L-21-071, Request for an Amendment to Revise Technical Specification 5.6.3, Core Operating Limits Report (COLR)

Request for an Amendment to Revise Technical Specification 5.6.3, Core Operating Limits Report (COLR)

ML21117A076
Person / Time
Site:	Beaver Valley
Issue date:	04/26/2021
From:	Grabnar J Energy Harbor Nuclear Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-21-071
Download: ML21117A076 (15)

Text

energy Energy Harbor Nuclear Corp.

Beaver Valley Power Station harbor P. 0. Box 4 Shippingport, PA 15077 John J. Grabnar 724-682-5234 Site Vice President, Beaver Valley Nuclear April 26, 2021 L-21-071 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington , DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334 , License No. DPR-66 Docket No. 50-412 , License No. NPF-73 Request for an Amendment to Revise Technical Specification 5.6.3, "Core Operating Limits Report (COLR)"

Pursuant to 10 CFR 50.90, Energy Harbor Nuclear Corp. is submitting a request to amend the Renewed Operating Licenses numbered DPR-66 and NPF-73 for the Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2, respectively. The proposed change would revise Technical Specification 5.6.3 to allow the use of feedwater venturis that have been normalized to prior leading edge flow meter measurements when calculating reactor thermal power.

An evaluation of the proposed change is enclosed. NRG staff approval is requested by April 29 , 2022 , and the amendment would be implemented within 60 days of approval.

This letter contains no new regulatory commitments. If there are any questions or if additional information is required , please contact Mr. Phil H. Lashley, Manager - Fleet Licensing , at (330) 696-7208.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April_, 26 2021.

Sincerely, Crnbnar, Jolin 19072 Sile Vice Prcsidcnl , Beaver Va lley Grabnar,J ohn 19072 ~~;2a6~~~i~r;! 5 p~umcnl Docu ~ .

John J. Grabnar

Enclosure:

Evaluation of the Proposed Change

Beaver Valley Power Station, Unit Nos. 1 and 2 L-21-071 Page 2 cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

Enclosure L-21-071 Evaluation of the Proposed Change (12 pages follow)

Evaluation of the Proposed Change Page 1 of 10

Subject:

Request for an Amendment to Revise Technical Specification 5.6.3, Core Operating Limits Report (COLR) 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirement 2.3 Reason for the Proposed Change 2.4 Description of the Proposed Change

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria 4.2 No Significant Hazards Consideration Analysis 4.3 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

ATTACHMENT: Technical Specification Page Markups

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 2 of 10 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend Operating Licenses DPR-66 for Beaver Valley Power Station (BVPS) Unit No. 1 (BVPS-1) and NPF-73 for Beaver Valley Power Station Unit No. 2 (BVPS-2).

The proposed change would revise Technical Specification 5.6.3 Core Operating Limits Report (COLR), to allow the use of feedwater venturis that have been normalized to prior leading edge flow meter measurements when calculating reactor thermal power. provides the existing technical specification page marked to show the proposed change. No changes are proposed for the Technical Specification Bases because the affected technical specification does not have associated Bases.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The core thermal power must be accurately measured in order to ensure it does not exceed the licensed power level and invalidate the initial assumptions used in the design basis transient and accident analyses. Neutron flux instrumentation used to protect the core is also calibrated to measured core thermal power; therefore, accurate measurements are required.

Core thermal power is calculated with a calorimetric energy balance around the plant nuclear steam supply system. The accuracy of this calculation primarily depends on the accuracy of steam generator feedwater flow and feedwater net enthalpy measurements.

Both BVPS units previously used venturi meters for feedwater flow measurement and resistance temperature detectors (RTDs) for temperature measurement. However, license amendment numbers 243 and 122 for BVPS-1 and BVPS-2, respectively, allowed the use of more accurate ultrasonic flowmeters to provide these measurements.

