NRC Generic Letter 1996-03
UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR REACTOR REGULATIONWASHINGTON, D.C. 20555-00O-1-----January 31, 1996NRC GENERIC LETTER 96-03: RELOCATION OF THE PRESSURE TEMPERATURE LIMIT CURVESAND LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEMLIMITS
Addressees
All holders of operating licenses or construction permits for nuclear powerreactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter toadvise licensees that they may request a license amendment to relocate thepressure temperature (P/T) limit curves from their plant technicalspecifications (TS) to a pressure temperature limits report (PTLR) or asimilar document. The low temperature overpressure protection (LTOP) systemlimits may also be relocated to the same document at the discretion of thelicensee.
Description of Circumstances
During the development of the improved standard technical specifications(STS), a change was proposed to relocate the P/T curves and LTOP setpointcurves and values currently contained in the TS to a licensee-controlleddocument. As one of the improvements to the STS, the NRC staff agreed withthe industry that the curves and setpoints may be relocated outside the TS toa licensee-controlled document so that the licensee could maintain theselimits efficiently and at a lower cost, provided that the parameters forconstructing the curves and setpoints are derived using a methodology approvedby the NRC.DiscussionTechnical specifications include limiting conditions for operation (LCOs) thatestablish P/T and LTOP system limits for the reactor coolant system. Thelimits are defined by figures and values that provide an acceptable range ofoperating temperatures and pressures for heatup, cooldown, low temperatureoverpressure, criticality, and inservice leak and hydrostatic testingconditions. These parameters are generally valid for a specified number ofeffective full-power years or for a specified fluence period (the period forwhich the curves are calculated to be applicable).License amendments are generally required at the end of the effective periodfor P/T limit curves or when surveillance specimens are withdrawn and tested.Also, each time the P/T curves are revised, the LTOP system must be9601290350TeKI'1 GL 96-03January 31, 1996 reevaluated to ensure that its functional requirements can still be met.Processing amendment requests for changes to TS that are developed using anaccepted methodology places an unnecessary burden on licensee and NRCresources. An alternative approach for controlling these limits was proposedduring the development of the improved STS. This approach, like the one usedfor the core operating limits, would relocate the P/T curves and LTOP setpointcurves or values to a PTLR or a similar document and would reference thatdocument in the affected LCOs and bases.The methodology used to determine the P/T and LTOP system limit parametersmust comply with the specific requirements of Appendices G and H to Part 50 ofTitle 10 of the Code of Federal Regulations (10 CFR), be documented in an NRC-approved topical report or in a plant-specific submittal, and be incorporatedby reference into the TS. Subsequent changes in the methodology must beapproved by a license amendment; 10 CFR 50.59 does not apply.Requested InformationLicensees and applicants who choose to adopt this line item improvement areencouraged to propose changes that are consistent with the attached guidance.However, licensees may propose changes, with justification, that differ fromthis guidance. The guidance requires that the licensee be able to reference amethodology for developing the curves and setpoints that has been approved bythe NRC, develop a PTLR or a similar document that contains the figures,values, parameters, and any explanations derived from the methodology, andmake appropriate changes to the applicable sections of the TS. The NRCproject manager for the facility will review the amendment requests thatconform to the guidance in this generic letter and will coordinate theappropriate staff review of the methodology proposed for calculating the P/Tlimit curves and LTOP system limits. Amendment requests that do not conformto the guidance in this generic letter will require additional review time.Required ResponseLicensees and applicants who choose to adopt this line item improvement areasked to submit the requested information described above to the U.S. NuclearRegulatory Commission, ATTN: Document Control Desk, Washington, D.C.20555-000
- GL 96-03January 31, 1996
Backfit Discussion
Any action by licensees to propose changes to TS in accordance with theguidance in this generic letter is voluntary and, therefore, is not a backfitunder 10 CFR 50.109. The staff, therefore, did not perform a backfitanalysis.
Federal Register Notification
The staff published a notice of opportunity for public comment in theFederal Register (60 FR 28805) on June 2, 1995.
