NOC-AE-000471, Application for Amends to Licenses NPF-76 & NPF-80, Relocating cycle-specific RCS-related TS Parameter Limits to COLR
| ML20195E412 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/07/1999 |
| From: | Cloninger T HOUSTON LIGHTING & POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20195E418 | List: |
| References | |
| NOC-AE-000471, NOC-AE-471, NUDOCS 9906110089 | |
| Download: ML20195E412 (13) | |
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June 7,1999 NOC-AE-000471 File No.: G20.02.0t
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G21.02.01 10CFR50.90 1
U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001 l
South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Proposed License Amendment for Relocation of Cycle-Specific Operating Parameters from the Technical Specifications to the Core Operatine Limits Renon
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The South Texas Project proposes to amend Operating Licenses NPF-76 and NPF-80 for Units 1 and 2 with the attached changes to Technical Specifications 2.0," Safety Limits and Limiting j
Safety Settings," 3.2.5, "DNB Parameters," and the associated bases, and administrative control Section 6.9.1.6 " Core Operating Limits Report". This amendment request proposes that the cycle-specific Reactor Coolant System-related Technical Specification parameter limits be relocated to the Core Operating Limits Report (COLR). This will allow the South Texas Project the flexibility to enhance plant operating margin and/or core design margins without the need for cycle-specific license amendment requests. This amendment request follows the Westinghouse WCAP-14483-A, " Generic Methodology for Expanding Core Operating Limits Report," which was accepted for referencing in licensing applications by the NRC staff on January 19,1999.
The Technical Specification changes include:
,1.
Revising Technical Specification 2.1, " Safety Limits," and the associated bases to replace figures 2.1-1 and 2.1-2 (Reactor Core Safety Limit) with more specific requirements regarding the safety limits, and to move the figures to the Core Operating Limits Report.
- 2. Revising Technical Specification 2.2," Limiting Safety System Settings," and the associated bases to relocate the Overtemperature AT (OTDT) and Overpower AT (OPDT) setpoint parameter values to the Core Operating Limits Report. In addition, the Reactor Coolant Loop Flow-Low Loop Design Flow value from Technical Specification 2.2.1, Table 2.2-1, is being moved to the Core Operating Limits Repon to be consistent with the flow assumed in the safety analysis.
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- 3. Revising Technical Specificati6n 3.2.5," Departure from Nucleate Boiling (DNB)
Parameters," to relocate the Pressurizer Pressum, and Reactor Coolant System average temperature (Tog) to the Core Operating Limits Report. The minimum measured flow is being moved from the Technical Specifications to the Com Operating Limits Report.
I Technical Specification 3.2.5 now reports the Thermal Design Reactor Coolant System Flow.
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- 4. Revising Technical Specification 6.9.1.6, ' Core Operating Limits Report," to reflect the
- relocations to the COLR and to add appropriate references.
Includbd in.this proposed change are format changes to ensure consistency with Improved Technical Specifications (ITS). Specifically, the minimum thermal design flow (approved by the Nuclear Regulatory Commission in' Amendments 97 and 84 on September 29,1998) will be l J reported in Technical Specification 3.2.5. Also, the note from Technical Specification 2.2.1, 7"
' Table'2.2-1 for Reactor Coolant Flow-Low loop design flow is being moved to the Core Operating Limits Report to ensure that the Reactor Coolant Flow-Low for the trip setpoint is consistent with the flow assumed in the Safety Analysis.
The. changes included in this proposed amendment affect some of the same Technical Specification pages'as other proposed amendments. Specifically, the proposed amendment to Technical Specification to Reflect Replacement Steam Generator Coolant Flow Differences, submitted on May 7,1998, (NOC-AE-0080) will be supplemented to incorporate the necessary related changes. Also, the proposed license amendment for removal of the Total Allowance (TA), Sensor Error (S), and Z terms from the ESFAS and Reactor Trip System Instrumentation Trip Setpoint Tables, submitted on June 7,1999, (NOC-AE-000465) affects Technical Specification page 2-4 which is also changed in this proposal.