The use of the Caldon, Inc. Leading Edge Flowmeter' (LEFM') at BVPS-1 and the LEFM CheckPlus' at BVPS-2 (hereafter both are referred to as LEFM) in place of the venturi meters and RTDs to measure feedwater flow allowed a reduction in the thermal power measurement uncertainty from 2 percent to 0.6 percent, and therefore, a power uprate of 1.4 percent. If the LEFM systems are nonfunctional, BVPS-1 and BVPS-2 Licensing Requirements Manual (LRM) sections 3.3.8, Leading Edge Flow Meter, in part, require the steady-state thermal power to be reduced to less than or equal to 98.6 percent of rated thermal power if the systems are not restored to functional status prior to the next daily calorimetric heat balance measurement.

As described in both BVPS-1 and BVPS-2 Updated Final Safety Analysis Report Section 7.7.1.10, the LEFM systems consist of an electronic processing cabinet and a measurement section, or spool piece, installed in the 26-inch main feedwater header.

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 3 of 10 Transducers that transmit and receive pulses are mounted in the measurement section, and transit time differences between pulses are used to measure integral velocities at precise locations with respect to the pipe centerline. The mass flow rate and feedwater temperature are displayed on the local display panel and transmitted to the plant process computer for use in the calorimetric measurement. Alarms are provided in the control rooms to alert operators should the systems require maintenance.

As stated previously, BVPS-1 and BVPS-2 LRM sections 3.3.8 currently require the LEFM to be functional and used for the daily calorimetric heat balance measurements to determine the steady-state thermal power when in Mode 1 and steady-state thermal power is greater than or equal to 98.6 percent. If the LEFM is nonfunctional, the LEFM is to be restored to functional status prior to the next daily calorimetric heat balance measurement. If the required action and completion time are not met, then:

The steady-state thermal power is reduced to less than or equal to 98.6 percent within one hour, and The calorimetric heat balance measurement is performed using the feedwater flow venturi and RTD indications with a completion time in accordance with the requirements of Technical Specification Surveillance Requirement 3.3.1.2, and Thermal power is maintained at less than or equal to 98.6 percent of rated thermal power steady-state until the LEFM is restored to functional status and the calorimetric heat balance measurement has been performed using the LEFM.

2.2 Current Technical Specification Requirement The current Technical Specification 5.6.3.b requirement is provided, in part, below:

As described in reference documents listed above, when an initial assumed power level of 102% [percent] of RATED THERMAL POWER is specified in a previously approved method, 100.6% of RATED THERMAL POWER may be used when input for reactor thermal power measurement of feedwater flow is by the leading edge flow meter (LEFM).

2.3 Reason for the Proposed Change In order to avoid a reduction in thermal power when the LEFM systems are nonfunctional, sufficient time is desired for repairs, which may include planning, procuring, and installing replacement components. An allowed outage time (AOT) of 3 days (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) for repair or replacement is an established safety practice in the nuclear power industry.

2.4 Description of the Proposed Change The Technical Specification 5.6.3.b requirements in Section 2.2 above would be modified with the following insertion underlined as follows:

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 4 of 10 As described in reference documents listed above, when an initial assumed power level of 102% of RATED THERMAL POWER is specified in a previously approved method, 100.6% of RATED THERMAL POWER may be used when input for reactor thermal power measurement of feedwater flow is by the leading edge flow meter (LEFM) or feedwater venturi normalized to a prior LEFM flow measurement.

If the proposed change is approved, sections 3.3.8, Leading Edge Flow Meter, of the BVPS-1 and BVPS-2 LRMs would be modified to allow the units to remain at rated thermal power for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the last calorimetric heat balance measurement was performed using the LEFMs only if the following conditions are met:

Thermal power is continuously maintained greater than or equal to 90 percent of rated thermal power since the last LEFM measurement, and Feedwater flow (used in the calorimetric energy balance calculation) is obtained from venturi-based feedwater flow measurements that have been previously normalized to the appropriate LEFM flow values used in the last calorimetric heat balance based on LEFM measurements.

If the conditions are not met, thermal power would be reduced within one hour to less than or equal to 98.6 percent of rated thermal power steady-state until the LEFM is restored to functional status and the calorimetric heat balance measurement has been performed using the LEFM.