Paperwork Reduction Act Statement
The voluntary information collections contained in this request are covered bythe Office of Management and Budget clearance number 3150-0011, which expireson July 31, 1997. The public reporting burden for this collection ofinformation is estimated to average 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per response, including the timefor reviewing instructions, searching existing data sources, gathering andmaintaining the data needed, and completing and reviewing the collection ofinformation. Send comments regarding this burden estimate or any other aspectof this collection of information, including suggestions for reducing thisburden, to the Information and Records Management Branch (T-6 F33),U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to theDesk Officer, Office of Information and Regulatory Affairs, NEOB-10202(3150-0011), Office of Management and Budget, Washington, D.C. 20503.The following information, although not requested under the provisions of10 CFR 50.54(f), would help the NRC to evaluate licensee cost to propose TSchanges in accordance with this generic letter:1. licensee staff time and costs to prepare the requested reports anddocumentation and2. an estimate of the long-term costs or savings accruing from the responseto this generic lette GL 96-03January 31, 1996 If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate Office of Nuclear Reactor Regulation(NRR) project manager.ennis M. Cru fie, DirectorDivision of Reacto rProgram ManagementOffice of Nuclear Reactor RegulationTechnical contact: Maggalean W. Weston, NRR(301) 415-3151Internet:mww@nrc.gov
Attachments:
1. Guidance for a Proposed License Amendmentto Relocate the Pressure TemperatureLimit Curves and Low TemperatureOverpressure Protection System Limits2. Model Safety Evaluation3. Model Technical Specifications:a. Definitionsb. Pressure Temperature Limitsc. Low Temperature Overpressure Protection Systemd. Administrative Controls4. List of Recently Issued Generic LetterseA- -7A# /e Attachment 1GL 96-03January 31, 1996 GUIDANCE FOR A PROPOSED LICENSE AMENDMENTTO RELOCATE THE PRESSURE TEMPERATURE LIMIT CURVESAND LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM LIMITSINTRODUCTIONThis attachment to the generic letter contains guidance for preparing alicense amendment request to modify the technical specifications (TS) torelocate the pressure temperature (P/T) limit curves and low temperatureoverpressure protection (LTOP) system limits currently contained in the plantTS to a pressure temperature limits report (PTLR) or a similar document. Thisalternative was based on a change included in the improved standard technicalspecifications (STS) to remove the P/T limit curves and LTOP system limitsfrom the TS and relocate them to a PTLR or a similar document to reduce thenumber of amendment requests associated with changes to these curves andlimits. Since an amendment request must be submitted whenever a change ismade to the TS, the relocation of the P/T curves and LTOP system limits willresult in a resource savings for the licensees and the NRC by eliminatingunnecessary license amendment requests for changes to the P/T limit curves andLTOP system limits in TS. To relocate the P/T curves and LTOP system limitsfrom the TS, the licensee must be able to reference a methodology approved bythe NRC for deriving the parameters used for constructing the curves andsetpoints, develop a PTLR or a similar document, and make appropriate changesto the applicable sections of the TS.In evaluating the relocation, the NRC staff concluded that, while it isessential to safety to operate the plant within the bounds of P/T limits andto satisfy the regulations that ensure the integrity of the reactor coolantpressure boundary (RCPB), the periodic adjustment of those limits to accountfor time-dependent parametric changes could be calculated in accordance with amethodology approved by the NRC. Criterion 2 of both 10 CFR Part 50, whichwas published in the Federal Register (58 FR 39132) on July 22, 1993, and10 CFR 50.36(c)(2)(ii)(B), which was published in the Federal Register(60 FR 36953) on July 19, 1995, require that the TS include operatingrestrictions (P/T limits) needed to preclude unanalyzed accidents andtransients. However, once the methodology is approved, the licensee maymodify the figures, values, and parameters without the need for a licenseamendment and without affecting nuclear safety, provided that these changesare determined using the approved methodology and are consistent with allapplicable limits of the plant design assumptions as stated in the finalsafety analysis report (FSAR). Additionally, the licensee must submit to theNRC a formal PTLR or a similar document containing the figures, values, andparameters derived from the application of the methodology approved by theNRC. This reporting requirement augments a reporting requirement that isalready in effect.Section III of Appendix H to 10 CFR Part 50 currentlyrequires a summary technical report of data relating to capsule withdrawal andspecimen test results. Application of these results will also be included inthe PTLR. This report will allow the NRC staff to continue monitoring the Attachment 1GL 96-03January 31, 1996 status of the structural integrity of the reactor vessel even through priorNRC approval of the changes to these limits would not be required if thelimits do not involve an unreviewed safety question.A provision was also added to the "Administrative Controls" section of the TSindicating that the figures, values, and parameters for inclusion in the PTLRwill be verified after each reactor vessel fluence period or when surveillancespecimens are withdrawn and tested and the PTLR submitted to the NRC. Hence,the staff can confirm proper application of the methodology approved by theNRC. Further, the .PTLR will be referenced in the TS so that the same degreeof control on plant operation will be maintained. As a result, thisalternative provides the same assurance of compliance with designspecifications as before, yet removes the unnecessary burden on both plant andNRC staff of processing amendment requests.DISCUSSIONTechnical specifications include limiting conditions for operation (LCOs) thatestablish P/T limits for the reactor coolant system (RCS). This