ML17223A425

Proposed Tech Specs Re Revised Pressure/Temp Limits & Results of Revised Low Temp Overpressure Protection Analysis

ML17223A425
Person / Time
Site:	Saint Lucie
Issue date:	12/05/1989
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17223A424	List: L-89-408, Application for Amend to License DPR-67,incorporating Revised Pressure/Temp Limits & Results of Revised Low Temp Overpressure Protection Analysis Into Tech Specs ML17223A425
References
NUDOCS 8912140196
Download: ML17223A425 (39)

Text

DEFINITIONS IDENTIFIED LEAKAGE 1.15 IDENTIFIED LEAKAGE shall be:

a.

Leakage (except CONTROLLED LEAKAGE) into closed systems, such as pump seal or valve packing leaks that are captured, and conducted to a sump or collecting tank, or b.

Leakage into the containment atmosphere from sources that are both specifically located and known either not to interfere with the operation of leakage detection systems:.or not to be PRESSURE BOUNDARY LEAKAGE, or c.

Reactor Coolant System leakage through a steam generator to the secondary system.

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LOW TEMPERATURE RCS OVERPRESSURE PROTECTION RANGE 1.16 The LOW TEMPERATURE RCS OVERPRESSURE PROTE ION RANGE is that operating condition when (1) the cold leg temperature is ( 484-F-and (2) the Reactor Coolant System has pressure boundary integrity.

The Reactor Coolant System does not have pressure boundary integrity when the Reactor Coolant System is open to containment and.the minimum area of the Reactor Coolant System opening is greater than 1.75 square inches.

MEMBER S OF THE PUBLIC 1.17 MEMBER(S) OF THE PUBLIC shall include all persons who are not occupation-ally associated with the plant.

This category does not include employees of the licensee, its contractors, or vendors.

Also excluded from this category are persons who enter the site to service equipment or to make deliveries.

This category does include persons who use portions of the site for recrea-tional,,occupational or other purposes not associated with the plant.

OFFSITE DOSE CALCULATION MANUAL ODCM 1.18 The OFFSITE DOSE CALCULATION MANUAL shall contain the current methodology and parameters used in the calculations of offsite doses due to radioactive gaseous and liquid effluents, in the calculation of gaseous and li'quid effluent monitoring alarm/trip setpoints, and shall include the Radiological Environ-mental Sample point locations.

ST.

LUCIE - UNIT 1 1-4 Amendment No.$9,N,PP, 81 89'12i40i96 8~i205 PDR ADOCK 05000335

REACTIVITY CONTROL SYSTEMS 3/4.1.2 BORATION SYSTEMS FLOW PATHS -

SHUTOOWN LIMITING CONOITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE:

'a

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A flow path from the boric acid makeup tank via either a

boric acid pump or a gravity feed connection and any charging pump to the Reactor Coolant System if only the boric acid makeup tank in Specification 3.1.2.7a is OPERABLE, or b.

The flow path from the refuel fng water tank via either a

charging pump or a high pressure safety injection pump*

to the Reactor Coolant System if only the refueling water tank in Specification 3.1.2.7b is OPERABLE.

APPLICABILITY:

MOOES 5 and 6.

ACTION:

With none of the above flow paths OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes until at least one injection path is restored to OPERABLE status.

SURVEILLANCE RE UIREMENTS 4.1.2.1 At least one of the above required flow paths shall be demonstrated OPERABLE:

a.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) fn the flow path that is not locked, sealed, or oth'hrwise secured fn position, is in its correct position.

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(a} the PCS pressure boundary does not exist, or (b} no charging pumps are operable.

In this case all charging pumps shall be disabled, and heatup and cooldown rates shall be limited in accordance with Fig. 3.l-lb.

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ST.

LUCIE - UNIT 1

3/4 1-8 Amendment No. g g, pg

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INSERT Ol At RCS temperatures below 115'F, any two ofthe followingvalves in the operable HPSI header shall be verified closed and have their power removed:

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Amendment No.