3.0 TECHNICAL EVALUATION

In order to support the proposed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> LEFM AOT, statistical evaluations have been performed on the difference between LEFM-based feedwater flow and temperature measurements and coincident venturi and RTD-based measurements. If the differences are sufficiently consistent, then venturi and RTD-based measurements normalized to LEFM measurements can provide a degree of accuracy comparable to LEFM measurements during that period. The evaluations reflect the combined effects of factors (such as gradual fouling or instrument drift) affecting consistency during the data sampling period.

The statistical evaluation involved evaluating corresponding feedwater flow data from the LEFMs, venturis, and RTDs through all seasonal time periods beginning January 2, 2016 and ending January 1, 2017, utilizing 52,560 data points per unit.

Deviations were compared between feedwater flow and temperature measurements obtained at 10-minute intervals with measurements obtained 24, 72, and 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> later to determine if the deviations exhibit random or bias behavior. The comparison for 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> is included to demonstrate that any fouling or other time-related changes are not likely to occur in a 72-hour period.

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 5 of 10 Data points were limited to reactor thermal powers greater than 90 percent where power is held relatively constant. Data points were not included in the analyses where power level was intentionally changed or instruments were out of service (for example, where instruments were being calibrated on-line). The data was sufficiently random as it followed a normal distribution. The number of valid data points for each unit was greater than 43,900, and therefore sufficient to allow determination of the 95 percent probability and 95 percent confidence bounding uncertainty using two standard deviations from the mean for a two-sided statistical application.

For BVPS-1, expressed in percent of feedwater flow, the 72-hour change in the upper bounds of the dataset with a 95 percent probability and 95 percent confidence was calculated to be 0.2859 percent. Similarly, the 120-hour change was calculated to be 0.2892 percent.

For BVPS-2, expressed in percent of feedwater flow, the 72-hour change in the upper bounds of the dataset with a 95 percent probability and 95 percent confidence was calculated to be 0.2360 percent. Similarly, the 120-hour change was calculated to be 0.2381 percent.

The results for each unit indicate a growing bias over time most likely attributable to venturi fouling. Fouling of the venturis would result in a conservatively high feedwater flow input to the calorimetric heat balance, thereby causing the reactor to be operated below the power level indicated by plant instrumentation. Sudden de-fouling during the AOT period is unlikely if stable power conditions are maintained. The proposed LRM requirements that power be continuously maintained greater than or equal to 90 percent of rated thermal power throughout the AOT period is intended to ensure a stable power condition.

These results demonstrate that when normalized venturi feedwater flow measurements are substituted for LEFM feedwater flow measurements to perform required calorimetric heat balance calculations during the proposed AOT, operation within the rated thermal power limit would be ensured. Therefore, the proposed 72-hour AOT is acceptable.

Finally, differences between the LEFM-based feedwater temperature measurements and the feedwater RTDs were evaluated over the same time period as the evaluated flow measurements. The average difference between corresponding LEFM and RTD temperature measurements was plus or minus 0.64 degrees Fahrenheit for BVPS-1 and plus or minus 0.098 degrees Fahrenheit for BVPS-2. This is similar or less than the uncertainty allowance of the LEFM temperature measurements of plus or minus 0.6 degrees Fahrenheit. Therefore, the use of measurements from the feedwater RTDs in lieu of the LEFMs during the 72-hour AOT would not impact the overall uncertainty of calculated reactor power.

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 6 of 10

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements / Criteria The following NRC regulatory requirements and guidance are applicable to this license amendment request.

10 CFR Part 50, Appendix K Appendix K to 10 CFR Part 50 requires loss of coolant accident and emergency core cooling system analyses to assume that the reactor has been operating continuously at a power level at least 1.02 times the licensed power level to allow for instrumentation uncertainties. Alternately, Appendix K allows an assumption of lower than the specified 102 percent, but not less than the licensed thermal power level, "provided the proposed alternative value has been demonstrated to account for uncertainties due to power level instrumentation error." This allowance provides licensees an option of justifying a power uprate with reduced margin between the licensed power level and the power level assumed in the analyses by using more accurate instrumentation to calculate the reactor power. Based on the use of the LEFM systems for measuring the main feedwater flow and temperature at BVPS, the plants are licensed to apply a power measurement uncertainty of 0.4 percent. The proposed amendment would maintain a similar low degree of power measurement uncertainty as the LEFM during the proposed allowed outage time. Therefore, the loss of coolant accident and emergency core cooling system analysis assumptions of 10 CFR Part 50, Appendix K remain satisfied.

