ML041200311

CNP Units 1 and 2 Improved Technical Specifications Conversion, Volume 4, Rev 0, ITS Chapter 2.0 Safety Limits.

ML041200311
Person / Time
Site:	Cook
Issue date:	04/06/2004
From:	Indiana Michigan Power Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
AEP:NRC:4901
Download: ML041200311 (46)

Text

Attachment 1, Volume 4, Rev. 0, Page 1 of 46 VOLUME 4 CNP UNITS 1 AND 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS CHAPTER 2.0 SAFETY LIMITS Revision 0 Attachment 1, Volume 4, Rev. 0, Page 1 of 46

Attachment 1, Volume 4, Rev. 0, Page 2 of 46 LIST OF ATTACHMENTS

1. ITS Chapter 2.0 Attachment 1, Volume 4, Rev. 0, Page 2 of 46

, Volume 4, Rev. 0, Page 3 of 46 ATTACHMENT 1 ITS Chapter 2.0, Safety Limits , Volume 4, Rev. 0, Page 3 of 46

, Volume 4, Rev. 0, Page 4 of 46 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 4, Rev. 0, Page 4 of 46

Attachment 1, Volume 4, Rev. 0, Page 5 of 46 ITS Chapter 2.0 A.1 ITS A.1 2.1.1 A.2 the COLR Add proposed SL 2.1.1.1 and SL 2.1.1.2 LA.1 2.2.1 2.1.2 2.2.2.1 2.2.2.2 Page 1 of 20 Attachment 1, Volume 4, Rev. 0, Page 5 of 46

Attachment 1, Volume 4, Rev. 0, Page 6 of 46 ITS Chapter 2.0 A.1 ITS A.1 LA.1 Page 2 of 20 Attachment 1, Volume 4, Rev. 0, Page 6 of 46

Attachment 1, Volume 4, Rev. 0, Page 7 of 46 ITS Chapter 2.0 A.1 ITS Page 3 of 20 Attachment 1, Volume 4, Rev. 0, Page 7 of 46

Attachment 1, Volume 4, Rev. 0, Page 8 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 4 of 20 Attachment 1, Volume 4, Rev. 0, Page 8 of 46

Attachment 1, Volume 4, Rev. 0, Page 9 of 46 ITS Chapter 2.0 A.1 ITS A.1 See ITS 3.3.1 Page 5 of 20 Attachment 1, Volume 4, Rev. 0, Page 9 of 46

Attachment 1, Volume 4, Rev. 0, Page 10 of 46 ITS Chapter 2.0 A.1 ITS A.1 See ITS 3.3.1 Page 6 of 20 Attachment 1, Volume 4, Rev. 0, Page 10 of 46

Attachment 1, Volume 4, Rev. 0, Page 11 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 7 of 20 Attachment 1, Volume 4, Rev. 0, Page 11 of 46

Attachment 1, Volume 4, Rev. 0, Page 12 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 8 of 20 Attachment 1, Volume 4, Rev. 0, Page 12 of 46

Attachment 1, Volume 4, Rev. 0, Page 13 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 9 of 20 Attachment 1, Volume 4, Rev. 0, Page 13 of 46

Attachment 1, Volume 4, Rev. 0, Page 14 of 46 ITS Chapter 2.0 A.1 ITS See CTS Chapter 6.0 2.2 A.3 LA.2 A.3 LA.2 A.3 Page 10 of 20 Attachment 1, Volume 4, Rev. 0, Page 14 of 46

Attachment 1, Volume 4, Rev. 0, Page 15 of 46 ITS Chapter 2.0 A.1 ITS A.1 2.1.1 A.2 the COLR Add proposed SL 2.1.1.1 and SL 2.1.1.2 LA.1 2.2.1 2.1.2 2.2.2.1 2.2.2.2 Page 11 of 20 Attachment 1, Volume 4, Rev. 0, Page 15 of 46

Attachment 1, Volume 4, Rev. 0, Page 16 of 46 ITS Chapter 2.0 A.1 ITS LA.1 Page 12 of 20 Attachment 1, Volume 4, Rev. 0, Page 16 of 46