81 ST.

LUCIE - UNIT 1

3/4 1-90 FIGURE 3.1-1b MAXIMUMALLOWABLEHEATUP AND COOLDOWN RATES, SINGLE HPSI PUMP IN OPERATION

100 x

80 us 60 I

R 40 Heatup 20 080 100 120 140 160 180 Cooldown 200 220 Tc - INDICATED REACTOR COOLANT TEMPERATURE,4F FIGURE 3.1-1b MAXIMUMALLOWABLEHEATUP AND COOLDOWN RATES, SINGLE HPSI PUMP IN OPERATION 3l4 1-98

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REACTIVITY CONTROL SYSTEMS CHARGING PUMP -

SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.3 At least one charging pump or one high pressure safety injection pump* in the boron injection flow path required OPERABLE pursuant to Specifi-cation 3.1.2.1 shall be OPERABLE and capable of being powered from an OPERABLE emergency bus.

APPLICABILITY:

MODES 5 and 6.

ACTION:

With no charging pump or high pressure safety injection pump OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes until at least one of the required pumps is restored to OPERABLE status.

SURVEILLANCE RE UIREMENTS 4.1.2.3 At least one of the above required pumps shall be demonstrated OPERABLE by verifying the charging pump develops a flow rate of greater than or equal to 40 gpm or the high pressure safety injection pump develops a total head of greater than or equal to 2571 ft. when tested pursuant to Specification 4.0.5.

Amendment No.l O.N, 9O 3/4 1-12

• The flow path from the RWT to the RCS via a single HPSI pump shall be established only if:

(a) the RCS pressure boundary does not exist, or (b) no charging pumps are operable.

In this case, all charging pumps shall be disabled and heatup and cooldown rates shall be limited in accordance with Fig. 3.1-lb.

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ST.

LUCIE - UNIT 1

INSERT 42 At RCS temperatures below 115'F, any two ofthe followingvalves in the operable HPSI header shall be verified closed and hav'e their power removed:

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REACTOR COOLANT SYSTEM 3 4.4.9 PRESSURE TEMPERATURE LIMITS REACTOR COOLANT SYSTEM LIMITING CONDITION FOR OPERATI'ON.

3.4.9.1 The Reactor Coolant System (except the pressurizer} temperature and pressure shall be limited in accordance with the limit lines shown on Figures 3.4-2a, 3.4-2b and 3.4-3 during heatup, cooldown, criticality,.and inservice leak and hydrostatic testing.

APPLICABILITY: At all times.*f ACTION:

Nth any of the above limits 'exceeded, restore the temperature and/or pressure to within the limits within 30 minutes; perform an analysis to determine the effects of the out-of-limit condition on the fracture toughness properties of the Reactor Coolant System; determine that the Reactor Coolant System remains acceptable for continued operations or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce. the RCS T 2 222't~ ~ ittt tllilt following 30 hour3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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• When the flow path from the RMT to the RCS via a single HPSI pump is established per 3.1.2.3, the heatup and cooldown rates shall be established

'in accordance with Fig. 3.3-1b.

8During hydrostatic testing operations above system design pressure, a

maximum temperature change in any one hour period shall Be limited to 5'F.

ST.

LUCIE - UNIT 1 3/4 4-21 Amendment No. g, 81

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)ISSUE.TE'EPLACE g)mf At&%+l2E,g+ZA-FIGURE3.4-2a ST. LUCIE UNIT 1 P/T LIMITS,10 EFPY HEATUP AND CORE CRITICAL 250

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LUCIE - UNIT 1 3/4 4-23a Amendment No. J7>RS> 81

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FIGURE 3 4-2a ST. LUCIE UNIT 1 P/T LIMITS, 15 EFPY HEATUP AND CORE CRITICAL 2500 ISOTHERMAL TO Sly/HR 2000 cA 0

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FIGURE 3.4.3 ST. LUCIE UNIT 1, 16 EFPY MAXIMUMALLOWABLECOOLDOWN RATES 80 X

60 Cz RATE oF/HR 20 30 40 50 76 100 TEMP I.IMIT oF 4125 125.146 146-166 166-185 186.196

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REACTOR COOLANT SY

.POWER OPERATED RELIEF VALVES LIMITING CONDITION FOR OPERATION';

3.4.13 Two power operated relief'valves (PORVs) shall be OPERABLE,.with their setpoints selected to the low temperature mode of operation as follows:

a.

