NL-15-014, Proposed Changes to Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Overpressure Protection System Requirements
| ML15061A275 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 02/12/2015 |
| From: | Coyle L Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15061A270 | List:
|
| References | |
| NL-15-014 | |
| Download: ML15061A275 (70) | |
Text
Enter-qy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB Ente"gyP.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254-6700 Lawrence Coyle Site Vice President NL-15-014 February 12, 2015 U.S. Nuclear Regulatory Commission Document Control Desk 11545 Rockville Pike, TWFN-2 F1 Rockville, MD 20852-2738
SUBJECT:
Proposed Changes to Indian Point Unit 3 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Overpressure Protection System Requirements Indian Point Unit No. 3 Docket No. 50-286 License No. DPR-64
Dear Sir or Madam:
Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc., (Entergy) hereby requests a License Amendment to Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed amendment will revise the Reactor Coolant System (RCS) heatup and cooldown curves and Low Temperature Overpressure Protection (LTOP) requirements in Technical Specifications (TS) 3.4.3 and 3.4.12, respectively.
The existing RCS pressure and temperature (P/T) limits are valid for a lifetime burnup of 27.2 Effective Full Power Years (EFPY) and the revised limits are for a lifetime burnup of 37 EFPY. The existing limits were originally estimated to be valid until December, 2015. However, because of the higher unanticipated core burnup rate attributed to improved plant operation, a new estimated date of when the 27.2 EFPY limit would be reached is September, 2015. Entergy respectfully requests approval of the proposed amendment by September 4, 2015.
Entergy has evaluated the proposed changes in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92 (c) and has determined that the proposed changes involve no significant hazards considerations, as described in Attachment 1. The proposed changes to the Technical Specifications are shown in Attachment 2. The associated TS Bases changes are provided in Attachment 3 for information. provides a proprietary version of WCAP-1 7954-P, Revision 0, "Indian Point Unit 3 Heatup and Cooldown Limit Curves for Normal Operation," and a non-proprietary version is provided as Enclosure 2. The Electric Power Research Institute (EPRI), the owner of the proprietary information used in WCAP-1 7954-P has provided a signed supporting affidavit in . This affidavit provides the basis on which the information in Enclosure 1 may be withheld from public disclosure by the Commission and addresses the considerations listed in paragraph (b)(4) of 10 CFR 2.390 of the Commission's regulations. Accordingly, it is respectfully W.C4
NL-15-014 Docket No. 50-286 Page 2 of 3 requested that the information, which is proprietary to EPRI, be withheld from public disclosure in accordance with 10 CFR 2.390 of the Commission's regulations. The proprietary information in is contained within double brackets. The proprietary information has been deleted in , so that only the double brackets remain.
A copy of this application and the associated attachments are being submitted to the designated New York State official in accordance with 10 CFR 50.91.
There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert W. Walpole, Regulatory Assurance Manager at (914) 254-6710.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on , . /2 /5" LC/rI Attachments:
- 1. Analysis of Proposed Technical Specification Changes regarding Reactor Heatup and Cooldown Curves and LTOP Requirements
- 2. Markup of Technical Specification Pages for Proposed Changes. regarding Reactor Heatup and Cooldown Curves and LTOP Requirements
- 3. Markup of Technical Specification Bases Pages for Proposed Changes regarding Reactor Heatup and Cooldown Curves and LTOP Requirements
Enclosures:
- 1. WCAP-17954-P, Revision 0, "Indian Point Unit 3 Heatup and Cooldown Limit Curves for Normal Operation," Westinghouse Electric Co, December 2014. (Proprietary)-
- 2. WCAP-17954-NP, Revision 0, "Indian Point Unit 3 Heatup and Cooldown Limit Curves for Normal Operation," Westinghouse Electric Co, December 2014. (Non-Proprietary)
- 3. EPRI letter to NRC, "Request for Withholding of the following Proprietary Information Included in: Proposed Changes to Indian Point Unit 3 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature
NL-15-014 Docket No. 50-286 Page 3 of 3 Overpressure Protection System Requirements, WCAP-17954-P, Revision 0, December 2014," dated January 21, 2015.
cc: Mr. Daniel H. Dorman, Regional Administrator, NRC Region I Mr. Douglas Pickett, NRC, Sr. Project Manager, Division of Reactor Licensing Mr. Michael Wentzel, NRC Project Manager, Division of License Renewal Ms. Bridget Frymire, New York State Dept. of Public Service (w/o proprietary)
Mr. John B. Rhodes, President and CEO NYSERDA (w/o proprietary)
NRC Resident Inspector's Office
ATTACHMENT 1 TO NL-15-014 ANALYSIS OF PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING REACTOR HEATUP AND COOLDOWN CURVES AND LTOP REQUIREMENTS ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286
NL-15-014 Docket No. 50-286 Attachment 1 Page 1 of 14
1.0 DESCRIPTION
Entergy Nuclear Operations, Inc. (Entergy) is requesting an amendment to Operating License DPR-64, Docket 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed change will revise the Reactor Coolant System (RCS) Heatup and Cooldown limitations in Unit 3 Technical Specification (TS) 3.4.3, and the Low Temperature Overpressure Protection System (LTOP) requirements in Unit 3 TS 3.4.12. These changes are necessary to account for a service life increase from 27.2 Effective Full Power Years (EFPY) to an extended service life of 37 EFPY.
The specific proposed TS changes are described below.
2.0 PROPOSED CHANGE
S 2.1 The Heatup and Cooldown limitations in IP3 TS 3.4.3 will be revised as follows:
- a. Replace the existing TS Figure 3.4.3-1 and Figure 3.4.3-2 with the proposed TS Figure 3.4.3-1 and Figure 3.4.3-2 as shown in Attachment 2.
- b. Delete the existing TS Figure 3.4.3-3. The RCS inservice leak testing limitations have been added to the proposed TS Figure 3.4.3-1.
- c. Change LCO 3.4.3 FROM RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within the limits specified in Figure 3.4.3-1, Figure 3.4.3-2, and Figure 3.4.3-3.
TO RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within the limits specified in Figure 3.4.3-1 and Figure 3.4.3-2.
NL-15-014 Docket No. 50-286 Attachment 1 Page 2 of 14
- d. Change SR 3.4.3.1 FROM SR 3.4.3.1 ----------------------- NOTE--- -------------
Only required to be performed during RCS heatup and cooldown operations and RCS inservice leak and hydrostatic testing.
30 minutes Verify RCS pressure, RCS temperature, and RCS heatup and cooldown rates are within the limits specified in the following:
- a. Figure 3.4.3-1 during RCS heatup;"
- b. Figure 3.4.3-2 during RCS cooldown; and
- c. Figure 3.4.3-3 during RCS inservice leak and hydrostatic testing.
TO SR 3.4.3.1 ----------------------- NOTE ------------------
Only required to be performed during RCS heatup, inservice leak testing, and cooldown operations.
Verify RCS pressure, RCS temperature, and RCS heatup 30 minutes and cooldown rates are within the limits specified in the following:
- b. Figure 3.4.3-2 during RCS cooldown.
2.2 Low Temperature Overpressure Protection system limitations in IP3 TS 3.4.12 will be revised as follows:
- a. Replace the existing TS Figure 3.4.12-1, Figure 3.4.12-2 and Figure 3.4.12-3 with the proposed TS Figure 3.4.12-1, Figure 3.4.12-2 and Figure 3.4.12-3 as shown in Attachment 2.
NL-15-014 Docket No. 50-286 Attachment 1 Page 3 of 14
- b. Delete the existing TS Figure 3.4.12-4.
- c. Change LCO 3.4.12 FROM LTOP shall be OPERABLE with no high head safety injection (HHSI) pumps capable of injecting into the RCS and the accumulator discharge isolation valves closed and de-energized, and either of the following:
Note --------------------------------
LCO 3.4. 12.a and LCO 3.4.12.b are not Applicable when all RCS cold leg temperatures are > 330'F.
- a. The Overpressure Protection System (OPS) OPERABLE with two power operated relief valves (PORVs) with lift settings within the limit specified in Figure 3.4.12-1; OR
TO LTOP shall be OPERABLE with no high head safety injection (HHSI) pumps capable of injecting into the RCS and the accumulator discharge isolation valves closed and de-energized, and either of the following:
Note -------------------------------
LCO 3.4.12.a and LCO 3.4.12.b are not Applicable when all RCS cold leg temperatures are > 330 0F.
.* power-operated relief valves (PORVs) with lift settings within the limit specified in Figure 3.4.12-1; OR
- b. The RCS depressurized with an RCS vent of _ 2.00 square inches, or one blocked open PORV with its block valve disabled in the open position..
NL-15-014 Docket No. 50-286 Attachment 1 Page 4 of 14 LCO 3.4.12 (Continued) FROM ACTIONS
NOTE LCO 3.0.4.b is not applicable when entering MODE 4.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more HHSI pump(s) A.I Initiate action to verify no Immediately capable of injecting into the HHSI pumps are capable RCS. of injecting into the RCS.
OR A.2.1 Verify RCS is vented with opening > 2.00 square inches. Immediately AND A.2.2 Verify pressurizer level is
< 0%.
Immediately AND AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> A.2.3 Verify no more than two HHSI pumps are capable of injecting into the RCS.
Immediately OR AND A.3.1 Verify RCS is vented with opening greater than or Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> equal to one pressurizer code safety valve flange.
Immediately AND A.3.2 Verify no more than two HHSI pumps are capable of injecting into the RCS Immediately AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)
NL-15-014 Docket No. 50-286 Attachment 1 Page 5 of 14 TO ACTIONS
--------- NOTE -------------------
LCO 3.0.4.b is not applicable when entering MODE 4.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more HHSI pump(s) A. 1 Initiate action to verify no Immediately capable of injecting into the HHSI pumps are capable RCS. of injecting into the RCS.
OR A.2.1 Verify RCS is vented with opening greater than or Immediately equal to one pressurizer code safety valve flange.
AND A.2.2 Verify no more than two HHSI pumps are capable of injecting into the RCS Immediately AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (continued)
NL-15-014 Docket No. 50-286 Attachment 1 Page 6 of 14 LCO 3.4.12 (Continued) FROM ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Two required PORVs E. I Depressurize RCS and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable, establish RCS vent of
> 2.00 square inches.
OR OR Required Action and E.2.1 Increase all RCS cold leg 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated Completion temperatures to > 330'F.
Time of Condition C or D not met. AND E.2.2 Isolate the RHR System from the RCS. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR E.3 Verify pressurizer level, RCS pressure, and RCS 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> injection capability are within limits specified in AND Figure 3.4.12-2 and Figure 3.4.12-3 for OPS not Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OPERABLE. thereafter F. LTOP inoperable for any F. I Depressurize RCS and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> reason other than Condition establish RCS vent of
.- A, BC, D, orE. - > 2.00 square inches.
TO ACTIONS (continued)'
CONDITION REQUIRED ACTION COMPLETION TIME
NL-15-014 Docket No. 50-286 Attachment 1 Page 7 of 14 CONDITION REQUIRED ACTION COMPLETION TIME E. Two required PORVs E. 1 Depressurize RCS and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable, establish RCS vent of
> 2.00 square inches, or one blocked open PORV OR with its block valve disabled in the open Required Action and position. 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated Completion Time of Condition C or D OR not met.
