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Revised Application to Amend License NPF-1,incorporating License Change Application 117,changing Tech Specs Re Reactor Trip Sys & ESFAS Instrumentation to Incorporate Revised WCAP-10271 & Westinghouse STS
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Issue date:	07/03/1986
From:	Withers B; PORTLAND GENERAL ELECTRIC CO.
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n' PORTLAND GENERAL ELECTRIC COMPANY EUGENE WATER & ELECTRIC BOARD AND PACIFIC POWER & LIGHT COMPANY TROJAN NUCLEAR PLANT ,

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Operating License NPF-1 Docket 50-344 License Change Application 117, Revision 2 This License Change Application requests modifications to Appendix A of Operating License NPF-1 for the Trojan Nuclear Plant to incorporate:

(1) changes proposed in Westinghouse Topical Report WCAP-10271,

" Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation Systems", (2) changes in the Westinghouse Standard Technical Specifications, and (3) miscellaneous improvements and corrections.

PORTLAND CENERAL ELECTRIC COMPANY By =A

Bart D. Wither's "

Vice President Nuclear Subscribed and swcen to before me this 3rd day of July 1986.

bd Notary'fublic of Orog8n ku OMyCommission

.e d 0

8607100249 860703 PDR ADOCK 05000344 P PDR ;

4 LCA 117. Rev. 2 Page 1 of 39 REASON FOR CHANCE:

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

Additional reasons for individual changes are discussed below.

DESCRIPTION OF CHANGE:

The recommended changes are as shown on the attached annotated pages and as outlined below. References 1 through 4 used throughout the text are identified at the end of this LCA (following Schedule Considerations). l A. Operating License Section 2.C(3) and Specifications 2.2.1 and 3/4.3.1:

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

B. Specification 2.2.1 Bases:

1. Power Range, Neutron Flux, High Rates:

This is changed to list the two trips separately: one for high positive rate and one for high negative rate. This is done to clarify the bases since the positive rate is not assumed tc operate in the accident analysis while the negative rate is. A statement is added to the positive rate to state that the trip is not used in the accident analysis. This agrees with TTS Tzble 3.J-2 requirements and UpJated FSAR, Chapter 15 accident analysis.

2. Intermediate and Source Range, Neutron Flux:

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

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o LCA 117, Rev. 2 Page 2 of 39

3. Pressurizer Pressure and Pressurizer Water Level:

Changes are made to clarify that these trips only occur when above the P-7 interlock setpoint.

4. Loss of Flow:

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

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

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

The specified flow rate in Ibs/hr at which the trip is actuated is revised to correct the number currently listed. Instead of

<.75 x 106 the number should be 11 51 x 106 as outlined below.

From Updated FSAR Table 5.1-1, steam flow at full power is 15.07 x 106 lbs/hr, or 3.77 x 106 lbs/hr per steam generator. Therefore, the 40 percent setpoint for the instrument e 6 or1.51x10guatestoaflowrateof(3.77x10)x(,4o) lbs/hr.

6. Undervoltage and Underfrequency - Reactor Coolant ? ump Buses:

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

7. Turbino Trip:

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

8. Auto Safety Injection Input:

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

9. Reactor Coolant Pump. Breaker Position Trip:

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

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.

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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 agree with the M-STS.

3. Intermediate Range Neutron Flux:

The APPLICABLE MODES column is revised to have applicability i

only in Modes 1 (when below P-10) and 2, as stated in the M-STS.

4. Source Range Neutron Flux:

The APPLICABLE NODES 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.

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5. Overtemperature AT and Overpower AT:

i 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 W-STS. ,

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

i 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-STJ. The addition of Note T requires the trips to be applicable only above P-7.

1 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.

' Addition of Note (1) to Pressurizer Pressure-Low conforms with the NRC guidelines provided in Reference 3. ACTION 6 is referenced for Pressurizer Level-High because ACTION 7 is 1

redundant to ACTION 6 and is deleted.

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

I 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 j 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 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 $ is added for the ressons outlined in D.6 above.

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

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

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

NOTE: The change in trip logic at P-8 shown in the W-STS for the RCP Breaker Position Trip does not occur at Trojan ,

per Drawing M-1-T-13. Sheet 5 (Updated FSAR Figure 7.2-1) .

12. Auto Safety Injection Input:

This FUNCTIONAL UNIT title is revised to " Auto Safety Injection Input" to clarify that this is from the engineered safety feature automatic actuation circuitry as shown on Drawing M-1-T-13 Sheet 8 (Updated FSAR Figure 7.2-1 Sheet 8).

i LCA 117, Rev. 2 l Page 5'of 39

, 13. Reactor Trip Breakers and Automatic Trip Logic: I a l The change splits the requirements for Modes 3, 4, and 5 (with the reactor trip breakers closed and capable of rod withdrawal) from the requirements in Modes 1 and 2 to agree with the M-STS.

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

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

b. TTS ACTION 3 does not limit operation in the power range as 4

does M-STS ACTION 3. This is done for the followirc reason.

As stated in the Bases for Specification 2.2.1, the Inter-

) mediate Range Neutron Flux Trip is not assumed to operate in any accident analysis. Therefore, there is no safety basis to have this Trip operable other than to provide backups to other trips (which are redundant in themselves). Since the 2

Inteemediate Range Trip is normally bypassed above P-10 i

(which means the Trip is essentially nonexistent), a cafety l concern does not exist for limiting power range. operation to less than P-10. Increasing power from the Intermediste ,

Range to the Power Range, when one Intermediate Range ,

channel is inoperable, will enhance the reliability of the Reactor Protection System because of the backup' trip s;

capability available in the Power Range. In other words, with one Intermediate Range Channel out of service, it is '

not logical to vary power level (<P-10) where. th'~e're is only one backup Trip (normally there are two Intermediate Range Channels) when you can go to a power'lavel (>P-10) where the Intermediate Range Trip is not utilized to provide backup.

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

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

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

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LCA 117 Rev. 2 1 Page 6 of 39

d. TTS ACTION Statements 2, 6, and 9 revised 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 . This is done in accor-dance with Reference 1, as discussed in the Significant Hazards Consideration Determination.

e. 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.

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

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

This change is consistent with FSAR Table 15.0-3 and Reference 4.

l 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 setpoints separately and associated surveillance requirements per the W-STS. The low setpoint CHANNEL FUNCTIONAL TEST is

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specified for startup per Reference 3.

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l LCA 117, Rev. 2 Page 7 of 39

3. Intermediate Range Neutron Flux:

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

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

4. Source Range Neutron Flux:

The new CHANNEL CHECK and CHANNEL CALIBRATION requirements (S, R(4,5)] are added to agree with the W-STS. In the " MODES. . . "

column, the changes are made to agree with the M-STS and revised Table 3.3-1. Reference to Note (9) is made to help ensure that the requirements of Technical Specification 4.9.2 are not over-looked. Note # is added to make TTS 4.0.4 not applicable. This will allow entry into MODE 2 (below P-6) without performing the CHANNEL FUNCTIONAL TEST since it cannot be performed when entering MODE 2 (below P-6) from a higher power level, due to an increased risk of damage to source range instrumentation.

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

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

6. Turbino Trip:

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

7. Auto Safety Injection:

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

8. Reactor Coolant Pump Breaker Position Trip:

The change to the required MODES from FA to 1* is made to make Table 4.3-1 consistent with the revised Table 3.3-1.

9. Reacter Trip Breaker and Automatic Trip Logic:

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

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

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LCA 117 Rev. 2 Page 8 of 39

10. Notation:

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

(M-STS Note 5) are made to make Table 4.3-1 consistent with the M-STS. Note (9) is added to ensure Specification 3.9.2 is properly implemented. Note (10) is added to remove the con-fusion concerning which trip signal should be used for the monthly surveillance testing.

Notes (11) and (12) are added in accordance with References 1 and 3.