A setpoint of less than or equal to 350 psia shall be selected:

l.

During cooldown when the temperature of any RCS cold leg is less than or equal to OSPP.and 2.

During heatup and isothermal conditions when the temperature of any RCS cold leg is less than or equal to@80-F'.

Ieaef b.

A setpoint of less than or equal to 530 psia shall be selected:

During cooldown when the temperature of any RCS cold leg is greater thanPggpR and less than or equal'.todggq-P; 2/58/

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2.

During heatup and isothermal conditions when the temperature of any RCS cold leg is greater than or equal to~ and less than or equal to~8$IP.

yea'r APPL'ICABILITY:

NODES ~ 4and 5*.

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ACTION:

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Mith 'less than two PORVs OPERABLE and while at Not~endby during a planned cooldown, both PORVs will be returned to OPERABLE status prior to entering the applicable NODE unless:

1.

The repairs cannot be accomplished within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the repairs cannot be performed under hot conditions, or 2.

Another action statement-requires co@%down, or 3.

Plant and personnel safety requires cooldown to Cold Shutdown with extreme caution.

b.

With less than two PORVs OPERABL'E while in COLD SHUTDOWN, both PORVs will be returned to OPERABLE status prior to startup.

c.

The provisions of Specification 3.0.4 are not applicable.

SURVEILLANCE RE UIREMENTS 4.4.13 The PORVs shall be verified OPERABLE by:

a.

Verifying the isolation valves are open when the PORVs are reset to the low temper atur e mode of operation.

b.

Performance of a CHANNEL FUNCTIONAL TEST of the Reactor Coolant System overpressurization protection system circuitry up to and including the relief valve solenoids once per refueling outage.

c.

Performance of a CHANNEL CALIBRATIONof the pressurizer pressure sensing cliannels once per 18 months.

Reactor Coo ant System co d leg temperature below 884-P;

• PORVs are not required below 140'F when RCS does not have pressure boundary integrity, ST. LUCIE - UNIT 1 3/4 4-59 Amendment SS. 8>

REACTOR COOLA T SYSTEM REACTOR COOLANT PUMP -'TARTING LIMITING CONDITION FOR OPERATION 3.4.14 If the steam generator temperature exceeds the primary temperature by more than 30'F, the first idle reactor coolant pump shall not be started.

APPLICABILITY:

MODES Q 4>and 5.

aM ACTION:

If a reactor coolant pump is started when the steam generator temperature exceeds primary temperature by more than 30'F, evaluate the subsequent transient to determine compliance with Specific ation 3.4.9.1.

SURVEILLANCE RE UIREMENTS AVLAlLT 4.4.14 Prior to starting a reactor coo~ pump, verify that the steam generator temperature does not exceed primary temperature by more than 30'F.

pQ'F, PReactor Coolant System Cold Leg Temperature is less than 084-P; ST.

LUCIE - UNIT 1 3/4 4-60 Amendment No. Nkl

'MERGENCY CORE COOLIN STEMS ECCS SUBSYSTEMS >> T

< 325.'F LIMITING CONDITION FOR OPERATION 3.5.3 As a minimum, one ECCS subsystem comprised of the fol'fowing Shall be OPERABLE:

a.

In MODES 3* and 4, one ECCS subsystem composed of one OPERABLE high pressure safety injection pump and one OPERABLE flow path capable of taking suction from the refueling water storage tank on a safety injection actuation signal and automatically transferring suction to the containment sump on a sump recirculation actuation signal.

b.

Prior to decreasing the reactor coolant system temperature below 5HRU-7POi a maximum of only one high pressure safety indection pumpdim e

OPERABLE withp'its associated header stop valve open.

c.

Prior to decreasing the reactor coolant system temperature below Z~F all high pressure safety injection pumps disabled MAL<

n their associated header stop valves closed excep as a

owe by Specifications 3.1.2.1 and 3.1.2.3.