E.2.1 Increase all RCS cold leg temperatures to > 330'F.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> AND E.2.2 Isolate the RHR System from the RCS.
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> OR AND E.3 Verify pressurizer level, RCS pressure, and RCS Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> injection capability are thereafter within limits specified in Figure 3.4.12-2 and Figure 3.4.12-3 for OPS not OPERABLE.
F. LTOP inoperable for any F. 1 Depressurize RCS and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />
-reason other than Condition establish RCS vent of A, B, C, D, or E. > 2.00 square inches, or one blocked open PORV with its block valve disabled in the open position.
NL-15-014 Docket No. 50-286 Attachment 1 Page 8 of 14
- d. Change SR 3.4.12.3 FROM SR 3.4612.3 ------------------------
-NOTE Only required to be met when complying with LCO 3.4.12.b.
Verify RCS vent > 2.00 square inches established. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for unlocked open vent valve(s)
AND 31 days for locked open vent valve(s)
TO SR 3.4.12.3 NOTE ---------
Only required to be met when complying with LCO 3.4.12.b.
Verify RCS vent > 2.00 square inches, or one blocked open 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for PORV with its block valve disabled in the open position unlocked open vent established. valve(s)
AND 31 days for locked open vent valve(s)
NL-15-014 Docket No. 50-286 Attachment 1 Page 9 of 14
- e. Change SR 3.4.12.9 FROM SURVEILLANCE FREQUENCY SR 3.4.12.9 --------------
NOTES ---------
- 1. Not required to be met when all RCS cold leg temperatures are > 330'F.
- 2. Not required to be met if SR 3.4.12.8 is met.
Verify each of the following conditions are satisfied prior to starting any RCP: Within 15 minutes prior to starting any
- a. Secondary side water temperature of the hottest RCP steam generator is < 64 0 F above the coldest RCS cold leg temperature; and
- d. Pressurizer level is _<
73%; and
- e. Coldest RCS cold leg temperature is within limits specified in Figure 3.4.12-4.
NL-15-014 Docket No. 50-286 Attachment 1 Page 10 of 14 TO SURVEILLANCE FREQUENCY 1*
SR 3.4.12.9 --------------
NOTES ---------
- 1. Not required to be met when all RCS cold leg temperatures are > 330'F.
- 2. Not required to be met if SR 3.4.12.8 is met.
Verify each of the following conditions are satisfied prior to starting any RCP: Within 15 minutes prior to starting any
- a. Secondary side water temperature of the hottest RCP steam generator is _ 50'F above the coldest RCS cold leg temperature; and
- d. Pressurizer level is < 73%.
NL-15-014 Docket No. 50-286 Attachment 1 Page 11 of 14
3.0 BACKGROUND
This Technical Specification (TS) amendment proposes to revise the Reactor Coolant System (RCS) Heatup, and Cooldown curves; and the Low Temperature Overpressure Protection System (LTOP) requirements, in order to compensate for an increased service life. The current Technical Specifications (TS) for these curves expire at a service life of 27.2 Effective Full-Power Years (EFPY), which is estimated to occur in September, 2015. Based upon estimates of lifetime neutron fluence, and allowing for the effects of the Stretch Power Uprate (Amendment #225), calculations have been performed to establish pressure versus temperature limits for all curves in TS Sections 3.4.3 and 3.4.12 for a service life extending up to 37 EFPY, which is the accumulated burnup estimated to occur in December, 2023 during the period of extended plant operating license.
As expected, some of the revised curves are more restrictive in some operating regions than the existing ones, due to the effects of greater lifetime neutron fluence on the reactor vessel inner wall, and the associated increase in RTNDT at the 1/4 and 3/4 locations. The new curves were developed using the standard Westinghouse methodologies which have been previously reviewed and approved by the NRC for other licensees.
4.0 TECHNICAL ANALYSIS
The IP3 TS establishes limits for RCS pressure at low temperatures in order to protect the carbon and low alloy steel RCS components from damage due to non-ductile crack propagation. These limits include normal heatup and cooldown restrictions, as well as the automatic setpoints and manual restrictions associated with operation of the LTOP system. These requirements are promulgated in accordance with 10CFR50 Appendix G, which provide guidelines for development of these limits.
The existing limits are valid for plant operation through a lifetime burnup of 27.2 EFPY, which was originally estimated to occur in December, 2015. However, because of the higher unanticipated core burnup rate attributed to improved plant operation, a new estimated date of when the 27.2 EFPY limit would be reached is September, 2015.
The revised limits provided in this amendment are valid for a lifetime burnup of 37 EFPY, which is estimated to occur in December, 2023. The revised curves fall into two categories: heatup, inservice leak test, and cooldown curves for normal operation (TS Section 3.4.3), and LTOP curves (TS Section 3.4.12). All of the revised curves were developed by Westinghouse Electric Co in Enclosures 1, 2 and 3.
WCAP-1 7954-P (Enclosure 1) identifies the methodology by which the figures for the normal plant operation heatup and cooldown curves were generated. These curves are based upon the latest available reactor vessel information and updated calculated fluences, which include the impact of stretch power uprate. The new IP3 heatup and cooldown curves were generated using the "Axial-Flaw" methodology of the 1998 ASME Code, Section Xl through the 2000 Addenda (which allows the use of the Kic methodology) and the "Circ-Flaw" methodology. The material with the highest adjusted reference temperature (ART) was lower shell plate B-2803-3 (using credible surveillance data) at both 1/4 thickness (1/4T) and 3/4 thickness (3/4T) locations. These curves were developed without allowance for instrumentation uncertainties. The curves in the plant operating procedures will be adjusted to account for the instrumentation uncertainties associated with the actual instruments used to implement these curves. In similar fashion to RPS and ESFAS setpoint
NL-15-014 Docket No. 50-286 Attachment 1 Page 12 of 14 determinations, the methodology used for estimating instrument uncertainties conforms to the recommended practices of industry standard ISA 67.04.
Appendix B in WCAP-17954-P (Enclosure 1) contains a P-T limit evaluation of the reactor vessel inlet and outlet nozzles based on a 1/4T flaw postulated at the inside surface of the reactor vessel nozzle corner. As discussed in Appendix B, the P-T limit curves generated based on the limiting cylindrical beltline material (Lower Shell Plate B-2803-3) bound the P-T limit curves for the reactor vessel inlet and outlet nozzles for Indian Point Unit 3 at 37 EFPY. The P-T limit curves were generated based on the limiting cylindrical beltline material for 37 EFPY using heatup rates of 60 and 100 'F/hr. and cooldown rates of steady state, 20, 40, 60 and 100 OF/hr.
The calculation for the LTOP curves uses the standard Westinghouse methodology which has been previously reviewed and approved by the NRC for other licensees. The LTOP curves in Reference 2 are based on the heatup and cooldown curves established in Reference 1. Therefore, the revised LTOP setpoints, and its family of associated curves, similarly reflect the increase in lifetime fluence for a service life of 37 EFPY. The maximum PORV opening setpoint shown in Figure 3.4.12-1 is implemented as a variable setpoint for the LTOP instrumentation. The revised LTOPS PORV setpoints meet all acceptance criteria for protecting the Appendix G limits, PORV discharge piping limits, and the RCP operation limits and provide increased operating margin compared to the current setpoints. The other curves in the LTOP family, as well as the heatup and cooldown curves in Section 3.4.3, are procedurally implemented as Operations Procedure graphs and do not relate to any automatic protection systems.
5.0 REGULATORY ANALYSIS
5.1 No Significant Hazards Consideration Entergy has determined that this proposed Technical Specification change does not involve a significant hazards consideration as defined by 10CFR.50.92(c).
- 1. Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated.
The proposed TS changes do not involve a significant increase in the probability or-consequences of an accident previously evaluated. Except for a setpoint change for automatic PORV actuation, there are no physical changes to the plant being introduced by the proposed changes to the heatup and cooldown limitation curves. The proposed changes do not modify the RCS pressure boundary. That is, there are no changes in operating pressure, materials, or seismic loading. The proposed changes do not adversely affect the integrity of the RCS pressure boundary such that its function in' the control of radiological consequences is affected. The proposed heatup and cooldown limitation curves were generated in accordance with the fracture toughness requirements of 10CFR50 Appendix G, and ASME B&PV code,Section XI, Appendix G to the 1998 edition through the 2000 Addenda. The proposed heatup and cooldown limitation curves were established in compliance with the methodology used to calculate and predict effects of radiation on embrittlement of RPV beltline materials. Use of this methodology provides compliance with 1 OCFR50 Appendix G and provides margins of safety that ensure non-ductile failure of the RPV and the other RCS carbon and low alloy steel components will not occur. The proposed heatup and cooldown limitation curves prohibit operation in regions
NL-15-014 Docket No. 50-286 Attachment 1 Page 13 of 14 where it is possible for non-ductile failure of carbon and low alloy RCS materials to occur.
Hence, the primary coolant pressure boundary integrity will be maintained throughout the limit of applicability of the curves, 37 EFPY.
Operation within the proposed LTOP limits ensures that overpressurization of the RCS at low temperatures will not result in component stresses in excess of those allowed by the ASME B&PV Code Section Xl Appendix G.
Consequently, the proposed changes do not involve a significant increase in the probability or the consequences of an accident previously evaluated.
- 2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed TS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. No new modes of operation are introduced by the proposed changes. The proposed changes will not create any failure mode not bounded by previously evaluated accidents. Further, the proposed changes to the heatup and cooldown limitation curves and the LTOP limits do not affect any activities or equipment other than the RCS pressure boundary and do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Consequently, the proposed changes do not create the possibility of a new or different kind of accident, from any accident previously evaluated.
- 3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety.
The proposed TS changes do not involve a significant reduction in the margin of safety.
The revised heatup and cooldown limitation curves and LTOP limits are established in accordance with current regulations and the ASME B&PV Code 1998 edition through the 2000 Addenda, Appendix G. These proposed changes are acceptable because the ASME B&PV Code maintains the margin of safety required by 10CFR50, Appendix G.. Because operation will be within these limits, the RCS materials will continue to behave in a non-brittle manner consistent with the original design bases.
Therefore, Entergy has concluded that the proposed changes do not involve a significant reduction in a margin of safety.
Based on the above evaluation, Entergy has concluded that the proposed changes will not result in a significant increase in the probability or consequences of any accident previously analyzed; will not create the possibility of a new or different kind of accident from any accident previously evaluated; and, does not result in a significant reduction in the margin of safety. Therefore, operation of IP3 in accordance with the proposed amendment does not involve a significant-'
hazards consideration.
5.2 Applicable Regulatory Requirements / Criteria The proposed changes were developed in accordance with the following NRC regulations and.
guidance:
NL-15-014 Docket No. 50-286 Attachment 1 Page 14 of 14
- Regulatory Guide (RG) 1.99, Radiation Embrittlement of Reactor Vessel Materials, Rev. 2
- NRC Regulatory Issue Summary (RIS) 2014-11, Information on Licensing Applications for Fracture Toughness Requirements for Ferritic Reactor Coolant Pressure Boundary Components, October 14, 2014 10CFR50 Appendix G, by reference to ASME B&PV Code Section Xl Appendix G specifies fracture toughness and testing requirements for the RCS carbon and low alloy steel materials.
