ML012690234
| ML012690234 | |
| Person / Time | |
|---|---|
| Site: | Technical Specifications Task Force, Nuclear Energy Institute |
| Issue date: | 09/16/2001 |
| From: | Pietrangelo A Nuclear Energy Institute |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUREG-1430, NUREG-1431, NUREG-1433, NUREG-1434 | |
| Download: ML012690234 (14) | |
Text
TSTF-419 (WOG-154, Rev. 0)
NUREGs Affected:
Revise PTLR Definition and References in ISTS 5.6.6, RCS PTLR Industry/TSTF Standard Technical Specification Change Traveler 1430 1431 1432 1433 1434 Classification:
- 1) Technical Change Priority 3)Low
Description:
The definition of PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) is revised to delete the reference to the Specifications containing the limits specified in the PTLR.
The requirement in ITS 5.6.6, "Reactor Coolant System (RCS) PRESSU RE AND TEMPERATURE LIMITS REPORT (PTLR)," to identify the NRC staff approval document by dat e is revised to allow the Topical Report(s) to be identified by number and title. A requirement is added to the Reviewers Note to specify the complete citation in the PTLR for each Topical Report, include the report number, ti tle, revision, date, and any supplements.
Justification:
BACKGROUND NRC Generic Letter 96
-06, "Relocation of the Pressure Temperature Limit Curves and Low T emperature Overpressure Protection System Limits," dated January 31, 1996, al lows licensees to relocate the pressure temperature (P/T) limit curves from their plant technical specific ations (TS) to a pressure temperature limits report (PTLR) or a similar document. The Low Temperature Overpressure Pr otection (LTOP) System limits were also allowed to be relocated to the same document. The methodology use d to determine the P/T and LTOP System limit parameters must comply with the specific requirements of App endices G and H to Part 50 of Title 10 of the Code of Federal Regulations (10 CFR), be documented in an NRC appr oved topical report or in a plant
-specific submittal, and be incorporated by reference into the TS. Subseque nt changes in the methodology must be approved by a license amendment.
Similar changes to NUREG
-1432, Rev. 2, are addressed in TSTF
-408.PROPOSED CHANGE 1.The definition of PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) is revised to delete the reference to the Specifications containing the limits specified in the PTLR.
2.The requirement in ITS 5.6.6, "Reactor Coolant System (RCS) PRESSU RE AND TEMPERATURE LIMITS REPORT (PTLR)," to identify the NRC staff approval document by dat e is revised to allow the Topical Report(s) to be identified by number and title. A requirement is added to the Reviewers Note to specify the complete citation in the PTLR for each Topical Report, include the report number, title, revision, date, and any supplements.
9/16/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
TSTF-419 (WOG-154, Rev. 0)
JUSTIFICATION 1.The definition of PTLR identifies the specifications in which the pressure and temperature limits are addressed. Specification 5.6.6a. requires that the individual spec ifications that address RCS pressure and temperature limits be referenced. The proposed changes to the def inition eliminate duplication between the definition of PTLR and Section 5.6.6.
2.The revision to ITS 5.6.6 to allow the Topical Reports to be ident ified by number and title would allow licensees to use current Topical Reports to support limits in the PTLR without having to submit an amendment to facility operating license every time the Topical Rep ort is revised. The PTLR would provide specific information identifying the particular approved Topical R eports used to determine the P/T limits or LTOP System limits. This still provides the assurance that only t he approved versions of the referenced Topical Reports will be used for the determination of the P/T limi ts or LTOP System limits since the complete citation will be provided in the PTLR. This proposed cha nge is consistent with TSTF
-363, "Revise Topical Report references in ITS 5.6.5, COLR," which was approved by the NRC on April 13, 2000.
The requirement to operate within the limits in the PTLR is specif ied in and controlled by the technical specifications. Only the figures, values, and parameters associat ed with the P/T limits and LTOP setpoints are relocated to the PTLR. The methodology for their development must be reviewed and approved by the NRC. The proposed changes do not change the requirements associated with th e review and approval of the methodology or the requirement to operate within the limits specified in the PTLR
.DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION In accordance with the criteria set forth in 10 CFR 50.92, the pro posed changes to NUREG
-1431 have been evaluated and determined they do not represent a significant hazar ds consideration. The following is provided in support of this conclusion:
Standard I
-Involves a Significant Increase in the Probability or Consequences of an Accident Previously Evaluated The proposed changes to reference only the Topical Report Number a nd title do not alter the use of the analytical methods used to determine the P/T limits or LTOP setpoints that ha ve been reviewed and approved by the NRC.