APPLICABILITY:

MODES 3* and 4.

ACTION:

a.

With no ECCS subsystems OPERABLE in MODES 3* and 4, immediately restore one ECCS subsystem to OPERABLE status or be in COLD SHUTDOWN within 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br />.

(ZAP F b.

With RCS temperature below Cd~and with more than the allowed high pressure safety injection pump OPERABLE or injection valves and header isolation valves open, immediately disable the high pressure safety injection pump(s) or close the header isolation valves.

c.

In the event the ECCS is actuated and injects water into the Reactor Coolant System, a Special Report shall be prepared and submitted to the Commission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation and the total accumulated actuation cycles to date.

SURVEILLANCE RE UIREMENTS 4.5.3.1 The ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2.

4.5.3.2 The high pressure safety injection pumps shhll be verified inoperable and the associated header stop valves closed prior to decreasing below the above specified Reactor Coolant System temperature and once per month when the Reactor Coolant System is at refueling temperatures.

• With pressurizer pressure

< 1750 psia.

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8REACTOR COOLANT SYSTEM cold leg temperature above CSS-P..

ST. LUCIE - UNIT 1 3/4 5-7J Amendment No. gS,SN, 8y

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REACTOR COOLANT SYSTEM BASES The. heatup end cooldoen limit curves (Figures 3.4-2a and 3.4-2b) are composite curves erich were prepared hy.determining the most conservative

case, with etther the inside or outside wall controlling, for any heatup rate of up to 50'F/hr and for any cooldown rate of up to 100'F per hour..

The heatup and cooldown curves were prepared based upon the most ltmiting value of the predicted adgusthd 1 eference temperature..at

.the, end:.of;ihe'.appltcable.service period.

The reactor vessel materials have been tested to determine their initial RTN T., the results of these tests are shown in Table B 3/4.4-1.

Reactor ops%ation and resultant fast neutron (E~l Nev) irradiation will cause an increase in the RT g.

Therefore, an ad)usted reference temperature can be calculated based upo he fluence.

The heatup and cooldown limit curves shown on Figures 3.4-2a and 3.4-2b include predicted adjustments for this shift in RT at the end of the applicable service period, as well as adjustments for

~mssu~nd=4enpem4um=sens4og-he actual shift in RT T of the vessel material will be established eriodically during operatil by removing and evaluating

~ in accordance with ASTH E185-73, reactor vessel material irradiation surveillance specimens installed near the inside wall of the reactor vessel in the core area.

Since the neutron spectra at the irratiation samples and vessel inside radius are essentially identical, the measured transition shift for a sample can be applied with confidence to the adjacent section of the reactor vessel.

The heatup and cooldown curves must be recalcu-lated when the aRT determined from the surveillahce capsule is dif-ferent from the ca%[lated aRTRRT for the equivaIent capsule radiation exposure.

The pressure-t'emperature limit lines shown on Figures 3.4-2a and 3.4-2b for reactor criticality and for inservice leak and hydrostatic testing have been provided to assure compliance with the minimum temperature require-ments of Appendix G to 10 CFR 50.

The maximum RT>> for all reactor coolant system pressure-retaining materials, with the exception bT the reactor pressure vessel.

has been estimated to be 90'F.

The Lowest Servt'ce Temperature limit line shown on Figures 3.4-2a and 3.4-2b is based upon this RT>> since Arttcle NB-2332 of Section IIIof the ASHE Boiler and Pressure Vessel Cotfl requires the Lowest Service Temperature to be RT

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LUCIE - UNIT 1 B 3/4 4-7 Amendment No. Bl

REACTOR COOLANT SYSTEM

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BASES i

r 3/4.4.13 POWER OPERATED RELIEF VALVES'and 3 4.4;14 R

CTOR COOLANT PUMP'-

RT NG The low temperature overpressure protection system (LTOP) s designed to prevent RCS overpressurization above the 10 CFR Appendix G gerating limit curves (Figures 3.4-2a and 3.4>>2b) at RCS temperatures below 884-P The LTOP system is based on the use of the pressurizer pow

-operated relief valves (PORVs) and the implementation of administrative and operational controls.

