View source for 3F1097-12, Provides Rev to LTOP Sys TS Change Request Notice 213, Including PORV Lift Setpoint TS Limit,Revised for Instrument Uncertainty.Calculation Encl

{{Adams
| number = ML20212C968
| issue date = 10/25/1997
| title = Provides Rev to LTOP Sys TS Change Request Notice 213, Including PORV Lift Setpoint TS Limit,Revised for Instrument Uncertainty.Calculation Encl
| author name = Cowan J
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F1097-12, GL-88-11, TAC-M99277, NUDOCS 9710300228
| package number = ML20212C970
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 17
| project = TAC:M99277
| stage = Other
}}

=Text=
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Florida PGwer CORPORATION Doch N 60 02 October 25,1997 3F1097-12 U. S. NucMr Regulatog Commission Attention: Document Control Desk Washington, DC 20555-0001

==Subject:==
Technical Specification Change Request Notice 213, Revision 1 (TAC No, M99277)

==References:==
: 1. FPC to NRC letter, 3F0797-10, " Technical Specification Change Request Notice 213. Revision 0," dated July 18,1997                 '
: 2. FPC to NRC letter, 3F0997-25, " Technical Specilication Change Request Notice 213, Supplement 1 (TAC No. M99277)," dated September 12,1997
: 3. NRC to FPL letter, " Crystal River Unit 3 - Request for Additional Information (RAI) Related to Proposed License Amendment for Low-Temperature Overpressure Protection Tecimical Specification (TAC No. M99277)," dated October 7,1997

==Dear Sir:==

l             Florida Power Corporation (FPC) submitted Technical Specification Change Request Notice
['            (TSCRN) 213, Revision 0, on July 18,1997 (Reference 1). The submittal proposed a new Improved Technical Specification (ITS) 3.4.11 (Low Temperature Overpressure Protection t
System, LTOPS), new Bases B 3.4.11 (LTOPS), revised ITS 3.5.3 (ECCS-Shutdown), and revised ITS Bases: B 3.4.9 (Pressurizer Safety Valves), B 3.5.2 (ECCS-Operating) and B 3.5.3 (ECCS-Shutdown) for Crystal River Unit 3 (CR-3). Reference 2 provided revised proposed Technical Specification pages 3.4-21B, B 3.4-52E and B 3.4-52H to TSCRN 213, Revision 0, and provided replacement pages 2,5, and 6 to substitute those pages in Attachment A of TSCRN 213, Revision 0, f
This letter provides a revision to LTOPS TSCRN 213 which includes the power operated relief valve (PORV) lift setpoint Technical Specification limit that has been revised for instrument l
uncertainty. This revision also includes the LTOPS Techmcal Specification enable temperature and the Pressurizer level Technical Specification limit that have been revised for instmment uncertainty
* 9710300228 971025 PDR P      ADOCK 05000302 pg                             .!b,  ,
iii  a c   .
CRYSTAL RIVER ENERGY COMPLEX 15780 W. Power Line Street Crystal River, Florida 34428-6708 * (352)795-6486 A Florida Progress Company
  ~~

U. S. Nuclear Regulatory Commission 3F1097-13 Page 2 of 6 Enclosure 1 to this letter provides FPC's response to the NRC request for additional information (RAI) (Reference 3). The revised LTOPS TSCRN 213 of this submittal serves to provide the response to the NRC RAI regarding adjustment of LTOP limits / values for instrument uncertainty.
Attachment A, as revised where margin bars appear per Reference 2 and this revision, provides the basis for, and a description of, the proposed revised TSCRN. Included with this attachment are the revised proposed Technical Specification and Bases pages. A complete set of the proposed Technical Specification and Bases page changes as revi'.ed to date, are also provided with this attachment. Attachment B provides the FPC safety analysis for the revised TSCRN. This analysis concludes that LTOP limits will protect the reactor vessel from overpressurization. The analysis which was provided in TSCRN 213, Revision 0, remains unchanged.
Reason for Revisine the Pronosed Technical Soccification and Bases Pages The PORV lift setpoint Technical Specification limit of 5 464 psig proposed by TSCRN 213.
Revision 0, was calculated to be the limiting reactor coolant system pressure for low temperature overpressure protection of the reactor vessel. The instrument corrected PORV lift l setpoint Technical Specification limit of s 457 psig is proposed by this revision to TSCRN
! 213. This revised Technical Specification limit provides additional conservatism to establish a threshold that, if exceeded, may mean the instrumentation has not periormed within the bounds of the setpoint calculation.
The LTOP enable temperature of 253 F was established by analysis performed as described in Attachment A to TSCRN 213, applying ASME Code Case N-514. The instrument corrected LTOPS Technical Specification enable temperature of s 259 F is proposed by this revision to TSCRN 213. This revised Technical Specification limit provides additional conservatism to establish a threshold that, if exceeded, could challenge the analytical limit.
The Pressurizer level limit of s 160 inches was determined as described in Attachment A to TSCRN 213, by the require. ment to provide 10 minutes for operator action during the limiting reactor coolant system transient with the PORV inoperable. The instrument corrected Pressurizer level Technical Specification limit of s 135 inches is proposed by this revision to TSCRN 213. This rev. sed Technical Specification limit provides additional conservatism to establish a threshold that, if exceeded, could challenge the analytical limit.
The basis for providing the PORV lift setpoint, enable temperature, and Pressurizer level Technical Specification limits that are corrected for instrument uncertainty is provided below:
   . The PORV lift setpoint, enable temperature, and Pressurizer level limit are corrected for uncertainties using the guidance of Instrument Society of America (ISA) - S67.04-1994 as endorsed by USNRC Regulatory Guide 1.105 (DG-1045, proposed Revision 3 to Regulatory Guide 1.105).

