NL-09-013, Proposed Changes to Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements

Proposed Changes to Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements

ML090760604
Person / Time
Site:	Indian Point
Issue date:	03/05/2009
From:	Joseph E Pollock Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-09-013
Download: ML090760604 (25)

Text

Enterqy Nuclear Northeast Indian Point Energy Center 450 Broadway, GSB 9

P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 734 6700 Joseph Pollock Site Vice President Administration March 5, 2009 Re:

Indian Point Unit 2 Docket No. 50-247 NL-09-013 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Proposed Changes to Indian Point 2 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements

Dear Sir:

Pursuant to 10 CFR 50.90, Entergy Nuclear Operations, Inc, (Entergy) hereby requests a License Amendment to Operating License DPR-26, Docket No. 50-247 for Indian Point Nuclear Generating Unit No. 2 (IP2). The proposed amendment will revise the Reactor Heatup and Cooldown curves and Low Temperature Overpressure Protection curves in Technical Specifications (TS) 3.4.3 and 3.4.12. Changes for Technical Specification Bases 3.4.3 and 3.4.12 are not included because the changes are minimal.

Entergy has evaluated the proposed change in accordance with 10 CFR 50.91 (a)(1) using the criteria of 10 CFR 50.92 (c) and Entergy has determined that this proposed change involves no significant hazards considerations, as described in Attachment 1. The proposed changes to the Technical Specifications are shown in Attachment 2. A non-proprietary Westinghouse WCAP addressing the development of the heatup and cooldown curves is included as Enclosure 1. A copy of this application and the associated attachments are being submitted to the designated New York State official.

Entergy requests approval of the proposed amendment by August 7th 2009. There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, IPEC Licensing Manager at (914) 734-6710.

NL-09-013 Dockets 50-247 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on 2009.

Sincerely, seph Pollock Site Vice President Indian Point Energy Center Attachments:

1:

Analysis of Proposed Technical Specification Changes regarding Reactor Heatup and Cooldown Curves and LTOPS Requirements 2:

Markup of Technical Specification Pages for Proposed Changes regarding Reactor Heatup and Cooldown Curves and LTOP Requirements

Enclosures:

1:

WCAP-16752-NP, Revision 0, "Indian Point Unit 2 Heatup and Cooldown Limit Curves for Normal Operation," Westinghouse Electric Co, January 2008 cc:

Mr. John P. Boska, Senior Project Manager, NRC NRR DORL Mr. Samuel J. Collins, Regional Administrator, NRC Region 1 NRC Resident Inspector, IP2 Mr. Robert Callender, Vice President, NYSERDA Mr. Paul Eddy, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-09-013 ANALYSIS OF PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING REACTOR HEATUP AND COOLDOWN CURVES AND LTOPS REQUIREMENTS ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

NL-09-013 Docket 50-247 Page 1 of 5

1.0 DESCRIPTION

Entergy Nuclear Operations, Inc (Entergy) is requesting an amendment to Operating License DPR-26, Docket 50-247 for Indian Point Nuclear Generating Unit No. 2 (IP2). The proposed change will revise the Reactor Vessel Heatup and Cooldown curves in Unit 2 Technical Specification (TS) 3.4.3 and the Low Temperature Overpressure Protection System (LTOPS) curves in IP2 TS 3.4.12.

The specific proposed changes are listed in the following section.

2.0 PROPOSED CHANGE

S A.

The Heatup requirements and Cooldown limitations in Unit 2 TS 3.4.3 will be revised as follows:

The proposed TS Figure 3.4.3-1 and Figure 3.4.3-2 shown in attachment 2, replaces the existing Figure 3.4.3-1 and Figure 3.4.3-2.

B.

The Low Temperature Overpressure Protection in IP2 TS 3.4.12 will be revised as follows:

The proposed TS 3.4.12 Figure 3.4.12-1 to Figure 3.4.12-6 shown in Attachment 2 replaces the existing Figure 3.4.12-1 to Figure 3.4.12-6.