system isdesigned to withstand the effects of cyclic loads resulting from systemtemperature and pressure changes. These cyclic loads are introduced by normalload transients, reactor trips, startup and shutdown operations, andhydrostatic and leak rate tests. During startup and shutdown, the rates oftemperature and pressure changes are limited so that the maximum specifiedheatup and cooldown rates are consistent with the design assumptions andsatisfy operating limits that provide a wide margin of safety to brittlefailure of the reactor vessel. The P/T limits are periodically modified asthe reactor vessel material toughness decreases as a result of materialembrittlement caused by neutron irradiation. The periodic modifications arenecessary when the applicable effective full-power years (EFPYs) or fluenceperiod for the P/T limits contained in the TS are about to expire or when thereactor vessel material surveillance data indicate an increase in the nil-ductility transition reference temperature (RTNDT).As required by Appendix G to 10 CFR Part 50, operating P/T limits arecalculated and adhered to by plant operations personnel to ensure thatfracture toughness requirements for the RCPB are maintained. Further, inaccordance with Appendix H to 10 CFR Part 50, specimens of reactor vesselmaterial are installed near the inside reactor vessel wall and are withdrawnon a schedule to provide data on the effects of radiation fluence and thethermal environment on the vessel material. These data are used to adjust theP/T limits, as necessary, to compensate for the shift in material transitiontemperature as indicated by tests on the withdrawn specimens. The withdrawaland analysis of the specimens, and resulting revision of the P/T limit curves,make up the requirements necessary to compensate for the shift in materialtransition temperature. This ensures that the reactor vessel is operated athigh enough temperatures to preclude brittle fracture of the vessel materia Attachment 1GL 96-03January 31, 1996 The LTOP system controls RCS pressure at low operating temperatures so thatthe integrity of the RCPB is not compromised by violating the P/T limits ofAppendix G to 10 CFR Part 50. The LTOP system provides overpressureprotection by limiting coolant input capability and having adequate pressurerelief capacity. Each time the P/T limit curves are revised, the LTOP systemmust be reevaluated to ensure that its functional requirements can still bemet. LTOP system limits may be relocated to the PTLR or retained in the TS.The LTOP system for pressure relief typically consists of two power-operatedrelief valves (PORVs), two residual heat removal (RHR) suction relief valves,or a combination of both. Some plants have only one PORV. The LTOP systemlimits consist of PORV and RHR relief valve setpoints. The RHR suction reliefvalves do not have variable pressure lift setpoints as the PORVs do and,therefore, are still addressed in the TS. As designed for the LTOP system,each PORV is signaled to open if the RCS pressure approaches a limitdetermined by the LTOP system actuation logic. This logic monitors both RCStemperature and RCS pressure to determine when a condition not acceptable inthe PTLR is approached. The PORV setpoints may be included in the PTLR andshould be updated when the revised P/T limits conflict with the LTOP systemlimits. LTOP requirements do not apply to boiling water reactors.REQUIREMENTS FOR RELOCATING THE CURVES AND SETPOINTSRelocation of the curves and setpoints to a licensee-controlled documentrequires three separate licensee actions. The licensee must (1) have amethodology approved by the NRC to reference in its TS; (2) develop a reportsuch as a PTLR or a similar document to contain the figures, values,parameters, and any explanation necessary; and (3) modify the applicablesections of the TS accordingly.* Methodologv and PTLRThe first two of the three requirements for relocating the P/T curves and LTOPsystem limits are an NRC-approved methodology and the associated reportingrequirements in the PTLR. The methodology will consist of only those methodsused for calculation, not the calculations themselves. The PTLR will consistof the explanations, figures, values, and parameters derived from thecalculations. Since the PTLR will be provided to the NRC upon issuance aftereach fluence period or EFPYs and after approval of the methodology, a PTLRshould be provided when the methodology is submitted so that questionsregarding the content and format of the PTLR can be addressed prior to itsformal completion.The following table shows the relationship between the provisions, ifapplicable, specified in the STS for the approved methodology and therequirements to be included in the methodology and the PTLR. The provisionsfor the methodology are those shown in the "Administrative Controls" sectionof the ST Attachment IGL 96-03Janaury 31, I1996REQUIREMENTS FOR
METHODOLOGY
AND PTLRPROVISIONS FOR
METHODOLOGY
MINIMUM REQUIREMENTS TO MINIMUM REQUIREMENTS TOFROM ADMINISTRATIVE CONTROLS BE INCLUDED IN BE INCLUDED IN PTLRSECTION IN STS
METHODOLOGY
1. The methodology shall Describe transport Provide the values ofdescribe how the neutron calculation methods neutron fluences that arefluence is calculated including computer codes used in the adjusted(reference new regulator and formulas used to reference temperatureguide when it is issued). calculate neutron (ART) calculation.fluence. Providereferences.2. The Reactor Vessel Briefly describe the Provide the surveillanceMaterial Surveillance surveillance program. capsule withdrawalProgram shall comply with Licensee transmittal schedule, or reference byAppendix H to 10 CFR Part letter should identify by title and number the50. The reactor vessel title and number report documents in which thematerial irradiation containing the Reactor schedule is located.surveillance specimen Vessel Surveillanceremoval schedule shall be Program and surveillance Reference theprovided, along with how capsule reports. surveillance capsulethe specimen examinations Topical/generic report reports by title andshall be used to update contains placeholder number if ARTs arethe PTLR curves. only. Reference Appendix calculated usingl H to 10 CFR Part 50. surveillance data.3. Low temperature Describe how the LTOP Provide setpoint curvesoverpressure protection system limits are or setpoint values.