The new Notes ##, ###, and 9 are added to make Table 4.3-1 consistent with the revised Table 3.3-1.

G. Technical Specification 3/4.3.2:

This Specification is revised to delete the extra .1 in the Specifi-cation number, which is not needed since there is not a Technical Specification 3/4.3.2.2.

H. Pages 3/4 3-14 through 3-30, General Comments:

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

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

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

Notes # and ## are reworded to clarify their effect on the APPLICABLE MODES column. This rewording removes the confusion about when the ACTION statements are applicable in MODE 3.

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

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LCA 117, Rev. 2 Page 9 of 39 In addition to the above, the following specific changes (listed by l function) are made:

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

Added MODE 4 to Item e for consistency with TTS 3.6.3.1. ]

Note (2) is referenced per Reference 3.

2. In part a. of the Containment 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 M-STS. Under CHANNELS TO TRIP for input d., clari-fled that the trip occurs on a trip from any two steam lines or loops.

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

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

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

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

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i LCA 117. Rev. 2 Page 10 of 39

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

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

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

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

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

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

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

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

1. Testing of the Manual Initiation is changed from M(1) to R, and Note 1 is deleted as allowed by the M-STS (NOTE: The 31-day test referenced in the former Note 1 is for plants having coincidence circuits between the manual switches and the rest of the actua-tion circuitry. Trojan does not have this configuration; there-fore, the note is not applicable).

, 2. 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 agree with revised Table 3.3-3.

5. The Modes in which surveillance is required are revised to agree with the E-STS and the revised Table 3.3-3. This includes the addition 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.

SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION:

The changes proposed fall into one of the following categories:

(1) administrative changes, (2) changes made to conform with the M-STS, (3) changes made to conform with WCAP-10271 and associated References 1 1

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LCA 117, Rev. 2 Page 11 of 39 and 3, and (4) other changes which do not pose a significant hazard. Each of these categories of changes is evaluated below.

I.A. The following changes do not involve a significant increase in the probability or consequences of an accident because they are administrative in that the changes are either corrections of errors, ,

additions to improve the technical descriptions, or clarifications to achieve consistency:

1. Operating License Section 2.c(3) and TTS 2.2.1, 3/4.3.1, and 3/4.3.2 - The removal of extra numerals in the TTS numbers is merely editorial.

2. TTS Bases 2.2.1, Power Range Neutron Flux, High Rates - Listing l the two trips separately is merely editorial to clarify which trip is assumed to operate in the accident analysis, f 3. TTS Bases 2.2.1. Intermediate and Source Range Flux -

Clarification is provided for descriptive purposes.

4. TTS Bases 2.2.1 Pressurizer Pressure, Pressurizer Water Level, Loss of Flow - Clarification is provided to reflect the as-built design for descriptive purposes.

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.

TTS Bases 2.2.1, Undervoltage and Underfrequency on RCP Buses -

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I 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.

9. TTS Tables 3.3-1 and 4.3-1, Pressurizer Pressure-Low, Pressurizer Level-High RCP Undervoltage and Underfrequency, Turbine Trip, RCP Breaker Position - Addition of Note T 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.

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LCA 117 Rev. 2 Page 12 of 39

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

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13. TTS Table 3.3-1, ACTION 8 - Deleting this ACTION and renumber-ing the subsequent ACTIONS is done 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 Table 3.3-2, RTS 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 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 preclude having to perfor1a 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 Y 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.

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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 manual testing is done to reflect the as-built design. Adding references to other FUNCTIONAL UNITS is done for consistency.

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

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

LCA 117, Rev. 2 Page 13 of 39

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

24. TTS Table 3.3-3, AFW Pumps Start - Referencing the new ACTION 21 is done for consistency with other TTS.

25. Table 3.3-3, Notes # and ## - Revision of these notes is done for clarification.

26. Table 3.3-3, Interlocks - P-12 wording is revised to reflect the as-built design. A description of P-4 and P-14 is added

. for completeness.

27. Table 3.3-3, General - Deletion of " Automatic" when referring to Actuation Logic is done to reflect the as-built design.

28. Tables 3.3-4 and 3.3-5, General - The changes made to these tables are done for simplification and consistency with other TTS.

29. Table 4.3-2, Safety Injection - Referencing back to this FUNCTIONAL UNIT throughout the table is done to eliminate.

duplication and be consistent with Table 3.3-3.

30. Table 4.3-2, General - Selected inputs are revised to be consistent with Table 3.3-3.

I.B. The following changes do not create the possibility of a new or different kind of accident because they are administrative in that the changes are either corrections of errors, additions to improve the technical descriptions, or clarifications to achieve consistency:

1. Operating License Section 2.c(3) and TTS 2.2.1, 3/4.3.1, and 3/4.3.2 - The removal of extra numerals in the TTS numbers is merely editorial.

2. TTS Bases 2.2.1, Power Range Neutron Flux, High Rates - Listing the two trips separately is merely editorial to clarify which trip is assumed to operate in the accident analysis.

3. TTS Bases 2.2.1 Intermediate and Source Range Flux -

Clarification is provided for descriptive purposes.

4. TTS Bases 2.2.1, Pressurizer Pressure, Pressurizer Water Level, Loss of Flow - Clarification is provided to reflect the as-built design for descriptive purposes.

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

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LCA 117. Rev. 2 Page 14 of 39 l l

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.

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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.

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

! Turbine Trip, RCP Breaker Position - Addition of Note Y to i 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.

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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.

13. TTS Table 3.3-1 ACTION 8 - Deleting this ACTION and renumber-

, ing the subsequent ACTIONS is done for consistency as discussed

! in the Description of Change.

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14. TTS Table 3.3-1, Reactor Trip 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. 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 preclude having to perform a CHANNEL FUNCTIONAL TEST prior to entering MODE 2 (below P-6) from a hipher power leval. 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.

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4 LCA 117. Rev. 2 Page 15 of 39

, 18. TTS Table 3.3-3, Safety Injection - The addition of Footnote j Y is for completeness. Referencing back to this FUNCTIONAL i

UNIT throughout the table 3s done to eliminate duplication.

Adding NODE 4 to Containmenc 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 NOCE 4 to Containment Pressure High-High is done for consistency with

other TTS.

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

manual testing is done to reflect the as-built design. Adding i references to other 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 l TO TRIP column for input d. is clarified to reflect the as-built design.

1

23. TTS Table 3.3-3, Turbine Trip and Feedwater Isolation - Adding -

reference to the SI FUNCTIONAL UNIT is done for consistency.

24. TTS Table 3.3-3, AFW Pumps Start - Referencing the new ACTION 21 is done for consistency with other TTS.

25. Table 3.3-3, Notes # and ## - Revision of these notes is done for clarification.

. 26. Table 3.3-3, Interlocks - P-12 wording is revised to reflect i the as-built design. A description of P-4 and P-14 is added

! for completeness.

27. Table 3.3-3, General - Deletion of " Automatic" when referring to Actuation Logic is done to reflect the as-built design.

4 1 28. Tables 3.3-4 and 3.3-5, General - The changes made to these tables are done for simplification and consistency with other TTS.

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29. Table 4.3-2, safety Injection - Referencing back to this FUNCTIONAL UNIT throughout the table is done to eliminate duplication and be consistent with Table 3.3-3.

! 30. Table 4,3-2, General - Selected inputs are revised to be j consistent with Table 3.3-3.

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o' l LCA 117, Rev. 2 Page 16 of 39 I.C. The following changes do not involve a significant reduction in a margin of safety because they are administrative in that the changes are either corrections of errors, additions to improve the technical descriptions, or clarifications to achieve consistency:

1. Operating License Section 2.c(3) and TTS 2.2.1, 3/4.3.1, and 3/4.3.2 - The removal of extra numerals in the TTS numbers is merely editorial.

