ML20212M351

Revised Application for Amend to License NPF-1,incorporating Rev 2 to License Change Application 117,changing Tech Specs Re Table 3.3-1, Turbine Trip & Expansion of Reactor Protection Bases Per Change in Surveillance Interval

ML20212M351
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	08/22/1986
From:	Withers B PORTLAND GENERAL ELECTRIC CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20212M353	List: ML20212M351 ML20212M398
References
TAC-56816, NUDOCS 8608250455
Download: ML20212M351 (12)

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August 22, 1986 .

Trojan Nuclear Plant Docket 50-344 q____ --e.i_

Director of Nuclear Reactor Regulation Attn: Mr. Steven A. Varga '

Director, PWR-A' Project Directorate No. 3

( U.S. Nuclear Regulatory Commission l Washington DC 20555

Dear Sir:

License Change Application (LCA) 117. Revision 2 In accordance with our discussion with your staff on August 18, 1986 concerning LCA 117 Revision 2, attached are.the agreed-upon changes to this LCA. The changes include:

(1) Table 3.3-1,." Turbine Trip"'- The' action' statement is revised to more closely follow our present action statement. This is because the Westinghouse Owners Group (WOG) guidance, which serves as the basis for the proposed change, was determined to be inconsistent for this particular trip input.

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(2) An editorial error in the text of the LCA referring to Note 2 in Table 3.3-3 is deleted.

(3) Table 3.3-3, Action 19 - The surveillance outage time is corrected to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to be consistent with outage times allowed for other Engineered.Saf.ety Features Actuation System. inputs.

(4) Th'e Reactor Protection-B'ases'are e.xpanded to address.the change in surveillance interval and allowed outage time consistent with WOG guidelines.

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Mr. Steven A. Varga ,

August 22, 1986 Page 2 . _

To incorporate the above changes, selected pages from both the text of the LCA and the associated Technical Specifications have been changed as indicated.by change bars in the margin of each.affected page attached.

- 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

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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 ACTION 7

'is deleted, since it is redundant to ACTION 6.

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

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The provisions of Specification 3.0.4 are made not applicable to agree with the W-STS. ACTION 6 is referenced because ACTION 7 ^

(' is deleted, since it is redundant to ACTION 6. Note (1) is added 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 M-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 adde'd 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 $ is added for the reasons outlined in D.6 above.

Since ACTION 7 is deleted as discussed in D.6 above, Action 8 is renumbered as ACTION 7. This results in ACTION 6 being

( applicable to " Turbine Trip - Low Hydraulic Control Oil l

Pressure" and ACTION 7 being applicable to " Turbine Trip -

Turbine Stop Valve Closure". ACTION Statements 9, 10, and 11 are renumbered 8, 9, and 10, accordingly.

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 H-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

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 l'as discussed in,the; j Significant Hazards Consideration Determination.

d. 'TTS ACTION Statements-26,'7, and 9 revised the time'within

, l which an inoperable channel m'st u 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 Hazdeds Consideration Determination.

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

redundant to ACTION 6 (see Reference 3). l:

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

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

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

This table is changed to consolidate al1 Not' Applicable trips into the new note and remove them from the. body o,f 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 Overtemp' era'ture 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 and Reference 4.

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F. Table 4.3-1, Reactor Trip System Instrumentation Surveillance Requirements is revised to change the CHANNEL FUNCTIONAL TEST from monthly to quarterl'y per References l'and 3. Footnotes (-11) and (12) have been added to clarify this change in surveillance frequency per i Reference 3. In addition, the following changes are made:

1. Manual Rea c tor Trip:

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

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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 I

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. Page 9 of 39 In addition to tha above, the following specific changes (listed by function) are made:

1. Safety ' Injection: . Referenced the new no'te stating Specifica-tion 3.0.4 :is not applicable for . inputs e, d, e (4 loops -

operating), and.f (4 loops; operating) .as allowed by the M-STS.

Added MODE 4'to Item'c for consistency with TTS 3.6.3.1.

2. In part a. of the Containmen:. isolation functional unit, the title is. revised by adding the word " Signal", This removes confusion on 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 instruments affects only

- the SI feature. Referenced the new note stating Specifica-tion 3.0.4 is not, applicable for input d._ (4 loops operating) as .

allowed by the W-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 'eedwater' F 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 aff cts the. auxiliary feedwater pumps.

For input c.', the applicable ACTION' statement is changed from

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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.

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Page 10 of 39

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

J. Pages 3/4 3-22 throusi 3-24. Table 3.3-4:

1. THe. mention of requirements.(both notIapplicable).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:

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( Item 1 is consolidated into a single "Not Applicable" statement to simplify the table. All other "Not Applicable" trips are removed to I

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

3. The requirement for the SI input to the various Functional Units

( is consolidated into Note

• to simplify the table.