(LTOP) system limits calculated applyingdeveloped using NRC- system/thermal hydraulicsapproved methodologies and fracture mechanics.may be included in the Reference SRP SectionPTLR. 5.2.2; ASME Code CaseN-514; ASME Code,Appendix G,Section XI asapplied in accordancewith 10 CFR 50.55.4. The adjusted reference Describe the method for Identify both thetemperature (ART) for calculating the ART using limiting ART values andeach reactor beltline Regulatory Guide 1.99, limiting materials at thematerial shall be Revision 2. 1/4t and 3/4t locationscalculated, accounting (t = vessel beltlinefor irradiation thickness).embrittlement, inaccordance with PWRs -identify RTPTsRegulatory Guide 1.99, value in accordance withRevision 2. 10 CFR 50.6 Attachment 1GL 96-03January 31, 1996 . The limiting ART shall be Describe the application Provide the P/T curvesincorporated into the of fracture mechanics in for heatup, cooldown,calculation of the constructing P/T curves criticality, andpressure and temperature based on ASME Code, hydrostatic and leaklimit curves in Appendix G,Section XI, tests.accordance with NUREG- and SRP Section 5.3.2.0800, SRP Section 5.3.2,Pressure-TemperatureLimits. .6. The minimum temperature Describe how the minimum Identify minimumrequirements of Appendix temperature requirements temperatures on the P/TG to 10 CFR Part 50 shall in Appendix G to 10 CFR curves such as minimumbe incorporated into the Part 50 are applied to boltup temperature andpressure and temperature P/T curves. hydrotest temperature.limit curves.7. Licensees who have Describe how the data Provide supplemental dataremoved two or more from multiple and calculations of thecapsules should compare surveillance capsules are chemistry factor in thefor each surveillance used in the ART PTLR if the surveillancematerial the measured calculation. data are used in the ARTincrease in reference calculation.temperature (RTNDT) to Describe procedure ifthe predicted increase in measured value exceeds Evaluate the surveillanceRTND ; where the predicted value. data to determine if theypredicted increase in meet the credibilityRTNDT is based on the WHEN OTHER PLANT DATA ARE criteria in Regulatorymean shift in RTIDT plus USED Guide 1.99, Revision 2.the two standard 1. Identify the source(s) Provide the results.deviation value (2a ) of data when other plantspecified in Regulatory data are used.Guide 1.99, Revision 2.If the measured value 2.a Identify by titleexceeds the predicted and number the safetyvalue (increase in RTNDT evaluation report that+ 2a ), the licensee approved the use of datashould provide a for the plant. Justifysupplement to the PTLR to applicability.demonstrate how theresults affect the ORapproved methodology.2.b Compare licenseedata with other plantdata for both theradiation environments(e.g., neutron spectrum,irradiation temperature)and the surveillance testresult Attachment 1GL 96-03January 31, 1996 Technical SDecificationsThe following changes must be made to the plant TS to complete the threerequirements for relocating the curves and setpoints to an alternativedocument.Three separate actions are necessary to modify the plant TS: (1) "Definitions"-the addition of the definition of a named formal report (PTLR or a similardocument) that would contain the explanations, figures, values, and parametersderived in accordance with an NRC-approved methodology and consistent with allof the design assumptions and stress limits for cyclic operation; (2) LCOs -the addition of references to the PTLR noting that the P/T limits shall bemaintained within the limits specified in the PTLR; and (3) "AdministrativeControls" -the addition of a reporting requirement to submit the PTLR to theNRC, when it is issued, for each reactor vessel fluence period.1. DefinitionsSection 1.0, "Definitions," should contain the following language:PRESSURE TEMPERATURE LIMITS REPORT (PTLR)The PTLR is the unit-specific document that provides the reactorvessel P/T limits and setpoints, including heatup and cooldownrates, for the current reactor vessel fluence period. These P/Tlimits shall be determined for each fluence period or effectivefull-power years (EFPYs) in accordance withSpecification 5.X.X.X. Plant operation within these operatinglimits is addressed in LCO 3.X.X, "RCS Pressure and Temperature(P/T) Limits," and LCO 3.X.X, "Low Temperature OverpressureProtection (LTOP) System."2. Limiting Conditions for Oneration (LCOs) and BasesLCO 3.X.X, "RCS Pressure and Temperature (P/T) Limits," and LCO 3.X.X, "LowTemperature Overpressure Protection (LTOP) System," must reference the PTLRas the document where the limits and curves can be found as demonstrated inthe attached model TS. The bases for these LCOs should be modifiedaccordingly.3. Administrative ControlsSection 5.X, "Administrative Controls," Subsection 5.X.X, "ReportingRequirements," must contain the following information:
Attachment 1GL 96-03January 31, 1996 Section 5.X.X.X Reactor Coolant System (RCS) PRESSURE AND TEMPERATURELIMITS REPORT (PTLR)a. RCS pressure and temperature limits for heatup, cooldown, LTOP,criticality, and hydrostatic testing as well as heatup and cooldownrates shall be established and documented in the PTLR for thefollowing: [The individual specifications that address RCS pressureand temperature limits must be referenced here.]b. The analytical methods used to determine the RCS pressure andtemperature limits shall be those previously reviewed and approved bythe NRC, specifically those described in the following document(s):[Identify the NRC staff approval document(s) by date.]c. The PTLR shall be provided to the NRC upon issuance for each reactorvessel fluence period or EFPYs and for any revision or supplementtheret Attachment 2GL 96-03January 31, 1996 MODEL SAFETY EVALUATION (SE)Underscored blank spaces are to be completed on the basis of the applicablefacility information. The information in brackets should be used, asapplicable, on a plant-specific basis.SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TOAMENDMENT NO. TO FACILITY OPERATING LICENSE NFP-_[UTILITY NAME][PLANT NAME], [UNIT_]DOCKET NO. 50-1.0 INTRODUCTIONBy letter dated , 19 _ , [utility name] (the licensee) proposed changesto the technical specifications (TS) for [plant name]. The requested changesare the relocation of the pressure temperature (P/T) limit curves and lowtemperature overpressure protection (LTOP) system limits to the [named plant-specific report] and the referencing of that report in the affected limitingconditions for operation and bases. The proposed changes also include theaddition of the [named plant-specific report] to the definitions section ofthe TS and the addition of a new section to the reporting requirements in theadministrative controls section of the TS delineating the necessary reports.Guidance on the proposed changes was developed by the Nuclear RegulatoryCommission (NRC) on the basis of a proposal by the owners groups during thedevelopment of the improved standard technical specifications (STS). Thisguidance was provided to all power reactor licensees and applicants by GenericLetter YY-XX, dated ,_19__, .2.0