3.0 BACKGROUND

This Technical Specifications (TS) amendment proposes to revise the Heatup (HU), Cooldown (CD) and Low Temperature Overpressure Protection System (LTOPS) related curves, in order to compensate for an increased service life. The current Technical Specifications (TS) for these curves expire at a service life of 25 Effective Full-Power Years (EFPY). Based on the most recent estimates of lifetime neutron fluence, and allowing for the effects of the Stretch Power Uprate (Amendment #241), calculations have been performed to establish pressure versus temperature limits for all curves in TS Sections 3.4.3 and 3.4.12 for a service life extending up to 29.2 EFPY, which is the estimated accumulated burnup at the expiration of the existing Operating License, which expires on September 28, 2013.

As expected, the revised curves are more restrictive than the existing ones, due to the effects of greater lifetime neutron fluence on the reactor vessel inner wall, and the associated increase in RTNDT at the / and 3/4 locations. The methodologies used for the generation of the new curves are identical to those used for the existing curves. In accordance with ASME BPV Code Section Xl, Appendix G, the LTOPS Arming Temperature can be as low as 264 degF. As the LTOPS Arming Temperature remains below the current value of 280 degF, the existing Tech Spec value of 280 degF is retained.

NL-09-013 Docket 50-247 Page 2 of 5

4.0 TECHNICAL ANALYSIS

The IP2 TS establishes limits on Reactor Coolant System (RCS) pressure at low temperatures, in order to protect the reactor vessel from damage due to crack propagation. These limits include normal Heatup and Cooldown restrictions, as well as the automatic setpoints and manual restrictions associated with operation of the LTOPS. These requirements are promulgated in accordance with 1 OCFR50 Appendix G, which provide guidelines for development of these limits.

The existing limits are valid for plant operation through a lifetime burnup of 25 EFPY, which will be reached in approximately September 11, 2009. The revised limits are valid for a lifetime burnup of 29.2 EFPY, which is the anticipated burnup at the time of Operating License expiration on September 28, 2013.

The revised curves fall into two categories: heatup and cooldown curves for normal operation (TS Section 3.4.3) and LTOPS curves (TS Section 3.4.12). The former have been prepared by Westinghouse (Reference 1), and the latter have been established via internal Entergy calculation (Reference 2).

The WCAP for normal HU and CD curves identifies the methodology under which the figures were generated. These curves are based on latest available reactor vessel information and updated calculated fluences, which include the impact of Stretch Power Uprate. The new Indian Point Unit 2 HU and CD curves were generated using the "Axial-Flaw" methodology of the 1998 ASME Code,Section XI through the 2000 Addenda (which allows the use of the KIc methodology) and the "Circ-Flaw" methodology. The material with the highest adjusted reference temperature (ART) was intermediate shell plate B-2002-3 (Heat Number B4782-1) for the Axial-Flaw methodology and circumferential weld wire Heat Number B34009 for the Circ-Flaw methodology. The pressure-temperature limit curves were generated for 29.2 EFPY using heatup rates 60 and 100 degF/hr and cooldown rates of steady state, 20, 40, 60 and 100 degF/hr. These curves were developed without allowance for instrumentation errors or pressure bias, as is the case for the existing TS curves. Prior to implementation, allowances for pressure and temperature instrument errors and bias will be applied to the 29.2 EFPY curves as has been the practice in previous implementations. In similar fashion to RPS and ESFAS setpoint determinations, the methodology used for estimating instrument uncertainties conforms to the recommended practices of industry standard ISA 67.04.

The calculation for the LTOPS curves uses a methodology identical to that of the existing curves, based on the source calculations for TS Amendment 224. The LTOPS curves in Reference 2 are based on the HU/CD curves established in Reference 1, and therefore the revised LTOPS setpoint, and its family of associated curves, similarly reflect the increase in lifetime fluence for a service life of 29.2 EFPY. The Maximum PORV Opening setpoint shown in Figure 3.4.12-1 is implemented as a variable setpoint for the LTOPS instrumentation. The other curves in the LTOPS family (as well as the HU and CD curves in Section 3.4.3) are procedurally implemented as Operations Procedure graphs and do not relate to any automatic protection systems.