4. The various inputs are revised as needed-to a5ree with revised Table 3.3-3.

5. The Modes in which surveillance is required are revised to agree

, with the W-STS and the revised Table 3.3-3. This includes the-additi'on of*the'two.'new NOTES'# and ##.

6. A new Note 2 is added to address'the appropriate testing-for ESFAS channels which are shared with the Reactor Trip System in accordance with Reference 3.

M. Page B 3/4 3-1, Bases:

The Bases are revised in accordance with Westinghouse Owners Group guidance.

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11. TTS Table 3.3-1 Turbine Trip - Describing the channels as "4-1/ valve" is a clarification.

12. TTS Table 3.3-1, Auto. Safety Injection Input .The change in the FUNCTIONAL UNIT.. title is a clarification.

l'3 . TTS Table 3.3-1, Renumbering' ACTIONS 8,'9, 10, an'd 11 is done -l for consistency as discussed in the Description of Change.

. 14 . TTS Table 3.3-1, Reactor Trip System (RTS) Interlocks - Added a desleiptio'n of the P-13 interlock for consistency.- .

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15. TTS Table 3.3-2, RTS Instrumentation Response Times - Deleting the not applicable trips is an editorial change.

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16. TTS Table 4.3-1, Source Range Neutron Flux - The addition of

(- Note # is an administrative change. In Reference 3, the NRC indicated that a quarterly CHANNEL FUNCTIONAL TEST of the Source Range Neutron Flux is required in the event of an extended shutdown. The quarterly surveillance has been added to the TTS in this LCA. However, Note # is added to 'reclude p having to perform a CHANNEL FUNCTIONAL TEST prior to entering.

MODE 2 (below P-6)'from,a higher power level. This CHANNEL FUNCTIONAL TEST would be required'if TTS'4.0.4 was applicable.

Performing this CHANNEL FUNCTIONAL TEST in MODE-2 (above P-6) presents an increased risk of source range cable and connector damage at.this higher flux. level.

17. TTS Table 4.3-1, Notes (9) and (10) - These notes are added for clarification.

18. TTS Table 3.3-3, Safety Injection - The addition of Footnote

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T'is for completeness. Referencing back to this FUNCTIONAL UNIT throughout the table is done to eliminate duplication.

Adding MODE 4 to Containment Pressure-High is done for consistency with other TTS.

19. TTS Table 3.3-3, Containment Isolation - Adding the word

" signal"_is a clarification. .

20. TTS Table 3.3-3, Containment Spray - Adding MODE.4,to ,

containment Pressure High-High is done for consistency with other TTS.

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21. TTS Table 3.3-3, Containment Ventilation Isolation - Deleting manual testing is done to reflect the as-built design. Adding references to other FUNCTIONAL UNITS is done for consistency.

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5. TTS Bases 2.2.1, Steam /Feedwater Flow' Mismatch and Low Steam Generator Water Level - Additional description is provided and an error is corrected for clarification and accuracy.

6. TTS Bases 2.2.1, Undervoltage'and Underfrequency on RCP Buses -

Clarification is provided to reflect the as-built design and descriptive'information-is added.

7. TTS Bases 2.2.1, Turbine Trip and Auto Safety Injection Input -

Rewording is done for consistency with other trips and inputs.

8. TTS Bases 2.2.1, RCP Breaker Position Trip.- Clarification is provided to reflect the as-built design and correct an error.

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9. TTS Tables 3.3-1 and 4.3-1 Pressurizer Pressure-Low, Pressu'rizer Level-High, RCP Undervoltage and Underfrequency,

( Turbine Trip, RCP Breaker Position - Addition of Note Y to these trips merely reflects the as-built design.

10. TTS Table 3.3-1, RCP Undervoltage and Underfrequency - The wording change in the CHANNELS TO TRIP column is provided for clarification.

11. TTS Table 3.3-1. Turbine Trip - Describing the channels as "4-1/ valve" is a clarification.

12. _ TTS Table .3.3-1, Auto Safety . Injection Input - The change in the FUNCTIONAL UNIT title is a clarification.

13. TTS Table 3.3 Renumbering ACTIONS 8, 9. 10, and 11 is done l for consistency as discussed in the Description of Change.

( 14. TTS Table 3.3-1, Reactor T. rip System (RTS) Interlocks - Added a description of the P-13 interlock for consistency.

15. TTS Table 3.3-2, RTS Instrumentation Response Times - Deleting the not applicable trips is an editorial change.

16. ' TIS Table.4.3-1, Source Ran'ge Neutron Flu'x - The addition of

. Note # is.an administra'tive. change' "In' Refer.ence 3, the NRC indicated 1that a iguarterly CHANNEL FUNCTIONAL TEST of the' '

Source Range Neutron Flux is required in the eve'nt of an i extended shutdown. The quarterly surveillance has been added l l to the TTS in this LCA. However, Note #,is added to preclude l 1

having to perform a CHANNEL FUNCTIONAL TEST prior to entering MODE 2 (below P-6) from a higher power level. This CHANNEL FUNCTIONAL TEST would be required if TTS 4.0.4 was applicable.

