NRC Generic Letter 1988-16
| ML031200485 | |
| Person / Time | |
|---|---|
| Issue date: | 10/04/1988 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| GL-88-016, NUDOCS 8810050058 | |
| Download: ML031200485 (10) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555 OCT 0 4 098 TO ALL POWER REACTOR LICENSEES AND APPLICANTS
SUBJECT: REMOVAL OF CYCLE-SPECIFIC PARAMETER LIMITS FROM TECHNICAL
SPECIFICATIONS (GENERIC LETTER 88-16)
update the values License amendments are generally required each fuel cycle to (TS). The of cycle-specific parameter limits in Technical Specifications using an NRC-approved method- processing of changes to TS that are developed A lead-plant ology is an unnecessary burden on licensee and NRC resources.
amendment proposal for an alternative that eliminates the need for a license was submitted to update the cycle-specific parameter limits each fuel cycle Wilcox Owners for the Oconee plant with the endorsement of the Babcock and proposal, the en- Group. On the basis of the NRC review and approval of that for this closed guidance for the preparation of a license amendment request alternative was developed by the NRC staff.
limits is Generally, the methodology for determining cycle-specific parameter submittal.
documented in an NRC-approved Topical Report or in a plant-specific for these limits As a consequence, the NRC review of proposed changes to TS are calculated is primarily limited to confirmation that the updated limits with all applicable limits using an NRC-approved methodology andconsistent to trend the of the safety analysis. These changes also allow the NRC staff experience. This alternative allows values of these limits relative to past NRC review continued trending of these limits without the necessity of prior and approval.
TS that are Licensees and applicants are encouraged to propose changes to amendments consistent with the guidance provided in the enclosure. Conforming by the NRC Project Manager for the facility.
will be expeditiously reviewed a longer, more Proposed amendments that deviate from this guidance will require questions on detailed review. Please contact the Project Manager if you have this matter.
Sincerely, Dennis M. Crutchfiel Acting Associate Di ctor for Projects Office of Nuclear Reactor Regulation Enclosure:
As stated
Enclosure Generic Letter 88-16 GUIDANCE FOR TECHNICAL SPECIFICATION CHANGES
FOR CYCLE-SPECIFIC PARAMETER LIMITS
INTRODUCTION
associated with A number of Technical Specifications (TS) address limits change with each reload core, requir- reactor physics parameters that generally each fuel cycle.
ing the processing of changes to TS to update these limits NRC-approved methodology, the license If these limits are developed using an and the NRC. An amendment process is an unnecessary burden on the licensee parameters in in- alternative to including the values of these cycle-specific industry and NRC
dividual specifications is provided and is responsive to efforts on improvements in TS.
license amendment This enclosure provides guidance for the preparation of a An acceptable request to modify TS that have cycle-specific parameter limits.
of cycle-specific parameter limits in TS
alternative to specifying the values proposal was developed on the basis of the review and approval of a lead-plantof this for this change to the TS for the Oconee units. The implementation and the NRC by alternative will result in a resource savings for the licenseeschanges in values of eliminating the majority of license amendment requests on cycle-specific parameters in TS.
DISCUSSION
the plant's TS:
This alternative consists of three separate actions to modifythat includes the
(1) the addition of the definition of a named formal report using an values of cycle-specific parameter limits that have been established limits of the safe- NRC-approved methodology and consistent with all applicable requirement to sub- ty analysis, (2) the addition of an administrative reporting the Commission for mit the formal report on cycle-specific parameter limitsto tonote that cycle- information, and (3) the modification of individual TS in the specific parameters shall be maintained within the limits provided defined formal report.
that it is In the evaluation of this alternative, the NRC staff concludedbounds of cycle- essential to safety that the plant is operated within the the plant within specific parameter limits and that a requirement to maintain the specific the appropriate bounds must be retained in the TS. However, affecting nuclear values of these limits may be modified by licensees, without NRC-approved method- safety, provided that these changes are determined using an safety analysis ology and consistent with all applicable limits of the plant Additionally, that are addressed in the Final Safety Analysis Report (FSAR).to NRC with the it was concluded that a formal report should be submitted of this information, values of these limits. This will allow continued trending would not be even though prior NRC approval of the changes to these limits required.
to assure conform- The current method of controlling reactor physics parametersdetermined to be with- ance to 10 CFR 50.36 is to specify the specific value(s) analyses)
the safety in specified acceptance criteria (usually the limits of contained in this using an approved calculation methodology. The alternativeand assures conform- guidance controls the values of cycle-specific parameters functional ance to 10 CFR 50.36, which calls for specifying the lowest
- 2 - Enclosure Generic Letter 88- 16 by specifying the performance levels acceptable for continued safe operation, operation at any calculation methodology and acceptance criteria. This permits methodology, to specific value determined by the licensee, using the specified Report will docu- be within the acceptance criteria. The Core Operating Limits licensee's calcula- ment the specific values of parameter limits resulting fromvalues.
tions including any mid-cycle revisions to such parameter A defined The following items show the changes to the TS for this alternative. as an example for used formal report, "Core Operating Limits Report" (the name section of the the title for this report), shall be added to the Definitions TS, as follows.