U. S. Nuclear Regulatory Commission 3F1097-12 Page 3 of 6 The corrected PORV lift setpoint ensures that the setpoint is initially within, and will remain within, the Technical Specification limit.
* The corrected enable temperature and Pressurizer level limit ensures that the instrumentation string for inc'ication is initially within, and will remain within, the Technical Specification limit.
* The corrected PORV lift setpoint, enable temperature, and Pressurizer level Technical Specification limits provide for additional margin and assurance that the reactor vessel is protected.
In summary, the original proposed PORV lift setpoint Technical Specification limit of 5 464 psig provided an acceptable margin to assure that the LTOP limin would not be exceeded.
The revised PORV lift setpoint Technical Specification limit of 5 457 psig provides additional conservatism to establish a threshold that, if exceeded, may mean the instrumentation has not performed within the bounds of the setpoint calculation. In addition, it ensures that the setpoint is initially within, and will remain within, the Technical Specification limit to assure that the reactor vessel is protected. Similarly, the original proposed LTOP enable temperature l            of 253 F and Pressurizer level limit of s 160 inches provided acceptable margin to assure that t-the LTOP limits would not be exceeded. The revised enable temperature Technical Specification limit of s 259"F and the revised Pressurizer level Tec!mical Specification limit of I
s 135 inches provide additional conservatism to establish a threshold that would not challenge the analytical limits. In addition, it ensures that the instrumentation string' for indication are initially within, and will remain within, the Technical Specification limit to assure that the reactor vessel . is protected. FPC concludes that the revised PORV lift setpoint, enable temperature, and Pressurizer level do not adversely impact any other TSCRN 213 requests, and that the proposed ITS Section 3.4.11 and Bases B 3.4.11 provided in TSCRN 213, as revised by this letter, do not affect the previous conclusions or the basis for the conclusions in the No Significant Hazards Consideration evaluation presented in Attachment A to TSCRN 213.
Resnonse to NRC Regttest for Additional Information Enclosure 1 to this letter provides FPC's response to the NRC RAI related to LTCPS TSCRN 213 (Refcen;.d 3). The resp <mse to RAI Item No.1 regarding adjusting LTOP limits / values for instrument uncertainties is provided as a result of submitting this revision to the CR-3 LTOPS license amendment request, TSCRN 213, Revision 1. The response to RAI Item No. 2 states that steps will be included in the plant heatup procedure to require a reactor coolant system heatup holding period of 90 minutes after the enable temperature has been exceeded and prior to exiting the LTOP Limiting Condition for Operation (LCO). This will ensure that the reactor vessel will be at steady state conditions and the vessel quarter-t lo( ion temperature will be above the enable temperature. The response to RAI Item No. 3, in Enclosure 1, also provides the available alarms and operator actions to terminate an LTOP event within 10 minutes.

U. S. Nuclear Regulatory Commission 3F1097-12 Page 4 of 6 FPC has included instrument uncertainty for the LTOPS Technical Specification limits. FPC concludes that the regulatory basis for this requirement for these LTOPS limits / values is a new interpretation and extension of Standard Review Plan 5.2.2, " Overpressure Protection," and Branch Technical Position RSB 5-2, "Overpressurization Protection of Pressurized Water Reactors While Operating at Low Temperatures " As instrument loop uncertainty calculations for Reactor Coolant System Cold Leg Temperature (Teoia) and Pressurizer level indication instrumentation are in the process of being finalized in December 1997 for the plant Setpoint Calculation Program and other issues, the instrument corrections included for these LTOPS Technical Specification limits have been conservatively calculated to be bounded by the forthcoming results of these final loop uncertainty calculations.
Other than TSCRN 213. Revision 0, as supplemented by iteference 2, this change does not affect any other proposed Technical Specification Change Request previously submitted by FPC for NRC review. FPC requests that the NRC review and approve the proposed LTOPS Technical Specification change, as revised, by November 28, 1997, and provide for a 30-day post-approval implementation period. This schedule will continue to support the current restart of CR-3. -Under the current administrative conttols for LTOP features, the reactor coolant pumps cannot be started until the proposed Technical Specification change is approved, and associated procedure changes are approved and issued.
Should you have any questions or require additional information, please contact Mr. David Kunsemiller, Manager, Nuclear Licensing at (352) 563-4566.
Sincerely, h ACJ John Paul Cowan Vice President Nuclear Production JPC/rsc/dnm/lve Attachments:
A. Technical Specification Change Request Notice 213, Revision 1 B. FPC Calculation F97-0003, ''CR-315 EFPY LTOP Limits"