Attachment 1, Volume 4, Rev. 0, Page 17 of 46 ITS Chapter 2.0 A.1 ITS Page 13 of 20 Attachment 1, Volume 4, Rev. 0, Page 17 of 46

Attachment 1, Volume 4, Rev. 0, Page 18 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 14 of 20 Attachment 1, Volume 4, Rev. 0, Page 18 of 46

Attachment 1, Volume 4, Rev. 0, Page 19 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 15 of 20 Attachment 1, Volume 4, Rev. 0, Page 19 of 46

Attachment 1, Volume 4, Rev. 0, Page 20 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 16 of 20 Attachment 1, Volume 4, Rev. 0, Page 20 of 46

Attachment 1, Volume 4, Rev. 0, Page 21 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 17 of 20 Attachment 1, Volume 4, Rev. 0, Page 21 of 46

Attachment 1, Volume 4, Rev. 0, Page 22 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 18 of 20 Attachment 1, Volume 4, Rev. 0, Page 22 of 46

Attachment 1, Volume 4, Rev. 0, Page 23 of 46 ITS Chapter 2.0 A.1 ITS See ITS 3.3.1 Page 19 of 20 Attachment 1, Volume 4, Rev. 0, Page 23 of 46

Attachment 1, Volume 4, Rev. 0, Page 24 of 46 ITS Chapter 2.0 A.1 ITS See CTS Chapter 6.0 2.2 A.3 LA.2 A.3 LA.2 A.3 Page 20 of 20 Attachment 1, Volume 4, Rev. 0, Page 24 of 46

Attachment 1, Volume 4, Rev. 0, Page 25 of 46 DISCUSSION OF CHANGES ITS CHAPTER 2.0, SAFETY LIMITS A.1 In the conversion of the CNP Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1431, Rev. 2, "Standard Technical Specifications-Westinghouse Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 2.1.1 references a curve providing limits on THERMAL POWER, pressurizer pressure, and the highest operating loop coolant average temperature (Tavg) "for 4 loop operation." ITS 2.1.1 does not contain this amplifying information.

This change is acceptable because the requirements have not changed. Both the ITS (ITS 3.4.4) and the CTS (CTS 3/4.4.1.1) require all four loops to be in operation in the applicable MODES (MODES 1 and 2). This change is designated as administrative because it eliminates redundant information in the CTS.

A.3 In the event that a safety limit is violated, CTS 6.7.1.a requires the NRC Operations Center to be notified by telephone within one hour, CTS 6.7.1.b requires a Safety Limit Violation Report to be prepared and specifies the information the report must contain, CTS 6.7.1.c requires the report to be submitted to the NRC, and CTS 6.7.1.d precludes resumption of operation of the unit until authorized by the NRC. The ITS does not specify any of these requirements.

These deletions are acceptable since the actual requirements are not being changed. These CTS requirements are duplicative of those currently located in 10 CFR 50.36(c)(1). Since CNP is required by the Operating License to comply with 10 CFR 50, the deletion of these requirements from the Technical Specifications is acceptable. The changes are designated as administrative since they are duplicative of regulations.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 2.1.1 requires that the combination of THERMAL POWER, pressurizer pressure, and the highest operating loop coolant average temperature not exceed the limits in Figure 2.1-1.

CNP Units 1 and 2 Page 1 of 3 Attachment 1, Volume 4, Rev. 0, Page 25 of 46

Attachment 1, Volume 4, Rev. 0, Page 26 of 46 DISCUSSION OF CHANGES ITS CHAPTER 2.0, SAFETY LIMITS ITS 2.1.1 states that the combination of THERMAL POWER, RCS highest loop average temperature, and pressurizer pressure shall not exceed the limits specified in the COLR and provides specific limits on DNBR and peak fuel centerline temperature. This changes the CTS by relocating limits that must be confirmed on a cycle specific basis to the COLR. The limiting Safety Limit parameters are retained in the SL.