10CFR50 Appendix G also requires prediction of the effects of neutron irradiation on vessel embrittlement by calculating the Adjusted Reference Temperature (ART) and the Charpy Upper Shelf Energy (USE). The methods provided in RG 1.99 Rev. 2, defines the ART as the sum of unirradiated reference temperature, the increase of reference temperature resulting from neutron irradiation, and a margin to account for uncertainties in the prediction method.
5.3 Environmental Considerations The proposed changes to the IP3 Technical Specifications do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent 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.
6.0 PRECEDENCE The methodology under which the heatup and cooldown curves were created is a standard used by Westinghouse throughout the industry. A previous request for a change to these curves was approved with NRC SER for TS Amendment 235 (Reference 3).
7.0 REFERENCES
- 1. WCAP-17954-P, Revision 0, "Indian Point Unit 3 Heatup and Cooldown Limit Curves for Normal Operation," Westinghouse Electric Co, dated December 2014 . a
- 2. LTR-PCSA-1 4-69 Attachment 1, "Indian Point 3: Low Temperature Overpressure Protection (LTOP) Analysis," Westinghouse Electric Co, dated December 2014. .
- 3. NRC letter to Entergy, Indian Point Nuclear Generating Unit No. 3 - Issuance of Amendment Re: Technical Specification Change Request for Pressure-Temperature and Low Temperature Protection System Limits (TAC No. MD 4079),,dated October 4, 2007.
ATTACHMENT 2 TO NL-15-014 MARKUP OF TECHNICAL SPECIFICATION PAGES FOR PROPOSED CHANGES REGARDING REACTOR HEATUP AND COOLDOWN CURVES AND LTOP REQUIREMENTS Text changes indicated by lineout for deletion and Bold/Italics for additions Figure changes are marked with either "Replace with New Figure" or "Delete this Figure" and all new Figures are unmarked Unit 3 Actual Affected Pages:
3.4.3-1 3.4.3-2 3.4.3-3 3.4.3-4 3.4.3-5 3.4.12-1 3.4.12-2 3.4.12-4 3.4.12-5 3.4.12-8 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286
RCS P/T Limits 3.4.3 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 RCS Pressure and Temperature (P/T) Limits LCO 3.4.3 RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within the limits 3
specified in Figure . 4 . 3 -1r and Figure 3.4.3-2,---an Figure 3.4.3 3.
APPLICABILITY: At all times.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.---------- NOTE ------- A.1 Restore 30 minutes parameter(s) to Required Action A.2 within limits.
shall be completed whenever this AND Condition is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> entered. A.2 Determine RCS is acceptable for continued operation.
Requirements of LCO not met in MODE 1, 2,3, or 4.
B. Required Action and B.1 Be in MODE-3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
associated Completion Time of AND Condition A not met. B.2 Be in MODE 5 with 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> RCS pressure
< 500 psig.
(continued)
INDIAN POINT 3 3.4.3-1 Amendment 205
RCS P/T Limits 3.4.3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.---------- NOTE ------- C.1 Initiate action to Immediately Required Action C.2 restore shall be completed parameter(s) whenever this to within limits.
Condition is entered. AND Prior to Requirements of LCO C.2 Determine RCS is entering MODE 4 not met any time in acceptable for other than MODE 1, continued 2, 3, or 4. operation.
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.3.1 ------------------- NOTE--------------
Only required to be performed during RCS heatup,inservice leak testing, and cooldown operations. anel RCS i" .... c leak anel hydrczstat~ic cti 30 minutes Verify RCS pressure.,. .RCS.temperature, and RCS heatup and c6oldown rates are within the limits specified in the.-
following:
- b. Figure 3.4.3-2 during RCS cooldowni,..
aft4.
- e. Figuro 3.4.3 3 during RPCS inoorvic leak and hydrosztatie teting.
INDIAN POINT 3 3.4.3-2 Amendment 205
rYYYTYTTTr
~ REPLACE WITH NEW FIGURE k k L k k ~ IL I RCS PIT Limits 1 3.4.3
______ + .
______ 1~______ ______ ______ -- 0 I
................ ~.
<0 . . .
_____________ 0 N..... ............... .*.\...
0 4--- - kd - N 0
-N .. ... . . .......
01110 M I .q Lo U.
C, LO__
I I U, 4l) 16 (L Ma I .
I- - e. .
u- t 2:esj
+ I L
©......... ................
I ~
k
[ ....... .. .. .-...
- U, mco . . . . .. . . . .. -.. .
S............
~
. I.. . . .. .. ,
'~ .~,
C
~
S.~
... .... . . . .. I. . ............ ..
0 (OlSd) sinsflSGd waISAS W1000o JOMOeeJ Figure 3.4.3-1:
Heatup Limitations for Reactor Coolant System INDIAN POINT 3 3.4.3-3 Amendm.ent 235
IIH NWFIUR in- RCS PiT Limits
.).4.3 LL
!6_ . .
- 1 I I
I I
I CL Ir
©
.. .... .......... .1-N C-,
I ............
0-w en
..I I ...........
I E 41
-VI','
I
~
I IV VICL0-0- v .............
0 E 2 LL1.1 M:.W UL .- I 0~ IS C CO C,4b. (t 0
+ 1 M +
0 0 0 0 ~ S R(OISd) ein~seJd WGISAS IUB1003 JoIpeeO Figure 3.4.3-2:
Cooldown Limitations for Reactor Coolant System INDIAN POINT 3 3.4.3-4 Amendment 235
rrrrryrrw
~ DELETE THIS FIGURE RCS P/T Limits 7[ .1 -.
i . . . . . . . . i 3.4.3 I . . . . ! . . . .
..... 00 .... .
I I
ir
©
. ...i.........
- l. ....
........... .... .......... C.,
LL L or
- Ii I
I !
Cj0)
-o C),
....... .Lj.
C14 qL h
I i,.
I In
-o-o C
CA t
IL I .
Hydrostaticand Inservice Leak Testing Limitations for Reactor Coolant System INDIAN POINT 3 3.4.3-5 Amendment 235
MATERIAL PROPERTY BASIS LIMITING MATERIAL: Lower Shell Plate B-2803-3 using credible surveillance data, Position 2.1 LIMITING ART VALUES AT 37 EFPY: 1/4T, 245.0°F (Axial Flaw) 3/4T, 198.2°F (Axial Flaw) 2500 .
2250 Leak Test Limit Cl, 22000 ----. - -- - Acceptable Operation W Unacceptable C" Operation__
E 1750 -- I 1500 . .60 Deg. F/Hr J~Heatup Ratet
- i Heatup Rate 1250 eg. F/Hr Dl1O
- 0---------
1000 1250 2I5 K250o --- - .... i. .. .. .....
0 0 50 100 150 200' 250 300 350 400 450 500 550 Tcold Temperature (Deg. F)
Figure 3.4.3-1:
Heatup and Inservice Leak Test Limitations for Reactor Coolant System (Without instrument uncertainties)
MATERIAL PROPERTY BASIS LIMITING MATERIAL: Lower Shell Plate B-2803-3 using credible surveillance data, Position 2.1 LIMITING ART VALUES AT 37 EFPY: i/4T, 245.0°F (Axial Flaw) 3/4T, 198.2'F (Axial Flaw) 2500-2250 . . . _.. . .-
ý2000 . -__
IL
'1750---
U)
Unacceptabin .
rL~o .
Operation
-! Acceptable I)
E 1500 .......... ___ -
100 C,
1250 . - . -.. -
250 1000ooiw ......
Rlates
-10 Deg. F/Hr steady -state
. . 500-G
- . .20 ... .
2500.4 0 50 10 W 1iK0 L3 " 4 0 50 100 150 200 250 300 350 400 450 500 550 TcoId Temperature (Deg. F)
Figure 3.4.3-2:
Cooldown Limitations for Reactor Coolant System (Without instrument uncertainties)
LTOP 3.4.12 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.12 Low Temperature Overpressure Protection (LTOP)
LCO 3.4.12 LTOP shall be OPERABLE with no high head safety injection (HHSI) pumps capable of injecting into the RCS and the accumulator discharge isolation valves closed and de-energized, and either of the following:
- -------- Note--------------------
LCO 3.4.12.a and LCO 3.4.12.b are not Applicable when all RCS cold leg temperatures are > 330 0 F.
- a. The Overpressure Protection System (OPS)
OPERABLE with two power operated relief valves (PORVs) with lift settings within the limit specified in Figure 3.4.12-1; OR
- b. The RCS depressurized with an RCS vent of Ž 2.00 square inches, or one blocked open PORV with its block valve disabled in the open position.
------ ------ ------ NOTES-----------------------
- 1. Accumulator isolation is only required when accumulator pressure is greater than or equal to the maximum RCS pressure for the coldest existing RCS cold leg temperature allowed by the P/T limit curve in Figure 3.4.12-1.
- 2. One HHSI pump may be made capable of injecting into the RCS as needed to support emergency boration or to respond to a loss of RHR cooling.
3!. One HHSI pump may be made capable of injecting into the RCS for pump testing for a period not to exceed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
APPLICABILITY: Whenever the RHR System is not isolated from the RCS, MODE 4 when any RCS cold leg temperature is : 330'F, MODE 5, MODE 6 when the reactor vessel head is on.
INDIAN POINT 3 3.4.12-1 Amendment 235
LTOP 3.4.12 ACTIONS
NOTE LCO 3.0.4.b is not applicable when entering MODE 4.
CONDITION REQUIRED ACTION COMPLETION TIME A. One or more HHSI A.I Initiate action to Immediately pump(s) capable of verify no HHSI injecting into the pumps are capable RCS. of injecting into the RCS.
7' '~ I ~i.......4 .~. - -~
vented wi-th
..pening Ž2.00 s~paare inehes.
Immediately w*-4 -F-~ -
level is ! 0%.
A.2.3 Verify no more than two IHIDI puffps aroe eapable e f injooet ing it AND OR A.42.1 Verify RCS is Immediately vented with Immediately opening greater than or equal to one pressurizer Immediately code safety valve flange.
AND A.42.2 Verify no more AND than two HHSI pumps are capable once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of injecting into the RCS (continued)
INDIAN POINT 3 3.4.12-2 Amendment 226
LTOP 3.4.12 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. An accumulator B.1 Close and de- 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> discharge isolation energize isolation valve not closed valve for affected and de-energized accumulator.
when the accumulator pressure is greater than or equal to the maximum RCS pressure for the coldest existing cold leg temperature specified in Figure 3.4.12-1.
C. Required Action and C.1.1 Increase all RCS 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated cold leg Completion Time of temperatures to Condition B not > 330°F.
met.
AND 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C.1.2 Isolate the RHR System from the RCS.
OR 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> C.2 Depressurize affected accumulator to less than the maximum RCS pressure for coldest existing cold leg temperature specified in Figure 3.4.12-1.