==Enclosure:==
Response to NRC RAI Regarding LTOPS TSCRN 213 cc: Regional Administrator, Region II Senior Resident Inspector NRR Project Manager
            .                                                                                                   u

U. S. Nucle:r Regulatory Commission 3F1097-12 Page 5 of 6 LTOPS TSCRN 213, REVISION 1, COMMITMENT (TAC No. M99277) 3F1097-12 COMMITMENT                           L E T T E R .1 E F.      DaTE DUE Steps will be included in the plant heatup procedure to RAl Item No. 2         Prior to MODE 4 require a reactor coolant system heatup holding period      Response of 90 minutes after the enable temperature has been       (Enclosure 1) exceeded and prior to exiting the LTOP LCO.
I I

U. S. Nuclear Regulatory Commission 3F1097-12 Page 6 of 6 STATE 0F FLORIDA COUNTY OF CITRUS John Paul Cowan states that he is the Vice President, Nuclear Production for Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto, and that all such statements made and matters set forth therein are true and correct to the be" of his knowledge, information, and belief.
f/                0       \
John Paul Cowan Vice President Nuclear Production Sworn to and subscribed before me this Mday of              6C/vM              ,1997, by John Paul Cowan.
C4w&a Adle                         --
Signature of Notary Public State of Florida
___=-=---;,
i
:,      w n== = - jt (Print, type, or stamp Commissioned Name of Notary Public)
Personally y              Produced Known              -OR- Identification l

U. S. Nelear Regulatory Commission                                       LTOPS TSCRN 213, Revision 1 3F1097-12 Attachment A FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3
            - DOCKET NUMBER 50-302/ LICENSE NUMnER DPR-72 TECHNICAL SPECIFICATION CHANGE REQUEST NOTICE 213, REVISION 1                                         ;
(TAC No. M99277)                                                !
ATTACHMENT A i

U. S. Nuclear Regulatory Commissicn                                       LTOPS TSCRN 213, R; vision 1 3F1097                                                                                Attachment A Page 1 FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302/ LICENSE NUMBER DPR-72 REQUEST NOTICE 213. REVISION 1                         l LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM LICENSE DOCUMENT INVOLVED:                          Improved Technical Specifications PORTIONS: 3.4.11[NEW)                        - Low Temperature Overpressure Protection (LTOP) System 3.5.3                             - ECCS-Shutdown B3.4.9                            - Pressurizer Safety Valves 83.4.11[NEW) - Low Temperature Overpressure Protection (LTOP) System B3.5.2                            - ECCS-Operating                                            '
B3.5.3                            - ECCS-Shutdown

==SUMMARY==
OF CHANGES:
This proposed change to the Crystal River Unit 3 (CR-3) Improved Technical Specifications (ITS) incorporates a new Section 3.4.11 and a new Bases Section B3.4.11 for the reactor vessel Low Temperature Overpressure Protection (LTOP)
System. These changes are being submitted in response to NRC letter to FPC dated February 4,1997, which requested that FPC submit a proposed LTOP Technical Specification to replace the administrative controls currently used to implement LTOP features. This proposed LTOP Technical Specification has been prepared applying ASME Code Case N-514, " Low Temperature Overpressure Protection Section XI, Divi: ion 1,"
and consistent with the recommendations in NRC Generic Letter i
88-11 "NRC Position on Radiation Embrittlement of Reactor Vessel Materials and Its Impact on Plant Operations." The balance of the proposed Technical Specification changes including, Section 3.5.3 and Bases Sections B3.4.9, B3.5.2,-
and 83.5.3. have been modified to provide reference to, and-consistency with, the-proposed new LTOPS Technical Specification.
: 1. CHANGE TO SPECIFICATION 3.4.11 There is currently no LTOPS Technical Specification in the CR-3 ITS. There is an ITS Section 3.4. 1 identified in the CR-3 ITS as "Not Used." This change adds a new specification for the Reactor Coolant System for LTOP to the CR-3 Improved Technical Specifications as Section 3.4.11. The change is modeled after the standard LTOP specification in NUREG-1430. Revision 1, Improved Technical Specifications for Babcock and Wilcox (B&W) plants.
Description of Specification Chance Since there is no current L10PS Technical Specification in the CR-3 Improved Technical Specifications, this proposed change adds a new specification, 3.4.11 and associated ITS Bases, modeled after the standard technical specification for LTOPS published by the BWOG in NUREG-1430, Revision 1, Improved Technical Specifications for Babcock and Wilcox (B&W) plants.
The new Technical Specification establishes requirements for an LTOP System which shall be OPERABLE in MODE 4 when RCS temperature is s 259'F, MODE 5, and MODE 6 J