2. TTS Bases 2.2.1, Power Range Neutron Flux, High Rates - Listing the two trips separately is merely editorial to clarify which trip is assumed to operate in the accident analysis.

3. TTS Bases 2.2.1, Intermediate and Source Range Flux -

Clarification is provided for descriptive purposes.

4. TTS Bases 2.2.1, Pressurizer Pressure, Pressurizer Water Level, Loss of Flow - Clarification is provided to reflect the as-built das15a for descriptive purposes.

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.

9. TTS Tables 3.3-1 and 4.3-1, Pressurizer Pressure-Low, Pressurizer 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 chan6e in the CHANNELS TO IRIP 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.

e' LCA 117, Rev. 2 Page 17 of 39

13. TTS Table 3.3-1 ACTION 8 - Deleting this ACTION and renumber-ing the subsequent ACTIONS is done 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 Table 3.3-2, RTS 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 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 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.

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 Y 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.

21. TTS Table 3.3-3, Containment Ventilation Isolation - Deleting manual testing is done to reflect the as-built design. Adding l

references to other 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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l O LCA 117. Rev. 2 Page 18 of 39

24. TTS Table 3.3-3, AFW Pumps Start - Referencing the new ACTION 21 is done for consistency with other TTS.

25. Table 3.3-3, Notes # and ## - Revision of these notes is done for clarification.

26. Table 3.3-3, Interlocks - P-12 wording is revised to reflect the as-built design. A description of P-4 and P-14 is added for completeness.

27. Table 3.3-3, Ceneral - Deletion of " Automatic" when referring to Actuation Logic is done to reflect the as-built design.

28. Tables 3.3-4 and 3.3-5, General - The changes made to these tables are done for simplification and consistency with other TTS.

29. Table 4.3-2, Safety Injection - Referencing back to this FUNCTIONAL UNIT throughout the tisle is done to eliminate duplication and be consistent with Table 3.3-3.

30. Table 4.3-2, General - Selected inputs are revised to be consistent with Table 3.3-3.

In the April 6,1983 Federal Remister, the NRC published a list of examples of amendments that are not likely to involve a significant hazards consideration. Example No. 1 applies to the above changes and states: -

"A purely administrative change to the technical specifica-tions: for example, a change to achieve consistency throughout the technical specifications, correction of an error, or a change in nomenclature."

This example is judged to apply to the above changes. Therefore, these administrative changes are deemed not to pose a significant hazard.

II.A. The changes below do not involve a significant increase in the probability or consequences of an accident previously evaluated since these changes confoca with the W-STS and, therefore, conform with regulatory guidance. In addition to conforming with the W-STS, these changes are further evaluated as follows:

1. TTS 3.0.3 - This change increases the time allowed to place the Plant into HOT STANDBY from I hour to a total of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . How-ever, this change decreases the time allowed to place the Plant in COLD SHUTDOWN from 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Therefore, the total time to attain COLD SHUTDOWN from POWER OPERATION remains

unchanged.

- , -, . _ . - - . . . . . -. .---,mm, ,-_..- ._ --,-. . _ . . - - - - - - - - _ . , - _ , - . . - .

LCA 117, Rev. 2 Page 19 of 39

2. TTS Table 3.3-1, Manual Reactor Trip - Specifically listing MODES 3*, 4*, and 5* clarifies the APPLICABLE MODES as opposed to only listing an asterisk.

3. TTS Table 3.3-1, Power Range Neutron Flux Trips - Specifica-tion 3.0.4 is made not applicable to allow entry into MODE 2 with less than the TOTAL NO. OF CHANNELS operable. ACTION 2 already allows startup to proceed with less than the TOTAL NO.

OF CHANNELS operable when in MODE 2. Therefore, entering MODE 2 with less than the TOTAL NO. OF CHANNELS should not be prevented by TTS 3.0.4, since operating in MODE 2 with less than the TOTAL NO. OF CHANNELS operable is already allowed.

This change ensures consistency throughout this TTS.

Expanding FUNCTIONAL UNIT 2 to separately identify the high and low setpoints is done to clarify the different APPLICABLE MODES for the two setpoints.

4. TTS Table 3.3-1. Intermediate Range Neutron Flux - The APPLICABLE MODES is revised to be consistent with the design in that Intermediate Range is blocked in MODE 1 when above the F-10 setpoint. Note

is deleted since the reactor trip breakers are already closed when in MODES 1 and 2, and reactor trip in other MODES is covered by the Source Range Trip.

5. TTS Table 3.3-1. Source Range Neutron Flux - The APPLICABLE MODES is revised to be consistent with the design in that Source Range is blocked in MODE 2 when above the P-6 setpoint.

This FUNCTIONAL UNIT is also revised to add the more restric-tive operability requirements of requiring both source Range channels operable in MODES 3, 4, and 5 when the reactor trip breakers are closed.

6. TTS Table 3.3-1, Overtemperature and Overpower AT - Revising the ACTION to "6" instead of "2" is done to correct an error.

I ACTIONS 2 and 6 are almost identical, except ACTION 2 has an additional provision relating to Neutron Flux setpoints and monitoring of QUADRANT POWER TILT RATIO. This provision is related to the Power and Intermediate Range trips only, and is not applicable to the Overtemperature and Overpower AT trips.

Specification 3.0.4 is made not applicable to allow entry into MODE 2 with less than the TOTAL No. OF CHANNELS operable.

ACTION 6 already allows operation to continue with less than ,

the TOTAL NO. OF CHANNELS operable when in MODE 2. Therefore, '

entering MODE 2 with less than the TOTAL NO. OF CHANNELS should )

not be prevented by TTS 3.0.4, since operating in MODE 2 with less than the TOTAL NO. OF CHANNELS operable is allowed. This change ensures consistency throughout the TTS.

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LCA 117. Rev. 2 Page 20 of 39

7. TTS Table 3.3-1 FUNCTIONAL UNITS 9 through 18 - Specifica-tion 3.0.4 is made not applicable to allow entry into MODE 2 with less than the TOTAL NO. OF CHANNELS operable. ACTION 6 already allows operation to continue with less than the TOTAL

, No. OF CHANNELS operable when in MODE 2. Therefore, entering MODE 2 with less than the TOTAL NO. OF CHANNELS should not be prevented by TTS 3.0.4, since operating in MODE 2 with less l

than the TOTAL NO. OF CHANNELS operable is allowed. This

! change ensures consistency throughout the TTS.

8. TTS Table 3.3-1, Reactor Trip Breakers and Automatic Trip Logic - Specifically listing MODES 3*, 4*, and 5* clarifies the j APPLICABLE MODES as opposed to only listing an asterisk.

! 9. TTS Table 3.3-1 ACTION 4 - Adding Note ## to Source Range

! makes it unnecessary to specify below and above P-6 in I ACTION 4. Instead, the distinct ACTION of suspending opera-tions involving reactivity changes as cited by the M-STS is an appropriate and more restrictive ACTION.

10. TTS Table 3.3-1 ACTION 10 - This change clarifles that the l' reactor trip breakers must be opened if the MINIMUM CHANNELS OPZRABLE is not met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This change is more restrictive than the current TTS in that presently the Plant j must be placed in HOT STANDBY, but there is no ACTION for opening the breakers.

11. TTS Table 4.3-1, Manual Reactor Trip - Specifying a refueling

, frequency for testing this trip not only conforms with the

! W-STS, but also is consistent with the surveillance frequency 1

cited in NRC Generic Letter 85-09, " Technical Specifications for Generic Letter 83-28, Item 4.3".

4 Specifically listing MODES 3*, 4*, and 5* clarifies the APPLICABLE MODES as opposed to only listing an asterisk.

This change is consistent with the related change made to Table 3.3-1.