The LTOPS Arming temperature is the point below which the LTOPS is required to be in service.

In TS Amendment 224, the Commission granted Entergy the use of ASME BPV Code Section XI, Appendix G; it allows use of code case N-588 and N-640 for determination of this setpoint. The ASME BPV Code Section XI, Appendix G with the 2000 Addenda incorporates these code cases.

This defines the LTOP systems to become effective at coolant temperatures corresponding to

NL-09-013 Docket 50-247 Page 3 of 5 reactor vessel temperatures less than RTNDT + 50 degF, to a minimum Arming Temperature of 200 degF. For IP2, use of this methodology caused the calculated Arming Temperature to fall well below the pre-2002 value of 280 degF. However, for convenience of use, the conservatively high value of 280 degF was retained for Amendment 224. Similarly, the LTOPS Arming Temperature for 29.2 EFPY is equal to 264 DegF, which is the limiting RTNDT of 214 degF from Table 4-8 of WCAP-16752 plus 50 degF. As the LTOPS Arming Temperature remains below the current value of 280 degF, the conservative value of 280 degF is retained for convenience of use.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration Entergy has determined that this proposed Technical Specification change does not involve a significant hazards consideration as defined by 10CFR.50.92(c).

1. Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated.

The proposed TS changes do not involve a significant increase in the probability or consequences of an accident previously evaluated. There are no physical changes to the plant being introduced by the proposed changes to the heatup and cooldown limitation curves. The proposed changes do not modify the RCS pressure boundary. That is, there are no changes in operating pressure, materials, or seismic loading. The proposed changes do not adversely affect the integrity of the RCS pressure boundary such that its function in the control of radiological consequences is affected. The proposed heatup and cooldown limitation curves were generated in accordance with the fracture toughness requirements of 10CFR50 Appendix G, and ASME B&PV code, Section Xl, Appendix G edition with 2000 Addenda. The proposed heatup and cooldown limitation curves were established in compliance with the methodology used to calculate and predict effects of radiation on embrittlement of RPV beltline materials. Use of this methodololgy provides compliance with the intent of 1 OCFR50 Appendix G and provides margins of safety that ensure non-ductile failure of the RPV will not occur. The proposed heatup and cooldown limitation curves prohibit operation in regions where it is possible for non-ductile failure of carbon and low alloy RCS materials to occur. Hence, the primary coolant pressure boundary integrity will be maintained throughout the limit of applicability of the curves, 29.2 EFPY.

Operation within the proposed LTOPS limits ensures that overpressurization of the RCS at low temperatures will not result in component stresses in excess of those allowed by the ASME B&PV Code Section Xl Appendix G.

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

2. Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed TS changes do not create the possibility of a new or different kind of accident from any accident previously evaluated. No new modes of operation are

NL-09-013 Docket 50-247 Page 4 of 5 introduced by the proposed changes. The proposed changes will not create any failure mode not bounded by previously evaluated accidents. Further, the proposed changes to the heatup and cooldown limitation curves and the LTOPS limits do not affect any activities or equipment other than the RCS pressure boundary and do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Consequently, the proposed changes do not involve a significant increase in the probability or consequence of a new or different kind of accident, from any accident previously evaluated.

3. Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in the margin of safety.

The Proposed TS changes do not involve a significant reduction in the margin of safety.

The revised heatup and cooldown limitation curves and LTOPS limits are established in accordance with current regulations and the ASME B&PV Code 1998 edition with 2000 Addenda. These proposed changes are acceptable because the ASME B&PV Code maintains the margin of safety required by 10CFR50.55(a). Because operation will be within these limits, the RCS materials will continue to behave in a non-brittle manner consistent with the original design bases.

The proposed changes to the allowable operation of charging and safety injection pumps when LTOPS is required to be operable is consistent with the IP2 licensing bases as established in TS Amendment 224.

