Specification 3.3.1.1 as 3.3.1.

Change B.1 - On page B 2-3, the bases for " Power Range, Neutron Flux, High Rates" is revised to provide separate bases for

" Power Range, Neutron Flux, High Positive Rate" and " Power Pange, Neutron Flux, Hioh Negative Rate."

Change B.2 - On page B 2-4, the bases for " Intermediate and Source Range, Neutron Flux" is revised for clarification.

Change R.3 - On page B 2-5, the bases for " Pressurizer Pressure,"

A B.4 " Pressurizer Water Level," and " Loss of Flow" are revised for clarification.

Changes B.5 - On page B 2-6, the bases for " Steam /Feedwater Flow Mismatch

& B.6 and Low Steam Generator Water Level" and "Undervoltage and Underfrequency - Reactor Coolant Pump Busses" are reworded for clarification.

Chances B.7 - On page B 2-7, the bases for " Turbine Trip," "Autonn Safety B.8 Injection Input," and " Reactor Coolant Pump Breaker

& B.9 Position Trip: are reworded for clarification.

Changes D.6 - In Tables 3.3-1 and 4.3-1 for Functional Units 9,11,16, D.10 17, and 18, entries under " APPLICABLE MODES" reference a D.11 new Note Y which is added with mode 2 deleted to specify F.5 operation only above P-7 which is consistent with plant F.6 design. For Functional Unit 20 a new entry "l

& F.8 "NA". NoteW is added under " TABLE NOTATION."y" replaces Changes D.10 - On page 3/4 3-3 under " CHANNELS TO TRIP" for Functional Units 16 and 17, the words "for each bus" are added for clarity.

Change D.11 - On page 3/4 3-4 for Functional Unit 18B, new Action Statement 7 is referenced in lieu of 8. For Functional Unit 20, Action Statement 9 is referenced in lieu of 10.

These changes result from other changes which deleted old Action Statement 7 and renumbered other Action Statements. Under " TOTAL NO. OF CHANNELS," " CHANNELS TO TRIP," AND " MINIMUM CHANNELS OPERABLE" for Functional Unit 188, "4-1/ valve" is used in lieu of "4" for clarity.

On pages 3/4 3-6 and 7, old Action Statements 8, 9 and 10 are renumbered as 7, 8 and 9 and old Action Statement 11 is split and reworded into new Action Statements 10 and 11.

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Change D.12 - On page 3/4 3-4 Functional Unit 19 is retitled " Auto Safety Injection Input" for clarity.

Change D.15 - On page 3/4 3-7 under " REACTOR TRIP SYSTEM INTERLOCKS,"

a discussion of the P-13 interlock is added for completeness and consistency.

Change E On page 3/4 3-9, all Functional Units with current entries of "NOT APPLICABLE" under " RESPONSE TIME" are removed from Table 3.3-2 for brevity. The entry under " RESPONSE TIME" for Functional Unit 3 is changed from "s6.0 seconds" to "d4.0 seconds" to provide consistency with the definition of response time and the value listed in the plant's FSAR.

Change F.4 - On page 3/4 3-10 under Functional Unit 6, a' reference to new Note 9 is added under " MODES IN WHICH SURVEILLANCE REQUIRED" to cross-reference the additional requirements of Specification 3/4.9.2.

Change F.7 - On page 3/4 3-11, Functional Unit 19 is retitled " Auto Safety Injection Input" for clarification.

Change F.9 - On page 3/4 3-11, under " CHANNEL FUNCTIONAL TEST" for Function Unit 21, reference to a new Note 10 is added for clarity.

Change F.10 - On page 3/4 3-12, Note 10 is added to clarify how the test signal is generated. Note 9 is added to cross-reference the additional requirements of Specification 3/4.9.2.

Notes ## and Y are added for consistency with Table 3.3-1.

Change G - On page 3/4 3-13, Specifications 3.3.2.1, 4.3.2.1.1, 4.3.2.1.?, and 4.3.2.1.3 are renumbered 3.3.2, 4.3.2.1, 4.3.2.2, and 4.3.2.3, respectively, for brevity.  !

1 l Change H - On pages 3/4 3-14 through 3-30, all current entries labeled l

" Automatic Actuation Logic" are relabeled " Actuation Logic" i and are moved to become the first entries under the functional units, where applicable, for general l clarification.

Change I - On page 3/4 3-70, Action Statements 13 through I6 have minor changes to improve readability. Notes # and ## are reworded for added clarity. On page 3/4 3-14 under Functional Unit 1, " SAFETY INJECTION," a note is added l

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to describe other actions, such as reactor trip, that occur on SI. In Table 3.3-3 wherever SI provides an input for a functional unit, a note referring to Functional Unit 1 is used in lieu of repeating the entries for SI each time.