The NRC has approved COLR additions, submitted by Duke Power, for relocating the OTDT t and OPDT setpoint parameter values to the Core Operating Limits Report for Catawba (March 28,'1994) and McGuire (May 31,1994) units to allow for cycle-specific margin utilization. The Duke Power submittal was based on NRC-approved Duke Power, B&W, and Westinghouse '
analytical methods.
i The affidavit, Safety Evaluation, and No Significant Hazards Consideration Determination required for the proposed change, and the proposed revised pages of the Technical Specifications
- and associated bases are included as attachments 1 through 4 to this letter. In addition, copies of
- the typical Core Opciating Limits Report for Unit 1 Cycle 9 and Unit 2 Cycle 7 are attached (see attachments 5 and 6).
The South Texas Pmject has reviewed the attached proposed amendment pursuant to 10CFR50.92 and determined that it does not involve a significant hazards consideration. In
- addition, there is no significant increase in the amounts of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure. Consequently, the proposed amendment satisfies the criteria of 10CFR51.22(c)(9) for categorical exclusion from the requirement for an environmental assessment.
- The South Texas Project Nuclear Safety Review Board has reviewed and approved the proposed change.
In accordance with 10CFR50.91(b), the South Texas Project is providing the State of Texas with a copy of this proposed amendment.
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. If there am any questiow, conceming this matter, please call either Mr S. M. Head at (512) 972-7136 or me at (512) 9 2-8787.
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- Attachments:
1 1." Affidavit
. 2. Safety Evaluation :
- 3. No Significant Hazards Consideration Determination
- 4. Proposed Changes to Technical Specifications '
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- 5. Typical Unit 1 Cycle 9 Core Operating Limits Report
- 6. Typical Unit 2 Cycle 7 Core Operating Limits Report i
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L NOC-AE-000471 File No.: G20.02.01 G21.02.01 Page 4 cc:
Ellis W.-Merschoff ;
Jon C. Wood
' Regional Administrator, Region IV Matthews & Branscomb U. S. Nuclear Regulatory Commission One Alamo Center 611 Ryan Plaza Drive, Suite 400 106 S. St. Mary's Street, Suite 700
-Arlington, TX 76011-8064 San Antonio,TX 78205-3692
- Thomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13H3 Operations - Records Center U. S. Nuclear Regulatory Commission 700 Galleria Parkway
., Washington, DC 20555-0001.
Atlanta, GA 30339-5957 Cornelius F. O'Keefe-Richard A~ Ratliff Sr. Resident Inspector.
Bureau of Radiation Control
- c/o U. S. Nuclear Regulatory Commission -
Texas Depanment of Health '
P. O. Box 910 1100 West 49th Street l
r Bay City, TX 77404-0910 Austin, TX 78756-3189 i
1 R. Newman, Esquire D. G. Tees /R. L. Balcom
, Morgan, Lewis & Bockius Houston Lighting & Power Co.
1800 M. Street, N.W.
P. O. Box 1700 J
Washington, DC 20036-5869 Houston,TX 77251 j
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= M. T. Hardt/W. C. Gunst.
Central Power and Light Company
- City Public Service A1TN
- G. E. Vaughn/C. A. Johnson P. O. Box 1771 P. O. Box 289, Mail Code: N5012 San Antonio,TX 782%
Wadswonh,TX 77483 -
. A; Ramirez/C. M. Canady--
U. S. Nuclear Regulatory Commission L
City of Austin.
Attention: Document Control Desk l
Electric Utility Department Washington, D.C. 20555-0001 l-721 Badon Springs Road l
Austin, TX - 78704 ~
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NOC-AE-000471 Page 1 of 2 l
ATTACHMENT 1 AFFIDAVIT j
pq-NOC-AE-000471 Page 2 of 2 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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STP Nuclear Operating
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Docket Nos.