BACKGROUND
Section 182a of the Atomic Energy Act (the Act) requires applicants fornuclear power plant operating licenses to include TS as part of the license.The Commission's regulatory requirements related to the content of TS are setforth in 10 CFR 50.36. That regulation requires that the TS include items infive specific categories: (1) safety limits, limiting safety system settingsand limiting control settings; (2) limiting conditions for operation;(3) surveillance requirements; (4) design features; and (5) administrativecontrols, and states also that the Commission may include such additional TSas it finds to be appropriate. However, the regulation does not specify theparticular requirements to be included in a plant's TS.The Commission has provided guidance for the contents of TS in its "FinalPolicy Statement on Technical Specifications Improvements for Nuclear PowerReactors" (Final Policy Statement), 58 FR 39132 (July 22, 1993), in which theCommission indicated that compliance with the Final Policy Statement satisfiesSection 182a of the Act. In particular, the Commission indicated that certain Attachment 2GL 96-03January 31, 1996 items could be relocated from the TS to licensee-controlled documents,consistent with the standard enunciated in Portland General Electric Co.(Trojan Nuclear Plant), ASLAB-531, 9 NRC 263, 273 (1979). In that case, theAtomic Safety and Licensing Appeal Board indicated that "technicalspecifications are to be reserved for those matters as to which the impositionof rigid conditions or limitations upon reactor operation is deemed necessaryto obviate the possibility of an abnormal situation or event giving rise to animmediate threat to the public health and safety."Consistent with this approach, the Final Policy Statement identified fourcriteria to be used in determining whether a particular matter is required tobe included in the TS, as follows: (1) installed instrumentation that is usedto detect, and indicate in the control room, a significant abnormaldegradation of the reactor coolant pressure boundary; (2) a process variable,design feature, or operating restriction that is an initial condition of adesign basis accident or transient analysis that either assumes the failure ofor presents a challenge to the integrity of a fission product barrier; (3) astructure, system, or component that is part of the primary success path andwhich functions or actuates to mitigate a design basis accident or transientthat either assumes the failure of or presents a challenge to the integrity ofa fission product barrier; (4) a structure, system, or component whichoperating experience or probabilistic safety assessment has shown to besignificant to public health and safety. As a result, existing TSrequirements which fall within or satisfy any of the criteria in the FinalPolicy Statement must be retained in the TS, while those TS requirements whichdo not fall within or satisfy these criteria may be relocated to otherlicensee-controlled documents.3.0 EVALUATIONAll components of the reactor coolant system (RCS) are designed to withstandthe effects of cyclic loads resulting from system pressure and temperaturechanges. These loads are introduced by heatup and cooldown operations, powertransients, and reactor trips. In accordance with Appendix G to 10 CFRPart 50, TS limit the pressure and temperature changes during RCS heatup andcooldown within the design assumptions and the stress limits for cyclicoperation. These limits are defined by P/T limit curves for heatup, cooldown,LTOP, and inservice leak and hydrostatic testing. Each curve defines anacceptable region for normal operation. The curves are used for operationalguidance during heatup and cooldown maneuvering, when pressure and temperatureindications are monitored and compared to the applicable curve to determinethat operation is within the allowable region.1 The Commission promulgated a change to 10 CFR 50.36, which amends therule to codify and incorporate these criteria. See Final Rule, "TechnicalSpecifications," 60 FR 36953 (July 19, 1995).
Attachment 2GL 96-03January 31, 1996 [Reviewer Note: While the NRC is completing the rulemaking process forrevisions to 10 CFR 50.55a and 10 CFR Part 50, Appendix G, licensees using theAmerican Society of Mechanical Engineers Boiler and Pressure Vessel CodeCase N-514 must request an exemption from Appendix G. The following orsimilar language should be included in the SE:The licensee used the American Society of Mechanical Engineers Boiler andPressure Vessel Code Case N-514 and requested an exemption from Appendix G byJustifying why Appendix G cannot be met and demonstrating that a specificexemption was warranted under 10 CFR 50.12.]The LTOP system controls RCS pressure at low temperatures so that theintegrity of the reactor coolant pressure boundary is not compromised byviolating 10 CFR Part 50, Appendix G. [Reviewer Note: The following sentencesshould be modified to identify the specific LTOP system being referred to inthe SE: The LTOP system for pressure relief, for most plants, consists ofpower-operated relief valves (PORVs), residual heat removal suction reliefvalves, or a combination of both. Some plants have one PORV. The LTOP systemlimits consist of PORV and RHR setpoints. The RHR suction relief valves donot have variable pressure and temperature lift setpoints like the PORVs and,therefore, are still addressed in the TS.] The LTOP system is reevaluatedeach time the P/T limit curves are revised to ensure that it meets itsintended function.The licensee-proposed changes to the TS are in accordance with the guidance inGeneric Letter YY-XX, as follows:(1) The definitions section of the TS was modified to include a definitionof the [named report] to which the figures, values, and parameters forP/T and LTOP system limits will be relocated on a unit-specific basisin accordance with a methodology approved by the NRC that maintainsthe acceptance limits and the limits of the safety analysis. As notedin the definition, plant operation within these limits is addressed byindividual specifications.