NL-07-008, Proposed Changes to Indian Point, Unit 3 Technical Specifications Regarding Updated Pressure-Temperature and Low Temperature Overpressure Protection System Limits

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Proposed Changes to Indian Point, Unit 3 Technical Specifications Regarding Updated Pressure-Temperature and Low Temperature Overpressure Protection System Limits
ML070240285
Person / Time
Site: Indian Point Entergy icon.png
Issue date: 01/18/2007
From: Dacimo F
Entergy Nuclear Northeast
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-07-008
Download: ML070240285 (27)


Text

Enterqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB

%-'bEýEnbeW,5 P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Fred Dacimo Site Vice President Administration January 18, 2007 Re: Indian Point Unit 3 Docket 50-286 NL-07-008 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Proposed Changes to Indian Point 3 Technical Specifications Regarding Updated Pressure-Temperature and Low Temperature Overpressure Protection System Limits

REFERENCES:

1. NRC letter to Entergy dated December 3, 2003; regarding issuance of Indian Point 3 License Amendment 220 for changes to pressure-temperature curves. (ML033370869)
2. NRC letter to Entergy dated March 24, 2005; regarding issuance of Indian Point 3 License Amendment 225 for stretch power uprate.

(ML050600380)

Dear Sir:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc, (Entergy) hereby requests an amendment to the Technical Specifications for Indian Point Nuclear Generating Unit 3 (IP3). The proposed change will:

" Revise the expiration limit from 20 Effective Full Power Years (EFPY) to 27.2 EFPY for the three Pressure / Temperature (P/T) Limit graphs in Technical Specification Section 3.4.3 and the four Low Temperature Overpressure Protection (LTOP) graphs in Technical Specification Section 3.4.12.

  • Revise the adjusted reference temperature (ART) for the reactor pressure vessel to reflect the above revised expiration limit. The ART at the 1 T location is changed from 230.1°F to 241.1°F and the ART for the % T location is changed from 188.8 0 F to 198.1 0 F.
  • Revise the Low Temperature Overpressure Protection (LTOP) system arming temperature value specified in Technical Specifications 3.4.7, 3.4.10, and 3.4.12 from 319OF to 3300 F.

In addition, editorial changes are proposed to make the use of inequality signs consistent among Sections 3.4.7, 3.4.10, and 3.4.12.

NL-07-008 Docket 50-286 Page 2 of 2 The current P/T limit and LTOP graphs, with an expiration of 20 EFPY were established by Amendment 220 (Reference 1) and were subsequently reevaluated in Amendment 225 (Reference 2). The analysis methodology used for this license amendment request is the same as that used in the prior amendments 220 and 225. The actual pressure-temperature operating limits depicted in the existing graphs are not being changed. The analysis previously approved by NRC for the existing graphs is valid for 34 EFPY. The existing limit of 20 EFPY was established by Entergy to allow use of the LTOP arming temperature (319 0 F) that was in effect when license amendment 220 was requested. This amendment will now specify the expiration limit as 27.2 EFPY, and a more restrictive LTOP arming temperature (3300 F) will be established to maintain the validity of the graphs for the new expiration limit.

Entergy has evaluated the proposed change in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92 (c) and Entergy has determined that this proposed change involves no significant hazards considerations, as described in Attachment One. The proposed changes to the Technical Specifications are shown in Attachment Two. A copy of this application and the associated attachments are being submitted to the designated New York State official.

Entergy estimates that the current limit of 20 EFPY will be reached in December 2007. Therefore, Entergy requests approval of the proposed amendment by November 15, 2007. The proposed change to 27.2 EFPY will provide for valid graphs and limits for operation through 2015. There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Patric W. Conroy, IPEC Licensing Manager at (914) 734-6668.

I declare under penalty of perjury that the foregoing is true and correct. Executed on I "f )7.

