ML22244A219

Revised Draft TSTF-588, Revise List of COLR Methods (July 2022)

ML22244A219
Person / Time
Site:	Technical Specifications Task Force
Issue date:	07/07/2022
From:	Technical Specifications Task Force
To:	Office of Nuclear Reactor Regulation
Honcharik M
References
Download: ML22244A219 (34)

Text

DRAFT PWROG-10, Rev. 0 TSTF-588, Rev. 0 Technical Specifications Task Force Improved Standard Technical Specifications Change Traveler Revise List of COLR Methods NUREGs Affected: 1430 1431 1432 1433 1434 2194 Classification: 1) Technical Change Recommended for CLIIP?: No Correction or Improvement: Improvement NRC Fee Status: Not Exempt Benefit: Avoids Future Amendments Changes Marked on ISTS Rev 5.0 PWROG RISD & PA (if applicable): PA-LSC-1756 RS-2019-009 See attached.

Revision History OG Revision 0 Revision Status: Active Revision Proposed by: PWROG Revision

Description:

Original Issue Owners Group Review Information Date Originated by OG: 22-Apr-22 Owners Group Comments (No Comments)

Owners Group Resolution: Approved Date: 10-Jun-22 TSTF Review Information TSTF Received Date: 20-Jun-22 Date Distributed for Review 20-Jun-22 TSTF Comments:

(No Comments)

TSTF Resolution: Approved Date: 07-Jul-22 Affected Technical Specifications 5.6.3 Core Operating Limits Report 07-Jul-22 Copyright(C) 2022, 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.

DRAFT TSTF-588, Rev. 0

1.

SUMMARY

DESCRIPTION The proposed change revises Technical Specifications (TS) Section 5.6, "Reporting Requirements," Specification 5.6.3, "Core Operating Limits Report," (COLR) to revise the list of NRC-approved methods in the TS and to permit licensee evaluation under 10 CFR 50.59 of changes. A description of the analytical methods that may be changed under 10 CFR 50.59 will be in the Updated Final Safety Analysis Report (UFSAR) and all of the methods used to calculate core operating limits will be listed in the licensee-issued COLRs. The proposed change affects the Standard Technical Specifications (STS) in NUREG-1430, NUREG-1431, NUREG-1432, NUREG-1433, NUREG-1434, and NUREG-21941.

2. DETAILED DESCRIPTION 2.1. Background 2.1.1. Development of the Core Operating Limits Report In the 1970s and the 1980s, it was common for a licensee to submit a license amendment request (LAR) to revise TS limits due to core reload design and analysis changes. Changes to TS limits on cycle-specific, core operating parameters were often requested on an expedited basis because determination of some of the limits for the next cycle depended on the core burnup of the previous cycle and the LAR could not be submitted until after previous cycle burnup was known.

The license amendment was needed prior to the start of the new operating cycle.

As part of the NRC and industry's Technical Specifications Improvement Project (TSIP) following the accident at Three Mile Island, the Atomic Industrial Forum issued a report that included a recommendation to move cycle-specific limits from the TS to licensee control.

("Technical Specification Improvements," AIF Subcommittee on Technical Specification Improvements of the Committee on Reactor Licensing and Safety, October 1, 1985, enclosure to M. R. Edelman (AIF) letter to H.R. Denton (NRC), October 8, 1985.)

From 1985 to 1988, Duke Power Company (DPC) (acting as the lead plant for the Babcock &

Wilcox Owners Group) submitted several proposed changes to the Oconee TS to relocate cycle-specific limits to licensee control and to respond to NRC comments. A license amendment was approved on January 26, 1989.

1 NUREG-1430 provides the STS for Babcock & Wilcox plant designs.

NUREG-1431 provides the STS for Westinghouse plant designs.

NUREG-1432 provides the STS for Combustion Engineering plant designs.

NUREG-1433 provides the STS for BWR/4 plant designs, but is also representative of the BWR/2, BWR/3, and, in this case, BWR/5 design.