d U. S. Nucletr Regulatory Commission                      LTOPS TSCRN 213. Revision 1 3F1097-12                                                                  Attachment A Page 2
.      when the reactor vessel head is not completely detensioned. - Operation of the RCS in LTOPS condition includes the following limitations; a maximum of one Makeup pump capable of injecting into the RCS, High Pressure Injection (HPI) deactivated, the Core Flood Tanks (CFT) isolated, limiting Pressurizer water level to s 135 inches, and an OPERABLE Power Operated Relief Valve (PORV) with a lift setpoir.t of 5 457 psig. Action statements are provided for individual inoperable components or features, as well as for a condition in which the LTOPS safety function is lost (e.g., Pressurizer water level > 135 inches and the PORV l
is inoperable, or; with the LTOPS inoperable for any reason other than for the listed condition:: f0r which there=are acceptable required action statements that can be met), in which case the RCS must be depressurized and a RCS vent 2 0.75 square inch established in 12 hours.
The LTOP limits / values listed in the new LTOPS Technical Specification for the PORV lift setpoint, enable temperature, and Prtssurizer level include correction for instrument uncertainty, When LTOP analytical values associated with the
.      Technical Specification limits are discussed within this change request, they are noted by the statement, " uncorrected for instrument uncertainty." All LTOP limits / values used for plant operations will be adjusted for instrument uncertainty and placed in the plant operating procedures.
Surveillance Requirements are specified with frequencies which have been shown by operating experience at other facilities and industry accepted practice to be sufficient te regularly assess conditions for potential degradation of components I
and to verify operation within the requirements discussed above, i
The new LTOPS Technical Specification for CR-3 is consistent with the standard 2      technical specification for LTOP referenced above, and includes changes for plant specific details which are not considered to be safety significant. These changes are discussed below.
With regard to RCS temperature measurement, CR-3 takes the measurement-from a cold leg with Reactor Coolant Pumps (RCP) operating and from the-decay heat outlet when no RCPs-are operating.- With the CR-3 reactor vessel head completely
      -detensioned (i.e., the pre-stress relieved from all the studs, and the nuts free spinning), overpressurization is not possible. Therefore, LTOPS applicability includes Mode 6 without the reactor vessel head completely detensioned, i      Surveillances are included to ensure LTOP System component operability whenever entering an RCS temperature condition requiring low temperature overpressure protection of the RCS. Two LTOPS surveillance frequency requirements have bean revised, and a new surveillance has been added to verify PORV operability. CR-3 RCS vents may be other than valves (e.g. , a OTSG manway cover, or a handhole cover), and therefore, surveillance frequency requirements for RCS vents have been appropriately clarified to be for vent openings rather than for vent valves.
To preclude operation with an inoperable PORV, the PORV cnannel functional test frequency is spec 1fied to be accomplished within 12 hours before or after entering the LTOPS Technical Specification at RCS temperature of 259'F. Pre-4      planning and implementing this PORV surveillance prior to entering LTOPS conditions verifies the PORV setpoint is proper for LTOP before being constrained to complete this task within 1 hour. This is considered more conservative than the standard specification. Finally, a new surveillance requirement is added to verify that the PORY is selected to the low range setpoint for LTOP. The CR-3 PORV has a mode selector switch for open, closed, high range and low range.

J. S. Nuclcar Regulct:ry Commission                               LT0rs TSCRN 213, R3 vision 1 3F1097-12                                                                          Attachment A Page 3 Description of Bases Chanog The new Technical Specification BASES provides Background information to explain how the LTOP System protects the RCS from overpressurization and the reactor vessel from brittle fracture. The purpose of the LTOP System is to ensure an adequate pressure relief capacity and a minimum coolant addition capability in applicable plant Modes. The Background information emphasizes the PORV and RCS Vent requirements to meet the purpose of the LTOPS design.
The BASES Applicable Safety Analyses section summarizes how the calculated results of the analyses demonstrate that the reactor vessel can be adequately protected from overpressurization transients during shutdown. The Safety Analyses section emphasizes results which show, for the most limiting transient, that with the LTOP limits established by the analyses and the performance of the PORV, Pressurizer level, and an established RCS vent, the RCS is protected from exceeding P/T limits. Finally, this section states that any change to RCS operation or design must be evaluated against these analyses to determine the impact of the change on the LTOP acceptance limits.
The balance of the BASES discussion provides clarification of the LTOPS Technical Specification regarding the LTOP LCO scceptance limits, the Applicability of the LCO (LTOP Modes), the anticipated Conditions and their acceptable corrective actions, and the performance of the spr.cified Surveillance Requirements. Much of this detail is discussed in the Description of Specification Change above and the
,         Evaluation of Request below for the LTOPS Technical Specification.
Heason For Reauest This proposed change to the CR-3 ITS fulfills FPC commitments as stated in FPC letters 3F0497-05, dated April 7,1997, and 3F0697-23, dated June 6. 1997, to submit a Technical Specification Change Request for LTOP features applying ASME Code Case N-514, and consistent with the recommendations in NRC Generic Letter 88-11.
CR-3 is currently in MODE 5, with the reactor pressure vessel (RPV) head fully tensioneo. CR-3 is currently implementing LTOP features through administrative controls and a reduced PGRV setpoint until a Technical Specification change request for LTOP features is submitted and approved by the NRC.
FPC's current procedures contain the following limits and precautions related to LTOPS:
: 1. Pressurizer level is s 220 inches to maintain a compressible volume to accommodate a water level surge.
: 2. Both trains of High Pressure Injection (HPI) valves are closed and breakers                   ,
secured in the lock / reset position to prevent inadvertent HPI into the RCS.
: 3. The PORV is operable with a low setpoint to maintain RCS pressure below the LTOP limit curves. A lower PORV setpoint of 454 psig based on the NRC approved 15 EFPY pressure-temperature (P/T) curves for Crystal River 3 with no reactor coolant pumps operating, and a RCS maximum pressure limit restriction of 100 psig have been implemented as confirmed by FPC letter 3F0697-23, dated 3une 6, 1997.
* l