(2) The following specifications were revised to replace the P/T and LTOPsystem limits with a reference to the [named report] that providesthese limits:[Provide list of specifications by number and title.](3) Specification [number], "[title]," was added to the reportingrequirements of the administrative controls section of the TS. Thisspecification requires that the [named report] be submitted, uponissuance, to the NRC Document Control Desk with copies to the regionaladministrator and resident inspector. The report provides theexplanations, figures, values, and parameters of the P/T and LTOPsystem limits for the applicable effective period. Furthermore, thisspecification requires that the figures, values, and parameters be Attachment 2GL 96-03January 31, 1996 established using the methodology approved by the NRC for this purposein [topical report or NRC letter approving a plant-specificmethodology] and be consistent with all the applicable acceptancelimits and the limits of the safety analysis.Finally, the specification requires that all changes in values ofthese limits be documented in the [named report] each effective periodand submitted upon issuance to the NRC.Relocation of the P/T curves and LTOP setpoints does not eliminate therequirement to operate in accordance with the limits specified in Appendix Gto 10 CFR Part 50. The requirement to operate within the limits in the namedreport or pressure temperature limits report (PTLR) is specified in andcontrolled by the TS. Only the figures, values, and parameters associatedwith the P/T limits and LTOP setpoints are to be relocated to the PTLR. Inorder for the curves and setpoints to be relocated to a PTLR, a methodologyfor their development must be reviewed and approved in advance by the NRC.The methodology to be approved by the NRC is to be developed in accordancewith GL 96-03. This generic letter delineates the requirements for both themethodology and the PTLR including, but not limited to, the requirements ofAppendix G to 10 CFR Part 50. The PTLR review process requires that changesto the methodology be approved by the NRC. Further, when changes are made tothe figures, values, and parameters contained in the PTLR, the PTLR is to beupdated and submitted to the NRC upon issuance.On this basis, the NRC staff concludes that the licensee provided anacceptable means of establishing and maintaining the detailed values of theP/T limit curves and LTOP system limits. Further, because plant operationcontinues to be limited in accordance with the requirements of Appendix Gto 10 CFR Part 50 and the P/T and LTOP system limits in the TS will beestablished using a methodology approved by the NRC, these changes will notimpact plant safety.The staff also concludes that the relocated requirements discussed aboverelating to the P/T limits and LTOP system limits are not required to be inthe TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act, and arenot required to obviate the possibility of an abnormal situation or eventgiving rise to an immediate threat to the public health and safety.Additionally, they do not fall within any of the four criteria set forth inthe Commission's Final Policy Statement, discussed above. Accordingly, thestaff concludes that the proposed changes are acceptable and that theserequirements may be relocated from the TS to the PTLR.4.0 STATE CONSULTATIONThe Commission consulted with the State of [ ]. No public comments werereceived, and the State of [ _ ] did not have any comment Attachment 2GL 96-03January 31, 1996 .0 ENVIRONMENTAL CONSIDERATIONThe amendment involves changes to requirements with respect to use of facilitycomponents located within the restricted area, as defined in 10 CFR Part 20,changes with respect to surveillance requirements, and changes inadministrative procedures or requirements. The NRC staff determined that theamendment involves no significant increase in the amounts and no significantchange in the types of any effluents that may be released off site and thatthere is no significant increase in individual or cumulative occupationalexposure. The Commission made a determination that the amendment involves nosignificant hazards consideration, which was published in the Federal Register(53 FR _ ) on _ _, 19._ , and there has been no public comment regardingsuch a finding. Accordingly, the amendment meets the eligibility criteria forcategorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuantto 10 CFR 51.22(b), no environmental impact statement or environmentalassessment need be prepared in connection with the issuance of the amendment.6.0 CONCLUSIONOn the basis of the considerations discussed above, the NRC staff concludesthat (1) there is reasonable assurance that the health and safety of thepublic will not be endangered by operation in the proposed manner, (2) suchactivities will be conducted in compliance with the Commission's regulations,and (3) the issuance of this amendment will not be inimical to the commondefense and security or to the health and safety of the public.Principal Contributor: Maggalean W. Weston, TSBDated: _-, 19_