TSin red R. Dacimo Site Vice President Indian Point Energy Center Attachments:

One: Analysis of Proposed Technical Specification Changes Regarding Updated Pressure-Temperature and Low Temperature Overpressure Protection System Limits Two: Markup of Technical Specification Pages for Proposed Changes Regarding Updated Pressure-Temperature and Low Temperature Overpressure Protection System Limits cc: Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspector, IP2 NRC Resident Inspector, IP3 Mr. Peter R. Smith, President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT ONE TO NL-07-008 ANALYSIS OF PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING UPDATED PRESSURE-TEMPERATURE AND LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM LIMITS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

NL-07-008 Docket 50-286 Attachment One Page 1 of 8

1.0 DESCRIPTION

This is a request to amend Operating License DPR-64, Docket No. 50-286 for Indian Point Nuclear Generating Unit No. 3 (IP3). The proposed change will revise Technical Specifications Sections 3.4.3, 3.4.7, 3.4.10, and 3.4.12 as follows:

" Revise the expiration limit from 20 Effective Full Power Years (EFPY) to 27.2 EFPY for the three Pressure / Temperature (P/T) Limit graphs in Technical Specification Section 3.4.3 and the four Low Temperature Overpressure Protection (LTOP) graphs in Technical Specification Section 3.4.12.

  • Revise the adjusted reference temperature (ART) for the reactor pressure vessel to reflect the above revised expiration limit. The ART at the 1/4 T location is changed from 230.1°F to 241 .10 F and the ART for the 3/4 T location is changed from 188.8 0 F to 198.1 0 F.
  • Revise the Low Temperature Overpressure Protection (LTOP) system arming temperature specified in Technical Specifications 3.4.7, 3.4.10, and 3.4.12 from 319°F to 330 0 F. In addition, editorial changes are proposed to make the use of inequality signs consistent among Sections 3.4.7, 3.4.10, and 3.4.12.

2.0 PROPOSED CHANGE

S The proposed changes and affected pages are summarized in the following table. The markup of existing Technical Specification pages is provided in Attachment Two.

NL-07-008 Docket 50-286 Attachment One Page 2 of 8 Summary Table of Affected Technical Specification Pages Revise Revise Revise LTOP Page EFPY ART temperature Section 3.4.3: Reactor Coolant System Pressure and Temperature (PIT) Limits 3.4.3-3 X X n/a 3.4.3-4 X X n/a 3.4.3-5 X X n/a Section 3.4.7: RCS Loops - Mode 5 Loops Filled 3.4.7-1 n/a n/a X Section 3.4.10 Pressurizer Spray Valves 3.4.10-1 n/a n/a X Section 3.4.12: Reactor Coolant System Low Temperature Overpressure Protection (LTOP) 3.4.12-1 n/a n/a X+

3.4.12-3 n/a n/a X+

3.4.12-4 n/a n/a X+

3.4.12-6 n/a n/a X+

3.4.12-7 n/a n/a X+

3.4.12-8 n/a n/a X+

3.4.12-9 X n/a X 3.4.12-10 X n/a n/a 3.4.12-11 X n/a n/a 3.4.12-12 X n/a n/a Notes: 'X' indicates value change required on this page

'+' indicates correction of inequality sign

'n/a' indicates parameter does not appear on this page Related Bases changes consist simply of revisions on approximately 15 pages to reflect the new values and inequality signs described above. Therefore, informational markups of these changes are not provided with this amendment request.

NL-07-008 Docket 50-286 Attachment One Page 3 of 8

3.0 BACKGROUND

This license amendment request proposes to revise the Effective Full Power Years (EFPY) limit associated with the Pressure-Temperature (P/T) and Low Temperature Overpressure Protection (LTOP) System graphs. The P/T curves define an acceptable region for normal plant operation.

They limit the pressure and temperature changes during Reactor Coolant System (RCS) heatup and cooldown to within the design assumptions and the established stress limits for cyclic operation.

The LTOP system controls the RCS pressure at low temperatures to ensure the integrity of the reactor coolant boundary is not compromised by violating the pressure and temperature limits of 10CFR 50, Appendix G. The current IP3 Technical Specifications associated with RCS heatup and cooldown are based on a designated expiration limit of 20 EFPY, with a calculated Adjusted Reference Temperature (ART) of 230.1 OF at the 1/ vessel thickness and 188.8°F at the 3/4 vessel thickness. The proposed amendment seeks to revise the EFPY limit to 27.2 EFPY, which corresponds to the expected service life at the expiration of the current operating license. The ARTs at 27.2 EFPY are 241.1 OF at the 1/4 vessel thickness and 198.1 OF at the 3/4 vessel thickness.