~+or The PORVs aligned to the RCS with the low pressure setpoints of 350 and 530 psia, restrictions on RCP starts, limitations on heatup and cooldown

rates, and disabling of non-essential components provide assur ance that Appendix G P/T limits will not be exceeded during normal operation or design basis overpressurization events due to mass or energy addition to the RCS.

3/4.4.15 REACTOR COOLANT SYSTEM VENTS Reactor Coolant System vents are provided to exhaust noncondensible gases and/or steam from the primary system that could 'inhibit natural circulation core cooling.

The OPERABILITY of at least one Reactor Coolant System vent path from the reactor vessel head and the pressurizer steam space ensures the capability exists to perform this function.

The redundancy design of the Reactor Coolant System vent systems serves to minimize the probability of inadvertent or irreverisible actuation while ensuring that a single failure of a vent valve, power supply, or control system does not prevent isolation of the venC p4th.

The function, capabilities, and testing requirements of the Reactor Coolant System vent system are consistent with the requirements of Item II.b.l of NUREG-0737, ".Clarification of TMI Action Plan Requirements,"

November 1980.

ST.

LUCIE - UNIT 1

B 3/4 4-15 Amendment No. Sg,HH, 81

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3/4.5 EMERGENCY CORE COOLING SYSTEMS ECCS BASES 3 4,5.1 SAFETY INJECTION TANKS The OPERABILITY of each of the RCS safety injection tanks ensures hat a sufficient volume of borated water will be iomediately forced into the reactor core through each of the cold legs in the event the RCS pressure falls below the pressure of the safety injection tanks.

This initial surge of water into the core provides the initial cooling echanism during large RCS pipe ruptures.

The limits on safety injection tank volume, boron concentration and ressure ensure that the assumptions used for safety injection tank injection in the accident analysis are met.

The limit of one hour for operation with an inoperable safety injection tank minimizes the time exposure of the plant to a LOCA event ccurring concurrent with failure of an additional safety injection tank hich may result in unacceptable peak cladding temperatures.

4.5.2 and 3 4.5.3 ECCS SUBSYSTEMS The OPERABILITY of two separate and independent ECCS subsystems nsures that sufficient emergency core cooling capability will be avail-ble in the event, of a LOCA assuming the loss of one subsystem through ny single failure consideration.

Either subsystem operating in conjunc-ion with the safety injection tanks is capable of supplying sufficient ore cooling to limit the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double ended break of the largest RCS cold leg pipe downward.

In addition, each ECCS ubsystem provides long term core cooling capability in the recirculation ode during the accident recovery period.

The Surveillance Requirements provided to ensure OPERABILITY of ach component ensure that at a minimum, the assumptions used in the ccident analyses are met and that subsystem OPERABILITY is maintained.

The limitations on KPSI pump operability when the RCS temperature f

and the associated Surveillance Requirements provide additional administrative assurance that the pressure/temperature limits (Figures 3.4-2a and 3.4-2b) will not be exceeded during a mass addition transient mitigated by a single PORV.

T. LUCIE - UNIT 1

B 3/4 5-1 Amendment No. W,8y

ATTACHMENT 2 SAFETY ANALYSXS Descri tion of Chan e

The current St.

Lucie Unit 1

Technical Specification Reactor Coolant System (RCS) pressure-temperature (P-T) limits are applicable up to 10 effective full power years (EFPY) of operation.

The existing low temperature overpressure protection (LTOP) analysis that is based upon these P-T limits is also applicable up to 10 EFPY.

To ensure that the reactor coolant pressure boundary will continue to behave in a non-brittle manner while operating at low RCS temperatures during the operating period starting at 10 EFPY, new P-T limits have been.developed and a

new LTOP analysis has been performed, based upon the revised P-T limits.

The LTOP analysis yielded Limiting Conditions for Operation (LCO) that constitute Overpressure Mitigation System (OMS) alignments beyond 10 EFPY.