The removal of these cycle specific parameter limits from the Technical Specifications to the COLR and the retention of the limiting Safety Limits in the Technical Specifications is acceptable because the cycle specific limits are developed or utilized under NRC-approved methodologies that ensure the Safety Limits are met. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From Technical Specifications," that this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the Safety Limits. NRC-approved Topical Report WCAP-14483-A, "Generic Methodology for Expanded Core Operating Limits Report," determined that the specific values for these parameters may be relocated to the COLR provided the limiting Safety Limits continue to appear in the Technical Specifications. The methodologies used to develop the parameters in the COLR were approved by the NRC in accordance with Generic Letter 88-16. Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.5, "Core Operating Limits Report." ITS 5.6.5 ensures that the applicable limits of the safety analysis are met (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits). This change is designated as a less restrictive removal of detail change because information relating to cycle specific parameter limits is being removed from the Technical Specifications.

LA.2 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) In the event that a Safety Limit is violated, CTS 6.7.1.a requires the Chairman of the NSRB to be notified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, CTS 6.7.1.b requires the Safety Limit Violation Report to be reviewed by the PORC, and CTS 6.7.1.c requires the report to be submitted to the Chairman of the NSRB and the Senior Vice President - Nuclear Operations within 14 days of the violation. The ITS does not include these requirements; they have been relocated to the Quality Assurance Program Description (QAPD).

The removal of these details for making notifications/reports from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The notification occurs following the Safety Limit violation and the reports are after-the-fact reports, thus they are not necessary to assure safe operation of the unit. The ITS still requires the unit to be shut down, and 10 CFR 50.36(c)(1) provides NRC reporting requirements and requires the NRC's permission to be obtained prior to restarting the unit. Also, this change is acceptable because these types of details will be adequately controlled in the QAPD. The QAPD is controlled under 10 CFR 50.54 which ensures changes are properly evaluated. This change is designated as a less restrictive removal of CNP Units 1 and 2 Page 2 of 3 Attachment 1, Volume 4, Rev. 0, Page 26 of 46

Attachment 1, Volume 4, Rev. 0, Page 27 of 46 DISCUSSION OF CHANGES ITS CHAPTER 2.0, SAFETY LIMITS detail change because reporting requirements are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES None CNP Units 1 and 2 Page 3 of 3 Attachment 1, Volume 4, Rev. 0, Page 27 of 46

Attachment 1, Volume 4, Rev. 0, Page 28 of 46 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 28 of 46

, Volume 4, Rev. 0, Page 29 of 46 , Volume 4, Rev. 0, Page 29 of 46

Attachment 1, Volume 4, Rev. 0, Page 30 of 46 2.0 1

INSERT 1 greater than or equal to the 95/95 DNB criterion for the DNB correlations and methodologies specified in Specification 5.6.5 Insert Page 2.0-1 Attachment 1, Volume 4, Rev. 0, Page 30 of 46

Attachment 1, Volume 4, Rev. 0, Page 31 of 46 JUSTIFICATION FOR DEVIATIONS ITS CHAPTER 2.0, SAFETY LIMITS

1. The brackets have been removed and the proper plant specific information/value has been provided.

2. ISTS 2.2.1 states that if SL 2.1.1 is violated to "restore compliance and be in MODE 3 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />." SL 2.1.1 is only applicable in MODES 1 and 2. Therefore, since ISTS 2.2.1 requires being in MODE 3 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, the "restore compliance" action is superfluous and has been deleted. This is also consistent with the CTS, which only requires being in MODE 3 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 31 of 46

Attachment 1, Volume 4, Rev. 0, Page 32 of 46 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 4, Rev. 0, Page 32 of 46

, Volume 4, Rev. 0, Page 33 of 46 , Volume 4, Rev. 0, Page 33 of 46

Attachment 1, Volume 4, Rev. 0, Page 34 of 46 B 2.1.1 1 INSERT 1 Plant Specific Design Criterion (PSDC) 6 1 INSERT 2 all expected conditions of normal operation, with appropriate margins for uncertainties and specified transient situations that can be anticipated Insert Page B 2.1.1-1 Attachment 1, Volume 4, Rev. 0, Page 34 of 46