The P/T and LTOP graphs which denote the operating limits to be implemented by plant operators are not being changed in this amendment request, since the limits remain valid through a service life of 34.0 EFPY (References 1 and 2). The validity of the existing graphs is maintained by establishing a more restrictive limit on the LTOP system arming temperature, which is the temperature at which the power operated relief valves (PORVs) will open if RCS pressure exceeds the temperature dependent value depicted in the LTOP curves. The current arming temperature value of 319°F is being increased to 330 0 F.

In addition, Entergy has determined that inequality signs used in relation to the LTOP arming temperature are not consistently used among three affected Technical Specification sections.

For example, Specification 3.4.7 establishes requirements for RCS heat removal capability, and a LCO Note imposes a restriction on RCP starts if RCS temperature is in the LTOP applicability window from Specification 3.4.12. Currently, the IP3 3.4.7 LCO Note is specified as "<", however IP3 3.4.12 applicability is specified as" < ". The inequality symbol in 3.4.12 needs to be changed to "< "to be consistent with 3.4.7. This change is also consistent with the inequality signs used in the Standard Technical Specifications (NUREG-1431).

In another example, Specification 3.4.10 establishes requirements for RCS overpressure protection (pressurizer safety valves) when at temperatures above the LTOP arming temperature stated in Specification 3.4.12. Currently, the IP3 3.4.10 applicability is specified as "> ", and the IP3 3.4.12 applicability is specified as "< ". This results in a situation where a temperature equal to the LTOP arming temperature is not covered by either applicability statement. Therefore, the inequality symbol in IP3 3.4.12 needs to be changed to "< ". This change is also consistent with the inequality signs used in NUREG-1431.

This observation regarding the use of inequality signs applies to 7 locations in IP3 Specification 3.4.12. The required corrections are shown on the technical specification markup pages provided in Attachment Two.

NL-07-008 Docket 50-286 Attachment One Page 4 of 8

4.0 TECHNICAL ANALYSIS

The P/T limits currently in the Technical Specifications were developed in accordance with the requirements of 1 OCFR50 Appendix G and Regulatory Guide 1.99 Rev 2 as described in WCAP-16037 Revision 1, May 2003 ("Final Report on Pressure-Temperature Limits for Indian Point Unit 3 NPP") which was provided in Reference 3. As noted in that WCAP, these curves were prepared for a plant service lifetime of up to 34.7 Effective Full Power Years (EFPY), based on the licensed power level of 3067.4 MWth in effect at that time. The License Amendment Request (LAR) for implementation of these limits (Reference 3) established a more limiting expiration date of 20 EFPY instead of 34.7 EFPY, so that the Technical Specification limit on LTOP system arming temperature (319 OF) did not have to be changed at that time.

In order to extend the P/T operating limits beyond the current 20 EFPY service life limit, a more restrictive limit on the LTOP system arming temperature must be implemented in order to compensate for the effects of the increase in neutron fluence on the reactor vessel. Reference 3 included a calculation showing the correlation of LTOP system arming temperature with lifetime service burnup. A formula was provided showing how an applicable arming temperature may be determined for any chosen lifetime burnup, and vice versa. Applying this formula for the proposed new service life limit of 27.2 EFPY yields a new LTOP system arming temperature of 330 0 F.

The choice of 27.2 EFPY is based upon Entergy's current estimate of the lifetime service burnup upon expiration of the current facility operating license. Furthermore, 27.2 EFPY is a burnup explicitly evaluated in WCAP-1 6037, including the determination of the RT-NDT temperatures at the 1/ and the 33/4 vessel thicknesses, as identified on TS Figures 3.4.3-1, 3.4.3-2 and 3.4.3-3.

Reference 1 documented NRC approval of Entergy's amendment request which was based on P/T curves valid for up to 34.7 EFPY, for the licensed power level of 3067.4 MWth in effect at that time.