The proposed P-T limits, which are based upon fluence predictions at 15

EFPY, and revised LCOs ensure that all RCS components will be able to withstand the effects of cyclic loads due to system temperature and pressure changes without their functions or performance being impaired.

These cyclic loads are introduced by normal load transients, reactor trips, and startup and shutdown operations.

Overpressure protection provided by the OMS ensures RCS overpressurization below certain temperatures would be prevented, thus maintaining reactor coolant pressure boundary integrity.

The proposed changes are as follows:

a ~

LCO 3.4.9.1 currently provides the pressure and temperature limits in terms of Figures 3.4-2a, 3.4-2b, and 3.4-3 for the RCS (except the pressurizer) during

heatup, cooldown, criticality, and inservice leak and hydrostatic testing for 10 EFPY.

The proposed amendment would replace these three figures with three new figures, 3.4-2a, 3.4-2b, and 3.4-3, that are applicable for 15 EFPY.

Furthermore, the proposed amendment would revise the maximum allowable heatup rates from 40'F/hr at cold leg temperatures less than or equal to 102'F and 50'F/hr at cold leg temperatures greater than 102'F to 50'F/hr at all cold leg temperatures during

heatup, and according to the new Figure 3.4-3 during cooldown.

LCO 3.4.13 currently requires that, two power operated relief valves (PORVs) shall be

OPERABLE, with their setpoints selected to the low temperature mode of operation as follows:

a setpoint of less than or equal to 350 psia, when the reactor coolant cold leg temperature is less than or equal to 200'F during cooldown and less than or equal to 180'F during heatup and isothermal conditions; or a setpoint of less than or equal to 530 psia, when the reactor coolant cold leg temperature is

SAFETY ANALYSIS Page two greater than 200'F and less than or equal to 334'F during cooldown and greater than 180'F and less than or equal to 334'F during heatup.

While leaving the existing PORV setpoints unchanged, the proposed amendment revises the applicable temperatures to less than or equal to 215'F during cooldown and less than or equal to 193'F during heatup and isothermal conditions for a

setpoint of less than or equal to 350 psia; and to greater than 215'F and less than or equal to 281'F during cooldown and greater than 193'F and less than or equal to 304'F during heatup and isothermal conditions for a setpoint of less than or equal to 530 psia.

c The APPLICABILITY of LCO 3.4.13 and LCO 3.4.14 would be revised from Mode 3 below 334'F and Modes 4 and 5 to Mode 4

below 304'F and Mode 5.

The typographical errors in LCO 3.4.14 would be corrected.

Accordingly, ACTION a.

of LCO 3.4.13 would be revised from "HOT STANDBY" to "HOT SHUTDOWN".

d.

DEFINITION 1.16 currently identifies the cold leg temperature of less than or equal to 334'F as one of the operating conditions consider'ed to be the LOW TEMPERATURE RCS OVERPRESSURE PROTECTION RANGE.

The proposed amendment would revise this temperature to less than or equal to 304'F during heatup and less than or equal to 281'F during cooldown.

e.

Footnotes

(*)

appended to LCO 3.1.2.1 and LCO 3.1.2.3 currently state that the flow path from the refueling water tank (RWT) to the RCS via a single high pressure safety injection (HPSI) pump shall only be established if:

(a) the RCS pressure boundary does not exist, or (b) no charging pumps are operable.

Footnotes

(*) also state that in this case all charging pumps shall be disabled, and heatup and cooldown rates shall be limited in accordance with Figure 3.1-1b.

The proposed amendment would add a new statement to Footnotes

(*) to state that at RCS temperature below 115'F, any two of the following valves in the operable HPSI header shall be verified closed and have their power removed:

High Pressure Header Auxiliary Header HCV-3616 HCV-3626 HCV-3636 HCV-3646 HCV-3617 HCV-3627 HCV-3637 HCV-3647 The proposed amendment would also replace the current Figure 3.1-1b with a new Figure 3.1-1b.

SAFETY ANALYSIS Page three Technical Specification 3.5.3 provides the operational modes in which one Emergency Core Cooling System (ECCS) subsystem is required to be OPERABLE, and the RCS temperature limits for the number of HPSI pumps allowed to be OPERABLE.