Change I.2 - On page 3/4 3-16, Functional Unit 3.a is retitled "Contain-ment Isolation Signal" for clarification.

Change I.1- On pages 3/4 3-la and 3-16, added Mode 4 to Functional A'I.3 Units 1.c, 2.a. 2.b, and 2.c for consistency with existing 3.6.2.1.

Change I.4 - On page 3/4 3-17 under Functional Unit 3.b, replaced current entries for manual input with entries referring to Functional Units 3.a.1, P.b, and I to provide consistency with the actual plant design.

Change I.5 - On pages 3/4 3-17 and 3-18 under Functional Unit 4, deleted all references to Note ## to provide consistency with the actual plant design. On page 3-18 for Functional Unit 4.d under " CHANNELS TO TRIP," revised all entries for 4 loops operating to provide consistency with the actual plant design, and clarity.

Change I.6 - On page 3/4 3-19 under Functional Unit 5, entries are added for the safety injection input for cor.pleteness and i

consistency with the plant's design.

Change I.7 - In Table 3.3-3 under Functional Unit 6.a. new Action State-ment 21 is referenced in lieu of 18 and on page 3/4 3-21 under " ACTION STATEMENTS " the new Action Statement 21 is added to ensure consistency with existing Specification 3.7.1.2.

Change I.8 - On page 3/4 3-21 under "ENGINEEPED SAFETY FEATURES INTERLOCKS," the entry under P-12 for the 3 out of 4 coin-cidence logic is deleted for brevity.

Change I.9 - On page 3/4 3-21 under " ENGINEERED SAFETY FEATURES INTERLOCKS," entries were added for P-4 and P-14 interlocks to provided consistency with the plant design.

Change i1.1 - In Table 3.3 A, all existing " Manual Initiation" and

" Automatic Actuation Logic" entries are removed from this table and a footnote is added indicating that setpoints and allowable values are not included for these functions for brevity.

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Change J.2 - In Table 3.3-4, entries under " FUNCTIONAL UNIT" are revised to agree with Table 3.3-3, as revised.

Change K - In Table 3.3-5, all current entries under Initiating Signal and Function 1, " Manual" are consolidated into a single entry for brevity. All initiating signals and functions with current entries of "Not Applicable" under " RESPONSE TIME IN SECONDS" are removed from this table for brevity.

Change L.3 - In Table 4.3-2 for each functional unit which has an input from safety injection, a cross-reference to Functional tinit 1 is added to simplify the table.

Change L.4 - In Table 4.3-2, entries under " FUNCTIONAL UNIT" are revised to agree with Table 3.3-3, as revised.

Change L.5 - In Table 4.3-2, entries under " MODES IN WHICP SURVEILLANCE REQUIRED" are revised to agree with Table 3.3-3, as revised, including references to two new Notes # and ##.

R. The licensee proposed the following changes to provide closer agreement between the plant's Technical Specifications and the Westinchouse Standard Technical Specifications (NUREG-045?, Revision 4) and to enhance the clarity of the Technical Specifications. We have reviewed the applicability of the proposed chances as related to the Tro.ian Nuclear Plant design and find that the changes as described below are acceptable on that basis.

Change D.1 - On page 3/4 3-? under Functional Unit I for Modes 3, 4, and 5 under "APPLICAP.LE MODES," a reference to Note

• is added to apply requirements in those modes only when the reactor trip breakers are closed.

Char.ge D.2 - On pace 3/4 3-2, Functional Unit 2 is expanded to provide entries for the high and low setpoints of this trip function. Under Functional Units 2, 3, and 4 a reference to Note # is added under " ACTION" stating that Specification 3.0.4 is not applicable.

Change D.3 - On page 3/4 3-2 under Functional Unit 5 under " APPLICABLE MODES," entries are limited to Mode I with reference to new Note ## and Mode 2.

Change D.4 - In Table 3.3-1 under Functional Unit 6.A under " APPLICABLE MODES," the entry is limited to Mode 2 with a reference

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to new Note ##. Under new Functional Unit 6.B. new entries are provided for shutdown conditions with the reactor trip breakers closed. Old Functional Unit 6.B is renumbered 6.C.

Change D.5 - In Table 3.3-1 under Functional Units 7 and 8 under

" ACTION," entries are revised. Under "FOUR LOOP OPERATION" reference to Note # is added under " ACTION."