I kAttachment 3aGL 96-03January 31, 1996 Definitions1.11.0 USE AND APPLICATION1.1 Definitions_____-----------------------------NOTE-------------------------------------The defined terms of this section appear in capitalized type and areapplicable throughout these Technical Specifications and Bases.TermDefinitionPRESSURE ANDTEMPERATURE LIMITSREPORT (PTLR)QUADRANT POWER TILTRATIO (QPTR)RATED THERMAL POWER(RTP)REACTOR TRIPSYSTEM (RTS) RESPONSETIMESHUTDOWN MARGIN (SDM)The PTLR is the unit specific document thatprovides the reactor vessel pressure andtemperature limits, including heatup and cooldownrates, for the current reactor vessel fluence period.These pressure and temperature limits shall bedetermined for each fluence period in accordance withSpecification 5.6.6. Plant operation within theseoperating limits is addressed in LCO 3.4.3, ARCSPressure and Temperature (P/T) Limits,' andLCO 3.4.12, "Low Temperature Overpressure Protection(LTOP) System."QPTR shall be the ratio of the maximum upperexcore detector calibrated output to the average ofthe upper excore detector calibrated outputs, or theratio of the maximum lower excore detector calibratedoutput to the average of the lower excore detectorcalibrated outputs, whichever is greater.RTP shall be a total reactor core heat transferrate to the reactor coolant of [2893] MWt.The RTS RESPONSE TIME shall be that time intervalfrom when the monitored parameter exceeds its RTStrip setpoint at the channel sensor until loss ofstationary gripper coil voltage. The response timemay be measured by means of any series of sequential,overlapping, or total steps so that the entireresponse time is measured.SDM shall be the instantaneous amount of reactivity bywhich the reactor is subcritical or would besubcritical from its present condition assuming:
Attachment 3bGL 96-03January 31, 1996 .4 REACTOR COOLANT SYSTEM (RCS)3.4.X RCS Pressure and Temperature (P/T) LimitsLCO 3.4.X RCS pressure, RCS temperature, and RCS heatup and cooldown ratesshall be maintained within the limits specified in the PTLR.APPLICABILITY:At all times.ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. ---------NOTE--------- A.1 Restore parameter(s) 30 minutesRequired Action A.2 to within limits.shall be completedwhenever this ANDCondition is entered.______________________ A.2 Determine RCS is 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />sacceptable forRequirements of LCO continued operation.not met in MODE 1, 2,3, or 4.B. Required Action and B.1 Be in MODE 3. 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />sassociated CompletionTime of Condition A ANDnot met.B.2 Be in MODE 5 with RCS 36 hour4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />spressure< [500] psig.(continued)
Attachment 3bGL 96-03.IJanuary 31, 1996 ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEC. ---------NOTE--------- C.1 Initiate action to ImmediatelyRequired Action C.2 restore parameter(s)shall be completed to within limits.whenever thisCondition is entered. AND______________________C.2 Determine RCS is Prior toRequirements of LCO acceptable for entering MODE 4not met any time in continued operation.other than MODE 1, 2,3, or 4.SURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.4.X.X -------------------NOTE--------------------Only required to be performed during RCSheatup and cooldown operations and RCSinservice leak and hydrostatic testing.___________________________________________Verify RCS pressure, RCS temperature, and 30 minutesRCS heatup and cooldown rates are withinthe limits specified in the PTL Attachment 3cGL 96-03January 31, 1996 .4 REACTOR COOLANT SYSTEM (RCS)3.4.X Low Temperature Overpressure Protection (LTOP) SystemLCO 3.4.X An LTOP System shall be OPERABLE with a maximum of [one] [highpressure injection (HPI)] pump [and one charging pump] capableof injecting into the RCS and the accumulators isolated andeither a or b below.a. Two RCS relief valves, as follows:1. Two power operated relief valves (PORVs) with liftsettings within the limits specified in the PTLR,or[2. Two residual heat removal (RHR) suction reliefvalves with setpoints 2 [436.5] psig and< [463.5] psig, or][3. One PORV with a lift setting within the limitsspecified in the PTLR and one RHR suction reliefvalve with a setpoint 2 [436.5] psig and< [463.5] psig].b. The RCS depressurized and an RCS vent of 2 [2.07] squareinches.APPLICABILITY: MODE 4 when all RCS cold leg temperature is < [275]0F,MODE 5,MODE 6 when the reactor vessel head is on.-___---------------------- -NOTE----------------------------Accumulator isolation is only required when accumulatorpressure is greater than or equal to the maximum RCSpressure for the existing RCS cold leg temperature allowedby the P/T limit curves provided in the PTL Attachment 3cGL 96-03' ' January 31, 1996 ACTIONSCONDITION REQUIRED ACTION COMPLETION TIMEA. Two or more [HPI] A.1 Initiate action to Immediatelypumps capable of verify a maximum ofinjecting into the [one] [HPI] pump isRCS. capable of injectinginto the RCS.B. Two or more charging B.1 --------NOTE----------pumps capable of Two charging pumpsinjecting into the may be capable ofRCS. injecting into theRCS during pump swapoperation for< 15 minutes._____________________Initiate action to Immediatelyverify a maximum of[one] charging pumpis capable ofinjecting into theRCS.C. An accumulator not C.1 Isolate affected 1 hourisolated when the accumulator.accumulator pressureis greater than orequal to the maximumRCS pressure forexisting cold legtemperature allowed inthe PTLR.(continued)
Attachment 3cGL 96-03, , January 31, 1996 A r TALIC' I --- * -..-AALI I UI, 1LuEnb IIIuCu)_CONDITION REQUIRED ACTION COMPLETION TIMED. Required Action and D.1 Increase RCS cold leg 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />sassociated Completion temperature toTime of Condition [C] > [275]0F.not met.ORD.2 Depressurize affected 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />saccumulator to lessthan the maximum RCSpressure for existingcold leg temperatureallowed in the PTLR.E. One required RCS E.1 Restore required RCS 7 daysrelief valve relief valve toinoperable in MODE 4. OPERABLE status.F. One required RCS F.1 Restore required RCS 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />srelief valve relief valve toinoperable in MODE 5 OPERABLE status.or 6.(continued)
Attachment 3cGL 96-03January 31, 1996 ACTIONS (continued)CONDITION REQUIRED ACTION COMPLETION TIMEG. Two required RCS G.1 Depressurize RCS and 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />srelief valves establish RCS vent ofinoperable. 2 (2.07] squareinches.ORRequired Action andassociated CompletionTime of Condition A,[B,] D, E, or F notmet.ORLTOP System inoperablefor any reason otherthan Condition A, [B,]C, D, E, or F.SURVEILLANCE REQUIREMENTSSURVEILLANCE FREQUENCYSR 3.4.X.X Verify a maximum of [one] [HPI] pump is 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />scapable of injecting into the RCS.3.4.X.X Verify a maximum of one charging pump is 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 7L capable of injecting into the RCS. JSR 3.4.X.X Verify each accumulator is isolated. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />(continued)