[CORE] OPERATING LIMITS REPORT document
1.XX The [CORE] OPERATING LIMITS REPORT is the unit-specific reload that provides [core] operating limits for the current operating shall be determined cycle. These cycle-specific [core] operating limits Plant for each reload cycle in accordance with Specification 6.9.X.
operation within these operating limits is addressed in individual specifications.
existing reporting A new administrative reporting requirement shall be added to requirements, as follows.
[CORE] OPERATING LIMITS REPORT
[6.9.J] [Core] operating limits shall be established and documented in the
[CORE] OPERATING LIMITS REPORT before each reload cycle or any remaining specifications that part of a reload cycle. (If desired, the individual analytical methods address [core] operating limits may be referenced.) The be those previously re- used to determine the [core] operating limits shall by number, viewed and approved by NRC in [identify the Topical Report(s)
report for a title, and date, or identify the staff's safety evaluation operating plant-specific methodology by NRC letter and date]. The [core]
limits (e.g., fuel therm- limits shall be determined so that all applicable nuclear ECCS limits, al-mechanical limits, core thermal-hydraulic limits, analysis limits)
limits such as shutdown margin, and transient and accident OPERATING LIMITS REPORT, in- of the safety analysis are met. The [CORE] shall be provided cluding any mid-cycle revisions or supplements thereto, Desk with upon issuance, for each reload cycle, to the NRC Document Control copies to the Regional Administrator and Resident Inspector.
values of cycle- Individual specifications shall be revised to state that the identified in the specific parameters shall be maintained within the limits for individual specifications defined formal report. Typical modifications are as follows.
operating The regulating rods shall be positioned within the acceptable OPERATING LIMITS
range for regulating rod position provided in the [CORE]
covers a range of acceptable REPORT. (Used where the operating limit operation, typically defined by a curve.)
in the The [cycle-specific parameter] shall be within the limit provided limit has a
[CORE] OPERATING LIMITS REPORT. (Used where the operating single point value.)
- 3 - Enclosure Generic Letter 88-16 SUMMARY
parameter limits in The alternative to including the values of cycle-specific new defined term for individual specifications includes (1) the addition of a limits, (2) the the formal report that provides the cycle-specific parameter Controls addition of its associated reporting requirement to the Administrative specifications to re- section of the TS, and (3) the modification of individual report for the values place these limits with a reference to the defined formal amendments for the of these limits. With this alternative, reload license be unnecessary.
sole purpose of updating cycle-specific parameter limits will
Enclosure LETTERS
LIST OF RECENTLY ISSUED GENERIC
Date of Generic Issuance Issued To Letter No. Subject
09/12/88 ALL POWER REACTOR
88-15 ELECTRIC POWER SYSTEMS - APPLICANTS
INADEQUATE CONTROL OVER
DESIGN PROCESSES
08/08/88 ALL HOLDERS OF
AIR SUPPLY 08/08/88
88-14 INSTRUMENT OPERATING LICENSES
SYSTEM PROBLEMS AFFECTING OR CONSTRUCTION
SAFETY-RELATED EQUIPMENT PERMITS FOR NUCLEAR
POWER REACTORS
08/08/88 ALL POWER REACTOR
88-13 OPERATOR LICENSING LICENSEES AND
EXAMINATIONS APPLICANTS FOR
AN OPERATING LICENSE.