Subsequently, Entergy proposed a 4.85% stretch power uprate (SPU) for IP3 and calculated that the neutron fluence used for developing those P/T curves would be reached in 34.0 EFPY, under the SPU conditions. Since a more limiting expiration period of 20 EFPY was used for the technical specification curves, no change to technical specification curves was needed for the SPU license amendment, Entergy also evaluated the effect of SPU on pressurized thermal shock (PTS) screening criteria (10 CFR 50.61) and Upper Shelf Energy limits (10 CFR 50 Appendix G). Entergy determined that the most limiting PTS screening criterion would be reached at 35.7 EFPY, based on the material properties of the Lower Shell Baseplate, B2803-3, which is the limiting material for the IP3 reactor vessel. Entergy also determined that the limit on reactor vessel Upper Shelf Energy (USE) of >50 ft-lb will be met through a lifetime burnup of greater than 45 EFPY.

Reference 2 documented NRC approval of SPU, including the effect on the service life applicable to the P/T graphs. Therefore, for these reasons, the P/T limit curves as they exist in the current technical specifications remain valid and need not be changed for the proposed new expiration limit of 27.2 EFPY.

The reactor vessel surveillance program for IP3 was evaluated as part of the SPU project. To date, four capsules have been withdrawn, with a fifth to be scheduled at a future refueling outage in accordance with the recommendations of ASTM-E1 85-82. The data analysis for the vessel specimens removed to date confirm that the vessel materials are responding as predicted, and the surveillance program has been shown to provide credible results in accordance with NRC standards.

NL-07-008 Docket 50-286 Attachment One Page 5 of 8 The methodology under which the existing curves were originally prepared remains valid. The curves are based on the irradiation damage prediction methods of Regulatory Guide 1.99, Rev 2.

This methodology has been used repeatedly to calculate the limiting material ARTs for IP3. The crack initiation reference stress intensity factor (Kic) was used for determining the fracture toughness of the beltline. The use of Kic as the basis for establishing the reference fracture toughness limit, KIR, value for the vessel is currently outlined in ASME Code Case N-640. Approval of the LAR for the existing technical specification curves was based on an exemption requested by Entergy and approved by NRC (Reference 4). Use of this Code Case is now approved in Regulatory Guide 1.147 (Revision 14, August 2005) and the exemption is no longer required.

In summary, this LAR proposes changes to the family of Heatup, Cooldown and LTOP figures and specifications in the IP3 TS. The curves themselves are still valid through a proposed lifetime of 27.2 EFPY and do not change. The LTOP system arming temperature has been increased from 319 OF to 330 OF, to ensure that 10 CFR 50 Appendix G limits will continue to be met for plant operation through 27.2 EFPY. The adjusted RT-NDT (ART) values appearing on TS Figures 3.4.3-1 through 3.4.3-3 also have been revised to account for the higher burnup limit.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Entergy Nuclear Operations, Inc. (Entergy) has evaluated the safety significance of the proposed changes to the Indian Point 3 (IP3) Technical Specification Sections 3.4.3, 3.4.7, 3.4.10, and 3.4.12. The proposed change is an increase of the service life limit specified for the graphs that define the pressure-temperature operating limits for the reactor coolant system. The current service life limit of 20 Effective Full Power Years (EFPY) will be increased to 27.2 EFPY. In order to maintain the validity of the graphs for 27.2 EFPY, two other changes are being made. The values specified on certain graphs for the adjusted reference temperatures (ART) with respect to reactor vessel material fracture toughness are updated and the arming temperature for the Low Temperature Overpressure Protection (LTOP) system is being revised. In addition, editorial changes are proposed in Section 3.4.12 to make the inequality signs used in that section consistent with those used in IP3 Sections 3.4.7 and 3.4.10 and as shown in the Standard Technical Specifications.

This proposed change has been evaluated according to the criteria of 10 CFR 50.92, "Issuance of Amendment' and Entergy has determined that the subject change does not involve a Significant Hazards Consideration as discussed below:

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

Response: No The proposed change does not affect the accident initiators or mitigation assumptions associated with any of the accidents previously evaluated. Operating restrictions on pressure-temperature conditions for the reactor pressure vessel provide assurance that reactor vessel integrity will be maintained under accident or

NL-07-008 Docket 50-286 Attachment One Page 6 of 8 transient conditions. The proposed change uses approved criteria and analysis methods to update the time period for which the current operating limits remain valid.