:U. S. Nuclear! Regulatory Commission-                     LTOPS TSCRN 213. Revision 1 13F1097-121                                                                  Attachment A Page 4
: 4. The Core Flood Tank:(CFT) pressure is maintained within maximum allowable RCS pressure / temperature limits when CFT isolation valves,- CFV-5 and/or CFV-6, are open or these valves are required-to be closed to prevent inadvertent CFT injection into.the RCS, FPC has committed to maintain these administrative controls in effect until a           i Technical- Specification amendment with approved- LTOP features that address the full
                                                 ~
          -range' of RCS pressures is submitted, issued by NRC, and implemented at CR-3.
With the- LTOP features listed above: implemented, CR-3 cannot start reactor
* coolant pumps.- This-prevents a plant startup. -Therefore, FDC is submitti g this
: Technical; Specification: change request for LTOP features based on 15 EFPY P/T-curves-and use of ASME Code Case N-514tto comply with the NRC's request and-to support CR-3's planned restart from the current outage in early December 1997.
Evaluation of Reauest This change will incorporate -limits and actions into the CR-3 Improved ' technical ~
Specifications which will ensure that low temperature overpre 5ure protection (LTOP) is provided for Crystal River Unit 3 for up to 15 EFPY of operation.
. n        These limits are based on analyses performed in accordance with ASME Code Case N-514. Use of this Code Case for Crystal-River was requested by FPC letter 3F0497-05, dated April 7,1997, and ras granted by the NRC (NRC letter to FPC l
dated -July 3,1997). The Code Case allows the use of 110% of the ASME Section XI, Appendix G limits on RCS pressure, when determining LTOP limits. It also defines ths LTOP enable temperature as the RTndt of the-limiting - material plus 50 degrees F -
The 15 EFPY pressure-tercerature limits were calculated in-accordance with ASME Section XI, ~ Appendix G, as a part of the current Heatup and Cooldown P/T curve p       - analysis for CR-3. These curvesLwere approved for use at. CR-3;per NRC letter-
: issuing' Amendment:No.133(dated February 7.1991s and were based on' RTndt values e    i calculated using RG 1.99, .Rev. 2, as specified in- NRC Generic Letter:88-11. The -
steady' state- results from Lthis . analysis were usedras the input = for the currents LTOP analyses and-the,110% pressure adjustment'was applied per ASME Code Case; N-514. The curve was further adjusted by applying plant characteristics due to the allowable operating pump combinations and resulting hydraulic effects. In particular, since RCPs are typically started with RCS temperatures above 100 degrees F, the LTOP analysis assumed a temperature of 85 degrees F was used for
          - startup of the first and second RCP. The analysis also assumed that'the third
           'RCP would not be started prior to an RCS temperature of 225 degrees F and four
          ' pump' operation is not considered for LTOP      The RCS temperatures assumed in the analysis are well within the actual starting temperatures allowed by procedures.
The results of this- analysis are discussed in Attachment B, FPC Calculation F97-0003, (See Reference 3 of- the new LTOPS Technical Specification Bases B3.4.11).
ASME Code Case N-514 requires that the enable temperature be evaluated for the quarter-t vessel location. -The LTOP analysis for this submittal assumes steady state conditions when e:tablishing the enable temperature. Since this assumption Lis non-conservative during RCS heatup, an RCS heatup holding period of 90 minutes will be completed after the LTOP enable temperature is exceeded but prior to exiting the LTOP LCO. This-will allow the vessel to stabilize at steady state conditions,: ensuring that the vessel quarter-t temperature is above the LTOP enable - temperature.