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

Based on the above evaluation, Entergy has concluded that the proposed change will not result in a significant increase in the probability or consequences of any accident previously analyzed; will not create the possibility of a new of different kind of accident from any accident previously evaluated; and, does not result in a significant reduction in the margin of safety. Therefore, operation of IP2 in accordance with the proposed amendment does not involve a significant hazards consideration.

5.2 Applicable Regulatory Requirements / Criteria The proposed changes were developed in accordance with the following NRC regulations and guidance:

10CFR50 Appendix G Regulatory Guide (RG) 1.99, Rev. 2 ASME B&PV Code Section Xl Appendix G, 1998 Edition with 2000 Addenda 10CFR50 Appendix G, by reference to ASME B&PV Code Section Xl Appendix G, 1998 Edition with 2000 Addenda, specifies fracture toughness and testing requirements for reactor vessel materials. 1 OCFR50 Appendix G also requires prediction of the effects of neutron irradiation on vessel embrittlement by calculating the Adjusted Reference Temperature (ART) and the Charpy Upper Shelf Energy (USE). Generic Letter 88-11 requested that the methods provided in RG 1.99 Rev. 2, defines the ART as the sum of unirradiated reference temperature, the increase of

NL-09-013 Docket 50-247 Page 5 of 5 reference temperature resulting from neutron irradiation, and a margin to account for uncertainties in the prediction method.

5.3 Environmental Considerations The proposed changes to the IP2 Technical Specifications do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 PRECEDENCE The methodology under which the Heatup and Cooldown curves were created is a standard used by Westinghouse throughout the industry. A previous request for a change to these Curves was approved with NRC SER dated 2/15/02 for TS Amendment 224.

7.0 REFERENCES

1) WCAP-16752-NP, Revision 0, "Indian Point Unit 2 Heatup and Cooldown Limit Curves for Normal Operation," Westinghouse Electric Co, January 2008

2) Entergy Calculation FMX-00270 Rev 1, "IP2 Overpressure Protection System (OPS)

Thermal Hydraulic Analysis, Setpoint Development And Tech Spec Revision," February 26, 2009

ATTACHMENT 2 TO NL-09-013 MARKUP OF TECHNICAL SPECIFICATION PAGES FOR PROPOSED CHANGES REGARDING REACTOR HEATUP AND COOLDOWN CURVES AND LTOP REQUIREMENTS Deleted Pages are marked "Void" and all new pages are unmarked Unit 2 Affected Pages:

3.4.3-3 and 4 3.4.12-8 to13 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

RCS P/T Limits 3.4.3 2500 Moderator Temperature (Deg.

Acceptable operation is to the right of or below the applicable curve. Unacceptable operation is to the left of or above the applicable curve.

Figure 3.4.3-1 is effective until 25 effective full power years (EFPYs)

Figure 3.4.3-1 does not include any allowance for instrument uncertainty.

2.

3.

Figure 3.4.3-1:

Heatup Limitations for the Reactor Coolant System (RCS) and Hydrostatic and Inservice Leak Testing Limitations for the RCS.

INDIAN POINT 2 3.4.3-3 Amendment No.238

RCS P/T Limits 3.4.3 I

I 2500 2250 2000 1750 1500 1250 1000 750 500 250 0

I 0

50 100 150 200 250 300 350 400 450 500 550 Moderator Temperature (Deg. F)

-Notes-

1.

Acceptable operation is to the right of or below the applicable curve. Unacceptable operation is to the left of or above the applicable curve.

2.

Figure 3.4.3-1 is effective until 29.2 effective full power years (EFPYs)

3.

Figure 3.4.3-1 does not include any allowance for instrument uncertainty.

Figure 3.4.3-1:

Heatup Limitations for the Reactor Coolant System (RCS) and Hydrostatic and Inservice Leak Testing Limitations for the RCS.

INDIAN POINT 2 3.4.3-3 Amendment No.

RCS P/T Limits 3.4.3 2500 Moderator Temperature (Deg. F)

-Notes-

1.

Acceptable operation is to the right of or below the applicable curve. Unacceptable operation is to the left of or above the applicable curve.

2.

Figure 3.4.3-2 is effective until 25 effective full power years (EFPYs).

3.