NUREG-1434 provides the STS for BWR/6 plant designs, and is representative, in some cases, of the BWR/5 plant design.

NUREG-2194 provides the STS for Westinghouse Advanced Passive (AP) 1000 plant designs.

Page 1

DRAFT TSTF-588, Rev. 0 On October 4, 1988, the NRC issued Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications." The GL referenced the Oconee LAR as the Babcock & Wilcox Owners Group lead plant submittal. It stated:

Generally, the methodology for determining cycle-specific parameter limits is documented in an NRC-approved Topical Report or in a plant-specific submittal. As a consequence, the NRC review of proposed changes to TS for these limits is primarily limited to confirmation that the updated limits are calculated using an NRC-approved methodology and consistent with all applicable limits of the safety analysis. These changes also allow the NRC staff to trend the values of these limits relative to past experience. This alternative allows continued trending of these limits without the necessity of prior NRC review and approval.

The GL also stated:

The current method of controlling reactor physics parameters to assure conformance to 10 CFR 50.36 is to specify the specific value(s) determined to be within specified acceptance criteria (usually the limits of the safety analyses) using an approved calculation methodology. The alternative contained in this guidance controls the values of cycle-specific parameters and assures conformance to 10 CFR 50.36, which calls for specifying the lowest functional performance levels acceptable for continued safe operation, by specifying the calculation methodology and acceptance criteria. This permits operation at any specific value determined by the licensee, using the specified methodology, to be within the acceptance criteria. The Core Operating Limits Report will document the specific values of parameter limits resulting from licensee's calculations including any mid-cycle revisions to such parameter values.

GL 88-16 was incorporated into the original versions of the improved STS. All operating plant TS include the COLR .

The correspondence leading up to and incorporated in GL 88-16 makes no mention of the need for NRC prior approval of changes to the methods listed in the COLR TS.

2.1.2. Removal of Revision Numbers and Dates from the TS TSTF-363-A, Rev. 0, "Revise Topical Report References in ITS 5.6.5, COLR," was submitted on March 13, 2000. It was based on a letter from Mr. Stuart A. Richards (NRC) to Mr. James F.

Mallay (Siemens Power Corporation) dated December 15, 1999, entitled "Acceptance for Siemens References to Approved Topical Reports in Technical Specifications," in which the NRC stated that it is acceptable for the references to Topical Reports in the TS to give only the Topical Report title and number as long as the complete citation is given in the COLR. The NRC proposed no questions on TSTF-363 and it was approved April 13, 2000.

The NRC Safety Evaluation for adoption of TSTF-363 for Arkansas Nuclear One, Unit 2, dated March 23, 2005, is typical. It states:

To further avoid the need for TS changes every time a revision to an approved TR is approved, the staff approved TS Task Force (TSTF) Traveler TSTF-363, Revised Page 2

DRAFT TSTF-588, Rev. 0 Topical Report References in ITS 5.6.5, COLR (reference 7), which allows for the listing of the TRs in the TS by only the numbers and titles, with the detailed identification of the TR revisions, supplement numbers, and approval dates specified in the COLR.

This method of referencing TRs allows the licensee to use current TRs to support limits in the COLR without having to submit an amendment to the TSs each time the TR is revised. The licensee also notes that future changes to the values of these limits by the licensee may only be developed using NRC approved methodologies, must remain consistent with all applicable plant safety analysis limits addressed in the safety analysis report, and are further controlled by the 10 CFR 50.59 process. The staff concludes that the licensees amendment conforms to the guidance in NRC GL 88-16 and TSTF-363.

Approximately three-quarters of the operating plants have relocated the methodology revisions and dates from the TS to the licensee-controlled COLR.

