Text

Revised Application to Amend License NPF-1,consisting of Changes to Rev 2 to License Change Application 117,revising Tech Spec Tables 3.3-1 Re Reactor Trip Sys Instrumentation & 4.3-1 Re ESF Sys Instrumentation Surveillance Requirements
	ML20211C790
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	10/17/1986
From:	Withers B; PORTLAND GENERAL ELECTRIC CO.
To:	Varga S; Office of Nuclear Reactor Regulation
Shared Package
ML20211C796	List: ML20211C790; ML20211C882;
References
	TAC-56816, NUDOCS 8610220024
	Download: ML20211C790 (8)
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Docket 50-344 License NPF-1 l Director of Nuclear Reactor Regulation Attn: Mr. Steven A. Varga Director, PWR-A Project Directorate No. 3 U.S. Nuclear Regulatory Commission Washington DC 20555

Dear Sir:

References:

1) PGE (Withers) to NRC (Varga) Letter Regarding LCA 117 Rev. 2, August 22, 1986.

2) Letter From H. R. Denton (NRC) to L. D. Butterfield (WOG)

Regarding Guidelines for Preparing Reactor Trip System Technical Specification Changes, July 24, 1985.

License Change Application (LCA) 117. Revision 2 In accordance with our additional discussions with your staff on September 18 and 19, 1986 concerning LCA 117, Revision 2, attached are I

further agreed-upon changes to this LCA. The changes include:

l (1) A matrix summarizing the Westinghouse Owners Croup /NRC guidance relevant to WCAP-10271, and PGE's conformance with this guidance,

.is provided as Attachment 2.

(2) Table 3.3-1, Action 1 - The surveillance outage time is corrected

.to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months since the reactor trip breakers are outside of the How-scope of the NRC Safety Evaluation Report for WCAP-10271.

ever, this item may be the subject of a future LCA.

(3) The shared Reactor Protection /ESFAS inputs are revised to clarify that only steam generator level - low-low is a shared input.

This is. based on the NRC clarification that a shared input means shared bistables, not shared sensors. As a result of this clari-fication, Note (2) to Table 4.3-2 is modified to apply to the Channel Functional Test in general, rather than a specific input.

In addition, Note (1) from Table 3.3-1 and Note (12) from Table 4.3-1 no longer apply to Pressurizer Pressure - Low.

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MWMW Mr. Steven A. Varga October 17, 1986 Page 2 (4) Table 3.3-1, Action 7 - The action statement provided in Refer-ence 1 is revised to allow more than one channel to be operable with continued Plant operation consistent with Reference 2.

(5) The description of the change to Action Statements 9, 10, and 11 is expanded for clarification.

To incorporate the above changes, selected pages from both the text of the LCA and the associated Technical Specifications have been changed as indi-cated by change bars in the margin of each affected page attached. Previ-ous changes to this LCA were provided in Reference 1.

Sincerely,

^ -#

Bart D. Withers.

Vice President Nuclear Attachment c: Mr. Lynn Frank, Director State of Oregon Department of Energy Mr. Michael J. Sykes chairman of County commissioners

LCA 117, Rev. 2 Page 3 of 39 C. Specification 3.0.3:

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

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

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:

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 agers with the M-STS.

3. Intermediate Range Neutron Flux:

The APPLICABLE MODES 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 APPLICABLE MODES 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 Overpower 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 M-STS.

6. Pressurizer Pressure-Low and Pressurizer Water Level-High Trips:

Two new notes are added to Table 3.3-1 concerning pressurizer pressure-low and pressurizer water level-high trips. The addi-tion of Note # is made to conform with the M-STS. The addition of Note T requires the trips to be applicable only above P-7.

This prevents having to meet the surveillance requirements at power levels where the trips are not needed and when in fact they can be bypassed and are, therefore, effectively nonexistent.

ACTION 6 is referenced for Pressurizer Level-High. The old ACTION 7 was redundant to ACTION 6 and was replaced with a new ACTION 7 that applies only to Turbine Stop Valve Closure.

