NRC-2004-0011, Supplement 1 to License Amendment Request 236 Pressure Temperature Limits Report

Supplement 1 to License Amendment Request 236 Pressure Temperature Limits Report

ML040340654
Person / Time
Site:	Point Beach
Issue date:	01/26/2004
From:	Vanmiddlesworth G Nuclear Management Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NRC-2004-0011, TAC MC0873, TAC MC0874
Download: ML040340654 (9)

Text

NMC Committed to Nuclear Excellence Point Beach Nuclear Plant Operated by Nuclear Management Company, LLC January 26, 2004 NRC 2004-0011 10 CFR 50.67 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington DC 20555 Point Beach Nuclear Plant, Units 1 and 2 Dockets 50-266 and 50-301 License Nos. DPR-24 and DPR-27 Supplement 1 to License Amendment Request 236 Pressure Temperature Limits Report (TAC Nos. MC0873 and MC0874)

Reference:

1) Letter from NMC to NRC dated September 26, 2003 (NRC 2003-0091)

In reference 1, Nuclear Management Company, LLC (NMC), submitted a request for NRC review and approval of certain exemptions, which would allow use of the Master Curve methodology for determining the adjusted RTNDT (reference nil-ductility temperature) of the Point Beach Nuclear Plant (PBNP) Unit 2 reactor vessel limiting circumferential weld metal. This method is used for the Pressurized Thermal Shock (PTS) screening evaluation.

In association with the request for exemptions to support the Master Curve methodology, a revised reference in PBNP Technical Specification (TS) 5.6.5, "Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)", was also submitted. The proposed amendment would modify TS 5.6.5, to add a reference to the issuance date of the NRC safety.evaluation accepting the new Master Curve Methodology for Unit 2.

The amendment proposed in reference 1 was consistent with changes made to NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Technical Specification Task Force TSTF- 419, Revision 0, "Revise PTLR Definition and References in ISTS 5.6.6, RCS PTLR".

As discussed during a conference call between NRC staff and NMC personnel on December 10, 2003, the NRC staff requested that a statement from the Reviewer's Notes in TSTF-419 be added to PBNP TS 5.6.5.

6590 Nuclear Road

• Two Rivers, Wisconsin 54241 0I l Telephone: 920.755.2321

Document Control Desk Page 2 Therefore, NMC is submitting this supplement, to License Amendment Request 236, to incorporate the requested statement. This submittal provides revisions to PBNP TS 5.6.5, which replace the originally proposed revisions.

Enclosure I to this letter provides a supplemental description, justification, and a significant hazards determination for the revised change. Enclosure II provides the existing Technical Specifications page marked up to show the revised change.

Enclosure III provides the revised (clean) Technical Specifications page.

NMC requests approval of the proposed license amendment by June 2004, with the amendment being implemented within 60 days. This proposed license amendment supports the PBNP license renewal application that is planned for submittal to NRC in February 2004.

This supplement contains no new commitments.

In accordance with 10 CFR 50.91, a copy of this application, with enclosures, is being provided to the designated Wisconsin Official.

I declare under penalty of perjury that the foregoing is true and accurate. Executed on January 26, 2004.

Gary D. Van Middlesworth Site Vice-President, Point Beach Nuclear Plant Nuclear Management Company, LLC

Enclosures:

I Description and Assessment of Change 11 Proposed Technical Specification Change III Revised Technical Specification Pages cc: Regional Administrator, Region IlIl, USNRC Project Manager, Point Beach Nuclear Plant, NRR, USNRC NRC Resident Inspector - Point Beach Nuclear Plant PSCW

ENCLOSURE I SUPPLEMENTAL DESCRIPTION AND ASSESSMENT OF CHANGE SUPPLEMENT 1 TO LICENSE AMENDMENT REQUEST 236 TECHNICAL SPECIFICATION LCO 5.6.5, "REACTOR COOLANT SYSTEM (RCS)

PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)"

POINT BEACH NUCLEAR PLANT, UNITS I AND 2

1.0 DESCRIPTION

This proposed Supplement to License Amendment Request (LAR) 236 is made pursuant to 10 CFR 50.90 to modify Technical Specifications (TS) 5.6.5, "Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)".

2.0 BACKGROUND

NMC originally requested that the PBNP TS be modified consistent with the changes described in the staff approved IndustrylTSTF Standard TS Change, TSTF419 Revision 0 (TSTF-419), "Revise PTLR Definition and References in ITS 5.6.6, RCS PTLR". TSTF-419 was approved by the NRC on March 21, 2002.

During a conference call between NRC staff and NMC personnel on December 10, 2003, the NRC staff requested that a statement from the Reviewer's Notes in TSTF419 be added to PBNP TS 5.6.5. Therefore, NMC is submitting this supplement to License Amendment Request 236 to incorporate the requested statement.

NRC Generic Letter 96-03, "Relocation of the Pressure Temperature Limit Curves and Low Temperature Overpressure Protection System Limits", dated January 31, 1996, allows licensees to relocate the pressure temperature (P/T) limit curves from their plant TS to a PTLR or a similar document. The methodology used to determine the P/T and low temperature overpressure (LTOP) system limit parameters must comply with the specific requirements of Appendices G and H to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR), be documented in an NRC approved topical report or an NRC approved plant-specific submittal, and be incorporated by reference into the TS.

Subsequent changes in the methodology must be approved by a license amendment.

Page 1 of 3

3.0 DESCRIPTION

OF CHANGE Summary of Proposed Technical Specifications Change:

NMC proposes to modify TS 5.6.5, "Reactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)", to add a reference to the issuance date of the NRC safety evaluation accepting the new Master Curve Methodology for PBNP Unit 2. The formatting of the specification is also being revised to comport to TSTF-419. Additionally, the following statement is also proposed for addition to TS 5.6.5.