12. TTS Table 4.3-1, Power Range Neutron Flux and Rates - Addition of Note 4 clarifies that neutron detectors are excluded from CHANNEL CALIBRATION since calibration of the detectors is not performed. Instead calorimetries are performed to measure power and detector output is calibrated to correspond to this measured power.

l Separating FUNCTIONAL UNIT 2 to identify the high and low l setpoints is consistent with the same change made to Table 3.3-1.

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LCA 117, Rev. 2 Page 21 of 39 l 13. TTS Table 4.3-1 Intermediate Range Neutron Flux - Addition of

! an "R" to the CHANNEL CALIBRATION column is an additional

restriction since no surveillance was specified previously.

1 Addition of Note 4 clarifies that neutron detectors are I excluded from CHANNEL CALIBRATION since calibration is not

! performed. Instead, calibration of the electronics associated

, with the neutron detectors is performed to correspond with j detector output. Addition of Note # allows entry into MODES 2-l and 1 to perform CHANNEL CALIBRATION.

Addition of Note ### and deletion of Note

in the APPLICABLE MODES column is consistent with the same change made to Table 3.3-1,

14. TTS Table 4.3-1, Source Range Neutron Flux - Addition of an "S" to the CHANNEL CHECK column and "R" to the CHANNEL CALIBRATION column are additional restrictions since no surveillance was specified previously. Addition of Notes 4 and 5 clarifies that neutron detectors are excluded from CHANNEL CALIBRATION since calibration is not performed. Instead, calibration of the electronics associated with the neutron detectors is performed to correspond with detector output. Addition of Note ## to the APPLICABLE MODES column is consistent with the same change made to Table 3.3-1.

15. TTS Table 4.3-1, Auto Safety Injection Input - The CHANNEL FUNCTIONAL TEST is changed from M(4) to R to be consistent with ,

the on-line testing capability of the design and Table 4.3-2, l ESFAS. The surveillance performed consists of an actual trip {

of the actuating device which cannot be performed during operation, since the reactor would be tripped. Therefore, this testing is performed during refueling. The input device and logic tests are governed by Table 4.3-2 and are performed on a monthly basis.

16. TTS Table 4.3-1, Reactor Trip Breaker and Automatic Trip Logic - The change to the APPLICABLE MODES column is consistent with the same change made to Table 3.3-1,

17. TTS Table 4.3-1, Note 2 - Expanding this note to require channel adjustment is an additional restriction since no adjustment was specified previously. I

18. TTS Table 4.3-1, Note 5 - This note is an additional restrie-tion since the TTS did not previously specify that detector plateau curves must be obtained and evaluated.

19. TTS Table 4.3-1, Note 6 - This note is an additional restric-tion since the TTS did not previously specify an incore-excore calibration.

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LCA 117. - Rev. 2

{ Page 22 of 39

20. TTS Table 4.3-1, Note 8 - Addition of this note is a clarifica-tion. Setpoint verification of hydraulic control oil pressure is performed during CHANNEL CALIBRATION. The CHANNEL FUNC-TIONAL TEST only confirms actuation of the pressure switches.

Setpoint verification of the turbine stop valve closure reactor j trip is not applicable because the trip is actuated by valve

closure. Therefore, there is no setpoint to verify.

21. TTS Table 3.3-3, Safety Injection - For FUNCTIONAL UNITS 1.c.

d, e, and f, Specification 3.0.4 is made not applicable to

, allow entry into MODES with less than the TOTAL NO. OF CHANNELS l operable. ACTION 14 already allows continued operation with i less than the TOTAL NO. OF CHANNELS operable. Therefore, i

entering an APPLICABLE MODE with less than the TOTAL NO. OF CHANNELS operable should not be prevented by Specifica-i tion 3.0.4, since operating in the APPLICABLE MODE with less than the TOTAL NO. OF CHANNELS operable is already allowed. ;

j This change ensures consistency throughout this TTS.

I j 22. TTS Table 3.3-3, Steam Line Isolation - Mode 4 is deleted from i the APPLICABLE MODES column to be consistent with TTS 3.7.1.6, l

" Main Steam Isolation Valves (MSIVs)". Since the MSIVs need not be operable in MODE 4, the associated ESFAS instrumentation i is not required to be operable.

ACTION 20 is referenced for the " Manual" FUNCTIONAL UNIT to be i consistent with the ACTION in TTS 3.7.1.6 for an inoperable

MSIV. ACTION 19 is referenced for the " Actuation Logic" FUNC-

! TIONAL UNIT because placing the Plant in HOT SHUTDOWN, as

) opposed to COLD SHUTDOWN, is all that is required. Since NOT i SHUTDOWN (MODE 4) is no longer an APPLICABLE MODE as discussed l above, attaining HOT SHUTDOWN satisfies the TTS.

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Specification 3.0.4 is made not applicable to FUNCTIONAL

$ UNIT 4.d for the same reason as discussed previously, is,

) ACTION 14 allows continued operation with less than the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE MODE can be entered with less than the TOTAL NO. OF CHANNELS operable.

23. TTS Table 3.3-3, Turbine Trip and Feedwater Isolation - MODE 3 J is deleted from the APPLICABLE MODES columns since turbine trip and feedwater isolation ars not required in MODE 3. The j transition from NODE 3 to MODE 2 during a startup occurs when l the reactor is made critical. Since the main turbine and feed-1 water system are not made operational until after criticality, l'

and well into MODE 2 MODE 3 should not be applicable for this FUNCTIONAL UNIT.

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LCA 117. Rev. 2 Page 23 of 39 i l Specification 3.0.4 is made not applicable to this FUNCTIONAL !

UNIT for the same reason as discussed previously, io. ACTION 14 )

allows continued operation with less than the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE MODES can be entered with less than the TOTAL NO. OF CHANNELS operable.

1

24. TTS Table 3.3-3, Auxiliary Feedwater Pumps Start - The ACTION for " Steam Generator Water Level - Low-Low" is changed to ACTION 14 for consistency. Steam Generator Water Level -

Low-Low serves as an input to both the reactor trip system and ESFAS. In TTS Table 3.3-1.for the reactor trip system, the applicable ACTION for Steam Generator Water Level - Low-Low is ACTION 6. ACTION 6 allows continued operation with one less than the TOTAL NO. OF CHANNELS operable. Therefore, it follows that in TTS Table 3.3-3 for ESFAS, the applicable ACTION for Steam Generator Water Level Low-Low should also allow continued operation with one less than the TOTAL NO. OF CHANNE S operable. ACTION 14 accomplishes this.

Specification 3.0.4 is made not applicable to Steam Generator Water Level - Low-Low for the same reason as discussed previ-

ously, ie, ACTION 14 allows continued operation with less than the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE MODE can be entered with less than the TOTAL NO. OF CHANNELS '

operable.

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25. Table 3.3-3, ACTIONS 13 through 16 - The proposed changes are provided merely for editorial consistency to conform with the l W-STS.

i i 26. Table 4.3-2, Manual Safety Injection - The CHANNEL FUNCTIONAL j TEST is changed from M(1) to R to be consistent with the on-line testing capability of the design. The surveillance performed consists of actuation of the manual switches which would cause a safety injection if performed during operation.

Therefore, the testing is performed during refueling.

27. Table 4.3-2, Note 3 - This note is deleted since it is pre-l scriptive information which is more appropriately contained in l the test procedure. Deleting this note does not change the requirement to perform a CHANNEL FUNCTIONAL TEST. '

4 II.B. The changes below do not create a new or different kind of acpident from any accident previously evaluated since these changes conform with the W-STS and, therefore, conform with regulatory guidance. In addition to conforming with the W-STS, these changes are further i

! evaluated as follows:

1. TTS 3.0.3 - This change increases the time allowed to place the l

Plant into HOT STANDBY from I hour to a total of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . How-ever, this change decreases the time allowed to place the plant i

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LCA 117 Rev. 2 5

Page 24 of 39 4

in COLD SHUTDOWN from 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Therefore, the total time to attain COLD SHUTDOWN from POWER OPERATION remains unchanged.

