ML022520240
| ML022520240 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/2002 |
| From: | Beckner W D NRC/NRR/DRIP/RORP |
| To: | Pietrangelo A R Nuclear Energy Institute |
| Tjader T., NRC/RORP, 415-1187 | |
| References | |
| NUREG-1432, Rev 2, TSTF-408 CE NPSD-683, Rev 6 | |
| Download: ML022520240 (6) | |
Text
September 6, 2002Mr. Anthony R. Pietrangelo, DirectorRisk & Performance-Based Regulation Nuclear Generation Nuclear Energy Institute 1776 I Street, N.W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Pietrangelo:
This is to inform you of the disposition for traveler TSTF-408 containing proposed changes tothe Combustion Engineering (CE) Standard Technical Specifications (STS) NUREG-1432, Revision 2, initiated by the NEI Technical Specification Task Force (TSTF). TSTF-408 is approved.The staff has reviewed traveler TSTF-408 to the CE STS, NUREG-1432, Revision 2, whichproposes relocation of the low temperature overpressure protection (LTOP) system enable temperature and the LTOP PORV lift setting to the pressure temperature limits report (PTLR),
and associated changes to PTLR Administrative Controls Specification. Approved Topical Report CE NPSD-683, Revision 6, "Development of a RCS Pressure and Temperature Limits Report for Removal of P-T Limits and LTOP Requirements from the Technical Specifications,"
supports relocation of the LTOP system enable temperature and the LTOP PORV lift setting to the PTLR. Enclosed for your information is the related safety evaluation. Although the safety evaluation is written in the form of a model, TSTF-408 will not go through the CLIIP process.Please contact me at (301) 415-1161 or email wdb@nrc.gov if you have any questions or needfurther information on these dispositions.Sincerely,/RA/William D. Beckner, Program Director Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
Enclosures:
As stated cc:T. Silko, BWROGD. Bice, CEOG N. Clarkson, BWOG S. Wideman, WOG D. Hoffman, EXCEL September 6, 2002Mr. Anthony R. Pietrangelo, DirectorRisk & Performance-Based Regulation Nuclear Generation Nuclear Energy Institute 1776 I Street, N.W.
Suite 400 Washington, DC 20006-3708
Dear Mr. Pietrangelo:
This is to inform you of the disposition for traveler TSTF-408 containing proposed changes tothe Combustion Engineering (CE) Standard Technical Specifications (STS) NUREG-1432, Revision 2, initiated by the NEI Technical Specification Task Force (TSTF). TSTF-408 is approved.The staff has reviewed traveler TSTF-408 to the CE STS, NUREG-1432, Revision 2, whichproposes relocation of the low temperature overpressure protection (LTOP) system enable temperature and the LTOP PORV lift setting to the pressure temperature limits report (PTLR),
and associated changes to PTLR Administrative Controls Specification. Approved Topical Report CE NPSD-683, Revision 6, "Development of a RCS Pressure and Temperature LimitsReport for Removal of P-T Limits and LTOP Requirements from the Technical Specifications,"supports relocation of the LTOP system enable temperature and the LTOP PORV lift setting to the PTLR. Enclosed for your information is the related safety evaluation. Although the safety evaluation is written in the form of a model, TSTF-408 will not go through the CLIIP process.Please contact me at (301) 415-1161 or email wdb@nrc.gov if you have any questions or needfurther information on these dispositions.Sincerely,/RA/William D. Beckner, Program Director Operating Reactor Improvements Program Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation
Enclosures:
As stated cc:T. Silko, BWROGD. Bice, CEOG N. Clarkson, BWOG S. Wideman, WOG D. Hoffman, EXCELDISTRIBUTION
- PUBLICDMatthews/FGillespieWBeckner TSS R/FTSS Staff ADAMS ACCESSION NO: ML022520240DOCUMENT NAME: C:\ORPCheckout\FileNET\ML022520240.wpd To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copyOFFICERE:TSSSC:TSSSC:EMCBAPD:RORPNAMETTJaderRDennigSCoffinWBecknerDATE08/30/200209/03/200209/05/200209/06/2002Official Record Copy MODEL SAFETY EVALUATION ON RELOCATION OFLTOP ENABLE TEMPERATURE AND PORV LIFT SETTINGS TOTHE PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)SAFETY EVALUATION BYTHE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TOAMENDMENT NO. TO FACILITY OPERATING LICENSE NFP-