The LTOP system performs an automatic function by opening relief valves if reactor coolant system pressure reaches a temperature-dependent limit. The proposed change includes establishing a more restrictive temperature limit for when this system must be in service, to reflect the material condition of the reactor vessel at the new EFPY limit proposed for the pressure-temperature graphs. The mitigation function and capability of the LTOP system is not being changed by this request.

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

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

Response: No There are no new accident initiators being introduced by this proposed change.

The proposed change does not involve installation of new plant equipment, modification of existing equipment, or changes in the way that plant equipment is operated. Pressure-temperature operating limits depicted by graphs in the technical specifications will not be changed and will continue to be used by plant operators. A change in the LTOP system arming temperature will assure that the graphs remain valid for the proposed new operating period of 27.2 EFPY.

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

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

Response: No Operating limits on pressure and temperature conditions for the reactor coolant system (RCS) are important to assure that the RCS pressure boundary stresses are within analyzed limits. Margins of safety are inherent in the analysis methods, assumptions, and limits specified in regulations and guidance documents. The proposed change is based on NRC-accepted methods, assumptions and limits and maintains the required margin of safety.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, Entergy Nuclear Operations, Inc. concludes that the proposed amendment to the Indian Point 3 Technical Specifications presents no significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and, accordingly, a finding of "no significant hazards consideration" is justified.

NL-07-008 Docket 50-286 Attachment One Page 7 of 8 5.2 Applicable Requlatory Requirements / Criteria General Design Criteria 14 (Reactor Coolant Pressure Boundary) requires that the reactor coolant pressure boundary be designed, fabricated, erected, and tested in order to have an extremely low probability of abnormal leakage, of rapid failure, and of gross rupture.

General Design Criteria 31 (Fracture Prevention of Reactor Coolant Pressure Boundary) requires, in part, that the reactor coolant pressure boundary be designed with sufficient margin to assure that when stressed under operating, maintenance, and testing, the boundary behaves in a non-brittle manner and the probability of rapidly propagating fracture is minimized.

Standard Review Plan (SRP) 5.3.2 (Pressure-Temperature Limits) describes acceptance criteria, methods, and assumptions for meeting regulatory requirements pertaining to pressure-temperature limits applied to the reactor coolant pressure boundary. This license amendment request applies methods and criteria which are based on SRP 5.3.2 and which NRC has previously approved for IP3.

The existing P/T operating limits approved by NRC and specified in the Technical Specifications are not being changed. The service limit for these curves is valid for 34 EFPY; however their use is currently restricted to 20 EFYP in order to allow use of the current LTOP system arming temperature. The current arming temperature and method for calculating the arming temperature for a given EFPY limit were previously approved by NRC. The same method is being used to determine the new arming temperature associated with the new 27.2 EFPY limit being proposed for the P/T graphs.

Entergy previously obtained NRC approval for a 10 CFR 50 Appendix G exemption which allowed use of ASME Code Case N-640 regarding alternative fracture toughness requirements for development of P/T graphs. Since that time, NRC has incorporated this code case into Regulatory Guide 1.147. The code case requirements are still applicable for this amendment request, but use of that code case no longer relies on a regulatory exemption.

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.

NL-07-008 Docket 50-286 Attachment One Page 8 of 8 6.0 PRECEDENCE References 1 through 3 provide an applicable precedence for this amendment request.

7.0 REFERENCES

1. NRC letter to Entergy dated December 3, 2003; regarding issuance of Indian Point 3 License Amendment 220 for changes to pressure-temperature curves.

(ML033370869)

2. NRC letter to Entergy dated March 24, 2005; regarding issuance of Indian Point 3 License Amendment 225 for stretch power uprate. (ML050600380)
3. Entergy letter NL-03-093 to NRC dated May 28, 2003; regarding proposed technical specification changes for pressure-temperature and overpressure protection system limits for up to 20 effective full power years. (ML031550595)
4. NRC letter to Entergy dated December 2, 2003; regarding issuance of Indian Point 3 exemption from the requirements of 10CFR50.60(a).