INDIAN POINT 3 3.4.12-3 Amendment 235
LTOP 3.4.12 CONDITION REQUIRED ACTION COMPLETION TIME D. One required PORV D.1 Restore required 7 days inoperable. PORV to OPERABLE status.
(continued)
INDIAN POINT 3 3.4.12-4 Amendment 235
LTOP 3.4.12 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME E. Two required PORVs E.1 Depressurize RCS 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> inoperable. and establish RCS vent of > 2.00 square inches, or OR one blocked open PORV with its Required Action and block valve 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> associated disabled in the Completion Time of open position.
Condition C or D not met. OR E.2.1 Increase all RCS 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> cold leg temperatures to
> 330 0 F.
AND 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E.2.2 Isolate the RHR AND System from the RCS. Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter OR E.3 Verify pressurizer level, RCS pressure, and RCS injection capability are within limits specified in Figure 3.4.12-2 and Figure 3.4.12-3 for OPS not OPERABLE.
INDIAN POINT 3 3.4.12-5 Amendment 235
LTOP 3.4.12 CONDITION REQUIRED ACTION COMPLETION TIME F. LTOP inoperable for F.l Depressurize RCS 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> any reason other and establish RCS than Condition A, vent of Ž 2.00 B, C, D, or E. square inches, or one blocked open PORV with its block valve disabled in the open position.
INDIAN POINT 3 3.4.12-6 Amendment 235
LTOP 3.4.12 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.12.1 Verify no HHSI pumps are capable of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> injecting into the RCS.
SR 3.4.12.2 Verify each accumulator discharge 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> isolation valve is closed and de-energized; OR 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Verify each accumulator pressure is less than the maximum RCS pressure for the coldest existing RCS cold leg temperature allowed by the P/T limit curve in Figure 3.4.12-1.
SR 3.4.12.3 -------------------NOTE----------------
Only required to be met when complying with LCO 3.4.12.b.
Verify RCS vent Ž 2.00 square inches, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for or one blocked open PORV with its block unlocked open valve disabled in the open position vent valve(s) established.
AND 31 days for locked open vent valve(s)
(continued)
INDIAN POINT 3 3.4.12-7 Amendment 205
LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.4.12.4 ------------------ NOTE--------------
Only required to be met when complying with LCO 3.4.12.a.
Perform CHANNEL CHECK of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Overpressure Protection (OPS) instrument channels.
SR 3.4.12.5 Verify PORV block valve is open for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> each required PORV.
SR 3.4.12.6 --------------------NOTE---------------
Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing any RCS cold leg temperature to : 330 0 F.
Perform a COT on each required PORV, 24 months excluding actuation.
SR 3.4.12.7 Perform CHANNEL CALIBRATION for each required OPS channel as follows:
- a. OPS actuation channels; and 18 months
- b. RCS pressure and temperature 24 months instruments.
(continued)
INDIAN POINT 3 3.4.12-8 Amendment 235
LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.4.12.8 --------------------- NOTES--------------
- 1. Not required to be met when all RCS cold leg temperatures are > 330'F.
- 2. Not required to be met if SR 3.4.12.9 is met.
Verify each of the following conditions Within 15 are satisfied prior to starting any minutes prior RCP: to starting any RCP
- a. Secondary side water temperature of the hottest steam generator (SG) is less than or equal to the coldest RCS cold leg temperature; and
- c. Steam generator pressure is not decreasing; and
- d. 1 Overpressure Protection System (OPS) is OPERABLE; OR d.2.1 RCS pressure less than nominal OPS setpoint specified in Figure 3.4.12-1; and d.2.2 Pressurizer level, RCS pressure, and RCS injection capability are within limits specified in Figure 3.4.12-2 and Figure 3.4.12-3 for OPS not OPERABLE.
(continued)
INDIAN POINT 3 3.4.12-9 N O4Amendlment 235
LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.4.12.9 ------------------- NOTES----------------
- 1. Not required to be met when all RCS cold leg temperatures are > 330'F.
- 2. Not required to be met if SR 3.4.12.8 is met.
Verify each of the following conditions Within 15 are satisfied prior to starting any minutes prior RCP: to starting any RCP
- a. Secondary side water temperature of the hottest steam generator is
! -450'F above the coldest RCS cold leg temperature; and
- b. RCS makeup is less than or equal to RCS losses; and C. Overpressure Protection System (OPS) is OPERABLE; and
- d. Pressurizer level is
- 73%; and
- r-Q140Q-9"i- 1l(4r- -'
=Pl 1pc r tir irtmr
...... 0 .
wltflin lifflts specifiecI in Figuroe 3.4.12 4.
INDIAN POINT 3 3.4.12-10 Amendment 235
REPAEWTNE FIGURE
... ... . . . J ~ . . & 1 1 1
...7. ....... ...........
LTOP ra. 3.4.12 2.
(1)
, 4,.-
F I . . . .. . . . . . . . . . ... . . . .. . . . .. i . . . . . .
M 8 t
... .. ... .... ... ........ ...t ... ..... . . ..... ... ... . ... . .... I .. ... . .
... ........ .... ... .... ... .... - I ..... .. ...
z
(!DlSd) ainssGJd SOU Figure 3.4.12-1: Maximum Allowable Nominal PORV Setpoint for LTOP (OPS), 27.2 EFPY INDIAN POINT 3 3.4.12-9 Amendment 235
-.3.4.12
.. .. . .. ..... .. . ;:Jt s-.
77 I N/
Z 3-I--
LC). .... ........... -U o -
- D *
[* I I 0 0 0 Q 0 0 0 0 0
%"1BA31 ZLninsSSbd Figure 3.4.12-2: Pressurizer Limitations for OPS Inoperable, 27.2 EFPY (Up to one charging pump capable of feeding the RCS)
INDIAN POINT.") .3.4.12-10 Amendment 215
... .... ... ....... 3.4.12
.... 7.....77 26
. .. . .... . . . . . . . . -S 9
ev
. . . . ..\. . . . .
- I l t:I:0
- .- )
/4 I
........... o CA
........ I....... ..........
Q 10
+
0 2~0N 0 0 Figure 3.4.12-3: Pressurizer Limitations for OPS Inoperable, 27.2 EFPY (Up to three charging pumps and/or one safety injection pump capable of feeding the RCS)
INDIAN POINT 3 3.4.12-11 Amcndnient 2' ) 5
DELETE THIS FIGURE LTOP 3.4.12 CM E.
C,,
(j 60(3) P03j-Figure 3.4.12-4: Secondary Side Limitations for RCP Start with Secondary Side Hotter than Primary Side, 27.2 EFPY INDIAN POINT 3 3.4.12-12 Amendment 235
S00 750 700 6s0 0
600 350 500 450 50 I0N 150 nD O 250 300 350 Auctioneered La~w lndicatedRCS Temperature (OFj Figure 3.4.12-1: Maximum Allowable PORV Setpoint for LTOP (OPS), 37 EFPY
100 Unacceptable 90 Operation 5 70
- 70 S.400 psig.
"50 s 450 psigj __ __ ____ ___
.30 -- :
-_ 5oO-p-.-- ------- >_ _ ____ ___
"I[Acceptable
- 10. Operation 0 _",_ ,
0 50 100 150 200 250 300 350 400 Indicated Tcold (*F)
Figure 3.4.12-2: Maximum Allowable Pressurizer Level for LTOPS Inoperable with 1 Charging Pump Capable of Injecting
90 80 --
560 -
Z 40
.2 30
~20 ~
..10
.0L 0 so 100 150 200 250 300 350 400
.Indicated Tcold (OD)
Figure 3.4.12-3: Maximum Allowable Pressurizer Level for LTOPS Inoperable with 3 Charging Pumps Capable of Injecting
ATTACHMENT 3 TO NL-13-014 MARKUP OF TECHNICAL SPECIFICATION BASES PAGES FOR PROPOSED CHANGES REGARDING REACTOR HEATUP AND COOLDOWN CURVES AND LTOP REQUIREMENTS Text changes indicated by lineout for deletion and Bold/Italics for additions Unit 3 Actual Affected Pages:
B 3.4.3-1 to B 3.4.3-9 B 3.4.12-1 B 3.4.12-3 to -14 B3.4.12-17to-19 ENTERGY NUCLEAR OPERATIONS, INC.
INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286
RCS P/T Limits B 3.4.3 BASES BACKGROUND All: cofpeneanto of 6he RCS; are designcd to wi~t~hstand effects of elbi leads do to system, ....cur. and tcxpcraturc .h.angc.
MThooc loaelsancr introeducol 13-tatu (heat-up) and shutdJB (e.eldewn)
. pfatlo*., pD-' r t.".... ;;ndr4 a-at-,-o trips. .h-i LG9 ]Lmitos the pr-essurc, and t5efnpeiaturce ehanges dur-ing RCZ heatup and cooldownff, w-ithin the design pasumtiens eand the strcacs limits-for cyclic operation.10CER50, Appendix G establishes the rec tiranens for pressure and tenperature limitations to prevent non-ductile failure of the low alloy steel ccxtvnents which are part of the reactor coolant pressure boundazy (RCPB). These caivn ents include the reactor vessel, the steam generators and the ptressurizer. The remainder of the RCPB caiponents are fabricated frmn either stainless steel or fron Nickel alloy materials and therefore are not susceptible to non-ductile fracture in the range of normal operating tergeratures. This LCO inplements the retuircnnts of 10CFR50, Appendix G.
LCO 3.4.3, Figure 3.4.3-1, Heatup and Imservice Leak Test Limitations for the Reactor Coolant SystET 7 , and Figure, 3.4.3-2, Cooldown Limitations for the Reactor Coolant System, and Figarc 3.4.3 3, Hyk.drotatic and Rnzcrvicc Lock] Tcctin Limitations for the R.a.t.r Coolantc S*t*.. , contain P/T limit curves for heatup, inservice leak test and cooldown, and "i... -nee leak kn*
hydrostatic (ISL..) tc,.ting, respectively-, ef-....
Each P/T limit curve defines an acceptable region for normal operation. The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable region. Thc happy fac ".e...n. cn i Figuar 3.4.3 1, Figaurc, 3.4.3 2, eand Figur 3.4.3 3, indicatcz thc side of c eunv in %4-ch epcratcien is pcxizz~siblc. Geon-rsely, the sad facc icon ind~icatcc the side of the curve in-ve eperation is p-e""bked Operation is pemnitted in the region located to the right and below the curves prvided in Figures 3.4.3-1 and 3.4.3-
- 2. Conversely, operaticn in the region located to the left and above the curves is not permitted. These curves were developed without allowance for instrumentation uncertainties. The curves in the plant operating procedures are adjusted to account for the instrumentation uncertainties associated with the actual instruments used to implement these curves.
The LCO establishes operating limits that provide a margin to britt-non-ductile failure of the rcactor vcsscl aed piping of te*-reactor coolant pressure boundary (RCPB)-- Thc vessel is t-h camqpencnt most; othi cot toe brittle failurc-, and the LGEO lifito apply ffalyý to the vessel. The !iRt=- do not apply to thc prczcuhrizer, 4hich has eliffarent design eharýactoricstioc can-INDIAN POINT 3 B 3.4.3 - 1 Revision 3
RCS P/T Limits B 3.4.3 BASES operating f-unctiin. cavapnents fabricated fran low alloy steel.