NRC Regulatory Issue Summary (RIS) 2002-03, "Guidance on the Content of Measurement Uncertainty Recapture Power Uprate Applications" This RIS provides guidance on the scope and detail of the information that should be provided to the NRC for reviewing measurement uncertainty recapture power uprate applications. The RIS Attachment 1,Section I, Item G requests a proposed allowed outage time for the instrumentation with increased accuracy, along with the technical basis for the time selected. Item H requests proposed actions to reduce power level if the allowed outage time is exceeded, including a discussion of the technical basis for the proposed reduced power level. These items were not explicitly addressed in the measurement recapture power uprate license amendment numbers 243 and 122 for BVPS-1 and BVPS-2, respectively, since the RIS was not issued at the time.

The proposed amendment requests allowing operation at rated thermal power when feedwater venturis have been normalized to prior LEFM flow measurements. Under certain conditions, the allowed LEFM system outage time would be 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the last calorimetric heat balance measurement was performed using the LEFMs, and a statistical basis provided. The proposed action to reduce power level if the allowed outage time has been exceeded has been provided. As the action requires reduction in power equivalent to the margin provided by the LEFM systems, no further technical

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 7 of 10 justification is required. Therefore, the information provided in this application is consistent with the guidance of RIS 2002-03.

4.2 No Significant Hazards Consideration Analysis Pursuant to 10 CFR 50.90, Energy Harbor Nuclear Corp. is submitting a request for amendment to the Renewed Operating Licenses DPR-66 and NPF-73 for the Beaver Valley Power Station, Unit Nos. 1 (BVPS-1) and 2 (BVPS-2), respectively. The amendment would revise Technical Specification 5.6.3, Core Operating Limits Report (COLR) to allow the use of feedwater venturis that have been normalized to prior leading edge flow meter (LEFM) measurements when calculating reactor thermal power.

If the requested amendments are approved, the Licensing Requirements Manuals or LRMs (licensee controlled documents, subject to 10 CFR 50.59, Changes, tests, and experiments) would be revised. The revisions would permit the units to operate at rated thermal power for up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the last calorimetric heat balance calculation based on LEFM measurements, provided that stable thermal power conditions have been maintained greater than or equal to 90 percent of rated thermal power, and feedwater flow is obtained from venturi-based measurements that have been normalized to prior LEFM measurements. Feedwater resistance temperature detectors (RTDs) would also be used to obtain temperature measurements used in the calculations.

Unit-specific statistical evaluations of the differences between historical LEFM-based feedwater flow measurements and venturi-based feedwater flow measurements have demonstrated that the average difference between LEFM-based measurements and venturi-based measurements do not vary significantly over short periods of time.

Therefore, if current venturi-based measurements are normalized to LEFM measurements that were obtained no greater than 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> prior, a similar low degree of uncertainty in the heat balance calculations would be obtained with the venturis as with the LEFMs. Temperature measurement differences between the LEFMs and feedwater RTDs were also evaluated. The evaluation demonstrates that the average difference between corresponding LEFM and RTD temperature measurements is similar to the margin already applied to LEFM temperature measurements used for calculating power. The proposed amendment would maintain a consistent degree of uncertainty in heat balance calculations during the proposed 72-hour LEFM outage period, thereby assuring that the units would not be operated above their rated thermal power limits.

Energy Harbor Nuclear Corp. has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed on the next page:

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 8 of 10

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed amendment would allow operation at rated thermal power when reactor thermal power measurement is calculated with feedwater venturis that have been normalized to a prior LEFM flow measurement. The LRMs would be modified to permit this under certain conditions up to a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the last calorimetric heat balance measurement was performed using the LEFMs.

There are no modifications to the plant being made. As there are no modifications to the plant or a change in plant control systems, extending the LEFM outage time would not significantly increase accident probability.