, Volume 4, Rev. 0, Page 35 of 46 , Volume 4, Rev. 0, Page 35 of 46

Attachment 1, Volume 4, Rev. 0, Page 36 of 46 B 2.1.1 2 INSERT 3 operational transients and transient conditions arising from faults of moderate frequency Insert Page B 2.1.1-2 Attachment 1, Volume 4, Rev. 0, Page 36 of 46

, Volume 4, Rev. 0, Page 37 of 46 , Volume 4, Rev. 0, Page 37 of 46

Attachment 1, Volume 4, Rev. 0, Page 38 of 46 B 2.1.1 2 INSERT 4 transient conditions arising from faults of moderate frequency 1

INSERT 5 UFSAR, Section 1.4.2.

2 INSERT 6

2. UFSAR, Section 3.5.3 (Unit 1) and Section 3.4.1 (Unit 2).

Insert Page B 2.1.1-3 Attachment 1, Volume 4, Rev. 0, Page 38 of 46

, Volume 4, Rev. 0, Page 39 of 46 , Volume 4, Rev. 0, Page 39 of 46

Attachment 1, Volume 4, Rev. 0, Page 40 of 46 B 2.1.2 1 INSERT 1 Plant Specific Design Criterion (PSDC) 9, "Reactor Coolant Pressure Boundary" 1 INSERT 2 shall be designed, fabricated, and constructed so as to have an exceedingly low probability of gross rupture or significant uncontrolled leakage throughout its design lifetime. The RCS, in conjunction with its control and protective provisions, was designed to accommodate the system pressures and temperatures attained under the expected modes of plant operation or anticipated system interactions, and to maintain the stresses within allowable code stress limits.

1 INSERT 3 PSDC 33, "Reactor Coolant Pressure Boundary Capability" (Ref. 1), the reactor coolant pressure boundary shall be capable of accommodating without rupture the static and dynamic loads imposed on any boundary component as a result of an inadvertent and sudden release of energy to the coolant. As a design reference, this sudden release shall be taken as that which would result from a sudden reactivity insertion such as rod ejection (unless prevented by positive mechanical means), rod dropout, or cold water addition.

Insert Page B 2.1.2-1 Attachment 1, Volume 4, Rev. 0, Page 40 of 46

, Volume 4, Rev. 0, Page 41 of 46 , Volume 4, Rev. 0, Page 41 of 46

, Volume 4, Rev. 0, Page 42 of 46 , Volume 4, Rev. 0, Page 42 of 46

Attachment 1, Volume 4, Rev. 0, Page 43 of 46 B 2.1.2 1 INSERT 4 UFSAR, Sections 1.4.2 and 1.4.6.

Insert Page B 2.1.2-3 Attachment 1, Volume 4, Rev. 0, Page 43 of 46

Attachment 1, Volume 4, Rev. 0, Page 44 of 46 JUSTIFICATION FOR DEVIATIONS ITS CHAPTER 2.0 BASES, SAFETY LIMITS

1. CNP Units 1 and 2 were designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. CNP Units 1 and 2 were designed and constructed to meet the intent of the proposed General Design Criteria, published in 1967.

However, the CNP UFSAR contains discussions of the Plant Specific Design Criteria (PSDCs) used in the design of CNP Units 1 and 2. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section of the UFSAR.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. Editorial correction made to the Bases.

4. Typographical/grammatical error corrected.

5. The brackets have been removed and the proper plant specific information/value has been provided.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 44 of 46

Attachment 1, Volume 4, Rev. 0, Page 45 of 46 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 4, Rev. 0, Page 45 of 46

Attachment 1, Volume 4, Rev. 0, Page 46 of 46 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS CHAPTER 2.0, SAFETY LIMITS There are no specific NSHC discussions for this Chapter.

CNP Units 1 and 2 Page 1 of 1 Attachment 1, Volume 4, Rev. 0, Page 46 of 46