Since the reactor vessel is the coly RCPB capoent which is subjected to neutro irradiaticn embrittlement, it is the nost limiting RCS cczponent. However, the remuinder of the RCPB ccuponents fabricated fran low alloy steel (i.e. Steam Generators and Pressurizer)have also been comsidered in the analysis and were found to be bounded by the beltline region of the reactor vessel.
10 CER 50, Appendix G (Ref. 2), requires the establishment of P/T limits for specific material fracture toughness requirements of the RCPB materials. Reference 2 requires an adequate margin to brittle failure during normal operation, anticipated operational occurrences, and system y *esvta* e-inservice leak tests. It mandates the use of the American Society of Mechanical Engineers (ASME) Code, Section 4 , Appendix G (Ref. 3).
The neutron embrittlement effect on the material toughness is reflected by increasing the nil ductility reference temperature (RTu) as exposure to neutron fluence increases.
The actual shift in the RTm of the vessel material will be established periodically using the methodology provided in Regulatory Guide 1.99, Revision 2. These calculated values are periodically confinrud by removing and evaluating the irradiated reactor vessel material specimens, in accordance with ASIM E 185 (Ref. 43) and Appendix H of 10 CFR 50 (Ref. -4). The operating P/T limit curves will be adjusted, as necessary, based on the evaluation findings and the riccerm,.ndatien of Regtlatorey *uide 1.99 (Ref. 6) . using the methodalogy pxuvided in Appendix G to the ASM Section xr Code (Ref. 2).
The P/T limit curves are composite curves established by superinposing limits derived from esese analyses of those portions of the reactor vessel nd head that are the most restrictive. At any specific pressure, temperature, and temperature rate of change, one location within the reactor vessel will dictate the most restrictive limit. Across the span of the P/T limit curves, different locations are more restrictive, and, thus, the curves are composites of the most restrictive regions.
The heatup curve represents a different set of restrictions than the cooldown curve because the directions of the thermal gradients through the vessel wall are reversed. The thermal gradient reversal alters the location of the tensile stress between the outer and inner walls.
The consequence of violating the LCO limits is that the RCS has been operated under conditions that cani rzsult in britt!l challenge the margins against non-ductile failure of the RCPB,
- . INDIAN POINT 3 B 3.4.3 - 2 Revision 3
RCS P/T Limits B 3.4.3 BASES possibly leading to a nonisolable leak or loss of coolant accident. In the event these limits are exceeded, an evaluation must be performed to determine the effect on the structural integrity of the RCPB components. The ASME Code,Section XI, Appendix E (Ref. -6), provides a recommended methodology for evaluating an operating event that causes an excursion outside the limits.
APPLICABLE SAFETY ANALYSES The P/T limits are not derived from Design Basis Accident (DBA) analyses. They are prescribed during normal operation to avoid encountering pressure, temperature, and temperature rate of change conditions that might cause undetected flaws to propagate and cause nonductile failure of the RCPB, an unanalyzed condition. Rfeloeren 1:es4t.bli*he" 64e meih*.
hdelgy f"v d.tr.i.-iJ, the P,4T !i ts. Although the P/T limits are not derived from any DBA, the P/T limits are acceptance limits since they preclude operation in an unanalyzed condition.
RCS P/T limits satisfy Criterion 2 of 10 CFR 50.36.
LCO The two elements of this LCO are:
- a. The limit curves for heatup, inservice leak test and cooldown-, -and IL toz4; and
- b. Limits on the rate of change of temperature.
Figure 3.4.3-1, Heatup and Xr*service Leak Test Limitations for the Reactor Coolant System-, and Figure, 3.4.3-2, Cooldown Limitations for the Reactor Coolant System, an4 Figure 3.4.3 3, i.-r..tati-cind inseri-Ae Looke Tosting Limitatiens fora the Reaeteir Coclon System, contain P/T limit curves for heatup, inservice leak test and cooldown, cindlnsorvie. -,ydrit leaik and atic4e (ILH) testin*,
respectively. These figures specify the maximum RCS pressure for various heatup and cooldown rates at any given reactor coolant temperature. The figures provide the limiting RCS pressure and reactor coolant temperature combination for reactor coolant temperature heatup and cooldown rates up to -6GV100F /hr and reactor coolant temperature cooldown rates up to 100°F/hr.
Therefore, heatup or cooldown rates that exceed ýWF100LF 100°F /hr eeeldown
. .id that oxcood 900V-are considered not within ratoz the limits of this LCO.
The LCO limits apply to all components of the RCS pressure boundary, except the pressurizer. Because the pressurizeris subjected to insurges and outsurges and it is used to control WS INDIAN POINT 3 B 3.4.3 - 3 Revision 3
RCS P/T Limits B 3.4.3 BASES pressure, it experiences higher heattv and coodown rates which have been analyzed separately.Those 1Lmits defino alleablo operrating roegions and ponrilt a large numbo)r- of operating eycica
%4hile prroviding a ofide ffargin te nenduetile failuroL.
The limits for the rate of change of teniperature control the thermal gradient through the vessel wall and are used as inputs for calculating the heatup7 and cooldownd, d-ID o....
ý' P/T limit curves. Thus, the LCO for the rate of change of temperature restricts stresses caused by thermal gradients and also ensures the validity of the P/T limit curves. Heatup and cooldown limits are specified in hourly increments (i.e., the heatup and cooldown limits are based on the temperature change averaged over a one hour period). Limit lines for cooldown rates between those presented may be obtained by interpolation.
Violating the LCO limits places the reactor vessel outside of the bounds of the steress analyses and can increase stresses in other RCPB ccromonents. The consequences depend on several factors, as follows:
- a. The severity of the departure from the allowable operating P/T regime or the severity of the rate of change of temperature;
- b. The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced); and
- c. The existence, size, and orientation of flaws in the vessel material.
I APPLICABILITY The RCS P/T limits LCO provides a definition of acceptable operation for prevention of nonductile failure in accordance with 10 CFR 50, Appendix G (Ref. -1). Although the P/T limits were developed to provid guidan".,, for operation during heatup, Znservice Leak test or cooldown (MODES 3, 4, and 5) er I*94 test', their Applicability is at all times in keeping with the concern for nonductile failure. The liff.ts do not apply to th proocurz r.
During MODES 1 and 2, other Technical Specifications provide limits for operation that can be more restrictive than or can supplement these P/T limits. LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure frcm Nucleate Boiling (ENB)
Limits"; LCO 3.4.2, "RCS Minimum Temperature for Criticality"; and Safety Limit 2.1, "Safety Limits," also provide operational restrictions for pressrc-e temperature and maximum pressure.
Furthermore, MODES 1 and 2 are above the temperature range of .
concern for nonductile failure, and stress analyses have been INDIAN POINT 3 B 3.4.3- 4 Revision 3
RCS P/T Limits B 3.4.3 BASES performed for normal maneuvering profiles, such as power ascension or descent.
Figuare 3.4.3 1 and 3.4.3 2 ano. applieable for- 34EC-P at 3216 M-it.
Bet~h figures aroe lableold applieable for 2:7.2 BEPP! sololy feor tho l*: teffpcrature evnr pressuro protootion sytcn a tompoerataro-.
ACTIONS A.1 and A.2 Operation outside the P/T limits during MODE 1, 2, 3, or 4 must be corrected so that the RCPB is returned to a condition that has been verified by stress analyses.
The 30 minute Completion Time reflects the urgency of restoring the parameters to within the analyzed range. Most violations will not be severe, and the activity can be accomplished in this time in a controlled manner.
Besides restoring operation within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify the RCPB integrity remains acceptable and must be ccomleted before continuing operation. Several methods may be used, including comparison with pre-analyzed transiento conditicns in the stress analyses, new analyses, or inspection of the components.
ASME Code,Section XI, Appendix E (Ref. -6), may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline.
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time is reasonable to accomplish the evaluation. The evaluation for a mild violation is possible within this time, but more severe violations may require special, event specific stress analyses or inspections. A favorable evaluation must be ccompleted before continuing to operate.
Condition A is modified by a Note requiring Required Action A.2 to be completed whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action A. 1 is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity.
B.1 and B.2 INDIAN POINT 3 B 3.4.3- 5 Revision 3
RCS P/T Limits B 3.4.3 BASES If a Required Action and associated Ccopletion Time of Condition A are not met, the plant must be placed in a lower MODE because either the RCS remained in an unacceptable P/T region for an extended period of increased stress or a sufficiently severe event caused entry into an unacceptable region. Either possibility indicates a need for more careful examination of the event, best accomplished with the RCS at reduced pressure and temperature. In reduced pressure and temperature conditions, the possibility of propagation w%-tof undetected flaws is decreased.
If the required restoration activity cannot be accomplished within 30 minutes, Required Action B.1 and Required Action B.2 must be implemented to reduce pressure and temperature.
If the required evaluation for continued operation cannot be accomplished within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the results are indeterminate or unfavorable, action must proceed to reduce pressure and temperature as specified in Required Action B. 1 and Required Action B.2. A favorable evaluation must be completed and documented before returning to operating pressure and temperature conditions.
Pressure and temperature are reduced by bringing the plant to MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and to MODE 5 with RCS pressure < 500 psig within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Note that LCO 3.4.12, Low Temperature Overpressure Protection (LTOP), will also apply and may require limits for operation that are more restrictive than or supplement this limit.
The allowed Cormpletion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.
C.A and C.2 Actions must be initiated inrmediately to correct operation outside of the P/T limits at times other than when in MODE 1, 2, 3, or 4, so that the RCPB is returned to a condition that has been verified by stress analysis.
The inmediate Completion Time reflects the urgency of initiating action to restore the parameters to within the analyzed range.
Most violations will not be severe, and the activity can be acccmplished in this time in a controlled manner.
Besides restoring operation within limits, an evaluation is required to determine if RCS operation can continue. The evaluation must verify that the RCPB integrity remains acceptable and must be ccmpleted prior to entry into MODE 4. Several methods may be used, including comparison with pre-analyzed tra--isntS -
INDIAN POINT 3 B 3.4.3- 6 Revision 3.-
RCS P/T Limits B 3.4.3 BASES cazditiow2 in the tress analyses, or inspection of the components.
ASME Code,Section XI, Appendix E (Ref. -6), may be used to support the evaluation. However, its use is restricted to evaluation of the vessel beltline. Condition C is modified by a Note requiring Required Action C.2 to be caomleted whenever the Condition is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration alone per Required Action C.A is insufficient because higher than analyzed stresses may have occurred and may have affected the RCPB integrity.
SURVEILLANCE REQUIREMENTS SR 3.4.3.1 Verification that operation is within the PT limits is required every 30 minutes when RCS pressure and temperature conditions are undergoing planned changes. This Frequency is considered reasonable in view of the control roan indication available to monitor RCS status. Heatup and cooldown limits are specified in hourly increments (i.e., the heatup and cooldown limits are based on the temperature change averaged over a one hour period). Also, since temperature rate of change limits are specified in hourly increments, 30 minutes permits assessment and correction for minor deviations within a reasonable time.