ATTACHMENT TWO TO NL-07-008 MARKUP OF TECHNICAL SPECIFICATION PAGES FOR PROPOSED CHANGES REGARDING PRESSURE-TEMPERATURE AND LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM LIMITS Affected Technical Specification Pages Section 3.4.3 RCS P/T Limits:

Section 3.4.7 RCS Loops - MODE 5, Loops Filled:

  • Page 3.4.7-1, Amend 205 Section 3.4.10 Pressurizer Safety Valves:
  • Page 3.4.10-1, Amend 205 Section 3.4.12 Low Temperature Overpressure Protection (LTOP):
  • Page 3.4.12-1, Amend 205
  • Page 3.4.12-3, Amend 205
  • Page 3.4.12-4, Amend 205

" Page 3.4.12-6, Amend 205

" Page 3.4.12-7, Amend 205

" Page 3.4.12-8, Amend 205

  • Page 3.4.12-9, Amend 220 (Figure 3.4.12-1: Maximum Allowable Nominal PORV Setpoint for LTOP (OPS))

Page 3.4.12-10, Amend 220 (Figure 3.4.12-2: Pressurizer Limitations for OPS Inoperable, Up to one charging pump capable of feeding the RCS)

" Page 3.4.12-11, Amend 220 (Figure 3.4.12-3: Pressurizer Limitations for OPS Inoperable, Up to three charging pumps and/or one safety injection pump capable of feeding the RCS)

" Page 3.4.12-12, Amend 220 (Figure 3.4.12-4: Secondary Side Limitations for RCP Start with Secondary Side Hotter Than Primary Side)

ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 3 DOCKET NO. 50-286

-,1Ii I 2

2500 Curves8 P5r( ki8ble, for tisatup RTmDT Initial 74DegF rtaes to 60VFhr forlothe service ndcnti up EPY . . ..

periodu , ac i RTmTAfte EFPY: '14T 30.1 F.

the fol o igstrument error margins: 3 Heatup Rate m.....u-w . ......

Presure: 37 psi for 0 _<P 5 1500 psig. using PT-413. 433. 443 108 psi for 1500 <P < 1700 psig usintgPT-402.403 ...... ......

30 psi for 1700 < P 5 2500 pslg, using PT455,456,457,474 *...-

Curves include allowance for differential pressure effects -. * . . . . ..

due to RCP and RHR pump operation.

2000 Material Proaertv Basis, * . . . . . .

Controlling Material. Plate Metal............. ........

Copper Content: 0.240wt. % ......

Phosphorous Content:002 t% . . . . .

. . ..... . . . . Heatup Rate :7.

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.......... * *.* . 60 a :Fnr .. . . ...........

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100 150 200 250 300 350 400 (Degrees F)

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"0 Curvesa~\e rates 3 10Q a¶o.plicble to .._jlour forforthe cooldown service ..........

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period up t( 20 1EFPY, and contain "the folowlnglistrument error margins:

Teaoeratura : 30°F

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-r.ess, ea 37 psi forO<P<1500 psig. using PT-413, 433, 443 0 108 psi for 1500 < P < 1700 psig. using PT-402,403 0

  • 30 psi for 1700 < P . 2500 psig. using PT-455,456.457.474 0 =00500 0- q

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-I 'E ........... ............... .. ....... ...... ...

100 Cooldown Rate 9 Deg F/hr m Controlln atre: Plate Metal

.............. ............ Copper Content: 0.240 wt. %

0 aD PhospcOus Content: 0.012 wt. %

0 ~0 ...............

500- 20 I . . . . . . . . I . . . .

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C,, ...............