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l LCA 117, Rev. 2 Page 4 of 39

7. Pressurizer Pressure-High:

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

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

The provisions of Specification 3.0.4 are made not applicable to agree with the W-STS. ACTION 6 is referenced because the old ACTION.7 is deleted, since it was redundant to ACTION 6. The new ACTION 7 applies only to Turbine Stop Valve Closure.

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. ACTION 6 is referenced because the old ACTION 7 is deleted, since it was redundant to ACTION 6. The new ACTION 7 applies only to Turbine Stop Valve Closure.

Note (1) is added to the Steam Generator Water Level - Low-Low input to conform with Reference 3.

10. Undervoltage-RCP and Underfrequency-RCP Trips:

The exclusion to specification 3.0.4 is added to agree with the W-STS. The Note $ 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.

11. Turbine Trip and RCP Breaker Position Trip:

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

Since ACTION 7 is deleted as discussed in D.6 above, Action 8 is l

renumbered as ACTION 7, with a wording change that allows more than one channel to be. inoperable per Reference 3. This results in ACTION 6 being applicable to " Turbine Trip - Low Hydraulic Control 011 Pressure" and ACTION 7 being applicable to " Turbine Trip - Turbine Stop Valve Closure". ACTION Statements 9, 10, l and 11 are renumbered 8, 9, and 10, accordingly. In addition, l

ACTIONS 10 and 11 have been slightly reworded. ACTION 10 j' applies to MODES 3, 4, and 5 when it is appropriate to open the reactor trip breakers. ACTION 11 applies to MODES 1 and 2 when it is appropriate to enter HOT STANDBY. 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 Drawing M-1-T-13, Sheet 5 (Updated FSAR Figure 7.2-1).

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'LCA 117, Rev. 2 Page 6 of 39 I

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

d. 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. hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This is done in accor-dance with Reference 1, as discussed in the Significant

Hazards Consideration Determination.

e. The old TTS ACTION Statement 7 is deleted since it is.

redundant to ACTION 6 (see Reference 3).

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

L 16. Added Footnote (1) to highlight the more restrictive aurveillance requirements for those channels shared with ESFAS.

E. 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 l

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 and Reference 4.

i F. Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements is revised to change the CHANNEL FUNCTIONAL TEST from monthly to quarterly per References 1 and 3. Footnotes (11) and (12) have been added to clarify this change in surveillance frequency per Reference 3. 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 W-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 W-STS.

FUNCTIONAL UNIT 2 is Expanded to identify the high and low

LCA 117, Rev. 2 Page 34 of 39 This example is judged to apply to the above changes which are made to agree with the W-STS (NUREG-0452, Rev. 4). The W-STS are not

. considered a regulation per se. .However, the W-STS do represent guidelines for Technical Specifications which are endorsed (and published) by the NRC. The TTS were issued prior to the availabil-ity of Revision 4 of the W-STS. The hhanges proposed to the TTS are made with the intent of keeping the TTS consistent with the latest NRC guidance to the extent possible. Therefore, this change is deemed not to pose a significant hazard.

III.A. The following changes do not involve a significant increase in the probability or consequences of an accident. These changes are con-sistent with WCAP-10271, " Evaluation of Surveillance Frequencies and Out of Services Times for the Reactor Protection Instrumentation Systems", and the associated NRC Safety Evaluation Report (Reference 1) accepting this WCAP. The changes also follow FRC guidance provided in Reference 3.

Table 3.3-1 ACTION Statements 2, 6, and 8 are revised to allow l 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . 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 surveillance testing when an inoperable channel is bypassed, and (2) increase the time within which an. inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ACTION Statement 9 in Table 3.3-1 is also revised to increase the time within which an inoperable channel must be placed in the tripped condition from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Note (1) is added to TTS Table 3.3-1 for the shared RPS/ESFAS inputs. The old ACTION 7 is deleted from TTS Table 3.3-1. The new ACTION 7 increases the time within which an inoperable channel must be placed in the tripped condition ~from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Notes (11)-and (12) are added to TTS Table 4.3-1 for those inputs tested on a staggered basis and for the shared RPS/ESFAS inputs. The power range flux low setpoint is to be tested during startup. Note (1) in Table 4.3-1 is revised from 7 days to 31 days. Note (2) is added to Table 4.3-2.