2.1.3. NRC Change in Position Regarding TSTF-363 In letters dated November 2, 2009, and December 11, 2009, the NRC described concerns with TSTF-363-A, Rev. 0 and two similar Travelers, TSTF-408-A, Revision 1, "Relocation of LTOP Enable Temperature and PORV Lift Setting to the PTLR (CE NPSD-683)," and TSTF-419-A, Revision 0, "Revise PTLR Definition and References in ISTS 5.6.6, RCS PTLR." The attachment to the November 2 letter (which was not modified by the December 11 letter) made the following statements:

GL 88-16 and GL 96-03 relocated the numerical values in TS Limiting Condition of Operations and added approved methodologies for calculating operating limits. This approach was considered to be acceptable so long as the Administrative Controls TS for the COLR or PTLR continued to provide a direct link to the specific methodology used to calculate the values previously listed in the TS. This arrangement would allow the actual values, previously listed in the TS, to be consistently reproduced and controlled. The guidance in GL 88-16 and GL 96-03 specifies the inclusion of Topical Report number, title, or other NRC approval document, and date in the TS for those parameters relocated to the COLR/PTLR. This approach links a particular parameter relocated to the COLR/PTLR to the specific analytical methodology that calculates the parameter.

Reference to a specific revision of a methodology in the TS was deemed equivalent to listing a particular parameter in the TS that is calculated by the methodology.

Removal of the Topical Report revision numbers or approval dates from the TS in accordance with the subject TSTF Travelers does not provide a direct link to specific TS numerical values relocated to the COLR/PTLR, since there is no reference to a specific methodology. The TSTF Travelers modify the TS removing reference to specific documents and, in effect, allow reference to a range of methodologies represented by various Topical Report revisions. Since the criterion contained in Title 10 of the Code of Federal Regulations Section 50.59(c)(2)(viii) allows licensees to use previously Page 3

DRAFT TSTF-588, Rev. 0 NRC-approved methodologies, this approach is not equivalent to listing a specific parameter in the TS.

On August 4, 2011, the NRC sent a letter to the TSTF stating amendment requests to adopt TSTF-363 would no longer be accepted. The NRC letter stated:

Maintaining a list of the methodologies in the TSs requires licensees to obtain NRC approval prior to editing the reference list. Among others, one reason that NRC approval is required prior to editing the reference list is so that the NRC staff can review the methodology and ensure that it is applicable to the facility of a given licensee.

Additionally, the NRC staff can verify that the licensee has properly satisfied all implementation conditions and limitations associated with a given methodology.

Because there is no inherent requirement to ensure that the implementation conditions and limitations associated with methodology revisions are maintained the same as previous revisions to the same methodology, or that the applicability of subsequent methodology revisions remains the same as earlier methodologies, the NRC staff finds that affording licensees the administrative flexibility to transition between or among methodology revisions is inappropriate.

Regarding the TSTF's contention that the change in position was a backfit, the NRC's letter stated:

The NRC staff does not intend to backfit licensees that have these travelers already in their TS. There is not a substantial increase in the overall protection of the public health and safety to be derived from backfitting licensees that have already adopted these travelers. A desire for additional clarity in the safety analysis is not indicative of an immediate safety concern. Therefore, backfitting would not be justified under Title 10 of the Code of Federal Regulations Section 50.109 because the safety benefit is not supported by the financial costs. As a result, these changes will not impact plants that already have TSTF-363, or previous versions of TSTF-408 or TSTF-419, approved and implemented in their plant-specific TS.

The NRC's position was incorporated into Revision 4 of the STS.

2.2. Current Technical Specifications Requirements STS Specification 5.6.3, "Core Operating Limits Report," in NUREG-1430, 1431, 1432, 1433, and 1434 states:

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

[ The individual specifications that address core operating limits must be referenced here. ]

Page 4

DRAFT TSTF-588, Rev. 0

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

---

REVIEWERS NOTE------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the Topical Report, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e.,

report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify the Topical Report(s) by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

In STS Specification 5.6.3 of NUREG-2194, the affected specifications are listed in paragraph "a" of the STS, the methods are listed in paragraph "b" of the STS, and there is no Reviewer's Note.

2.3. Reason for the Proposed Change The need for a license amendment to change the list of NRC-approved methods in Specification 5.6.3 limits licensee efforts to use new NRC-approved methods. As new NRC-approved methods generally have improved modeling or correct errors, the delay in implementing the new methods can have an unquantifiable but definite impact on plant safety.