- 80 RTOT Initial: 74 Deg F

- 100o . .............. T MAe 20EFPY: ',/T 0.1 eg F. .RT, B 3,,T= 88.8 egF 00 L 0

50 100 150 200 250 300 350 4' TCold (Degrees F) tJ 0

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/1,00, I IIIJJll 80 a ppble Curveto are rates C for for Ie service .

theheatup". " . . ........

initial:

74 7T~o Deg F period up t 20FPY, and contain RTNo7 Aft 20 EFPY: '/,T 230.1 eg F

-S CL W"

the following**strument error margins:

Iaessure7 337p0 5 1500 u 1 -413,433,443 108 psi for 1500 < P < 1700 psig, using PT-402.403 3/.T = 8 F

  • 2 4 65 .0 Sig

....@34 g.

30 psi for 1700 < P <2500 psig. using PT-455.456.457.474 ........

Curves Include allowance for differential pressure effects -

2000 due to RCP and RHR pump operation.

CI

  • Material Properly Basis . .

Controlling Material: Plate Metal Copper Content: 0.240 wt.% ......... ..... .....

0L Phosphorous Content: 0.0 12 wt. % . . . - .

a. 1500-

>1/

oil 0~

Heatup Rate (12 1000 20 *Ffhr w

500 I i L -

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CS Oi, CA Heatup Rate

........... .40 F/hr ..... p Rate..

.0'  : '.: 60 F/hr 0o 100 150 200 250 300 350 4( 002 Tc (Degrees F) tJ 0'.

RCS Loops - Mode 5, Loops Filled 3.4.7 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.7 RCS Loops-MODE 5, Loops Filled LCO 3.4.7 One residual heat removal (RHR) loop shall be OPERABLE and in operation, and either:

a. One additional RHR loop shall be OPERABLE; or
b. The secondary side water level of at least two steam generators (SGs) shall be Ž 71% wide range.

NOTES --------------------------

1. The RHR pump of the loop in operation may not be in operation for
  • 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period provided:
a. No operations are permitted that would cause reduction of the RCS boron concentration; and
b. Core outlet temperature is maintained at least 10OF below saturation temperature.
2. One required RHR loop may be inoperable for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for surveillance testing provided that the other RHR loop is OPERABLE and in operation.
3. No reactor coolant pump shall be started with the average of the RCS cold leg temperatures : 3F unless the requirements of LCO 3.4.12, "Low Temperature Ov rpressure Protection (LTOP)," are met.
4. All RHR loops may be removed from operation during planned heatup to MODE 4 when at least one RCS loop is in operation.

APPLICABILITY: MODE 5 with RCS loops filled.

INDIAN POINT 3 3.4.7-1 Amendment 205

Pressurizer Safety Valves 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Pressurizer Safety Valves LCO 3.4.10 Three pressurizer safety valves shall be OPERABLE with lift settings set Ž 2460 psig and

  • 2510 psig.

73 0 APPLICABILITY: MODES 1, 2, and 3, MODE 4 with all RCS cold leg temperatures >14F.


NOTE -------------------------------

The lift settings are not required to be within the LCO limits during MODES 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> following entry into MODE 3 provided a preliminary cold setting was made prior to heatup.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pressurizer safety A.1 Restore valve to 15 minutes valve inoperable. OPERABLE status.

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 not met. AND OR B.2 Be in MODE 4 with any 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> RCS cold leg Two or more pressurizer temperature F.

safety valves inoperable. 230 INDIAN POINT 3 3.4.10-1 Amendment 205

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 ar 31 F. 30 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 _>2.00 square inches.

1.

NOTES --------------

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 i F, MODE 5, MODE 6 when the reactor vessel head is on.

T,30S INDIAN POINT 3 3.4.12-1 Amendment 205

i LTOP 3.4.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. An accumulator discharge B.1 Close and de-energize I hour isolation valve not isolation valve for closed and de-energized affected 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 cold 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> associated Completion le temperatures to Time of Condition B not A31_ F.

met.

AND ._.>

C.1.2 Isolate the RHR System 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from the RCS.

OR C.2 Depressurize affected 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> accumulator to less than the maximum RCS pressure for coldest existing cold leg temperature specified in Figure 3.4.12-1.

D. One required PORV D.1 Restore required PORV to 7 days inoperable. OPERABLE status.

(continued)

INDIAN POINT 3 3.4.12-3 Amendment 205

LTOP 3.4.12 ACTIONS (continued)

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 OR Required Action and associated Completion E.2.1 Increase all RCS cold 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Time of Condition C or D leg temperatures to not met.AN F."