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 occurring during testing of Reactor Protection System instrumentation. This reduction-is primarily attributable to test-ing in bypass and less frequent surveillance. This reduction in inadvertent core melt probability offsets the increase in ATWT core melt probability, resulting in a negligible change in core melt

LCA 117, Rev. 2 Page 35 of 39 4 probability. In addition, this change does not increase the conse-quences of an accident since it does not alter the manner in which protection is afforded nor the manner in which limiting criteria are established.

III.B. The following changes do not create the possibility of a new or different kind o'f accident. These changes are consistent with WCAP-10271, " Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation Systems",

and the associated NRC Safety Evaluation Report (Reference 1) y accepting this WCAP. The changes also follow NRC guidance provided i

in Reference 3.

i Table 3.3-1 ACTION Statements 2, 6, and 8 are revised to allow l 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Table 4.3-1 is revised to chango 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 surveillance testing when an inoperable channel is bypassed, and (2) increase the time within which an inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ACTION Statement 9 in Table 3.3-1 is also revised to increase the time within which an inoperable channel must be placed in the tripped condition from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . -Note (1) is added to TTS Table 3.3-1 for the shared RPS/ESFAS inputs. The old ACTION 7 is deleted from TTS Table 3.3-1. The new ACTION 7 increases the time within which an inoperable channel must be placed in the tripped condition from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Notes (11) and (12) are added to TTS Table 4.3-1 for those inputs tested on a

j. staggered basis and for the shared RPS/ESFAS inputs. The power range flux low setpoint is to be tested during startup. Note (1) in Table 4.3-1-is revised from 7 days to 31 days. Note (2) is added to Table 4.3-2.

The proposed chenge 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 imple-ment 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. Therefore, testing in bypass has been previously spproved and implementation of the proposed changes for testing in 4

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.

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LCA 117, Rev. 2' Page-36 of 39 III.C. The following changes do not involve a significant reduction in a margin of safety. These changes are consistent with WCAP-10271, "Evaluatien of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instramentation Systems", and the associated NRC Safety Evaluation Report (Reference 1) accepting the WCAP. The changes also follow NRC guidance provided in Reference 3.

Table 3.3-1 ACTION Statements 2, 6, and 8 are revised to allow l

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing instead of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . 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 surveillance testing when an inoperable channel is bypassed, and (2) increase the time within which an inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ACTION Statement 9 in Table 3.3-1 is also revised to increase the time within which an inoperable channel nest be placed in the tripped condition from I hour to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Note (1) is added to TTS Table 3.3-1 for the shared RPS/ESFAS inputs. The old ACTION 7 is deleted from TTS Table 3.3-1. The new ACTION 7 increases the time within which an inoperable channel must be placed in the tripped condition from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . Notes.(11) and (12) are added to TTS Table 4.3-1 for those inputs tested on a staggered basis and for the shared RPS/ESFAS inputs. The power range flux low setpoint is to be tested during startup. Note (1) in Table 4.3-1 is revised from 7 days to 31 days. Note (2) is added to Table 4.3-2.

The proposed change does not alter the manner in which safety limits, limiting safety system settings, or limiting conditions for operation are determined. The impact of reduced testing other than as addressed above is to allow a longer time interval over which instrument uncertainties, eg, drift, may act. Experience at two Westinghouse plants with extended surveillance intervals has shown the - tial uncer.tainty assumptions to be valid for reduced testing.

The proposed change is expected to result in an overall improvement

-in safety by: (1) fewer inadvertent reactor trips duo to less frequent testing and testing in bypass 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 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.

IV.A. The change to Table 3.3-1, ACTION 3, to allow continued operation above the P-6 setpoint with an Intermediate Range Flux channel inoperable does not involve a significant increase in the probabil-ity or consequences of an accident as discussed below.

._ _ -

v t e Letter Sequence Request
TAC:56816, (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance... Administration Questions Answers Results Approval, Approval Other: ML20133B233, ML20133B249, ML20133B254, ML20207B814, ML20211C882, ML20212M398
MONTHYEAR1986-07-03 [Table View]

ML20211C790

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Dear Sir:

References:

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