Surveillance for heatup, xnser'4ce Leak test and cooldown, er- I8l testi.g may be discontinued when the definition given in the relevant plant procedure for ending the activity is satisfied.
This SR is modified by a Note that only requires this SR to be performed during system heatup, Iaservice Leak test and cooldownT-,
and ISI41 tcstl. No SR is given for criticality operations-because LCO 3.4.2 contains a more restrictive requirement.
REFERENCES 1. WCA A, July 1972.
,7924
- 23. ASME, Boiler and Pressure Vessel Code, Section .
Appendix G.
- 34. ASIIM E 185--0.
- 45. 10 CER 50, Appendix H.
INDIAN POINT 3 B 3.4.3 - 7 Revision 3.
RCS P/T Limits B 3.4.3 BASES 5 6. Regulatory Guide 1.99, Revision 2, May 1988.
6 ASME, Boiler and Pressure Vessel Code,Section XI, Appendix E.
- 8. W.NP 1621l2P, T:Hon, Peint Nuolear- Pewcr Conerrat~ing UnhitN.
3 Strroteh Pewer Ufrate NSSS and B9P Licoensing floport, Jifno
.2. . . ....
INDIAN POINT 3 B 3.4.3 - 8 Revision 3
LTOP B 3.4.12 B 3.4 REACTOR COOLANT SYSTEM (RCS)
B 3.4.12 Low Temperature Overpressure Protection (LTOP)
BASES BACKGROUND LTOP is established to limit RCS pressure at low temperatures so the integrity of the reactor coolant pressure boundary (RCPB) is not compromised by violating the pressure and temperature (P/T) limits of 10 CFR 50, Appendix G (Ref. 1). The reactor vessel is the limiting RCPB component for demonstrating such protection. LCO 3.4.12, Figure 3.4.12-1 provides the maximum allowable nominal actuation logic setpoints for the power operated relief valves (PORVs) and the maximum RCS pressure for the coldest existing RCS cold leg temperature during cooldown, shutdown, and heatup to meet the Reference 1 requirements during the LTOP MODES.
The reactor vessel material is less tough at low temperatures than at normal operating temperature. As the vessel neutron exposure accumulates, the material toughness decreases and becomes less resistant to pressure stress at low temperatures (Ref. 2). RCS pressure, therefore, is maintained low at low temperatures and is increased only as temperature is increased.
The potential for vessel overpressurization is most acute when the RCS is water solid, occurring only while shutdown because a pressure fluctuation can occur more quickly than an operator can react to relieve the condition. Exceeding the RCS P/T limits by a significant amount could cause brittle crackingnon-ductile failure of the reactor vessel. LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," requires administrative control of RCS pressure and temperature during heatup and cooldown to prevent exceeding the limits in Figufc 3.4.12 1 of Reference 1.
When the RHR-System is isolated from the RCS, the RHR System is protected from overpressure by two spring loaded relief valves (SI-733A and SI-733B). When the RHR System is not isolated from the RCS, the RHR System is protected from overpressure by spring loaded relief valve:'(i~e., AC-1836) which has sufficient capacity to accommodate all 3 charging pumps. However, this relief
... valve does not have sufficient capacity to ensure that the RHR system does not exceed design pressure limits
-iduring a mass addition resulting from an inadvertent
.-injection of one or more high head safety injection (HHSI) pumps. Therefore, LTOP requirements are used to INDIAN POINT 3 B 3.4.12 - 1 Revision 6
protect the RHR System whenever the RHR System is not isolated from the RCS.
This LCO provides RCS overpressure protection by limiting maximum coolant input capability and having adequate pressure relief capacity. Limiting coolant input capability is achieved by not permitting any High Head Safety Injection (HHSI) pumps to be capable of injection into the RCS and isolating the accumulators.
The pressure relief capacity requires either two redundant power operated relief valves (PORVs) or a depressurized RCS and an RCS vent of sufficient size.
One PORV or the open RCS vent is sufficient to provide overpressure protection to terminate an increasing pressure event. Alternately, if redundant PORVs are not Operable or an RCS vent cannot be established, LTOP protection may be established by limiting the pressurizer level to within limits specified in Figure 3.4.12-2 and Figure 3.4.12-3 consistent with the number of charging pumps and number of high head safety injection (HHSI) pumps capable of injecting into the RCS. This approach is acceptable because pressurizer level can be maintained such that it will either accommodate any anticipated pressure surge or allow operators time to react to any unanticipated pressure surge. When pressurizer level is used to satisfy LTOP requirements, operator action is assumed to terminate the unplanned HHSI pump injection within 10 minutes.
With high pressure coolant input capability limited, the ability to create an overpressure condition by coolant addition is restricted. The LCO does not require the makeup control system deactivated or the safety injection (SI) actuation circuits blocked. Due to the lower pressures in the LTOP MODES and the expected core decay heat levels, the makeup system can provide adequate flow via the makeup control valve. There is no
... restriction on the status of charging pumps when LTOP is established using either a PORV or an RCS vent. If conditions require the use of more than one HHSI pump for makeup in the event of loss of inventory, then pumps can be-made available through manual actions. Charging
.. pumps and low pressure injection systems are available to provide makeup even when LTOP requirements are applicable.
When configured to provide low temperature overpressure protection, the PORVs are part of the Overpressure Protection System (OPS).
INDIAN POINT 3 B 3.4.12 - 2 Revision 6
LTOP for pressure relief can consist of either the OPS (two PORVs with reduced lift settings), or a depressurized RCS and an RCS vent of sufficient size.
Two PORVs are required for redundancy. One PORV has adequate relieving capability to keep from overpressurization for the required coolant input capability.
PORV Requirements The Overpressure Protection System (OPS) provides the low temperature overpressure protection by controlling the Power Operated Relief Valves (PORVs) and their associated block valves with pressure setpoints that vary with RCS cold leg temperature. Specifically, cold leg temperature signals from three RCS loops are supplied to three associated function generators that calculate the maximum RCS pressures allowed at those temperatures. The maximum RCS pressure limits at any RCS temperature correspond to the 10 CFR 50, Appendix G, limit curve maintained in the Pr. . .. r. and Temperatuir..
Limits Report and are used as the OPS pressure setpoint.
Having the setpoints of both valves within the limits in Figure 3.4.12-1 ensures that the Reference 1 limits will not be exceeded in any analyzed event.
In addition to generating the OPS pressure setpoint, the same cold leg temperature signals are used to "arm" the OPS when RCS temperature falls below the temperature at which low temperature overpressure protection is required (330'F). This temperature. includes an allowance 0
of 14.4 F for instrument uncertainty and margin. Each PORV opens when a two-out-of-two (temperature and pressure) coincidence logic is satisfied. OPS is "armed" when RCS temperature falls below the temperature that satisfies one half of the two-out-of-two (temperature-pressure) coincidence logic. When OPS is enabled, the PORVs will open if RCS pressure exceeds the calculated pressure setpoint that varies with RCS
-temperature.
The PORV block valves open when the RCS temperature falls below the OPS arming'temperature. Note that the control switches for the PORV and PORV block valves must be in the AUTO position and the OPS states links closed for OPS signals to actuate the PORVs.
Three channels of RCS cold leg temperature are used in the two-out-of-three coincidence logic to satisfy the temperature portion of the two-out-of-two (temperature and pressure) coincidence logic for each PORV. Three INDIAN POINT 3 B 3.4.12 - 3 Revision 6
channels of RCS pressure are used in a two-out-of-three coincidence logic to satisfy the pressure portion of the two-out-of-two (temperature-pressure) coincidence logic for each PORV. Use of a two-out-of-three coincidence logic for pressure and for temperature ensures that a single failure will not cause or prevent an OPS actuation. Use of two PORVs, each with adequate relieving capability to prevent overpressurization, ensures that a single failure will not prevent an OPS actuation.
When a PORV is opened in an increasing pressure transient, the release of coolant will cause the pressure increase to slow and reverse. As the PORV releases coolant, the RCS pressure decreases until a reset pressure is reached and the valve is signaled to close. The pressure continues to decrease below the reset pressure as the valve closes.
RCS Vent Recruirements Once the RCS is depressurized, a vent exposed to the containment atmosphere will maintain the RCS at containment ambient pressure in an RCS overpressure transient, if the relieving requirements of the transient do not exceed the capabilities of the vent.
Thus, the vent path must be capable of relieving the flow resulting from the limiting LTOP mass or heat input transient, and maintaining pressure below the P/T limits. The required vent capacity may be provided by one or more vent paths.
Multiple methods exist for establishing the required RCS vent capacity including removing or blocking open a PORV and disabling its block valve in the open position. An RCS vent of > 2.00 square inches or by a blocked open PORV when no HHSI pump is capable of injecting into the RCS; or, an RCS vent with opening greater than or equal to one pressurizer code safety valve flange and up to two HHSI pumps capable of injecting into the RCS will satisfy LTOP requirements because either configuration ensures pressure limits are not exceed during a transient. Two (2) PORVs open on nitrogen with the associated block valves open and disabled is equivalent to a blocked open PORV with its block valve open and disabled. Alt..nat.ly, .. an.. .
vent f 5 2.00 sare inches coupled with a proessurizor lo-vel < A% and uip to twe HHSI ptumps capable of injecting intze the 11CC will:
satisfy LTOPP roqutiromoffnts. because it ensures a mitnimumfff
.of 10 mineuts fo operator a.tion befor. pr.ssure limits are e.... d during
.. a transient. The vent path(s) must INDIAN POINT 3 B 3.4.12 - 4 Revision 6
be above the level of reactor coolant, so as not to drain the RCS when open.
APPLICABLE SAFETY ANALYSES Safety analyses (Ref. 3) demonstrate that the reactor vessel is adequately protected against exceeding the Reference 1 P/T limits. In MODES 1, 2, and 3, with RCS cold leg temperature exceeding 3-84We-330F, the pressurizer safety valves will prevent RCS pressure from exceeding the Reference 1 limits. At 330 'F and below, overpressure prevention falls to two OPERABLE PORVs in conjunction with the Overpressure Protection System (OPS) or to a depressurized RCS and a sufficient sized RCS vent. Each of these means has a limited overpressure relief capability. Alternately, if redundant PORVs are not Operable, Low Temperature Overpressure protection may be maintained by limiting the pressurizer level to within limits specified in Figure 3.4.12-2 and Figure 3.4.12-3 consistent with the number of charging pumps and number cf no high head safety injection (HHSI) pumps capable of injecting into the RCS. This approach is acceptable because pressurizer level can be established to either accommodate any anticipated pressure surge or allow operators time to react to any unanticipated pressure surge.
When the RCS temperature is greater than the LTOP arming temperature (i.c., 3W-
- 3 but below the minimum temperature at which the pressurizer safety valves lift prior to violation of the 10 CFR 50, Appendix G, limits (i.e., _ 380'r-) , administrative controls in the Technical Requirements Manual (TRM) (Ref. 34) are used to limit the potential for exceeding 10 CFR 50, Appendix G, limits. These administrative controls may include operating with a bubble in the pressurizer and/or otherwise limiting plant time or activities when the RCS temperature is in the specified range. The use of administrative controls to govern operation above the LTOP arming temperature but below the minimum temperature at which the pressurizer safety valves lift prior to violation of the 10 CFR 50, Appendix G, limits is consistent with the guidance provided in Generic Letter 88-011, NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its Impact on Plant Operations (Ref.2). GL 88-011 states that automatic, or passive, protection of the P-T limits will not be required but administratively controlled when in the INDIAN POINT 3 B 3.4.12 - 5 Revision 6
upper end of the 10 CFR 50, Appendix G, temperature range.