The proposed amendment would revise the RCS temperature in LCO 3.5.3b and ACTION b from 253'F to 270'F, and the RCS temperature in LCO 3.5.3c from 220'F to 236'F.

The applicability of LCO 3.5.3 would be revised from MODES 3 and 4 above 235'F to MODES 3 and 4 above 250'F.

The value of 250'F was chosen to allow a margin above the analyzed value of 236'F for the inoperable HPSI pump to be returned to service.

In LCO 3.5.3b, the predicate would be revised from "is to be OPERABLE" to "shall be OPERABLE" and words "stop valves" would be revised to "stop valve".

In LCO 3.5.3c, the predicate would be revised from "will be disabled" to "shall be disabled".

g.

The APPLICABILITYof LCO 3.4.9.1 currently requires the unit to be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the RCS T,~ and pressure to less than 200'F and 500

psia, respectively, within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

The proposed amendment would revise this statement to require the unit to be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and reduce the RCS T,, to less than 200'F within the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, in accordance with Figures 3.4-2b and 3.4-3.

h.

Finally, the proposed amendment would revise the appropriate Bases.

A detailed report on the methodology used to calculate the new P-T limits and determine new LTOP requirements that provide a basis for this amendment is provided in Attachment 4.

ATTACHMENT 3 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission's regulation, 10 CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a

new or different kind of accident from any accident previously evaluated; or (3) involve a

significant reduction in a margin of safety.

Each standard is discussed below:

(1)

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The pressure-temperature (P-T) limit curves in the Technical Specifications are conservatively generated in accordance with the fracture toughness requirements of 10 CFR 50 Appendix G

as supplemented by the ASME Code Section III, Appendix G

recommendations.

The RT>>, values for the revised curves are based on Regulatory Guide 1.99, Revision 02 shift prediction and attenuation formula.

Analyses of reactor vessel material irradiation surveillance specimens are used to verify the validity of the fluence predictions and the P-T limit curves.

Use of the revised curves in conjunction with the surveillance specimen program ensures that the reactor coolant pressure boundary will behave in a non-brittle manner and that the possibility of rapidly propagating fracture is minimized.

In conjunction with revising the P-T limit curves, a

low temperature overpressure protection (LTOP) analysis has been performed to confirm that the current Overpressure Mitigation System (OMS) setpoints for the power-operated relief valves (PORVs) will provide the appropriate overpressure protection at the low Reactor 'Coolant System (RCS) temperatures.

The LTOP analysis also revised the current values of the limiting temperatures for the PORV setpoints'pplicability, heatup and cooldown rates, and disabling of non-essential components, based upon the revised P-T limits.

To ensure compliance with the P-T limit curves, overpressure protection is provided to keep the RCS pressure below the P-T limits for any given temperature after the initiation of assumed pressure transients (energy-addition and mass-addition transients) while operating below the enable temperatures that were determined in accordance with Standard Review Plan 5.2.2, Revision 02.

1

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION Page two The revised P-T curves and applicable OMS temperatures do not represent a

significant change in the configuration or operation of the plant.

The results of the LTOP analysis show that the limiting pressures for given temperatures are not exceeded for=-the assumed transients and that reactor vessel integrity is maintained.

Thus, the proposed amendment does not involve an increase in the probability or consequences of accidents 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 evaluation performed has resulted in revised P-T limits based on the fracture toughness requirements of 10 CFR 50 Appendix G, and in revised OMS temperatures based on standard energy and mass addition transients.

Since there is no significant change in the configuration or operation of the facility as a result of the proposed amendment, the use of revised P-T limits and the OMS setpoints do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a

margin of safety.

The proposed amendment does not involve a

significant reduction in a

margin of

safety, because the fracture toughness requirements of 10 CFR 50 Appendix G are satisfied and conservative operating restrictions are applied for the purpose of low temperature overpressure protection.

In conclusion, based on the analysis performed, we have determined that the amendment request does not (1) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the probability of a

new and different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and

,therefore does not, involve a significant hazards consideration.

)v

~

~.

ATTACHMENT 4