Accident consequences are, in part, dependent on the operating power level of the reactor assumed in accident analyses. The LEFMs are used to obtain information needed to perform a calorimetric heat balance calculation to determine reactor power output and maintain operation within accident analysis limits. The proposed amendment would permit measurements from feedwater venturis and RTDs to be substituted for LEFM measurements while maintaining a stable power level during a 72-hour period. Venturi-based feedwater flow measurements would be normalized to the last LEFM-based measurements used as input to a calorimetric heat balance and would have a similar low degree of uncertainty as LEFM measurements for the duration of the proposed allowed outage time when stable thermal power conditions are maintained. Therefore, calculated reactor power based on normalized feedwater flow venturi measurements would continue to be maintained within accident analysis limits, ensuring that accident consequences would not be significantly increased.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed amendment would allow operation at rated thermal power when reactor thermal power measurement is calculated with feedwater venturis that have been normalized to a prior LEFM flow measurement. The LRMs would be modified to permit this under certain conditions up to a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the last calorimetric heat balance measurement was performed using the LEFMs.

Modifications to the plant are not being made. Feedwater flow venturi measurements that are normalized to the last LEFM-based measurements used as input to a calorimetric heat balance have a similar low degree of uncertainty as LEFM measurements for the duration of the proposed allowed outage time

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 9 of 10 when stable thermal power conditions are maintained. Calculated reactor power based on normalized feedwater flow venturi measurements would continue to be maintained within accident analysis limits.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed amendment would allow operation at rated thermal power when reactor thermal power measurement is calculated with feedwater venturis that have been normalized to a prior LEFM flow measurement. The LRMs would be modified to permit this under certain conditions up to a period of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after the last calorimetric heat balance measurement was performed using the LEFMs.

Unit-specific statistical evaluations of the differences between historical LEFM-based feedwater flow measurements and venturi-based feedwater flow measurements have demonstrated that the average difference between LEFM-based measurements and venturi-based measurements do not vary significantly over short periods of time.

Therefore, if current venturi-based measurements are normalized to LEFM measurements that were obtained no greater than 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> prior, the same degree of uncertainty in the heat balance calculations would be obtained with the venturis as with the LEFMs. Temperature measurement differences between the LEFMs and feedwater RTDs were also evaluated. The evaluation demonstrates that the average difference between corresponding LEFM and RTD temperature measurements is similar to the margin already applied to LEFM temperature measurements used for calculating power. The proposed amendment would maintain a consistent degree of uncertainty in heat balance calculations during the proposed 72-hour LEFM outage period, thereby assuring that the units would not be operated above their rated thermal power limits.

As the proposed change would result in the same degree of uncertainty in reactor power calculations using alternate measurements as with using the LEFMs, there is no significant reduction in a margin of safety.

Based on the above, Energy Harbor Nuclear Corp. concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

Evaluation of the Proposed Change Beaver Valley Power Station, Unit Nos. 1 and 2 Page 10 of 10 4.3 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment Technical Specification Page Markups (1 page follows)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR) (continued)

WCAP-16045-P-A, Qualification of the Two-Dimensional Transport Code PARAGON, WCAP-16045-P-A, Addendum 1-A, Qualification of the NEXUS Nuclear Data Methodology, WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO'.

As described in reference documents listed above, when an initial assumed power level of 102% of RATED THERMAL POWER is specified in a previously approved method, 100.6% of RATED THERMAL POWER may be used when input for reactor thermal power measurement of feedwater flow is by the leading edge flow meter (LEFM) or feedwater venturi normalized to a prior LEFM flow measurement.

Caldon, Inc. Engineering Report-80P, "Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM TM System" Caldon, Inc. Engineering Report-160P, "Supplement to Topical Report ER-80P: Basis for a Power Uprate with the LEFM TM System"

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, and hydrostatic testing, Overpressure Protection System (OPPS) enable temperature, and PORV lift settings as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," and LCO 3.4.12, "Overpressure Protection System (OPPS)"

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

Beaver Valley Units 1 and 2 5.6 - 3 Amendments /