Attachment 3cGL 96-03January 31, 1996 SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYS 3.4.X.X Verify RHR suction valve is open for each 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />srequired RHR suction relief valve.SR 3.4.X.X -------------------NOTE--------------------Only required to be performed whencomplying with LCO 3.4.12.b.-__________________________________________Verify RCS vent 2 [2.07] square inches 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> foropen. unlocked openvent valve(s)AND31 days forlocked openvent valve(s)SR 3.4.X.X Verify PORV block valve is open for each 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />srequired PORV.S 3.4.X.X Verify associated RHR suction isolation 31 daysvalve is locked open with operator powerremoved for each required RHR suctionrelief valve.SR 3.4.X.X -------------------NOTE--------------------Not required to be met until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> afterdecreasing RCS cold leg temperature to< (275]VF.Perform a COT on each required PORV, 31 daysexcluding actuation.(continued)
Attachment 3cGL 96-03.3 t January 31, 1996 SURVEILLANCE REQUIREMENTS (continued)SURVEILLANCE FREQUENCYSR 3.4.X.X Perform CHANNEL CALIBRATION for each [18] monthsrequired PORV actuation channe Attachment 3dGL 96-03January 31, 1996 .0 ADMINISTRATIVE CONTROLS5.6 Reporting Requirements5.6.X Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITSREPORT (PTLR)a. RCS pressure and temperature limits for heat up,cooldown, low temperature operation, criticality, andhydrostatic testing as well as heatup and cooldown ratesshall be established and documented in the PTLR for thefollowing: [The individual specifications that addressRCS pressure and temperature limits must be referencedhere.]b. The analytical methods used to determine the RCS pressureand temperature limits shall be those previously reviewedand approved by the NRC, specifically those described inthe following documents: [Identify the NRC staffapproval document by date.]c. The PTLR shall be provided to the NRC upon issuance foreach reactor vessel fluence period and for any revisionor supplement thereto.Reviewers' Notes: The methodology for the calculation of theP-T limits for NRC approval should include the followingprovisions:1. The methodology shall describe how the neutron fluence iscalculated (reference new Regulatory Guide when issued).2. The Reactor Vessel Material Surveillance Program shallcomply with Appendix H to 10 CFR Part 50. The reactorvessel material irradiation surveillance specimen removalschedule shall be provided, along with how the specimenexaminations shall be used to update the PTLR curves.3. Low Temperature Overpressure Protection (LTOP) Systemlift setting limits for the Power Operated Relief Valves(PORVs), developed using NRC-approved methodologies maybe included in the PTLR.4. The adjusted reference temperature (ART) for each reactorbeltline material shall be calculated, accounting forradiation embrittlement, in accordance with RegulatoryGuide 1.99, Revision Attachment 3dGL 96-03January 31, 1996 . The limiting ART shall be incorporated into thecalculation of the pressure and temperature limit curvesin accordance with NUREG-0800 Standard Review Plan 5.3.2,Pressure-Temperature Limits.5.6.X Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITSREPORT (PTLR) (continued)6. The minimum temperature requirements of Appendix G to 10CFR Part 50 shall be incorporated into the pressure andtemperature limit curves.7. Licensees who have removed two or more capsules shouldcompare for each surveillance material the measuredincrease in reference temperature (RT DT) to the predictedincrease in RTNDT; where the predicted increase in RTNT isbased on the mean shift in RTNDT plus the two standarydeviation value (2a ) specified in Regulatory Guide 1.99,Revision 2. If the measured value exceeds the predictedvalue (increase RT + 2O), the licensee should provide asupplement to the RLR to demonstrate how the results _affect the approved methodolog Attachment 4GL 96-03January 31, 1996 I vtT ir nripri v TealwnCFMIrOTr I rTTDRCEl sa r WUncuiLl'1Lf1. A£jjwL F Ae.GenericDate ofT cciianenlcciind TnN.. k: L.A-_Letter zu-lc ----- --v .w.89-10,Supp. 796-0195-1095-0995-08CONSIDERATION OF VALVEMISPOSITIONING INPRESSURIZED-WATERREACTORSTESTING OF SAFETY-RELATEDLOGIC CIRCUITSRELOCATION OF SELECTEDTECHNICAL SPECIFICATIONSREQUIREMENTS RELATED TOINSTRUMENTATIONMONITORING AND TRAINING OFSHIPPERS AND CARRIERS OFRADIOACTIVE MATERIALS10 CFR 50.54(p) PROCESS FORCHANGES TO SECURITY PLANSWITHOUT PRIOR NRC APPROVAL01/24/9601/10/9612/15/9511/03/9510/31/95ALL HOLDERS OF OLs(EXCEPT THOSE LICENSESTHAT HAVE BEEN AMENDEDTO A POSSESSION ONLYSTATUS) OR CPs FOR NPRsALL HOLDERS OF OLs ORCPs FOR NPRsALL HOLDERS OF OLs ORCPs FOR NPRsALL U.S. NRC LICENSEESALL HOLDERS OF OLs &CPs FOR NPRsOL = OPERATING LICENSECP -CONSTRUCTION PERMITNPR = NUCLEAR POWER REACTORS c GL 96-03January 31, 1996 If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate Office of Nuclear Reactor Regulation(NRR) project manager.original signed byDennis M. Crutchfield, DirectorDivision of Reactor Program ManagementOffice of Nuclear Reactor RegulationTechnical contact: Maggalean W. Weston, NRR(301) 415-3151Internet:mww~nrc.gov
Attachments:
1. Guidance for a Proposed License Amendmentto Relocate the Pressure TemperatureLimit Curves and Low TemperatureOverpressure Protection System Limits2. Model Safety Evaluation3. Model Technical Specifications:a. Definitionsb. Pressure Temperature Limitsc. Low Temperature Overpressure Protection Systemd. Administrative Controls4. List of Recently Issued Generic LettersTech Editor reviewed and concurred on 11/16/95 *SEE PREVIOUS CONCURRENCESDOCUMENT NAME: 96-03.GLTo receive a copy of this document, indicate in the box: AC" -Copy without enclosures E. -Copy wit enclosures "N" = No copyOFFICE TSB/ADPR l OGC l C/PECB I D/D lNAME lMWWeston* SLewis* AEChaffee* DMC k6fieldDATE 109/01/95 10/10/95 12/14/95 01 /96OFFICIAL RECORD COPY