Changes D.6 - In Table 3.3-1 under Functional Units 9, 10, 11, 12, 13, thru 14. 15, 16, 17, 18, and 20, reference to Note # is added D.11 under " ACTION." ,

Change D.13 - In Table 3.3-1 under Functional Units 21 and 22, entries are provided for Modes 3, 4, and 5 with a reference to Note *.

Change F.1 - In Table 4.3-1 under Functional Unit 1, the entry under

" CHANNEL FUNCTIONAL TEST" is revised to "R" and Medes I thru 5 are added under " NODES IN WHICH SURVEILLANCE RE0VIRED" with a reference to Note *.

Change F.2 - In Table 4.3-1 under Functional Units 2, 3, and 4, a ,

reference to Note 4 is added under " CHANNEL CALIBRATION" to exclude the neutron detectors from the requirement for channel calibration. Functional Unit 2 is expanded to provide entries for high and low setpoints of this function.

Change F.3 - In Table 4.3-1 under Functional Unit 5, a new entry "R(4)#" is added under " CHANNEL CALIPRATION." Under " MODES IN WHICH SURVEILLANCE REQUIRED," entries are limited to Mode I with reference to the new Note ### and Mode 2.

1 Change F.4 -

On pageunder is added 3/4 3-10 underCHECK"

" CHANNEL Functional and aUnit new6, a new entry entry)"S" "R(4,5 "

is added under " CHANNEL CALIBRATION." Under " MODES..."

entries are revised to agree with Functional Unit 6 revised entries in Table 3.3-1.

Change F.6 - On page 3/4 3-11 under Functional Unit 18, a reference is made to Note 8 under " CHANNEL FUNCTIONAL TEST." Under

" MODES..." Mode 2 is deleted.

Change F.7 - On page 3/4 3-11 under Functional Unit 19, the entry under

" CHANNEL FUNCTIONAL TEST" is revised to "R".

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4 Change F.9 - On page 3/4 3-11 under Functional Units 21 and 22 the entries under " MODES..." is revised to Modes I, 2, 3, 4 and 5 with references to Note

• for Modes 3, 4, and 5. -

' Change F.10 - On page 3/4 3-12 a new Note ### is added (referenced by Functional Unit 5).

Change I - On page 3/4 3-?O under " TABLE NOTATION," a new Note

• is added stating that the provisions of Specifications 3.0.4 are not applicable.

Change I.1 - In Table 3.3-3 under Functional Units 1.c. 1.d. I.e (four loop), and 1.f (four loop), reference to Note

• is added under " ACTION."

Change I.5 - In Table 3.3-3 under Functional Units 4.a and 4 b deleted Mode 4 from under " APPLICABLE MODES" and referenced Action Statements 10 and 20 added to page 3/4 3-21. Under Functional Unit 4.d (four loop), reference to Note

• is added under " ACTION."

Change I 6 - In Table 3.3-3 under Functional Unit 5 deleted Mode 3 from under " APPLICABLE MODES" for " Steam Generator Water Level-High-High." Added a reference to Note

• under " ACTION."

Change I.7 - In Table 3.3-3 under Functional Unit 6, the entry under

" ACTION" is revised to "14" for " Steam Generator Water Level-Low-Low" with a reference to Note *.

Change L.1 - In Table 4.3-2 under " Manual Initiation" inputs under

" CHANNEL FUNCTIONAL TEST," entries are revised to "R". Old Note 1 is deleted from this table. The'31-day test is for plants with coincidence circuits between the manual switches and the rest of the actuation circuit; however.

Trojan does not employ this configuration, hence, the change to "R".

Change L.2 - In Table 4.3-2 under Functional Units 1.c, 2.c. and 4.c, reference to Note 3 is deleted from under " CHANNEL FUNCTIONAL TEST." Old Note 3 is also deleted from this table.

Change L.5 - In Table 4.3-2 under Functional Units 4.a and 4.b, Mode 4 is deleted from under "P0 DES...". Under Functional '

. Unit 5.a. Mode 3 is deleted from under " MODES...".

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C. The licensee proposed the following changes based on the Westinghouse Technical Specification Optimization Program set forth in WC4P-10271 l and Supplement 1 thereto. We have reviewed these proposed changes with respect to their applicability at the Tro.ian Nuclear Plant and find them ac,ceptable on the basis discussed below:

Changes D.6 - In Table 3.3-1 under Functional Units 9, 14 and 15, a D.9 new Note 1 is referenced under " ACTION." On page 3/4 3-5 8 D.16 under " TABLE NOTATION," a new Note 1 is added to reference the more stringent requirements of Engineered Safety Feature Actuation System (ESFAS) channels for Reactor Trip System (RTS) channels common to ESFAS. We find these changes acceptable on the basis set forth in the staff's February 21, 1985 Safety Evaluation Report (SER) on the Westinghouse Technical Specification Optimization Program.