Performing this CHANNEL FUNCTIONAL TEST in MODE 2 (above P-6) presents an increased risk of source range cable and connector damage at' this higher flux -level.

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Page 17 of 39 l

13. TTS Table 3.3 Renumbering ACTIONS 8, 9, 10, and 11 is done l for consistency as discussed in the Description of Change.

14. TTS Table 3.3-1, Reactor. Trip System (RTS) Interlocks .Added a description of the P-13 interlock for. consistency.

15. TTS T'able 3.'3-2,'TS R Instrumentation Response' Times - Deleting' the not applicable trips is an editorial change.

16. 'TTS Table 4.3-1, Source Range Neutron Flux - The addition of Not$ # is an administrative change. In Reference 3, the NRC indicated that a quarterly CHANNEL FUNCTIONAL TEST of the Source Range Neutron Flux.is required in the event of an extended shutdown. The quarterly surveillance has been added to the TTS in this LCA. However, Note # is added to preclude having to perform a CHANNEL FUNCTIONAL TEST prior to entering -

( MODE 2 (below P-6) from a higher power level. This CHANNEL FUNCTIONAL TEST would be required if TTS 4.0.4 was applicable.

Performi.ng this CHANNEL FUNCTIONAL TEST in MODE 2 (above P-6) presents an increased risk of source range cable and connector damage at this higher flux level. -

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TTS Table 4.3-1, Notes (9) and (10) - These notes are added for clarification.

18. TTS Table 3.3-3, Safety Injection - The addition of Footnote Y is.for comple.teness. Referencing back to this FUNCTIONAL UNIT throughout the table is done to eliminate' duplication.

Adding MODE 4 to Containment Pressure-High is done for condistency with other TTS.

19. TTS Table 3.3-3, Containment Isolation - Adding the word

(. " signal" is a clarification.

20. TTS Table 3.3-3, Containment Spray - Adding MODE 4 to -

Containment Pressure High-High is done for consistency with other TTS.

21. ~TTS Table 3.3-3, Containment Ventilation Isolation - Deleting.

1 manual; testing is.done to reflect the as-built design. Adding ,

references tocother FUNCTIONAL UNITS is done for consistency.

22. TTS Table 3.3-3, Steam Line Isolation - Deleting reference to.

Note ## is done to reflect the as-built design. The CHANNELS TO TRIP column for input d. is clarified to reflect the as-built design.

23. TTS Table 3.3-3, Turbine Trip and Feedwater Isolation - Adding reference to the SI FUNCTIONAL UNIT is done for consistency.

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. '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 Te'chnical Specifications which are endorsed (and

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published) by the NRC. The TTS were issued ~ prior to the availabil-ity of Revision.4 of,the W-STS. 'TheDchanges 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 hasard.

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 s Systems", and the associated NRC Safety Evaluation Report .

(' (Reference 1) accepting this WCAP.

guidance provided in Reference 3.

The changes also follow NRC 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 surveillance testing when an-inoporable channel is bypassed,7and (2) increase the time'within

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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 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 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 />. Note (1) is added to TTS Table 3.3-1 for the shared RPS/ESFAS inputs. The l 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

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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 />. 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 Readtor 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 i 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 2

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.-l LC'A 117, Rev. 2 l Page 35 of 39 probability. In addition, this change doss 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. -

t III.B.

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

and the pasociated NRC Safety Evalu& tion Report (Reference-1) l accepting this WCAP. The-changes also follow NRC guidance provided in Reference 3. .

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 surveillance testing when an inoperab1'e channel is bypassed, and (2) increase the time within which an inoperable channel must be placed in the tripped condition from I hour to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. 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 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 />. 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

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in the tripped condition from I hour to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. 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 4

range flux low setpoint is to be tested during startup. Note (1) in j 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 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 typass. .. Testing isi bypass.is also recognized by IEEE. '

Standa'eds. Therefore, testing in bypass'has been.previously.'

app' roved and-implemen'tation ~o~f.the pebposed 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 fur.ctioning of the Reactor i Protection System, the possibility of a new or different kind of I

accident from any previously evaluated has not been created.

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. < s 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,

" Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation 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 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 I 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 s 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 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 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 />. 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. hours. 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/EJFAS inputs. The power range flux low setpol'nt is to' be tested,during startup. Note (1) in Table 4.3-1 is~ revise'd fr'm o 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, drif t, may act. Experience at two l

Westinghouse plants with extended surveillance intervals has shown the intial uncertainty 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 due 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 reliabilit'y.due.to. longer allowed

-repair times, and (3) improvements in.the, effectiveness of the Coperating 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.

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