2. TTS Table 3.3-1, Manual Reactor Trip - Specifically listing MODES 3*, 4*, and 5* clarifies the APPLICABLE MODES as opposed to only listing an asterisk.

3. TTS Table 3.3-1, Power Kange Neutron Flux Trips - Specifica-tion 3.0.4 is made not applicable to allow entry into MODE 2

}

4 with less than the TOTAL NO. OF CHANNELS operable. ACTION 2 already allows startup to proceed with less than the TCTAL NO.

OF CHANNELS operable when in MODE 2. Therefore, entering l MODE 2 with less than the TOTAL NO. OF CHANNELS should not be

! prevented by TTS 3.0.4, since operating in MODE 2 with less j

than the TOTAL NO. OF CHANNELS operable is already allowed.

j This change ensures consistency throughout this TTS.

[1 Expanding FUNCTIONAL UNIT 2 to separately identify the high and j low setpoints is done to clarify the different APPLICABLE MODES 1 for the two setpoints.

4. TTS Table 3.3-1. Intermediate Range Neutron Flux - The APPLICABLE MODES is revised to be consistent with the design in that Intermediate Range is blocked in MODE 1 when above the P-10 setpoint. Note

is deleted since the reactor trip breakers are already closed when in MODES 1 and 2, and reactor trip in other MODES is covered by the Source Range Trip.

} S. TTS Table 3.3-1. Source Range Neutron Flux - The APPLICABLE 1 MODES is revised to be consistent with the design in that I

Source Range is blocked in MODE 2 when above the P-6 setpoint.

f This FUNCTIONAL UNIT is also revised to add the more restric-1 tive operability requirements of requiring hath Source Range

] channels operable in MODES 3, 4, and 5 when the reactor trip j breakers are closed.

< 6. TTS Table 3.3-1, Overtemperature and overpower AT - Revising

, the ACTION to "6" instead of "2" is done to correct an error.

3 ACTIONS 2 and 6 are almost identical, except ACTION 2 has an j additional provision relating to Neutron Flux setpoints and

! monitoring of QUADRANT POWER TILT RATIO. This provisict, is i related to the Power and Intermediate Range tcips only, and is j not applicable to the overtemperature and Overpower AT trips, i Specification 3.0.4 is made not applicable to allow entry into MODE 2 with less than the TOTAL NO. OF CHANNELS operable.

i ACTION 6 already allows operation to continue with less than the TOTAL No. OF CHANNELS operable when in MODE 2. Therefore, entering MODE 2 wit'n less than the TOTAL NO. OF CHANNELS should l

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4 LCA 117. Rev. 2 Page 25 of 39

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not be prevented by TTS 3.0.4, since operating in MODE 2 with less than the TOTAL NO. OF CHANNELS operable is allowed. This 3 change ensures consistency throughout the TTS.

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7. TTS Table 3.3-1, FUNCTIONAL UNITS 9 through 18 - Specifica-

) tion 3.0.4 is made not applicable to allow entry into MODE 2 i

with less than the TOTAL NO. OF CHANNELS operable. ACTION 6 already allows operation to continue with less than the TOTAL

, NO. OF CHANNELS operable when in MODE 2. Therefore, entering 4

MODE 2 with less than the TOTAL No. OF CHANNELS should not be

)

prevented by TTS 3.0.4, since operating in MODE 2 with less than the TOTAL NO. OF CHANNELS operable is allowed. This

change ensures consistency throughout the TTS.

. 8. TTS Table 3.3-1, Reactor Trip Breakers and Automatic Trip Logic 1

- Specifically listing NODES 3*, 4*, and 5* clarifies the APPLICABLE NODES as opposed to only listing an asterisk.

9. TTS Table 3.3-1 ACTION 4 - Adding Note ## to source Range

! makes it unnecessary to specify below and above P-6 in ACTION 4 Instead, the distinct ACTION of suspending opera-tions involving reactivity changes as cited by the M-STS is an appropriate and more restrictive ACTION.

10. TTS Table 3.3-1. ACTION 10 - This change clarifies that the reactor trip breakers must be opened if the MININUM CHANNELS OPERABLE is not met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This change is more restrictive than the current TTS in that presently the plant must be placed in HOT STANDBY, but there is no ACTION for opening the breakers.

11. TTS Table 4.3-1, Manual Reactor Trip - Specifying a refueling frequency for testing this trip not only conforms with the M-STS, but also is consistent with the surveillance frequency cited in NRC Ceneric Letter 85-09, " Technical Specifications

, for Generic Letter 83-28, Item 4.3".

Specifically listing NODES 3*, 4*, and 5* clarifies the APPLICABLE MODES as opposed to only listing an asterisk.

This change is consistent with the related change made to 1

Table 3.3-1. '

12. TTS Table 4.3-1, power Range Neutron Flux and Rates - Addition of Note 4 clariflos that neutron detectors are excluded from CHANNEL CALIBRATION since calibration of the detectors is not performed. Instead calorimetrics are performed to measure power and detector output is calibrated to correspond to this

{ measured power. '

- ,,,r.,, ,s _.____ , _ - _ _ . _. . . w... _ ._---__-___.,,___m. ,_.-__.,,..m, , _ . ,. _. _ _ . , _ . , _ . _ _ ,-m - - - ., ,,

LCA 117, Rev. 2 Page 26 of 39 Separating FUNCTIONAL UNIT 2 to identify the high and low setpoints is consistent with the same change made to Table 3.3-1.

13. TTS Table 4.3-1 Intermediate Range Neutron Flux - Addition of an "R" to the CHANNEL CALIBRATION column is an additional restriction since no surveillance was specified previously. ,

Addition of Note 4 clarifies that neutron detectors are excluded from CHANNEL CALIBRATION since calibration is not performed. Instead, calibration of the electronics associated with the neutron detectors is performed to correspond with detector output. Addition of Note # allows entry into MODES 2 and 1 to perform CHANNEL CALIBRATION.

l Addition of Note ### and deletion of Note

in the APPLICABLE MODES column is consistent wi.th the same change made to Table 3.3-1,

14. TTS Table 4.3-1, source Range Neutron Flux - Addition of an "S" to the CHANNEL CHECK column and "R" to the CHANNEL CALIBRATION column are additional restrictions since no surveillance was specified previously. Addition of Notes 4 and 5 clarifles that neutron detectors are excluded from CHANNEL CALIBRATION since calibration is not performed. Instead, calibration of the electronics associated with the neutron detectors is performed i to correspond with detector output. Addition of Note ## to the APPLICABLE MODES column is consistent with the same change made to Table 3.3-1.

1 15. TTS Table 4.3-1 Auto Safety Injection Input - The CHANNEL FUNCTIONAL TEST is changed from M(4) to R to be consistent with the on-line testing capability of the design and Table 4.3-2, ESFAS. The surveillance performed consists of an actual trip of the actuating device which cannot be performed during opera-tion, since the reactor would be tripped. 'Therefore, this testing is performed during refueling. The input device and logic tests are governed by Table 4.3-2 and are performed on a monthly basis.

16. TTS Table 4.3-1, Reactor Trip Breaker sed Automatic Trip Logic - The change to the APPLICABLE MODES column is consistent j with the same change made to Table 3.3-1.

17. TTS Table 4.3-1 Note 2 - Expanding this note to require channel adjustment is an additional restriction since no adjustment was specified previously.

18. TTS Table 4.1-1, Note 5 - This note is an additional restric-tion since the TTS did not previously specify that detector plateau curves must be obtained and evaluated.

f LCA 117 Rev. 2 Page 27 of 39

19. TTS Table 4.3-1, Note 6 - This note is an additional restrie-tion since the TTS did not previously specify an incore-excore calibration.