1 U. S. Nuclear R;gulctory Commission                     LTOPS TSCRN 213, Revision 1 3F1097-12                                                               Attachment A Page 5 Based on the LTOP analyses, the enable temperature for CR-3 is 253 degrees F (uncorrected for instrument uncertainty). The LTOP enable temperature limit of s 259'F includes correction for instrument uncertainty. Below this temperature, the LTOP limits will be implemented. These limits are based on protecting the reactor vessel from overpressurization due to an RCS transient. Several transients were evaluated for CR-3 (Sec LTOP ITS Bases 83.4.11, Reference 4, B&W     l (FTI) Document 51-1176431-01; Section 5.0). This analysis report was earlier submitted to the NRC by FPC letter 3F1089-23, dated October 31, 1989, to support CR-3 Technical Specification Change Request No.174. The transient evaluations in Section 5.0 of this report are applicable to ar.d support the bases for this change request. If a condition is identified in which the RCS response to a transient would not allow at least 10 minutes for operator actic;n, ecuipment is deactivated to preclude this transient from occurring. Of the remain 1ng transients that could not be precluded by deactivations, the most limiting transient for CR-3 is a stuck full-open Makeup valve with one Makeup pump operating. The time available to mitigate this most limiting transient is determined by the makeup flow into the RCS and the initial RCS Pressurizer level.
Inadvertent HPI injection and Core Flood Tank discharge into the RCS are the transients which were evaluated as requiring deactivation of equipment to preclude RCS overpressurization. Actions have been included to ensure that, under required conditions, all but one HPI pump (i.e. , one Makeup pump) is made inoperable, that flow through the HPI injection valves is blocked, and that the CFTs are isolated or operated below the LTOP limits. With these controls in place, adequate protection from these transients exists.
In the unlikely event a small break LOCA does occur subsequent to the High Pressure Injection (HPI) deactivation required for LTOPS, HPI can be restored by operator action. Reactor coolant makeup flow would be available in the interim to provide core cooling, except in the unlikely event that the makeup line would break. An engineering evaluation is being prepared by FPC in order to determine the decay heat removal requirementr of the ECCS in Mode 4 (See TSCRN 210 submittal to the NRC by FPC letter 3F0697-10, dated June-14, 1997). This evaluation includes modeling operation of HPI and LPI systems in LTOPS Mode 4 and may lead to revisions of Technical Specification 3.5.3, "ECCS-Shutdown," or 3.7.5, " Emergency Feedwater (EFW) System." Any such revisions will preserve all of the LTOP requirements of this TSCRN.
The Pressurizer level upper limit for LTOP is determined by the requirement to provide 10 minutes for operator action during an RCS transient with the PORV inoperable. The limiting transient analyzed for CR-3 is a stuck full-open Makeup valve with one Makeup pump operating. The starting points for this transient are the maximum pressures and temperatures allowed by the PTLR or PORV operating limits. The ending point of the transient after 10 minutes must be below the LTOP limits as analyzed per Code Case N-514. An initial Pressurizer water level of no greater than 160 inches (uncorrected for instrument uncertainty) ensures that the operators have at least 10 minutes to mitigate the transient before the LTOP limits are exceeded. The Pressurizer level Technical Specification limit of s 135 inches includes correction for instrument uncertainty.

       -U. S. Nuclcar R;gulatory Commission                      LTOPS TSCRN 213. Revision 1 3F1097-12                                                               Attachment A Page  6 Asi an LTOP safety factor, Pressurizer water level has been analyzed and will be lowered based on the acceptable criteria discussed above to provide a compressible vapor space that can accommodate a coolant insurge and prevent a rapid pressure increase to the RCS due to uncontrolled mass addition. Although the lower water level reduces the operators abilities to maneuver during cooldown, heatup, or any anticipated operational occurrence through the LTOP modes, they have enough margin to accomplish the actions needed to control these occurrences without violating LCO 3.4.3, "RCS Pressure and Tempr ature (P/T)
       -Limits."
In addition to deactivating equipment and limiting the Pressurizer level, the          i PORV low pressure setpoint is set to open at or below the minimum RCS pressure determined by the LTOP analysis. The RCS pressure at this point is 464 psig (uncorrected for instrument uncertainty). The PORV lift setpoint limit of s 457 psig includes correction for instrument uncertainty. The relief capacity of the PORV was also analyzed and determined to be greater at this pressure than the makeup flow resulting from the stuck open Makeup valve transient. Thus, the PORV can provide the- required protection at low temperatures.
If the PORV is inoperable due to the PORV itself or due to the block valve, additional controls are implemented to limit the capability to overpressurize the RCS. Analysis has determined that a Makeup tank level of no greater than 88 inches (uncorrected for instrument uncertainty) limits the available water l
inventory below what is needed to exceed the LTOP limits. In these Cases, the
!        Makeup tank which is the. suction source for the Makeup pump will be controlled to maintain this limit.
If the PORV is inoperable when LTOP is applicable (due to the PORV block valve being closed and deenergized per the PORV ITS LCO 3.4.10), it can be made operable by reenergizing and opening-the PORV block valve at this time. Should the PORY block valve not open at this time of-lower RCS temperature due to thermal-binding, the PORV would remain inoperable for LTOP. The required actions-for an inoperable PORV in LTOP are to reduce Makeup = tank level and< to deactivate the low low Makeup tank level interlock to the borated water storage tank, thereby minimizing -coolant addition capability to preclude overpressuring the' RCS, -This is an acceptable limitation for LTOP.
Action statements for each LCO provide allowable times to implement the actions-and controls described abote. These times range from immediately to 12 hours.
The times are based on operational and industry experience and regulatory
          .ecommendations.      The times are intended to balance the time necessary to accomplish the actions and the likelihood of experiencing a limiting transient during the action.                                                                      3 If for any reason, the LTOP controls described above cannot be implemented within the times specified after RCS tempe ature is reduced below 259'F, the RCS will be   l
        .depressurized and a vent estuolished such that overpressurization cannot occur.
When a vent is established under these conditions, controls will be implemented such as, locking or deactivating power to the component. A minimum vent size of 0.75 square inch has been specified. The relief capacity of this vent was also analyzed and determined to be greater at the limiting LTOP pressure than the makeup flow resulting from the stuck open Makeup valve transient. Thus the vent can provide the required protection at low temperatures.