This method of referencing Topical Reports would allow the use of current Topical Reports to support limits in the PTLR without having to submit an amendment to the operating licens
- e. Implementation of revisions to Topical Reports would still be reviewed in accordance with 10 CFR 50.59 an d where required receive NRC review and approval.The proposed changes do not adversely affect accident initiators o r precursors nor alter the design assumptions, conditions, or configuration of the facility or the manner in whic h the plant is operated and maintained. The proposed changes do not alter or prevent the ability of structures , systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits. The proposed changes do not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequenc es of an accident previously evaluated.
Further, the proposed changes do not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occup ational/public radiation exposures. The proposed changes are consistent with safety analysis assumptions and result ant consequences.
Therefore, it is concluded that this change does not increase the probability of occurrence of an accident previously evaluated.
9/16/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
TSTF-419 (WOG-154, Rev. 0)
Standard II
-Create the Possibility of a New or Different Kind of Accident from any Previously Evaluated The proposed changes to reference only the Topical Report Number a nd title do not alter the use of the analytical methods used to determine the P/T limits or LTOP setpoints that ha ve been reviewed and approved by the NRC.
This method of referencing Topical Reports would allow the use of current Topical Reports to support limits in the PTLR without having to submit an amendment to the operating licens
- e. Implementation of revisions to Topical Reports would still be reviewed in accordance with 10 CFR 50.59 an d where required receive NRC review and approval.The changes do not involve a physical alteration of the plant (i.e
., no new or different type of equipment will be installed) or a change in the methods governing normal plant opera tion. In addition, the changes do not impose any new or different requirements or eliminate any existing requir ements. The changes do not alter assumptions made in the safety analysis. The proposed changes are consistent with the safety analysis assumptions and current plant operating practice.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.
Standard III
- Involve a Significant Reduction in the Margin of Safety The proposed changes to reference only the Topical Report Number a nd title do not alter the use of the analytical methods used to determine the P/T limits or LTOP setpoints that ha ve been reviewed and approved by the NRC.
This method of referencing Topical Reports would allow the use of current Topical Reports to support limits in the PTLR without having to submit an amendment to the operating licens
- e. Implementation of revisions to Topical Reports would still be reviewed in accordance with 10 CFR 50.59 an d where required receive NRC review and approval. The proposed changes do not alter the manner in which s afety limits, limiting safety system settings or limiting conditions for operation are determined. The setpoints a t which protective actions are initiated are not altered by the proposed changes. Sufficient equipment remains ava ilable to actuate upon demand for the purpose of mitigating an analyzed event.
Therefore, it is concluded that this change does not involve a sig nificant reduction in the margin of safety.
Industry Contact:
NRC Contact:
Wideman, Steve (316) 364-4037 stwidem@wcnoc.com Tjader, Bob (301) 415-1187 trt@nrc.gov Revision History OG Revision 0 Revision Status:
Active NRC Next Action:
Original Issue Revision
Description:
Revision Proposed by:
Wolf Creek Owners Group Review Information Date Originated by OG:
02-May-01 Owners Group Comments (No Comments)
Date: 02-May-01 Owners Group Resolution:
Approved 9/16/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.
TSTF-419 (WOG-154, Rev. 0)
File to BBS/LAN Date:
TSTF Informed Date:
TSTF Approved Date:
NUREG Rev Incorporated:
Incorporation Into the NUREGs Affected Technical Specifications OG Revision 0 Revision Status:
Active NRC Next Action:
TSTF Review Information TSTF Received Date:
02-May-01 Date Distributed for Review:
02-May-01 TSTF Comments: (No Comments)
Date: 02-May-01 TSTF Resolution:
Approved OG Review Completed:
BWOG CEOG WOG BWROG NRC Review Information NRC Received Date:
15-Sep-01 NRC Comments: (No Comments)
Final Resolution Date:
Final Resolution:
NRC Action Pending 1.0 Definitions - PTLR 5.6.6 Reactor Coolant System PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) 9/16/2001 Traveler Rev. 2. Copyright (C) 2001, Excel Services Corporation. Use by Excel Services associates, utility clients, and the U.S. Nuclear Regulatory Commission is granted. All other use without written permission is prohibited.