The PTLR will contain the complete identification for each of the topical reports used to prepare the PTLR (i.e., report number, title, revision, date, and any supplements).

4.0 ASSESSMENT This amendment request is consistent with TSTF-419, meeting the requirements in TS 5.6.5, to identify either the topical report(s) by number and title or the NRC safety evaluation for a plant specific methodology by NRC letter and date. The NRC letters currently referenced in TS 5.6.5 are those dated October 6, 2000 and July 23, 2001. For PBNP Unit 2 only, this proposed amendment would add a reference to the NRC letter that will be issued accepting the new Master Curve Methodology. The NRC exemption dated October 6, 2000 and NRC safety evaluation dated July 23, 2001, will continue to remain applicable to both PBNP Units. The added statement is consistent with the Reviewers Note in TSTF-419.

The details of the proposed change and the justification for the finding of no significant hazards are provided in this enclosure. Enclosures II and IlIl provide the revisions to the affected TS pages.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Determination In accordance with the requirements of 10 CFR 50.90, Nuclear Management Company, LLC (NMC) (licensee) hereby requests a supplemental amendment to facility operating licenses DPR-24 and DPR-27, for Point Beach Nuclear Plant (PBNP), Units 1 and 2, respectively. The purpose of the proposed amendments is to revise TS 5.6.5, MReactor Coolant System (RCS) Pressure and Temperature Limits Report (PTLR)", to add the reference of the NRC Safety Evaluation letter accepting the new Master Curve Methodology for PBNP Unit 2 and a statement regarding topical report references in the PTLR.

Page 2 of 3

NMC has evaluated the proposed amendment in accordance with 10 CFR 50.91 against the standards in 10 CFR 50.92 and has concluded that the No Significant Hazards Determination provided in the original September 26, 2003 submittal, remains applicable to this supplement.

5.2 Applicable Regulatory Requirements The Applicable Regulatory Requirements provided in the original September 26, 2003 submittal, remain applicable to this supplement.

5.3 Commitments There are no actions committed to by NMC in this supplemental License Amendment Request.

6.0 ENVIRONMENTAL EVALUATION NMC has determined that this supplement does not involve a significant hazards consideration, authorize a significant change in the types or total amounts of effluent release, or result in any significant increase in individual or cumulative occupational radiation exposure. Therefore, we conclude that the proposed amendment meets the categorical exclusion requirements of 10 CFR 51.22(c)(9) and that an environmental impact appraisal need not be prepared.

Page 3 of 3

ENCLOSURE II PROPOSED TECHNICAL SPECIFICATION CHANGES SUPPLEMENT I TO LICENSE AMENDMENT REQUEST 236 TECHNICAL SPECIFICATION LCO 5.6.5, "REACTOR COOLANT SYSTEM (RCS)

PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)"

POINT BEACH NUCLEAR PLANT, UNITS I AND 2 MARKUP TS PAGE:

TS 5.6-5

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, hydrostatic testing, LTOP enabling, and PORV lift settings as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

(1) LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits" (2) LCO 3.4.6, "RCS Loops-MODE 4" (3) LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled" (4) LCO 3.4.10, "Pressurizer Safety Valves" (5) LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP)"

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

M NRC Letters dated October 6, 2000 asn (2) NRC Letter dated July 23, 2001 (3) NRC Letter dated , 20041 (Unit 2 only)

The PTLR will contain the complete identification for each of the topical reports used to prepare the PTLR (i.e., report number, title, revision, date, and any supplements).

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.6 PAM Report When a report is required by Condition B or G of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report Abnormal conditions observed during testing will be evaluated to determine the effect of such conditions on containment structural integrity. This evaluation should be completed within 30 days of the identification of the condition. Any condition which is determined in this evaluation to have a significant adverse effect on containment structural integrity will be considered an abnormal degradation of the containment structure.

Point Beach 5.6-5 Unit 1 - Amendment No. 207-Unit 2 - Amendment No. 24-2

ENCLOSURE III PROPOSED TECHNICAL SPECIFICATION CHANGES SUPPLEMENT 1 TO LICENSE AMENDMENT REQUEST 236 TECHNICAL SPECIFICATION LCO 5.6.5, "REACTOR COOLANT SYSTEM (RCS)

PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)"

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 REVISED TS PAGE:

TS 5.6-5

-~~ ~ ~ ~~RprigRqieet Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, hydrostatic testing, LTOP enabling, and PORV lift settings as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

(1) LCO 3.4.3, -RCS Pressure and Temperature (PIT) Limits" (2) LCO 3.4.6, -RCS Loops-MODE 4" (3) LCO 3.4.7, URCS Loops-MODE 5, Loops Filled" (4) LCO 3.4.10, 'Pressurizer Safety Valves" (5) LCO 3.4.12, 'Low Temperature Overpressure Protection (LTOP)"

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

(1) NRC Letter dated October 6, 2000 (2) NRC Letter dated July 23, 2001 (3) NRC Letter dated , 2004 (Unit 2 only)

The PTLR will contain the complete identification for each of the topical reports used to prepare the PTLR (i.e., report number, title, revision, date, and any supplements).

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supplement thereto.

5.6.6 PAM Renort When a report is required by Condition B or G of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.7 Tendon Surveillance Report Abnormal conditions observed during testing will be evaluated to determine the effect of such conditions on containment structural integrity. This evaluation should be completed within 30 days of the identification of the condition. Any condition which is determined in this evaluation to have a significant adverse effect on containment structural integrity will be considered an abnormal degradation of the containment structure.

Point Beach 5.6-5 Unit 1 - Amendment No.

Unit 2 - Amendment No.