U. S. Nuclear Rtgulatory Commission                    LTOPS TSCRN 213. Revision 1 3F1097-12                                                             Attachment A l                                                                                  Page  7 Surveillance Requirements with frequencits which have been shown by operating experience and industry accepted practice to be sufficient to regularly assess conditions for potential degradation of components and to verify operation within the requirements discussed above, are specified in the LTOP Technical Specification to ensure that LTOP limits are set and that the equipment required j-      to support LTOP safety factors is available.
Overall, these new requirements provide a level of protection greater than or equivalent to the existing administratively controlled LTOP features. Based on-the discussions provided above, FPC concludes that the new LTOP Technical Specifications being submitted provide asserance that cont ols are being implemented which are consistent with ASME Code Case N-514 and the recommendations of NRC Generic Letter 88-11, and provide for continued safe operation of CR-3.
: 2. CHANGE TO SPECIFICATION 3.5.3 Description of Specification and Bases Chenoes CR-3 'ITS Section 3.5.3 [LCO 3.5.3] for ECCS operability in plant Shutdown includes a Note that High Pressure injection (HPI) may be deactivated in accordance with LTOP administrative controls. This editorial change references that LTOP administrative controls are now requirements of Technical Specification LCO 3.4.11," Low Temperature Overpressure rotection (LTOP) System."
CR-3 ITS Bases Section B3.5.3 for ECCS operability in plant Shutdown includes references to the Note with LCO 3.5.3 that states High Pressure Injection (HPI) may be deactivated in accordance with LTOP administrative controls. These editorial changes reference that LTOP administrative controls are now requirements of Technical Specification LCO 3.4.11. " Low Temperature Frerpressure Protection-(LTOP) System."
Reasen/ Evaluation of Reauest A new Technical Specification Section 3.4.11, " Low Temperature Overpressure Protection (LTOP) System," is proposed to replace the provisions for overpressure protection which are currently implemented by LTOP administrative controls. This new specification includes the LCO to deactivate HPI. Therefore. LCO 3.4.11 should now be referenced as the provision for overpressure protection as it applies to HPI deactivation.
These editoriai changes reference the new Technical Specification LCO 3.4.11 and deactivation of HPI for LTOPS.
: 3. CHANGE TO SPECIFICATION BASES B3.4.9 Description of Bases Chance               4 CR . ITS Bases Section 83.4.9 for Pressurizer Safety Valves includes references to LTOP administrative controls. These editorial changes reference that LTOP administrative controls are now requirements of Technical Specification LCO 3.4.11. " Low Temperature Overpressure Protection (LTOP) System."
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si t ,
U. S. Nuclear R:gulatory Commission                    L' OPS TSCRN 213, Revision 1 3F1097-12 Attachment A Page      8 Reason / Evaluation of Request A new Technical Specification Section 3.4.11. " Low Temperature Overpressure Protection (LTOP) System," is proposed to replace the provisions for overpressure protection which are currently implemented by LTOP administrative controls.
Since LCO 3.4.11 includes the requirements for LTOP, this LCO is now proposed as the provision for overpressure protection.
These editorial changes reference the new LTOP Technical Specification LCO 3.4.11 regarding how overpressure protection is provided.
: 4. CHANGE TO SPECIFICATION BASES R3.5.2                                                       I Descrintion of Bases Chance CR-3 ITS Bases Section B3.5.2 for ECCS operability while the plant is Operating includes references to the currently implemented LTOP administrative controls.
These references to LTOP discuss operability of HPI in Modes 1, 2, and 3 under conditions required by the current LTOP administrative controls. The changes to Bases Section 83.5.2 remove all reference to HPI deactivation required at RCS                    1 temperature s 283'F for the currently implemented LTOP administrative controis.
Although TSCRN 210 (FPC letter 3F0697-10, dated 3une 14,1997) includes proposed changes to Bases Section B3.5.2, page B 3.5-15, as does this submittal, the l
proposed  changes proposed with TSCRN to 210.
this bases page for the LTOPS do not impact those changes Reason / Evaluation of Reauest 7
A new Technical Specification Section 3.4.11 " Low Temperature Overpressure Protection (LTOP) System," is proposed to replace-the provisions for overpressure protection which are currently implemented by LTOP administrative controls. This new specification includes the LCO 3.4.11 requirements to deactivate HPI and to limit Makeup for LTOP during plant shutdown beginnirg in Mode 4 when RCS temparature is s 259'F.
ITS Section B3.5.2 discusses the bases for Technical          l Specification 3.5.2, "ECCS-Operating,' and its limiting conditions of operation which are applicable in plant Modes 1, 2, and 3 only. The new proposed LTOP requirements are not applicable in Modes 1, 2, and 3.
The currently implemented LTOP administrative controls require HPI to be deactivated at RCS temperatures s 283'F. Mode 4 plant operation (Hot Shutdown) is defined by the CR-3 ITS as beginning when the average RCS teh.perature is < 280'.c Therefore, current LTOP administrative controls require HPI to be deactivated while the plant is in Hot Standby Mode 3 for a period of time while the RCS temperature is in the range of 283'F to 280'F. Thus, the reason for LTOP references presently in ITS Bases Section 83.5.2 is concluded. Since the proposed LTOPS Technical Specification 3.4.11 will require HPI deactivation in Mode 4 when RCS ter.perature is s 259'F, there is no time within Mode 3 when HPI is deactivated,  and therefore, references to LTOP in Bases Section B3.5.2 may be             l removed.