08/02/88 ALL POWER REACTOR
88-12 REMOVAL OF FIRE PROTECTION LICENSEES AND
REQUIREMENTS FROM TECHNICAL APPLICANTS
SPECIFICATIONS
07/12/88 ALL LICENSEES OF
88-11 NRC POSITION ON RADIATION OPERATING REACTORS
EMBRITTLEMENT OF REACTOR AND HOLDERS OF
VESSEL MATERIALS AND ITS CONSTRUCTION PERMITS
IMPACT ON PLANT OPERATIONS
07/01/88 ALL POWER REACTOR
88-10 PURCHASE OF GSA APPROVED LICENSEES AND
SECURITY CONTAINERS HOLDERS OF PART 95 APPROVALS
05/17/88 ALL LICENSEES OF ALL
88-09 PILOT TESTING OF FUNDAMENTALS BOILING WATER REACTORS
EXAMINATION AND APPLICANTS FOR A
BOILING WATER REACTOR
OPERATOR'S LICENSE
UNDER 10 CFR PART 55
05/03/88 ALL LICENSEES FOR POWER
88-08 MAIL SENT OR DELIVERED TO AND NON-POWER REACTORS
THE OFFICE OF NUCLEAR REACTOR AND HOLDERS OF
REGULATION CONSTRUCTION PERMITS
FOR NUCLEAR POWER
REACTORS
04/07/88 ALL POWER REACTOR
88-07 MODIFIED ENFORCEMENT POLICY LICENSEES AND
RELATING TO 10 CFR 50.49, APPLICANTS
"'ENVIRONMENTAL QUALIFICATION
OF ELECTRICAL EQUIPMENT
IMPORTANT TO SAFETY FOR
NUCLEAR POWER PLANTS"
UNITED STATES
Enclosure 2 NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C. 20555
0*+
MEMORANDUM FOR: Sholly Coordinator FROM: [ ], Director PWR, Project Directorate No.
Division of PWR Licensing-A
SUBJECT: REQUEST FOR PUBLICATION IN BIWEEKLY FR NOTICE -
NOTICE OF CONSIDERATION OF ISSUANCE OF AMENDMENT
TO FACILITY OPERATING LICENSE AND PROPOSED NO
SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION AND
OPPORTUNITY FOR A HEARING
[Utility Name], Docket No. STN 50-f 1, [Plant Name, Unit(s) #]
[County], [State]
Date of application for amendment:
Description of amendment request: The proposed amendment would revise Technical Specifications 3/4. _ , 3/4. , and 3/4. of Appendix A of that a refer- license to replace the values of cycle-specific parameter limits with of those ence to the [Core] Operating Limits Report, which contains the values in limits. In addition, the [Core] Operating Limits Report has been included that it is the Definitions Section of the Technical Specifications (TS) to note operating the unit-specific document that provides these limits for the current of these reload cycle. Furthermore, the definition notes that the values with the cycle-specific parameter limits are to be determined in accordance Specification 6.9. . This Specification requires that the [Core] Operating Limits be determined for each reload cycle in accordance with the referenced NRC-apporved methodology for these limits and consistent with the applicable revis- limits of the safety analysis. Finally, this report and any mid-cycle
, dated ions shall be provided to the NRC upon issuance. Generic Letter 88-16 for October 4, 1988, from the NRC provided guidance to licensees on requests removal of the values of cycle-specific parameter limits from TS. The licensee's proposed amendment is in response to this Generic Letter.
Sholly Coordinator - 2 -
The Basis for proposed no significant hazards consideration determination:
staff has evaluated this proposed amendment and determined that it Involves no significant hazards considerations. According to 10 CFR 50.92(c), a proposed amendment to an operating license involves no significant hazards considerations if 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.
The proposed revision to the License Condition is in accordance with the of guidance provided in Generic Letter 88-16 for licensees requesting removal of the values of cycle-specific parameter limits from TS. The establishment of these limits in accordance to an NRC-approved methodology and the incorpor- ation of of these limits into the [Core] Operating Limits Report will ensure that proper steps have been taken to establish the values of these limits.
Furthermore, the submittal of the [Core] Operating Limits Report will allow for the staff to continue to trend the values of these limits without the need prior staff approval of these limits and without introduction of an unreviewed of safety question. The revised specifications with the removal of the values for cycle-specific parameter limits and that addition of the referenced report these limits does not create the possibility of a new or different kind of accident for those previously evaluated. They also don't involve a significant reduction in the margin of safety since the change does not alter the methods used to establish these limits.
Sholly Coordinator - 3 -
Consequently, the proposed change on the removal of the values of cycle- or specific limits do not involve a significant increase in the probability consequences of an accident previously evaluated.
to be Because the values of cycle-specific parameter limits will continue with determined in accordance with an NRC-approved methodology and consistent the applicable limits of the safety analysis, these changes are administrative that in nature and do not impact the operation of the facility in a manner involves significant hazards considerations.
be The proposed amendment does not alter the requirement that the plant operated within the limits for cycle-specific parameters nor the required While it is remedial actions that must be taken when these limits are not met.
values of recognized that such requirements are essential to plant safety, the limits can be determined in accordance with NRC-approved methods without affecting nuclear safety. With the removal of the values of these limits from
[Core]
the Technical Specifications, they have been incorporated into the Operating Limits Report that is submitted to the Commission. Hence, appropriate measures exist to control the values of these limits. These changes are a
administrative in nature and do not impact the operation of the facility in manner that involves significant hazards considerations.