[UTILITY NAME] [PLANT NAME], [UNIT
]DOCKET NO. 50-
1.0 INTRODUCTION
By letter dated , 20 , [utility name] (the licensee) proposed changes to the technicalspecifications (TS) for [plant name]. The requested changes are to relocate the low temperature overpressure protection (LTOP) system enable temperature and the LTOP PORV lift setting pressure to the pressure temperature limits report (PTLR) and the referencing of the related specifications in the PTLR administrative controls section of the TS. The proposed changes are consistent with the approved Technical Specification Task Force (TSTF) change traveler TSTF-408 to the Combustion Engineering (CE) Standard Technical Specifications (STS), NUREG-1432, Revision 2. Approved Topical Report CE NPSD-683, Revision 6, "Development of a RCS Pressure and Temperature Limits Report for Removal of P-T Limitsand LTOP Requirements from the Technical Specifications," supports relocation of the LTOPsystem enable temperature and the LTOP PORV lift setting to the PTLR.Guidance on the use of a PTLR was developed by the Nuclear Regulatory Commission (NRC)and was provided to all power reactor licensees and applicants by Generic Letter 96-03, dated January 31, 1996.NUREG-1432, Revision 2, is written assuming that the pressure/temperature limits are locatedin a PTLR. However, other changes are required to NUREG-1432 to support this use of the Topical Report and TSTF-408. Specifically, the following changes are proposed to NUREG-1432:1. Revise the PTLR definition to not state which Specifications contain limits specified inthe PTLR. This information is located in Administrative Control 5.5.6, PTLR, and need not be repeated in Section 1.12. Eliminate the value of the LTOP enable temperature and LTOP PORV lift setpoint andsubstitute a reference to the PTLR in LCO 3.4.6, LCO 3.4.7, LCO 3.4.10, Required Action 3.4.10.B.2, LCO 3.4.12, Applicability 3.4.12, and Surveillance Requirement 3.4.12.6.3. Revise Administrative Controls Specification 5.6.6 to include reference to NRCapproved Topical Report CE NPSD-683, Revision 6. (Note: TSTF-408 assumes the plant has adopted approved TSTF-419, which is consistent with the wording approved for the Core Operating Limits Report in TSTF-363.)
2.0 REGULATORY EVALUATION
Section 182a of the Atomic Energy Act (the Act) requires applicants for nuclear power plantoperating licenses to include TS as part of the license. The Commission
's regulatoryrequirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories: (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls, and states also that the Commission may include such additional TS as it finds to be appropriate.
However, the regulation does not specify the particular requirements to be included in a plant
'sTS.Currently 10 CFR 50, Appendix G imposes special fracture toughness requirements on theferritic components of the Reactor Coolant Pressure Boundary. These fracture toughness requirements result in pressure restrictions which vary with RCS temperature. Determination of these restrictions requires that specific loading conditions be evaluated and the resulting P-T limits not be exceeded.NRC Generic Letter 96-03, "Relocation Of The Pressure Temperature Limit Curves And LowTemperature Overpressure Protection System Limits," dated January 31, 1996, allowslicensees to relocate the pressure temperature (P-T) limit curves from their plant TS to a PTLR or a similar document. The LTOP system limits were also allowed to be relocated to the same document. The methodology used to determine the P-T and LTOP system limit parameters must comply with the specific requirements of appendices G and H to Part 50 of Title 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 incorporated by reference into the TS.Topical Report CE NPSD-683 Revision 6, "Development of a RCS Pressure and TemperatureLimits Report for Removal of P-T Limits and LTOP Requirements from the Technical Specifications," provides the approved methodology which may be referenced in moving itemsto the PTLR.