50-498 Company, et al.,
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50-499
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South Texas Project
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Units 1 and 2
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AFFIDAVIT I, T. H. Cloninger, being duly sworn, hereby depose and say that I am Vice President, Generation, of STP Nuclear Operating Company; that I am duly authorized to sign and file with the Nuclear Regulatory Commission the attached proposed operating license amendment; that I am familiar with the content thereof; and that the matters set forth therein are true and correct to the best of my knowledge and belief.
JN m
.IUClonin r ice Presid t,
Generation STATE OFTEXAS
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COUNTY OF MATAGORDA
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Subscribed and sworn to before me, a Notary Public in and for the State of Texas, this i E day of 3on(
,1999,
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OCT.b,2001 l
Notary Public in and for the V
State of Texas I
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ATTACHMENT 2 SAFETY EVALUATION I
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g NOC-AE-000471 Page 2 of 4 SAFETY EVALUATION BACKGROUND
SUMMARY
In 1988, the Nuclear Regulatory Commission issued Generic I2tter 88-16, entitled " Removal of Cycle-specific Parameter Limits from Technical Specifications." The purpose of the Generic Ietter was to provide guidance for the removal of cycle-specific parameter limits from the Technical Specifications, because processing cycle-specific limit changes was an unnecessary burden on both licensees and the NRC. The Generic 12tter was intended to apply to those Technical Specification changes that were developed with NRC-approved methodologies. To support removal of the cycle-specific parameter limits, the Generic Letter recommended that cycle-specific parameter limit values be placed in a " Core Operating Limits Report" (COLR) thereby eliminating the need for many reload license amendments. The COLR would be submitted to the NRC to allow continued trending of this information even though NRC approval of these limits would not be required.
In response to Generic letter 88-16, the Westinghouse Owners Group (WOG) authorized the development of a generic COLR License Amendment Request package forWestinghouse plants.
DESCRIPTION OF PROPOSED CHANGE This amendment request proposes that the cycle-specific Reactor Coolant System-related Technical Specification parameter limits be relocated to the Core Operating Limits Report. This change will allow the South Texas Project the flexibility to enhance plant operating margin and/or core design margins without the need for cycle-specific license amendment requests. The Technical Specification Changes include:
- 1. Revising Technical Specification 2.1," Safety Limits," and the associated bases to replace figures 2.1-1 and 2.1-2 (Reactor Core Safety Limit) with more specific requirements regarding the safetylimits.
- 2. Revising Technical Specification 2.2," Limiting Safety System Settings," and the associated bases to miocate the Overtemperature AT (OTDT) and Overpower AT (OPDT) setpoint parameter values to the Core Operating Limits Repon. In addition, the Reactor Coolant Loop Flow-Low loop. design flow value from Technical Specification 2.2.1, Table 2.2-1, is being moved to the Core Operating Limits Repon to be consistent with the flow assumed in the safety analysis.
- 3. Revising Technical Specification 3.2.5," Departure from Nucleate Boiling (DNB)
Parameters," to relocate the pressurizer pressure, and Reactor Coolant System average temperature (Tog) to the Com Operating Limits Report. The minimum measured flow is being moved from the Technical Specifications to the Com Operating Limits Report.
Technical Specification 3.2.5 now repons the Thermal Design Flow.
- 4. Revising Technical Specification 6.9.1.6, " Core Operating Limits Repon," to reflect the relocations to the COLR and to add appropriate references.
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Page 3 of 4 SAFETY EVALUATION -
L The methodologies for calculating these parameters have been approved by the NRC (Safety Evaluation relating to Topical Report WCAP-14483-A, " Generic Methodology for Expanded l
~ Core Operating Limits Report," approved January 19,1999) and are consistent with the applicable limits in the Updated Final Safety Analysis Report. The current Technical Specification method for controlling reactor physics parameters to assure conformance to
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- 10CFR50.36 (which requims the lowest functional levels acceptable for continued safe operation) is to specify the values determined to be within the acceptance criteria using an NRC-
. approved calculation methodology. If approved, the proposed amendment will not alter the input parameters or the methodologies for calculating these limits.