Changes D.6 - In Table 3.3-1 under Functional Units 11, 12, 13, 14 D.8 15 and 18.A. under " ACTION " the entry is revised from D.9 "7" to "6".. On page 3/4 3-6 under " ACTION STATEMENTS,"

D.11 old Action 7 is deleted and new Action 7 is reworded.

D.14.e These changes, as discussed in Supplement I to WCAP-10271, result from the similarity and the intent of Actions 6 and

7. Further, the staff in a July 24, 1985 letter from Parold R. Denton to L. D. Butterfield identified this as a specific acceptable revision in the model technical specifications r.rovided to the Westinghousd Owners Group (WOG). On this basis, we find these changes acceptable as proposed by the licensee.

Change D.14.c - Under " ACTION STATEMENTS" for Table 3.3-1, the time an inoperable RTS analog channel may be bypassed to allow testing of another channel in the same function is increased from two hours to four hours in Actions 2, 6 and 8. We find this acceptable on the basis set forth in the staff's February 21, 1985 SER.

Change D.14.d - Under " ACTION STATEMENTS" for Table 3.3-1, the time during which an inoperable RTS analog channel may be maintained in an untripped condition is increased from one hour to six hours in new Actions 2, 6, 7 and 9.

We find this acceptable on the basis set forth in the staff's February 21, 1985 SER.

Changes F - In Table 4.3-1 under Functional Units 2.A. 3, 4, 7

& F.10 through 11, 12, 14, 15, 16 and 17, the entries under

" CHANNEL FUNCTIONAL TEST" are changed from "M" to "0(11)." A new Note 11 is added under " NOTATION" to this table for a staggered test basis. Under

.o 5 Functional Units 9 and 14 under " CHANNEL FUNCTIONAL TEST," a new Note 12 is referenced. A new Note 12 is added under " NOTATION" to this table to reference the more stringent requirements of ESFAS channels for RTS channels comen to ESFAS. We find these changes acceptable on the basis set forth in the staff's February 21, 1085 SER.

I Change F.2 - In Table 4.3-1 under new Functional Unit 2.B under " CHANNEL FUNCTIONAL TEST," entry is revised to "S/U(1)." Ve find this change acceptable as proposed on the basis set forth in the July 24, 1985 letter from Harold R. Dentnn to L. D. Butterfield which provided model technical specifications to the WOG related to the staff's generic l SER.

Change L.6 - In Table 4.3-2 under Functional Unit 1.f under " CHANNEL

( FUNCTIONAL TEST " a new Note 2 is referenced which is added to exempt components which are only part of RTS channels from the more frequent ESFAS surveillance requirements.

We find these changes acceptable on the basis set forth in the July 24, 1985 letter.

Change M - In Bases Section 3/4 3.1 and 3/4 3.2, a discussion of WCAP-10271 has been included. Since the proposed revision is t

equivalent to that in the "WOG Guidelires for Preparation of Submittals Requesting Revisions to RPS Technical Specifications," Revision 1, dated September 3,1985, and encompasses the specific coments in the staff's July 24, 1985 letter, we find this change acceptable al prcposed.

D. Ry letter dated March 23, 1987, PGE withdrew its request for r,roposed chtnge P.14.b as related to the revision of Action Statement 3.h of iable 3.3-1, Reactor Trip Systen Instrumentation. This action applies to Functional Unit 5, i.e., Intermediate Range Neutron Flux. The proposed d,ange in Action 3b would have allnwed continued operation with one less intermediate range flux channel operable than the minimum channels operable required (two), above P-6, provided that the thermal power would be expeditiously placed within the range of the source range or power range instrumentation.

Currently, Action 3h requires that when above P-6, the inoperable channel must be restored to operable status prior to increasing thermal power above 5% which is basically consistent with other action statements such as for source range neutron flux channels which prohibit any increase in reactor power if a channel is inoperable.

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Since the proposed Action Statement was insufficiently explicit in that it inadvertently appeared to advocate changing modes to avoid an Action Statement, PGE withdrew its request for proposed change D.14.b. The staff finds this withdrawal acceptable.

ENVIRONMENTAL CONSIDERATION This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.

The staff has determined that the emendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Comission has previously published a proposed finding that the amendment involves no significant hazards consideration and there has been no public coment on such finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in10CFR651.22(c)(9). Pursuant to 10 CFR 651.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

CONCLUSION We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Comission's regulations, and the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public, i

i Dated: April 22, 1987 PRINCIPAL CONTRIPitTORS:

i F. Burrows

! L. Lois 4

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