~

20. TTS Table 4.3-1, Note 8 - Addition of this note is a clarifica-tion. Setpoint verification of hydraulic control oil pressure is performed during CHANNEL CALIBRATION. The CHANNEL FUNC-TIONAL TEST only confirms actuation of the pressure switches.

Setpoint verification of the turbine stop valve closure reactor trip is not applicable because the trip is actuated by valve closure. Therefore, there is no setpoint to verify.

21. TTS Table 3.3-3, Safety Injection - For FUNCTIONAL UNITS 1.c.

d, e, and f, Specification 3.0.4 is made not applicable to

, allow entry into NODES with less than the TOTAL No. OF CHANNELS operable. ACTION 14 already allows continued operation with

! less than the TOTAL NO. OF CHANNELS operable. Therefore,

! entering an APPLICABLE NODE with less than the TOTAL NO. OF CHANNELS operable should not be prevented by Specifica-tion 3.0.4, since operating in the APPLICABLE NODE with less than the TOTAL NO. OF CHANNELS operable is already allowed.

This change ensures consistency throughout this TTS.

22. TTS Table 3.3-3, Steam Line Isolation - Mode 4 is deleted from the APPLICABLE MODES column to be consistent with TTS 3.7.1.6, ,

" Main Steam Isolation Valves (NSIVs)". Since the NSIVs need

not be operable in NODE 4, the associated ESFAS instrumentation is not required to be operable.

ACTION 20 is referenced for the " Manual" FUNCTIONAL UNIT to be

' consistent with the ACTION in TTS 3.7.1.6 for an inoperable MSIV. ACTION 19 is referenced for the " Actuation Logic" FUNC-TIONAL UNIT because placing the Plant in HOT SHUTDOWN, as i opposed to COLD SHUTDOWN, is all that is required. Since HOT SHUTDOWN (MODE 4) is no longer an APPLICABLE MODE as discussed I

above, attaining HOT SHUTDOWN satisfies the TTS.

i Specification 3.0.4 is made not applicable to FUNCTIONAL UNIT 4.d for the same reason as discussed previously, is, ACTION 14 l allows continued operation with less than the TOTAL NO. OF

{

CHANNELS operable, therefore, the APPLICABLE MODE can be entered with less than the TOTAL NO. OF CHANNELS operable.

23. TTS Table 3.3-3, Turbine Trip and Feedwater Isolation - NODE 3 is deleted from the APPLICABLE MODES colunes since turbine trip and feedwater isolation are not required in NODE 3. The

, transition from MODE 3 to MODE 2 during a startup occurs when j

the reactor is made critical. Since the main turbine and feed-l water system are not made operational until after criticality, i and well into MODE 2, MODE 3 should not be applicable for this l FUNCTIONAL UNIT.

i l

I

LCA 117, Rev. 2 Page 28 of 39 Specification 3.0.4 is made not applicable to this FUNCTIONAL UNIT for the same reason as discussed previously, ie, ACTION 14

allows continued operation with less than the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE MODES can be entered with less than the TOTAL NO. OF CHANNELS operable.

24. TTS Table 3.3-3, Auxiliary Feedwater Pumps Start - The ACTION

, for " Steam Generator Water Level - Low-Low" is changed to

ACTION 14 for consistency. Steam Generator Water Level -

l Low-Low serves as an input to both the reactor trip system and

ESFAS. In TTS Table 3.3-1 for the reactor trip system, the i applicable ACTION for Steam Generator Water Level - Low-Low is i

ACTION 6. ACTION 6 allows continued operation with one less 4

than the TOTAL No. OF CHANNELS operable. Therefore, it follows that in TTS Table 3.3-3 for ESFAS, the applicable ACTION for Steam Generator Water Level - Low-Low should also allow con-

} tinued operation with one less than the TOTAL NO. OF CHANNELS j operable. ACTION 14 accomplishes this.

l

! Specification 3.0.4 is made not applicable to Steam Generator l Water Level - Low-Low for the same reason as discussed previ-j ously, ie, ACTION 14 allows continued operation with less than i the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE i

MODE can be entered with less than the TOTAL No. OF CHANNELS l operable.

t

25. Table 3.3-3, ACTIONS 13 through 16 - The proposed changes are provided merely for editorial consistency to conform with the i W-STS.

26. Table 4.3-2, Manual Safety Injection - The CHANNEL FUNCTIONAL 1

TEST is changed from H(1) to R to be consistent with the on-line testing capability of the design. The surveillance performed consists of actuation of the manual switches which I would cause a safety injection if performed during operation.

j Therefore, the testing is performed during refueling.

} 27. Table 4.3-2, Note 3 - This note is deleted since it is pre- ,

j scriptive information which is more appropriately contained in I

the test procedure. Deleting this note does not change the i requirement to perform a CHANNEL FUNCTIONAL TEST.

1 II.C. The changes below do not involve a significant reduction in a margin of safety since these changes conform with the W-STS and, therefore, 1 conform with regulatory guidance. In addition to conforming with 1 the W-STS, these changes are further evaluated as follows:

1. TTS 3.0.3 - This change increases the time allowed to place the '

Plant into HOT STANDBY from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to a total of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . How-ever, this change decreases the time allowed to place the Plant i

J

, ,,__-.,,wn .,, , - - . - - - , . - - . . - - - . - - . - . _ - - , ~ , . . - . . . - . - - . .

.,m- . - , _ . _ , . . _ . ~,--...,m,.-e , . - - . , . - , , , , - . ,

LCA 117. Rev. 2 Page 29 of 39 in COLD SHUTDOWN from 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Therefore, the total time to attain COLD SHUTDOWN from POWER OPERATION remains unchanged.

2. TTS Table 3.3-1 Manual Reactor Trip - Specifically listing MODES 3*, 4*, and 5* clarifies the APPLICABLE MODES as opposed l to only listing an asterisk.

I 3. TTS Table 3.3-1 Power Range Neutron Flux Trips - Specifica-tion 3.0.4 is made not applicable to allow entry into MODE 2 with less than the TOTAL NO. OF CHANNELS operable. ACTION 2 already allows startup to proceed with less than the TOTAL NO.

OF CHANNELS operable when in MODE 2. Therefore, entering MODE 2 with less than the TOTAL NO. OF CHANNELS should not be prevented by TTS 3.0.4, since operating in MODE 2 with less than the TOTAL NO. OF CHANNELS operable is already allowed.

This change ensures consistency throughout this TTS.

i Expanding FUNCTIONAL UNIT 2 to separately identify the high and i

low setpoints is done to clarify the different APPLICABLE MODES for the two setpoints.

4. TTS Table 3.3-1 Intermediate Range Neutron Flux - The ,

i APPLICABLE MODES is revised to be consistent with the design in that Intermediate Range is blocked in MODE 1 when above the P-10 setpoint. Note

is deleted since the reactor trip breakers are already closed when in MODES 1 and 2, and reactor trip in other MODES is covered by the Source Range Trip.

5. TTS Table 3.3-1, Source Range Neutron Flux - The APPLICABLE MODES is revised to be consistent with the design in that Source Range is blocked in MODE 2 when above the P-6 setpoint.

This FUNCTIONAL UNIT is also revised to add the more restric-tive operability requirements of requiring both Source Range channels operable in MODES 3, 4, and 5 when the reactor trip breakers are closed.

6. TTS Table 3.3-1, Overtemperature and Overpower AT - Revising the ACTION to "6" instead of "2" is done to correct an error.

ACTIONS 2 and 6 are almost identical, except ACTION 2 has an additional provision relating to Neutron Flux setpoints and monitoring of QUADRANT POWER TILT RATIO. This provision is related to the Power and Intermediate Range trips only, and is

! not applicable to the Overtemperature and Overpower AT trips.

Specification 3.0.4 is made not applicable to allow entry into MODE 2 with less than the TOTAL NO. OF CHANNELS operable.