Removal of cycle-dependent variables from the Technical Specifications has no impact upon plant operations 'or safety. No safety-related equipment, safety function, or plant operations will be altered as a result of this proposed change. The safety limits imposed in Technical' Specification 2.1.1.1 and 2.1.1.2 are consistent with the values stated in the STP Updated Final Safety Anaylsis Report. Because applicable FSAR limits will be maintained, and Technical Specifications will contin"e to require operation within the core operational limits calculated by
. the approved methodolor
, this proposed change is administrative in nature, and does not affect ~
. the purpose of the Tech i Specifications involved. Appropriate actions to be taken if the limits are violated will main in the Technical Specifications.'
The Reactor Coolant System Flow value in the Technical Specifications will be changed from the Minimum Measured Flow to the Thermal Design Reactor Coolant System Flow, approved by the Nuclear Regulatory Commission in Amendments 97 and 84 on September 29,1998, and which is consistent with WCAP-14483-P-A.
This proposed change will control the cycle-specinc parameters within the acceptance criteria and assure conformance to 10CFR50.36 by using the approved methodology instead of specifying Technical Specification values. The COLR will document the specific parameter limits resulting from NRC-approved calculations, including mid-cycle or other revisions to parameter values. Therefore, the proposed change is in conformance with the requirements of 10CFR50.36.
Any changes to the COLR will be made in accordance with the requirements of 10CFR50.59 with a copy of the revised COLR sent to the NRC as required in section 6.9.1.6 of the Technical Specifications.' From cycle to cycle, the COLR will be revised such that the appropriate core
. operating limits for the applicable unit and cycle will apply.
- CONCLUSION The relocation of selected Reactor Coolant System related technical specification limits to the Core Operating Limits Report will allow STP to present cycle-specific operating condition parameters in the COLR.' Thus, the safety analyses could credit the actual cycle-specific operating configuration,
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as is currently done to the core reload designs. This approach is supported by existing NRC-approved reload methodologies, such as the Westinghouse reload methodology (WCAP-9272-P-A) j which examines each of the DNB Parameter Technical Specification limits of Reactor Coolant i
System Tng, Reactor Coolant System total flow rate and pressurizer pressure as well as the OTDT and OPDT setpoints and the supporting bases for the setpoints, on a cycle-specific basis. Relocating these technical specification limit parameter values to the COLR, consistent with what has been accomplished for the core-related parameters curmntly in the COLR, will allow STP the flexibility to 3
utilize available margins to increase cycle operating margins and/or improve core reload designs. It will also bring consistency to the technical specifications, the safety analyses, and how the plant control and protection systems are set for each cycle. In addition, STP will conserve resources by reducing the number of license amendment submittals and the need for associated NRC reviews.
IMPLEMENTATION j
The South Texas Project requests that this amendment be approved by October 1,1999, and that j
- the effective date be 30 days after approval by the Nuclear Regulatory Commission.
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ATTACHMENT 3 u
N'O SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i
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'NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION.
Pursuant to 10CFR50.91, this analysis provides a determination that the proposed change to the Technical Specifications does not involve any significant hazards consideration as defined in
, '10CFR50.92 :
The; proposed. change does not involve a significant inc'rease in the probability or consequences of an accident previously evaluated, iThe proposed amendment is a pmgrammatic and administrative change that does not physically
-alter safety-nlated systems, nor does it affect the way in which safety-related systems perform -
'their functions., Because the design of the facility and system operating parameters are not being :
changed, the, proposed amendment does not involve an increase in the probability or consequences of any accident previously evaluated.