The actual temperature at which the pressure in the P/T limit curve falls below the pressurizer safety valve setpoint increases as the reactor vessel material toughness decreases due to neutron embrittlement. Each time the Figure 3.4.12-1 curves are revised, LTOP must be re-evaluated to ensure its functional requirements can still be met using the OPS (PORVs) method or the depressurized and vented RCS condition.
Figure 3.4.12-1 contains the acceptance limits that define the LTOP requirements. Any change to the RCS must be evaluated against theo Ref. 3 analyses to determine the impact of the change on the LTOP acceptance limits.
Transients that are capable of overpressurizing the RCS are categorized as either mass or heat input transients, examples of which follow:
Mass Input Type Transients
- a. Inadvertent safety injection; or
- b. Charging/letdown flow mismatch.
Heat Input Type Transients
- a. Inadvertent actuation of pressurizer heaters;
- b. Loss of RHR cooling; or
- c. Reactor coolant pump (RCP) startup with Steam Generator secondary side temperature up to 500'F higher than the RCS primary side temperature.
aszqmmoltzry within the 11CC er between the 11CC and -
Dtoam, gonorators.
The following are required during the LTOP MODES to ensure that mass and heat input transients do not occur.
This is accomplished by the following:
- a. Rendering all HHSI pumps incapable of injection;
- b. Deactivating the accumulator discharge isolation valves in their closed positions or maintaining accumulator pressure less than the maximum RCS pressure for the coldest existing RCS cold leg INDIAN POINT 3 B 3.4.12 - 6 Revision 6
temperature allowed by the P/T limit curves provided in Figure 3.4.12-1; and
- c. Disallowing start of an RCP unless conditions are established that ensure a RCP pump start will not cause a pressure excursion that will exceed LTOP limits. Required conditions for starting a RCP when LTOP is required include a combination of primary and secondary water temperature differences and Overpressure Protection System (OPS) status or pressurizer level. Meeting the LTOP RCP starting surveillances ensures that theses conditions are satisfied prior to a RCP pump start.
The Ref. 3 analyses demonstrate that either one PORV or the depressurized RCS and RCS vent can maintain RCS pressure below limits when no HHSI pump is capable of injecting into the RCS. This assumes an RCS vent of >
2.00 square inches or by a blocked open PORV. Two (2)
PORVs open on nitrogen with the associated block valves open and disabled is equivalent to a blocked open PORV with its block valve open and disabled. The same protection can be provided when up to two HHSI pumps are capable of injecting into the RCS assuming an RCS vent with opening greater than or equal to one code pressurizer safety valve flange. Alternately, LTOP requirements can be satisfied by various combinations of pressurizer level, RCS pressure, and RCS injection capability (i.e., maximum number of HHS! pu,,ps and..r.
charging pumps and no BHSI pumps) shown in Figure 3.4.12-2 and 3.4.12-3. These combinations of pressurizer level, RCS pressure, and RCS injection capability satisfy LTOP requirements by ensuring a minimum of 10 minutes for operator action to terminate an unplanned event prior to exceeding maximum allowable RCS pressure. None of the analyses addressed the pressure transient need from accumulator injection, therefore, when RCS temperature is low, the LCO also requires the accumulator isolation when accumulator pressure is greater than or equal to the maximum RCS pressure for the coldest existing RCS cold leg temperature allowed in Figure 3.4.12-1.
If the accumulators are isolated and not depressurized, then the accumulators must have their discharge valves closed and the valve power supply breakers fixed in their open positions.
Frcaeture meehanic analyses establishcd the t.mpratur. .
ef LTO9P Appilcability at 30 INDIAN POINT 3 B 3.4.12 - 7 Revision 6
The consequences of a loss of coolant accident (LOCA) in LTOP MODE 4 conform to 10 CFR 50.46 and 10 CFR 50, Appendix K (Refs. -4 and &5) requirements by having ECCS OPERABLE in accordance with requirements in LCO 3.5.3, ECCS-Shutdown.
PORV Performance The fracture mechanics oAnalyses show that the vessel is protected when the PORVs are set to open at or below the limit shown in Figure 3.4.12-1. The setpoints are derived by analyses that model the performance of the LTOP System, assuming the limiting LTOP transient with HHSI not injecting into the RCS. These analyses consider pressure overshoot and undershoot beyond the PORV opening and closing, resulting from signal processing and valve stroke times. The PORV setpoints at or below the derived limit ensures the Reference 1 P/T limits will be met. The OPS setpoint is based on an comparative analysis of Reforonec 3, with allowances for metal/fluid temperature differences, static head due to elevation differences, and dynamic head from the operation of the reactor coolant pumps and RHR pumps.
The P9R-V setpeints in Figure 3.4.12 1 will be udpdated-when the revised P/T limits conflict with the LTOP analy*i* limits. The P/T limits are periodically modified as the reactor vessel material toughness decreases due to neutron embrittlement caused by neutron irradiation. Revised limits are determined using neutron fluence projections and the results of examinations testing of the reactor vessel material irradiation surveillance specimens. The Bases for LCO 3.4.3, ",,C Pr...u... and T....p.ratur (P,'T) Limits,"
diouczss these exiaminations.
The PORVs are considered active components. Thus, the failure of one PORV is assumed to represent the worst:z-'
case, single active failure.
RCS Vent Performance With the RCS depressurized, analyses show a.vont size of 1.4 soqaro inchcs that one blocked open PORV (note that a 2 square inches vent path is more conservative than one blocked open PORV) is capable of mitigating the allowed LTOP overpressure transient assuming no HHSI pump and no accumulator injects into the RCS. Two (2)
PORVs open on nitrogen with the associated block valves open and disabled is equivalent to a blocked open PORV with its block valve open and disabled. The LCO limit INDIAN POINT 3 B 3.4.12 - 8 Revision 6
for an RS vent is conscrvativcly established at 2..0 square inches. The capacity of a vent this size is greater than the flow of the limiting transient for the LTOP configuration, maintaining RCS pressure less than the maximum pressure on the P/T limit curve. An RCS vent with opening greater than or equal to one pressurizer code safety valve flange and up to two HHSI pumps capable of injecting into the RCS will satisfy LTOP requirements because it ensures pressure limits are not exceeded during a transient. An S vent
... f ;f2.00 squ~aro~ Inches coudpled with a pr-essuizor~e level < 096 and up to two HHS! pumps capable of in~jecting intoq~ thcRC will Satisfy TO.. r..qui.rom..nts
.P bcaus. it .nsur.s a minimum of 10 Efinutes for oporator aetion boforoe pressure limits are i..c..d.d during a t.ransient.
The RGS vent size will be ro evaluated for com~plianco cah ti-m* the P,'T limit .urv.s arc. rvis"d based on th-results of the vessel m-at:ial surci"llianc.
The RCS vent is passive and is not subject to active failure.
LTOP satisfies Criterion 2 of 10 CFR 50.36.
LCO This LCO requires that LTOP is OPERABLE. LTOP is OPERABLE when the minimum coolant input and pressure relief capabilities are OPERABLE. Violation of this LCO could lead to the loss of low temperature overpressure mitigation and violation of the Reference 1. limits as a result of an operational'transient.
To limit the coolant input capability, the LCO requires that no HHSI pumps be capable of. injecting into the RCS and all accumulator discharge isolation valves be closed and de-energized if accumulator pressure is greater than or equal to the maximum RCS pressure for-the existing RCS cold leg temperature allowed in Figure 3.4.12-1-r Maimumah- Allowablo Nomainal POR-V Getpeint forc LTOTP ()PS).
The elements of the LCO that provide low temperature overpressure mitigation through pressure relief are:
A PORV is OPERABLE for LTOP when its block valve is open, its lift. setpoint is set to the limit required by INDIAN POINT 3 B 3.4.12 - 9 Revision 6
Figure 3.4.12-1 and testing proves its ability to open at this setpoint, and motive power is available to the two valves and their control circuits.
The OPS is OPERABLE for LTOP when there are three OPERABLE RCS pressure channels and three OPERABLE RCS temperature channels. The OPS is still OPERABLE when an inoperable RCS pressure or temperature channel is in the tripped condition. OPS is considered OPERABLE for meeting LCO 3.4.12 requirements even if one or two RCS cold leg temperatures is above the LTOP Applicability limit.
An RCS vent is OPERABLE when open with an area of > 2.00 square inches or by a blocked open PORV. Two (2) PORVs open on nitrogen with the associated block valves open and disabled is equivalent to a blocked open PORV with its block valve open and disabled.
Each of these methods of overpressure prevention is capable of mitigating the limiting LTOP transient.
APPLICABILITY This LCO is applicable whenever the RHR System is not isolated from the RCS to protect the RHR system piping.
When all RCS cold leg temperatures are < 330 OF, RHR system piping is adequately protected by making the accumulators and all HHSI pumps incapable of injecting into the RCS. Therefore, a Note in the LCO specifies that requirements for the OPS System and/or an RCS vent are not Applicable when all RCS. cold leg temperatures are > 330 OF.
This LCO is applicable to provide protection for the RCS pressure boundary in MODE 4 when any RCS cold leg temperature is < 330 °F, in MODE 5, and in MODE 6 when the reactor vessel head is on. The pressurizer safety
-valves provide overpressure protection that-meets-ithe. -
Reference 1 P/T limits above 330 °F. When the reactor vessel head is off, overpressurization cannot occur.
Although LTOP is not Aapplicable when the RCS temperature is greater than the LTOP arming temperature (i.e., > 330 OF) but below t.h. mftinimum t.. .p.ratur.. at-which tho pressurizzr safety valves lift prier t. -
violation of the 10 CFR 50, Appendim G, limits (io.e,,
3849:-F, administrative controls in the Technical Requirements Manual (TRM) (Ref. 43) are used to limit the potential for exceeding 10 CFR 50, Appendix G, -
limits. LCO 3.4.3 provides the operational P/T limits for all MODES. LCO 3.4.10, "Pressurizer Safety Valves,'i:
requires the OPERABILITY of the pressurizer safety INDIAN POINT 3 B 3.4.12 - 10 Revision 6
valves that provide overpressure protection during MODES 1, 2, and 3, and MODE 4 above 330 'F when the RHR system is isolated from the RCS.
Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.
The Applicability is modified by three Notes--. Note 1 states that accumulator isolation is only required when the accumulator pressure is more than the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This Note permits the accumulator discharge isolation valve Surveillance to be performed only under these pressure and temperature conditions.
Note 2 ensures that LCO 3.4.12 will not prohibit a HHSI pump being energized and aligned to the RCS as needed to support emergency boration or to respond to a loss of RHR cooling.
Note 3 specifies that one HHSI pump may be made capable of injecting into the RCS for a period not to exceed 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to perform pump testing. During testing, administrative controls are used to ensure that HHSI testing will not result in exceeding RCS or RHR system pressure limits.