ACTION 6 already allows operation to continue with less than the TOTAL NO. OF CHANNELS operable when in MODE 2. Therefore, entering MODE 2 with less than the TOTAL NO. OF CHANNELS should i

i .,

LCA 117, Rev. 2 l Page 30 of 39 i

! i not be prevented by TTS 3.0.4 since operating in MODE 2 with less than the TOTAL NO. OF CHANNELS operable is allowed. This

change ensures consistency throughout the TTS.

l

, 7. TTS Table 3.3-1 FUNCTIONAL UNITS 9 through 18 - Specifica-l tion 3.0.4 is made not applicable to allow entry into MODE 2 i with less than the TOTAL NO. OF CHANNELS operable. ACTION 6 ,

j already allows operation to continue with less than the TOTAL l l NO. OF CHANNELS operable when in MODE 2. Therefore, entering MODE 2 with less than the TOTAL NO. OF CHANNELS should not be l 1 prevented by TTS 3.0.4, since operating in MODE 2 with less '

j than the TOTAL NO. OF CHANNELS operable is allowed. This j change ensures consistency throughout the TTS.

! 8. TTS Table 3.3-1, Reactor Trip Breakers and Automatic Trip Logic - Specifically listing MODES 3*, 4*, and 5* clarifies the -

, APPLICABLE MODES as opposed to only listing an asterisk.

I i

9. T*S Table 3.3-1, ACTION 4 - Adding Note ## to Source Range

! makes it unnecessary to specify below and above P-6 in

! ACTION 4. Instead, the distinct ACTION of suspending opera-

$ tions involving reactivity changes as cited by the M-STS is an

appropriate and more restrictive ACTION.

10. TTS Table 3.3-1 ACTION 10 - This change clarifies that the

reactor trip breakers must be opened if the MINIMUM CHANNELS j OPERABLE is not met within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . This change is more

restrictive than the current TTS in that presently the Plant

must be placed in HOT STANDBY, but there is no ACTION for j opening the breakers.

1

} 11. TTS Table 4.3-1, Manual Reactor Trip - Specifying a refueling j frequency for testing this trip not only conforms with the i M-STS, but also is consistent with the surveillance frequency

cited in NRC Ceneric Letter 85-09, " Technical Specifications

{ for Generic Letter 83-28, Item 4.3".

Specifically listing MODES 3*, 4*, and 5* clarifies the APPLICABLE MODES as opposed to only listing an asterisk.

This change is consistent with the related change made to Table 3.3-1.

j 12. TTS Table 4.3-1. Power Range Neutron Flux and Rates - Addition j of Note 4 clarifies that neutron detectors are excluded from j CHANNEL CALIBRATION since calibration of the detectors is not t

performed. Instead calorimetrics are performed to measure

power and detector output is calibrated to correspond to this measured power.

t i

1

]

I f,.

j LCA 117, Rev. 2 Page 31 of 39 Separating FUNCTIONAL UNIT 2 to identify the high and low setpoints is consistent with the same change made to i Table 3.3-1.

13. TTS Table 4.3-1, Intermediate Range Neutron Flux - Addition of an "R" to the CHANNEL CALIBRATION column is an additional restriction since no surveillance was specified previously.

Addition of Note 4 clarifies that neutron detectors are i excluded from CHANNEL CALIBRATION since calibration is not

, performed. Instead, calibration of the electronics associated l with the neutron detectors is performed to correspond with detector output. Addition of Note # allows entry into NODES 2 and 1 to perform CHANNEL CALIBRATION.

Addition of Note ### and deletion of Note

in the APPLICABLE j MODES column is consistent with the same change made to Table 3.3-1.

14. TTS Table 4.3-1, Source Range Neutron Flux - Addition of an "S" to the CHANNEL CHECK column and "R" to the CHANNEL CALIBRATION i column are additional restrictions since no surveillance was

] specified previously. Addition of Notes 4 and 5 clarifies that j neutron detectors are excluded from CHANNEL CALIBRATION since '

calibration is not performed. Instead, calibration of the j electronics associated with the neutron detectors'is performed to correspond with detector output. Addition of Note ## to the l APPLICABLE NODES column is consistent with the same change made j

to Table 3.3-1.

4 j

15. TTS Table 4.3-1, Auto safety Injection Input - The CHANNEL j FUNCTIONAL TEST is changed from N(4) to R to be consistent with the on-line testing capability of the design and Table 4.3-2 ESFAS. The surveillance performed consists of an actual trip of the actuating device which cannot be performed during j

operation, since the reactor would be tripped. Therefore, this testing is performed during refueling. The input device and

logic tests are governed by Table 4.3-2 and are performed on a ,

, monthly basis.

16. TTS Table 4.3-1, Reactor Trip Breaker and Automatic Trip Logic

- The change to the APPLICABLE MODES column is consistent with the same change made to Table 3.3-1.

I 17. TTS Table 4.3-1, Note 2 - Expanding this note to require

] channel adjustment is an additional restriction since no l

adjustment was specified previously.

18. TTS Table 4.3-1, Note 5 - This note is an additional restric-

tion since the TTS did not previously specify that detector

{ plateau curves must be obtained and evaluated.

l l

3

+ .

LCA 117 Rev. 2 Page 32 of 39

19. TTS Table 4.3-1, Note 6 - This note is an additional restric-tion since the TTS did not previously specify an incore-excore calibration.

20. TTS Table 4.3-1 Note 8 - Addition of this note is a clarifica-tion. Setpoint verification of hydraulic control oil pressure is perfor1ned during CHANNEL CALIBRATION. The CHANNEL FUNC-TIONAL TEST only confirms actuation of the pressure switches.

Setpoint verification of the turbine stop valve closure reactor trip is not applicable because the trip is actuated by valve closure. Therefore, there is no setpoint to verify.

I

21. TTS Table 3.3-3, Safety Injection - For FUNCTIONAL UNITS 1.c.

d, e, and f, Specification 3.0.4 is made not applicable to allow entry into MODES with less than the TOTAL NO. OF CHANNELS operable. ACTION 14 already allows continued operation with less than the TOTAL NO. OF CHANNELS operable. Therefore, entering an APPLICABLE MODE with less than the TOTAL NO. OF CHANNELS operable should not be prevented by Specifica-tion 3.0.4, since operating in the APPLICABLE MODE with less than the TOTAL NO. OF CHANNELS operable is already allowed.

This change ensures consistency throughout this TTS.

22. TTS Table 3.3-3, Steam Line Isolation - Mode 4 is deleted from the APPLICABLE MODES column to be consistent with TTS 3.7.1.6,

" Main Steam Isolation Valves (MSIVs)". Since the MSIVs need not be operable in MODE 4, the associated ESFAS instrumentation is not required to be operable.

ACTION 20 is referenced for the " Manual" FUNCTIONAL UNIT to be consistent with the ACTION in TTS 3.7.1.6 for an inoperable MSIV. ACTION 19 is referenced for the " Actuation Logic" FUNCTIONAL UNIT because placing the Plant in HOT SHUTDOWN, as opposed to COLD SHUTDOWN, is all that is required. Since HOT SHUTDOWN (MODE 4) is no longer an APPLICABLE MODE as discussed above, attaining HOT SHUTDOWN satisfies the TTS.

Specification 3.0.4 is made not applicable to FUNCTIONAL UNIT 4.d for the same reason as discussed previously, ie, ACTION 14 allows continued operation with less than the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE MODE can be entered with less than the TOTAL NO. OF CHANNELS operable.