The cycle-specific limits in the Coie Operating Limits Report will continue to be controlled by
,the STP programs and procedures. Each accident analysis addressed in the UFSAR will be examined.with' respect to changes in the cycle-dependent parameters, which am obtained from
? the use of NRC-approved mload design methodologies, to ensure that the transient evaluation of new reloads are bounded by previously. accepted analyses. This examination, which will be conducted per the requirements of 10CFR50.59, will ensure that future mioads will not involve a significant increase in the probability or consequences of an accident previously evaluated.
LThe safety limits imposed in Technical _ Specification 2.1.1.1 and 2.1.1.2 are consistent with the
. values stated in the STP Updated Final Safety Analysis Repon. The Reactor Coolant System.
Flow value in the Technical Specifications will be changed from the Minimum Measured Flow to the Thermal l Design System-Flow (approved by the Nuclear Regulatory Commission in
- Amendments 97 and 84 on September 29,1998) consistent with WCAP-14483-P-A. This change
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?does not involve an increase in the probability or consequences of any accident pmviously evaluated.
- The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Removal of the cycle specific variables has'no influence or impact on, nor does it contribute in any way to the probability or consequences of an aceident. ~ No safety-related equipment, safety function, or plant operation will be altered as a result of this proposed change. The' cycle specific variables am calculated using the'NRC-approved methods, and submitted to the NRC to allow the taff'to continue to tmnd the values of these limits. The Technical Specifications will
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. continue to require operation within'the com operating limits, and appropriate actions will be
_ requimd if these limits am exceeded. The safety limits imposed in Technical Specification 2.1.1.1 g
p and 2.1.1.2 are consistent with the values stated in the STP Updated Final Safety Analysis t
Repon. The Reactor Coolant System Flow value in the Technical Specifications will be changed
^ from;the Minimum' Measured Flow to the Thermal Design System Flow (appmved by the l:
Nuclear Regulatory Commission in Amendments 97 and 84 on September 29,1998) consistent
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L, Attcchment 3 NOC-AE-00M71 Page 3 of 3 with WCAP-14483-P-A. This proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
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. The proposed change does not involve a significant reduction in a margin of safety.
. The margin of safety is not affected by the removal of cycle specific core operating limits from the Technical Specifications. The margin of safety presently provided by current Technical q
Specifications remains unchanged. Appropriate measures exist to control the values of these cycle specific limits. The proposed amendment continues to mquire operation within the core j
limits as obtained from NRC-approved reload design methodologies, and the actions to be taken if a limit is exceeded remain unchanged.
1 The development of the limits for future reloads will continue to conform to those methods j
described in NRC-approved documentation. In addition, each future reload will involve a
' 10CFR50.59 safety review to assure that operation of the unit within the cycle-specific limits will not involve a significant mduction in the margin of safety.
The safety limits imposed in Technical Specification 2.1.1.1 and 2.1.1.2 are consistent with the 4
values stated in the STP Updated Final Safety Analysis Report. The Reactor Coolant System Flow value in the Technical Specifications will be changed from the Minimum Measured Flow to the Thermal Design System Flow (approved by the Nuclear Regulatory. Commission in Amendments 97 and 84 on September 29, 1998) consistent with WCAP-14483-P-A. This proposed change does not involve a significant reduction in the margin of safety.
The proposed amendment is a programmatic and administrative change that provides assurance that plant operations' continue to be. conducted in a safe manner. As stated previously, the proposed amendment does not physically alter safety-related systems, nor does it affect the way in which safety-related systems perform their functions. Because the design of the facility and system operating parameters are not being changed, the pmposed amendment does not involve a significant reduction in the margin of safety.
Conclusion Based on the information presented above, the proposed change does not involve a significant hazards consideration and will not have a significant effect on the safe operation of the plant as previously analyzed. Therefore, there is reasonable assurance that operation of the South Texas Project in accordance with the proposed revised Technical Specification will not endanger the public health and safety, r
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