Figure 3.4.3-2 does not include any allowance for instrument uncertainty.

Figure 3.4.3-2:

Cooldown Limitations for the RCS (including RCS cooldown following RCS inservice leak and hydrostatic testing).

INDIAN POINT 2 3.4.3-4 Amendment No. 238

RCS P/T Limits 3.4.3 I

2500 2250 2000 1750 1500 1250 1000 750 500 250 0

0 50 100 150 200 250 300 350 400 450 500 550 Moderator Temperature (Deg. F)

-Notes-

1.

Acceptable operation is to the right of or below the applicable curve. Unacceptable operation is to the left of or above the applicable curve.

2.

Figure 3.4.3-2 is effective until 29.2 effective full power years (EFPYs).

3.

Figure 3.4.3-2 does not include any allowance for instrument uncertainty.

Figure 3.4.3-2:

Cooldown Limitations for the RCS (including RCS cooldown following RCS inservice leak and hydrostatic testing)

INDIAN POINT 2 3.4.3-4 Amendment No.

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- Curve Applicable to 3 Charging Pumps Capable of Injecting into RCS

- For 1 SI and 2 Charging Pumps Capable of Injecting into RCS, Reducethe Horizontal Portion of the Curve by 30 psi.

- Includes 50F and 10 psi M argin.

Unacceptable Operation (To Left or Above Applicable Curve)

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Unacceptable Operation (To Left or Above Applicable Curve)

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a.

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600-

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Unacceptable Operation (To Left or Above Applicable Curve)

/

/

2 FARM 1_J I

IIIIIrIK)1122 Acceptable Operation Maximum Pressurizer Level of 36%

(To Right or Below Maximum Pressurizer Level of 51%

Applicable Curve) 0 50 100 150 200 250 300 RCS TEMPERATURE (OF)

Na-Figure 3.4.12-4:

Maximum RCS Pressure - PORVs Inoperable and 3 Charging Pumps Capable of Injecting into the RCS.

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MAXIMUM PRESSURIZER LEVEL 0F 100 51%

-MAXIMUM PRESSURIZER LEVEL OF 85%

0-60 70 80 90 100 110 120 130 140 150 160 170 180 1!

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I Notes:

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- Includes 57 and 10 psi Margin.

Unacceptable Operation (To Left or Above Applicable Curve) 0 A2

/K, ~1 7

Acceptable Operation I

TARM

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Maximum Pressurizer Level of 51%/6 A

M aximum Pressurizer Level of 710/%

M aximum Pressurizer Level of 85%

(To Rght or Below Applicable Curve)

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50 100 150 200 250 300 RCS TEMPERATURE (OF)

Figure 3.4.12-5:

• -- I Maximum RCS Pressure and Pressurizer Level during Reactor Coolant Pump Start with PORVs Inoperable and SGs _< 40°F Hotter than RCS.

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,BLE TO 25 EFPY.

)WANCE FOR 4ENT ERROR OR E BIAS.

'°FAND 10 PSI 3

CD

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CL 3

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-MAXIMUM PRESSURIZER LEVEL OF 36%

-MAXIMUM PRESSURIZER LEVEL OF 51%10 111111111111111111 111111111 111111111 lI III1 60 70 80 90 100 110 120 130 140 150 160 170 180 RCS TEM I CD-

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(U) 1000 900-800-700-600-500-400-300-200-I I N I

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Notes:

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-Applicable to 29.2 EFPY.

- No Allowance for Instrument Error or Pressure Bias.

- Includes 5TF and 10 psi Margin.

1I1 Unacceptable Operation (To Left or Above Applicable Curve)

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100 _t 0

50

-Maximum Pressurizer Level of 36%

Maxmum Pressurizer Level of 51%

Acceptable Operation

- (To Right or Below Applicable Curve)

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I 100 150 200 250 300 RCS TEMPERATURE (OF)

CD Figure 3.4.12-6:

Maximum RCS Pressure and Pressurizer Level during Reactor Coolant Pump Start with PORVs Inoperable and SGs _< 1 00F Hotter than RCS.