Based on the preceding assessment, the staff believes this proposed amendment involves no significant hazards considerations.
Local Public Document Room location:
Attorney for Licensee:
NRC Project Director:
, Director VWTF-roject Directorate No.
Division of PWR Licensing-A
a (Document Name "CYCLE SHOLLY" on 1NRC1112, Contact Pat Coates, X21183, for copy)
Enclosure 3 MODEL SAFETY EVALUATION REPORT (SER)
of the Underscored blank spaces are to be completed on the basis should be applicable facility information. The information in brackets used, as applicable, on a plant-specific basis.
REGULATION
SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR LICENSE NFP-
RELATED TO AMENDMENT NO. TO FACILITY OPERATING
AND AMENDMENT NO.__ T1-FACILITY OPERATING LICENSE NFP-_
[UTILITY NAME]
DOCKET NOS. 50- AND 50-
[PLANT NAME], OUTTS 1 AND-E
INTRODUCTION
, 1988, [utility name] (the licensee) proposed changes By letter dated Units 1 and 2. The to the Technical SpeciTTcations (TS) for [plant name]cycle-specific parameter proposed changes would modify specifications having to the [named limits by replacing the values of those limits with a reference The proposed changes plant-specific report] for the values of those limits. Definitions section also include the addition of the [named report] to the Controls section of TS.
and to the reporting requirements of the Administrative the basis of the re- Guidance on the proposed changes was developed by NRC on plant docket that was view of a lead-plant proposal submitted on the Oconee guidance was provided to endorsed by the Babcock and Wilcox Owners Group. This Letter 88-16, dated all power reactor licensees and applicants by Generic October 4, 1988.
EVALUATION
with the guidance The licensee's proposed changes to the TS are in accordance provided by Generic Letter 88-16 and are addressed below.
include a definition of
(1) The Definitions section of the TS was modified to limits the [named report] that requires cycle/reload-specific parameter with an NRC-
to be established on a unit-specific basis in accordance safety analysis.
approved methodology that maintains the limits of the is addressed The definition notes that plant operation within these limits by individual specifications.
the values of cycle-
(2) The following specifications were revised to replace [named report] that pro- specific parameter limits with a reference to the vides these limits.
[Provide list of specifications by number and title]
requirements
(3) Specification [number], [title], was added to the reporting specification of the Administrative Controls section of the TS. This to the NRC
requires that the [named report) be submitted, upon issuance, and Document Control Desk with copies to the Regional Administrator Resident Inspector. The report provides the values of cycle-specific Further- parameter limits that are applicable for the current fuel cycle. be estab- values of these limits more, this specification requires that the or NRC letter lished using the NRC-approved methodology in [Topical Report
- 2- approving a plant-specific methodology submittal] and consistent with all applicable limits of the safety analysis. Finally, the specification requires that all changes in cycle-specific parameter limits be documented in the [named report] before each reload cycle or remaining part of a reload cycle and submitted upon issuance to NRC, prior to operation with the new parameter limits.
On the basis of the review of the above items, the NRC staff concludes that the licensee provided an acceptable response to those items as addressed in the NRC
guidance in Generic Letter 88-16 on modifying cycle-specific parameter limits in TS. Because plant operation continues to be limited in accordance with the values of cycle-specific parameter limits that are established using an NRC-
approved methodology, the NRC staff concludes that this change is administra- tive in nature and there is no impact on plant safety as a consequence.
Accordingly, the staff finds the proposed changes acceptable.
ENVIRONMENTAL CONSIDERATION
These amendments involve changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assess- ment need be prepared in connection with the issuance of these amendments.
CONCLUSION
The Commission made proposed determinations that the amendments involve no significant-hazards consideration that.were published in the Federal Register
(53 FR ) on __, 1988. The Commission consulted with the State of
. R0-public comments were received, and the State of did not have any comments.
On the basis of the considerations discussed above, the NRC staff concludes that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: Daniel B. Fieno, SRXB/DEST
Thomas G. Dunning, OTSB/DOEA
, PD__/DPR_
Dated: , 1988 (Document Name "CYCLE SER" on 1NRC1112, Contact Pat Coates, X21183, for a copy)