AN>or E.2.2 Isolate the RHR System from the RCS.

OR E.3 Verify pressurizer 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> level, RCS pressure, and RCS injection capability A are within limits Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 establish RCS vent of Condition A, B, C, D, > 2.00 square inches.

or E.

INDIAN POINT 3 3.4.12-4 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 Overpressure 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Protection (OPS) instrument channels.

SR 3.4.12.5 Verify PORV block valve is open for each required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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

--- ecreasing any RCS cold leg temperature to 3So.........................................

< 31 F.

Perform a COT on each required PORV, excluding 24 months 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 instruments. 24 months (continued)

INDIAN POINT 3 3.4.12-6 Amendment 205

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 : 31 F.
2. Not required to be met if SR 3.4.12.9 is met.

Verify each of the following conditions are Within 15 minutes satisfied prior to starting any RCP: prior 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
b. RCS makeup is less than or equal to RCS losses; 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 3.4.12-7 Amendment 205

LTOP 3.4.12 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY 4.

SR 3.4.12.9 NOTES ----------------------

1. Not required to be met when all RCS cold leg temperatures are 1 .319F.
2. Not required to be met if SR 3.4.12.8 is met.

Verify each of the following conditions are Within 15 minutes satisfied prior to starting any RCP: prior tostarting any RCP

a. Secondary side water temperature of the hottest steam generator is < 640F 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
e. Coldest RCS cold leg temperature is within limits specified in Figure 3.4.12-4.

INDIAN POINT 3 3.4.12-8 Amendment 205

33o OPS Enable Tempera 20EFPY 319 egrees U ~1500.1 -LV 00

  • . , + . . . . i . . ... . . ... . . . . . . . .. . . . . . . . . ... . . . .. . . .

z .1 ...... ......

100 500- " . .. . ... . . . . ... ..

0" 50 100 150 20 250 300

=

  • T0 old (Oeg F) oNote: OPS Enable Temperature *,

includes an allowance of 14.4 degF for instrument uncertainty and margin.

Analytical Curve

°!

80 RCS Pressure (PSIG) ........... : . .... ........

Less Than 400 ............ .................... .. ..................

. ..... ... ...I . ... .... .. . ...... . .

70 IVI "a

60 500 V

9. ... ... . . .. .... ... .... .. 450 . ...... ... . ..... .. .....

cIt ... ... ..... .... .... ........ . .... ..

kD 550 50 LUI

-J . .... ....... * .. .. .. ... . ..... ... ..

n-ft W 40 N ..........

ý.:.....

CD IV Of f 30 a-.

-W CL

'7 ... ..... ..: : - -- ,C-,Curves

.: include the following

"...... instrument uncertainties:

I..

20 , -.i 4 . . . . 4 . . 1 - 4 10

/ . . .

Temperature: 30'F

..:..,...:Pressure: 37 psi

. Pressurizer Level: 7%

0 50 100 t

150 t

200 TCOL, (OF) 1~ .4 250 I.

300 350 Figure Applicable 20 FPY N

0O Curves represent maximum allowable pressurizer levels for the conditions defined

Curves include the following 50 instrument uncertainties:

Temperature: 30°F ...........

Pressure: 37 psi . . ... . . ....

0 cl ..

.... .~~s....

7 ........

H ................

40 C.

RCS Pressure (PSIG)

Less Than 100 .... ...........

Wbf 9 I 30

-.1

. .... .. ..... ... 20 0 .....

WO D ...... ..... ..... ........ . .. ..

U.)

20 oor 30..........

10 400 I. 50 100 150 200 TCOLD (OF) 250 300 350 Figure Applicable to0FPY t'J

- Curves represent maximum allowable pressurizer levels for the conditions defined 7 3--L_

350 Curve includes a primar I secondary temperature z instrume uncertainty alowance of 36 egF 0 269'F 4 300 -__ _ _ ___

ee

-U L,*

  • 1-200 150 OXI~
4J 0 10 20 30 40 50 60 70 80 g0 Hottest SG Temp - Tr (Deg F)

.. J

  • OV