3.0 TECHNICAL EVALUATION
All components of the reactor coolant system (RCS) are designed to withstand the effects ofcyclic loads resulting from system pressure and temperature changes. These loads are introduced by heatup and cooldown operations, power transients, and reactor trips. In accordance with Appendix G to 10 CFR Part 50, TS limit the pressure and temperature changes during RCS heatup and cooldown within the design assumptions and the stress limits for cyclic operation. These limits are defined by P-T limit curves for heatup, cooldown, LTOP, and inservice leak and hydrostatic testing. Each curve defines an acceptable region for normal operation. The curves are used for operational guidance during heatup and cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable region.Topic Report CE NPSD-683 Revision 6, "Development of a RCS Pressure and TemperatureLimits Report for Removal of P-T Limits and LTOP requirements from the Technical Specifications, " provides a methodology for licensees to relocate the Pressure-Temperature(P-T) limit curves, low temperature overpressure protection (LTOP) setpoint values (including PORV lift settings) and curves, currently contained in the Technical Specifications (TS) to a licensee-controlled document. The approach is based upon the guidance contained in Nuclear Regulatory Commission (NRC) Generic Letter (GL) 96-03.
[Reviewer's Note: Topical Report CE NPSD-683, Revision 6, as supplemented by the CEOGletters of November 16 and 30, 2000, provides a methodology that may be used by licenseesas the basis for establishing P-T limits and LTOP system limits, including PORV lift settings.
While the contents of the report are technically acceptable, the report leaves the description of certain key methodology details up to the licensee to provide. These items have been identified in Sections 2.0 and 5.0 of the NRC
's approving Safety Evaluation of February 28, 2001, forTopical Report CE NPSD-683, Revision 6. Licensees requesting a license amendment to adopt this change will need to include these details, along with a description of the plant
's LTOPsystem, in their plant specific submittals. In some cases a licensee may need to apply for an exemption to the requirements of Appendix G to 10 CFR 50.]The LTOP system controls RCS pressure at low temperatures so that the integrity of thereactor coolant pressure boundary is not compromised by violating 10 CFR Part 50, Appendix G. The LTOP system is reevaluated each time the P-T limit curves are revised to ensure that it meets its intended function.Relocation of the P-T curves and LTOP setpoints does not eliminate the requirement to operatein accordance with the limits specified in Appendix G to 10 CFR Part 50. The requirement to operate within the limits in the named report or PTLR is specified in and controlled by the TS.
Only the figures, values, and parameters associated with the P-T limits and LTOP setpoints are to be relocated to the PTLR. In order for the curves and setpoints to be relocated to a PTLR, a methodology for 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 accordance with GL 96-03.
This generic letter delineates the requirements for both the methodology and the PTLR including, but not limited to, the requirements of Appendix G to 10 CFR Part 50. The PTLR review process requires that changes to the methodology be approved by the NRC. New and different methodologies that require changes to the base reference in the Administrative Controls section of the Technical Specifications must be approved by license amendment.
Further, when changes are made to the figures, values, and parameters contained in the PTLR, the PTLR is to be updated and submitted to the NRC upon issuance. On this basis, the NRC staff concludes that the licensee provided an acceptable means ofestablishing and maintaining the detailed values of the P-T limit curves and LTOP system limits.
Further, because plant operation continues to be limited in accordance with the requirements of Appendix G to 10 CFR Part 50, and the P-T and LTOP system limits in the TS will be established using a methodology approved by the NRC, these changes will not impact plant safety. The staff also concludes that the relocated requirements discussed above relating to the P-Tlimits and LTOP system limits are not required to be in the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act. Accordingly, the staff concludes that the proposed changes are acceptable and that these requirements may be relocated from the TS to the PTLR.
4.0 STATE CONSULTATION
The Commission consulted with the State of [ ]. No public comments were received, and theState of [ ] did not have any comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment involves changes to requirements with respect to use of facility componentslocated within the restricted area, as defined in 10 CFR Part 20, changes with respect to surveillance requirements, and changes in administrative procedures or requirements. The NRC staff determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released off site and that there is no significant increase in individual or cumulative occupational exposure. The Commission made a determination that the amendment involves no significant hazards consideration, which was published in the Federal Register ( FR ) on , 20 , and there has been no publiccomment regarding such a finding. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant to 10 CFR 51.22(b),
no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
On the basis of the considerations discussed above, the NRC staff concludes that (1) there isreasonable 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 Commission
's regulations, and (3) the issuance of this amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Dated:
, 20