U. S. Nuclenr Regulatsry Commissicn                     LTOPS TSCRN 213    Revision 1 3F1097-12                                                               Attachment A Page 9 NO SIGNIFICANT HAZARDS EVALUATION (SHOLLY)                                            l l
This proposed change to the Crystal River Unit 3 (CR-3) Improved Technical Specifications incorporates :: new section 3.4.11 for reactor vessel Low Temperature Overpressure Protection (LTOP). An evaluation of the proposed change has been performed in accordance with 10CFR50.91(a)(1) regarding no significant hazards considerations using the standards in 10CFR50.92(c). A discussion of these standards as they relate to this amendment request follows:
1 - Does Not Involve a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated This change does no_t involve a significant increase in the probability or consequenen of any accident previously evaluated.
There arg curr9ntly no LTOP requirements in the CR-3 Improved Technical Specifications. CR-3 currently implements LTOP features through administrative cont ois and a lowered PORV setpoint. The proposed change will establish new LTOP technical specification requirements necessary to preclude an LTOP event from occurrine. The proposed LTOP requirements are based on safety analyses that apply ASME Code Casa N-514. These requirements will decrease the probability of a low temp (rature overpressure event by providing protection for all pressure and temperature combinations for which a low temperature overpressure event may be postulated.
The consequences of a low temperature overpressure accident are not affected by this chance. There is no change to the 10CFR Part 100 dose calculation for a low
:   temperature overpressurs accident.
2 - Does Not Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated This change does nn.t create the possibility of a new or different kind of accident from any previously evaluated.
The new LTOP Technical Specification does not require modification to the plant nor does it create a new mode of plant operation. The LTOP system adds no new accident initiators.
3 - Does Not Involve a Significant Reduction in the Margin of Safety The prog sed change does co: involve a significant reduction in the margin of safety and will provide added cafety benefit gained through the requirements to preclude a low temperature overpressurization event to the RCS.
The margin of safety prior to having an LTOP sy" m was limited due to the informal, administrative method of minimizine         impact of a low temperature overpressure accident. By formalizing th m        iuirements into a technical specification, at the least, margin of af e:     s retained and perhaps improved due to the elevated significance of require:    crions.
Therefore, based upon the reasoning prese" ad above and the pre n ,as discussion of the amendment request, FPC has determined that the requested change does nat involve a significant hazard.

U. S. Nuclear Regulatsry Commissicn                    LTCPS TSCRN 213   Revisicn 1 3F1097-12                                                              Attachment A Page   10 ENVIRONMENTAL IMPACT EVALUATION 10CFR51.22(c)(9) provides criteric for and identification of licensing and regulatory actions eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant hazards consideration, (2) result in a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) result in an increase in individual or cumulative occupational        .
radiation exposure. FPC has reviewed this license amendment and concludes that it meets the eligibility criteria for categorical exclusion set forth in 10CFR51.22(c)(9). Pursuant to 10CFR51.22(c), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance l
of the proposed Technical Specification changes. The basis for this
  -determination is as follows:
: 1. The proposed Technical Specificatioe changes do not involve a significant hazard as described previously in the No Significant Hazards Evaluation.
: 2. Ti.e proposed Technical Specification changes do not result in a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite. The proposed Technical Specification changes do not introduce any new equipment nor do they require any existing equipment or systems to perform a different type of function than they are presently designed to perform. The changes ensure that the consequences of previously evaluated accidents will not be increased. FPC has concluded that there will not be a significant increase in the types or amounts of any effluents -that may be released offsite and these changes do not involve irreversible environmental consequences beyond-those already associated with normal operation.
: 3. The proposed Technical Specification changes do not increase individual or cumulative radiation exposure beyond that already associated with normal operation.
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