23. TTS Table 3.3-3 Turbine Trip and Feedwater Isolation - MODE 3 is deleted from the APPLICABLE MODES columns since turbine trip and feedwater isolation are not required in MODE 3. The transition from MODE 3 to MODE 2 during a startup occurs when the reactor is made critical. Since the main turbine and feed-water system are not madt operational until after criticality, and well into MODE 2. MODE 3 should not be applicable for this FUNCTIONAL UNIT.

t

, i'

t LCA 117, Rev. 2 i \ Page 33 of 39 Specification 3.0.4 is made not applicable to this FUNCTIONAL '

} UNIT for the same reason as discussed previously, ie, ACTION 14 allows continued operation with less than the TOTAL NO. OF -

l CHANNELS operable, therefore, the APPLICABLE NODES can be entered with less than the TOTAL NO. OF CHANNELS operat'le. s j 24. TTS Table 3.3-3. Auxiliary Feedwater Pumps Start - The ACTION ' '

i for " Steam Generator Water Level - Low-Low" is changed to ,

ACTION 14 for consistency. Steam Generator Water Level -

Low-Low serves as an input to both the reactor trip system and ESFAS. In TTS Table 3.3-1 for the reactor trip system, the applicable ACTION for Steam Generator Water Level - Low-Low is

$ ACTION 6. ACTION 6 allows continued operation with one less

l than the TOTAL NO. OF CHANNELS operable. Therefore, it follows i that 'in TTS Table 3.3-3 for ESFAS, the applicable ACTION for i

' Steam Cenerator Water Level - Low-Low should also allow con-tinued operation with one less than the TOTAL NO. OF CHANNELS j operable. ACTION 14 accomplishes this.

Specification 3.0.4 is made not applicable to Steam Generator Water Level - Low-Low for the same reason as discussed previ-ously, ie, ACTION 14 allows continued operation with less than

! the TOTAL NO. OF CHANNELS operable, therefore, the APPLICABLE j

MODE can be entered with less than the TOTAL NO. OF CHANNELS

, operable.

J

! 25. Table 3.3-3, ACTIONS 13 through 16 - The proposed changes are

provided merely for editorial consistency to conform with the j W-STS.

i j 26. Table 4.3-2, Manual Safety Injection - The CHANNEL FUNCTIONAL i TEST is changed from M(1) to R to be consistent with the

on-line testing capability of the design. The surveillance performed consists of actuation of the manual switches which l would cause a safety injection if performed during operation.

Therefore, the testing is perfomed during refueling.

j

27. Table 4.3-2, Note 3 - This note is deleted since it is pre-i scriptive information which is more appropriately contained in j

the test procedure. Deleting this note does not change the i j requirement to perform a CHANNEL FUNCTIONAL TEST.

J

] In the April 6, 1983 Federal Reaister, the NRC published a list of examples of amendments that are not likely to involve a significant hazards consideration. Example No. 7 of that list applies to the i above changes and states:

"A change to make a license conform to changes in the regula-l tions, where the license change results in very minor changes l '

to facility operations clearly in keeping with the regulations."

i i

4 4*

j LCA 117 Rev. 2

page 34 of 39 1

, This example is judged to apply to the above changes which are made i

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-i ity of Revision 4 of the M-STS. The changes 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-j 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 NRC j guidance provided in Reference 3.

Table 3.3-1 ACTION Statements 1, 2, 6, and 8 are revised to allow I 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing instsad 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 )

i .

monthly to quarterly. In addition, Table 3.3-1 ACTION Statements 2 j and 6 are revised to: (1) allow surveillance testing when an inoperable channel is bypassed, and (2) increase the time within j

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 j

revised to increase the time within which an inoperable channel must i

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).

l is added to TTS Table 3.3-1 for the shared RPS/ESFAS inputs.

ACTION 7 is deleted from TTS Table 3.3-1. Notes (11) and (12) are j

added to TTS Table 4.3-2 .br those inputs tested on a staggered l basis and for the shared RPS/ESFAS inputs e The power range flux low j 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.

s 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 Withou$ !

Trip (ATWT), and in the probability of core melt resulting from' an l ATWT. However, this change is expected to result in a significant '

reduction in the probability of core melt from inadvertent reactor j

trips. This is a result of a reduction in the number of inadvertent reactor trips occurring during testing of Reactor Protection System j 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 j probability. In addition, this change does not increase the conse-quences of an accident since it does not alter the manner in which I protection is afforded nor the manner in which limiting criteria are established.

LCA 117, Rev. 2 Page 35 of 39 i

III.B. The following changes do not create the possibility of a new or different kind of 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)

accepting this WCAP. The changes also follov 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 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 j 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 i

from I hour 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 j revised to 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 . Note (1) is added tc TTS Table 3.3-1 for the shared RPS/ESFAS inputs.

4 ACTION 7 is deleted from TTS Table 3.3-1. 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 n.ot 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 approved and implementation of the proposed changes for testing in bypass does not create the possibility of a new or different kind of !

accident from any previously evaluated. Furthermore, since the '

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

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 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

= .

LCA 117. Rev. 2 Page 36 of 39 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 Statament 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.

ACTION 7 is deleted from TTS Table 3.3-1. 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, es, drif t, may act. Experience at two Westinghouse plants with extended surveillance intervals has shown the intial uncertainty asrumptions 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 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.

1. As stated in the Bases for Specification 2.2.1, the Intermedi-ate Range Neutron Flux Trip is not assumed to operate in any accident analysis. Therefore, there is not a safety basis to

. have this trip OPERABLE.

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

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. . i LCA 117 Rev. 2 Page 37 of 39

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

4. Reference 2 states that changes in OPERATIONAL NODES, es, increasing power above 5 percent (MODE 2 to MODE 1), with selected equipment inoperable, is acceptable on a case basis if adequately justified. Consistent with the NRC guidance supplied in Reference 2, the necessary justification is provided in Items 1 through 3 above.

The change to Table 3.3-1 ACTION 3, to allow continued operation above the P-6 setpoint with an Intermediate Range Flux channel inoperab.le does not create the possibility of a new or different kind of accident because the Intermediate Range Flux Trip is not assumed to operate in any accident analysis. Therefore, its operability is not relevant to creating an accident.

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 reduction in a margin of safety as discussed below.

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

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

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

4. Reference 2 states that changes in OPERATIONAL MODES, es, increasing power above 5 percent (MODE 2 to MODE 1), with selected equipment inoperable, is acceptable on a case basis if adequately justified. Consistent with the NRC guidance supplied in Reference 2, the necessary justification is provided in Items 1 through 3 above.

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

LCA 117, Rev. 2 Page 38 of 39 IV.B. The change in Table 3.3-2 to reduce the response time for the Overtemperature AT trip does not involve a significant increase in !

the probability or consequences of an accident. This change is made as directed by the NRC in Reference 4. In addition, this change constitutes an additional restriction not presently included in the TTS.

The change in Table 3.3-2 to reduce the response time for the i

Ov6ctemperature AT trip does not create the possibility of a new or different kind of accident. This change is made as directed by the NRC in Reference 4. In addition, this change constitutes an additional restriction not presently included in the TTS. t The change in Table 3.3-2 to reduce the response time for the Overtemperature AT trip does not involve a significant reduction }

in a margin of safety. This change is made as directed by the NRC in Reference 4. In addition, this change constitutes an additional restriction not presently included in the TTS.

l In the April 6, 1983 Federal Reaister, the NRC published a list of examples of amendments that are not likely to involve a significant hazards consideration. Example No. 2 applies to the above change to Table 3.3-2 and states:

"A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications, eg, a more stringent surveillance required."

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

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

SCHEDULE CONSIDERATION It is requested that the effective date of this amendment be 30 days after receipt by PGE.

REFERENCES

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

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

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LCA 117 Rev. 2 Page 39 of 39 3.

Letter form H. R. Denton (NRC) to L. D. Butterfield (WOG) regarding l guidelines for preparing Reactor Trip System technical specification changes, dated July 24, 1985.

4.

Letter form E. J. Butcher (NRC) to B. D. Withers (PGE) regarding Reactor Trip System response time, dated June 6, 1985.

l BLK/kal 5501k.686 i

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