ACTIONS A Note prohibits the application of LCO 3.0.4.b to an inoperable LTOP system. There is an increased risk associated with entering MODE 4 from MODE 5 with LTOP inoperable and the provisions of LCO 3.0.4.b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing-inoperable'-systems and components, should not be applied in this circumstance.
A.1, A.2.1-r and A.2.2, A.2.3, A.3.1 and A.3.2 When one or more HHSI pumps are capable of injecting into the RCS, LTOP assumptions regarding l~imits- on-mass input capability may not be met. Therefore, immediate action is required to limit injection capability consistent with the LTOP analysis assumptions and the existing combination of pressurizer level and RCS venting capacity. Required Action A.1 requires restoration with LCO requirements. Required Action.& A.2 and A.3 requires verification and periodic re-INDIAN POINT 3 B 3.4.12 - 11 Revision 6
verification that alternate LTOP configurations are met.
The Completion Times of immediately reflects the urgency that one of the acceptable LTOP configurations is established as soon as possible.
B.l, C.1 and C.2 To be considered isolated, an accumulator must have its discharge valves closed and the valve power supply breakers fixed in the open position.
An unisolated accumulator requires isolation within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. This is only required when the accumulator pressure is at or more than the maximum RCS pressure for the existing temperature allowed by the P/T limit curves.
If isolation is needed and cannot be accomplished in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, Required Action C.A and Required Action C.2 provide two options, either of which must be performed in the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. By increasing the RCS temperature to > 330 OF, an accumulator pressure of 700 psig cannot exceed the LTOP limits if the accumulators are injected.
Isolating the RHR system from the RCS ensures that the RHR system is not subjected to accumulator pressure.
Depressurizing the accumulators below the LTOP limit from Figure 3.4.12-1 also gives this protection.
Additionally, the RHR System must be isolated from the RCS to protect RHR piping from a potential mass addition event.
The Completion Times are based on operating experience that these activities can be accomplished in these time periods and on engineering evaluations indicating that an event requiring LTOP is not likely in the allowed times.
D.1. -
When any RCS cold leg temperature is < 330 °F, with one required PORV inoperable, the PORV must be restored to OPERABLE status within a Completion Time of 7 days. Two PORVs are required to provide low temperature overpressure mitigation while withstanding a single.
failure of an active component.
The Completion Time considers the facts that only one of the PORVs is required to mitigate an overpressure transient and that the likelihood of an active failure of the remaining valve path during this time period is very low.
INDIAN POINT 3 B 3.4.12 - 12 Revision 6
E.I When both required PORVs are inoperable or the Required Action and associated Completion Time of Condition C or D is not met, an alternate method of low temperature overpressure protection must be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The acceptable alternate methods of LTOP include the following:
- b. Increase all RCS cold leg temperatures to > 330'F and isolate the RHR system from the RCS; or If the option selected is to depressurize the RCS and establish an RCS vent path, the vent must be sized >
2.00 square inches or by a blocked open PORV to ensure that the flow capacity is greater than that required for the worst case mass input transient reasonable during the applicable MODES. Two (2) PORVs open on nitrogen with the associated block valves open and disabled is equivalent to a blocked open PORV with its block valve open and disabled. This action is needed to protect the RCPB from a low temperature overpressure event and a possible b-ri-tt enon-ductile failure of the reactor vessel.
The Completion Time considers the time required to place the plant in this Condition and the relatively low probability of an overpressure event during this time period due to increased operator awareness of administrative control requirements.
F.1 If LTOP requirements-areý.not. met for reasons other, than Conditions A, *B, C, D or E, LTOP requirements must be re-established by depressurizing the RCS-and establishing an RCS vent of > 2.00 square inches or by a blocked open PORV within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Two (2) PORVs open on nitrogen with the associated block valves open and disabled is equivalent to a blocked open PORV with its block valve open and disabled. -
SURVEILLANCE REQUIREMENTS SR 3.4.12.1 and SR 3.4.12.2 -
INDIAN POINT 3 B 3.4.12 - 13 Revision 6
To minimize the potential for a low temperature overpressure event by limiting the mass input capability, all HHSI pumps are verified incapable of injecting into the RCS. Additionally, the accumulator discharge isolation valves are verified closed and locked out or the accumulator pressure less than the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in Figure 3.4.12-1.
The HHSI pumps are rendered incapable of injecting into the RCS either through removing the power from the pumps by racking the breakers out or by providing isolation of the injection path with the valve de-energized or locked closed under administrative control. Other methods may be employed using at least two independent means to prevent a pump injection such that a single failure or single action will not result in an injection into the RCS. This may be accomplished through the pump control switch being placed in Trip Pullout and at least one valve in the discharge flow path being closed or by one valve in the discharge flow path being locked or de-energized closed.
The Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment.
SR 3.4.12.3 The RCS vent of > 2.00 square inches or by a blocked open PORV is proven OPERABLE by verifying its open condition either:
- a. Once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for a valve that is not locked.
- b- *-Once every 31** days.fot a valve that- i's-locked, sealed, or secured in position. A removed pressurizer safety valve,. PORV, or Manway Cover fits this category.
The passive vent arrangement must only be open to be OPERABLE. This Surveillance is required to be performed if the vent is being used to sat-isfy the pressure relief requirements of the LCO 3.4.12'b.
SR 3.4.12.4 Performance of the CHANNEL-CHECK of the Overpressure Protection System (OPS) RCS pressure and temperature INDIAN POINT 3 B 3.4.12 14 Revision 6
channels every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ensures that gross failure of instrumentation has not occurred. A CHANNEL CHECK is normally a comparison of the parameter indicated on one channel to a similar parameter on other channels. It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value. Significant deviations between the two instrument channels could be an indication of excessive instrument drift in one of the channels or of something even more serious. A CHANNEL CHECK will detect gross channel failure; thus, it is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION.
Agreement criteria are determined by the unit staff based on a combination of the channel instrument uncertainties, including indication and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.
The Frequency is based on operating experience that demonstrates channel failure is rare. The CHANNEL CHECK supplements less formal, but more frequent, checks of channels during normal operational use of the displays associated with the LCO required channels. This SR is required only when LCO 3.4.12.a is used to establish LTOP protection.
SR 3.4.12.5 The PORV block valve opens automatically when RCS cold leg temperature is below the OPS arming temperature; however, the valves must be verified open every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to provide the flow path for each required PORV to perform its function when actuated. The valve may be remotely verified open in. the control room. This Surveillance is. performed-only if->the PORV is being used to satisfy LCO 3.4.12.a.
The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required removed, and the manual operator is not-required locked in the inactive position. Thus, the blocklvalve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation. If closed, the block valve must be de-energized to prevent the valve from re-opening automatically. -
INDIAN POINT 3 B 3.4.12 - 15 Revision 6
The 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Frequency is considered adequate because the PORV block valves are opened automatically by the OPS when below the OPS arming temperature if the valve control is positioned to auto and other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.
SR 3.4.12.6 Performance of a COT is required within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing all RCS temperatures to < 330 OF and every 31 days on each required PORV to verify and, as necessary, adjust its lift setpoint. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable COT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with appplicable extensions. The COT will verify the setpoint is within the allowed maximum limits in Figure 3.4.12-1. PORV actuation could depressurize the RCS and is not required.
The 24 month Frequency considers the demonstrated reliability of the Overpressure Protection System and the PORVs.
A Note has been added indicating that this SR is required to be met within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after decreasing RCS cold leg temperature to < 330'F. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> allowance considers the unlikelihood of a low temperature overpressure event during this time.
SR 3.4.12.7 Performance of a CHANNEL CALIBRATION on each required PORV actuation channel is required every 18 months.
Performance of a CHANNEL CALIBRATION of RCS pressure and temperature instruments that support the Overpressure Protection System is required every 24 months. These calibrations verify both the OPS and PORV function and ensure the;OPERABILITY of the whole channel so that it responds and the valve opens within the required range and accuracy to known input.
SR 3.4.12.8 and SR 3.4.12.9 INDIAN POINT 3 B 3.4.12 - 16 Revision 6
The RCP starting prerequisites must be satisfied prior to starting or jogging any reactor coolant pump (RCP) when low temperature overpressure protection is required--. The RCP starting prerequisites prevent an overpressure event due to thermal transients when an RCP is started. Plant conditions prior to the RCP start determines whether SR 3.4.12.8 or SR 3.4.12.9 must be satisfied prior to starting any RCP.
The principal contributor to an RCP start induced thermal and pressure transient is the difference between RCS cold leg temperatures and secondary side water temperature of any SG prior to the start of an RCP. The RCP starting prerequisites vary depending on plant conditions but include the following: reactor coolant temperature relative to the LTOP enable temperature; secondary side water temperature of the hottest SG relative to the temperature of the coldest RCS cold leg temperature; and, status of the Overpressure Protection System (OPS). When the OPS is inoperable, additional compensatory requirements are required including limits for the pressurizer level and RCS pressure and temperature. When a pressurizer level is specified as a requirement, the level specified is sufficient to prevent the RCS from going water solid for 10 minutes which is sufficient time for operator action to terminate the pressure transient.
SR 3.4.12.8 is used if secondary side water temperature of the hottest steam generator (SG) is less than or equal to the coldest RCS cold leg temperature. SR 3.4.12.9 is more restrictive and is used if the secondary side water temperature of the hottest steam generator is < 50°64OF above the coldest RCS cold leg temperature.
RCP starting is prohibited if the hottest steam
.generator is. >. 50°64 F above RCS cold leg temperature or if neither of the RCP starting prerequisites SRs can be satisfied. ..The steam generator temperature may be measured .-using the Control Room instrumentation or, as a backup,, from.a contact reading off the steam generator's shells. Pressurizer level may be determined using control rbom.instrumentation or alternate methods.
The FREQUENCY of the RCP starting prerequisites SRs is Within 15 minutes prior to starting any RCP. This means that each of the required verifications must be performed within 15 minutes prior to the pump start and must be met at the time of the pump start.
INDIAN POINT 3 B 3.4.12 - 17 Revision 6
SR 3.4.12.8 and SR 3.4.12.9 are each modified by two Notes. Note 1 specifies that these SRs are required as a condition for pump starting only when the RCS is below the LTOP arming temperature. Note 2 specifies that meeting either SR 3.4.12.8 or SR 3.4.12.9 ensures that pump starting prerequisites are met.
REFERENCES 1. 10 CFR 50, Appendix G.
- 2. Generic Letter 88-011, NRC Position on Radiation Embrittlement of Reactor Vessel Materials and its Impact on Plant Operations.
- 3. !P3 TLw Tcmperaturc Ovcrprssiurizatien y*t.*m Analysis Final Rpoert, Aug..t 24, 1984, in eenJ:unet-4en wi ! 1 IL.':-.
A! i ý Ai ,*- ý , :" , AT r- 1" A T I -L Tempeiraturce Overpressure Pretectien, Februdary 12,
- 34. IP3 Technical Requirements Manual.
4-. 10 CFR 50, Section 50.46.
- 5. 10 CFR 50, Appendix K.