The current TS requirement is inconsistent with the regulations. The 1999 10 CFR 50.59 rule change explicitly gives the licensee the responsibility for evaluating the use of new NRC-approved methods of evaluation. The rule change should have resulted in a change to Specification 5.6.3 to remove from the list those NRC-approved methods of evaluation which can be changed following the guidance in 10 CFR 50.592. Under 10 CFR 50.59, NRC prior 2

In this document, references to revising a method of evaluation following 10 CFR 50.59 does not necessarily mean that a screening or evaluation is required. The regulation is referenced in total, including 10 CFR 50.59(c)(4) which may require a review under a regulation that establishes more specific criteria for accomplishing the change.

Page 5

DRAFT TSTF-588, Rev. 0 approval should only be required if a revised method of evaluation is not NRC-approved for the proposed application or if the limitations or conditions are not met.

Further, the requirement for NRC prior review of changes to COLR analytical methods is not consistently implemented:

• Half of the BWRs primarily reference the GE GESTAR document in their COLR list without a revision number or date. Use of new methods referenced in an NRC-approved revision to the GESTAR are made without a license amendment.

• Approximately two-thirds of US plants have removed the revision numbers and approval dates from the list of approved methods in the TS. Adoption of a different revision may be evaluated under 10 CFR 50.59 for those plants, but not for the remaining third of the fleet.

Revising the list of analytical methods in the TS to remove the NRC-approved methods of evaluation that can be revised under the controls in 10 CFR 50.59 would permit a consistent regulatory position to be applied to all licensees.

2.4. Description of the Proposed Change In NUREG-1430 through -1434, the following changes are proposed to Specification 5.6.3 (additions are in italics, deletions are struck through):

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR.

Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59.

Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE---------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the any Topical Report that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved analytical methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Page 6

DRAFT TSTF-588, Rev. 0 System (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

In NUREG-2194, the list of methods in paragraph b is placed in brackets indicating that the licensee should list only the references that are not methods of evaluation that can be changed under 10 CFR 50.59. The other changes are the same.

The TS Bases are not affected by the proposed change.

A model application is attached. The model may be used by licensees desiring to adopt the traveler following NRC approval. Attachment 1 of the model application contains a description of the methods currently listed in TS 5.6.3 to be removed and that can be changed under 10 CFR 50.59.

3. TECHNICAL EVALUATION The proposed change removes from the Specification 5.6.3 list of NRC-approved methods used to calculate COLR values those methods of evaluation that are subject to control under 10 CFR 50.59, which states:

(c)(2) A licensee shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would:

(viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses.

NEI 96-07, Revision 1, "Guidelines for 10 CFR 50.59 Implementation," (November 2000),

which is endorsed by NRC Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, 'Changes, Tests, And Experiments'," Section 3.10 states:

Methods of evaluation described in the UFSAR subject to criterion 10 CFR 50.59(c)(2)(viii) are:

• Methods of evaluation used in analyses that demonstrate that design basis limits of fission product barriers are met (i.e., for the parameters subject to criterion 10 CFR 50.59(c)(2)(vii)).

• Methods of evaluation used in UFSAR safety analyses, including containment, ECCS and accident analyses typically presented in UFSAR Chapters 6 and 15, to demonstrate that consequences of accidents do not exceed 10 CFR 100 or 10 CFR 50, Appendix A, dose limits.

• Methods of evaluation used in supporting UFSAR analyses that demonstrate intended design functions will be accomplished under design basis conditions that the plant is required to withstand, including natural phenomena, environmental conditions, dynamic effects, station blackout and ATWS.

Page 7

DRAFT TSTF-588, Rev. 0 Many of the NRC-approved methods of evaluation used to calculate COLR values meet one or more of these criteria. Those methods will be removed from the Specification 5.6.3 list and changes to those NRC-approved analytical methods will be evaluated by the licensee under 10 CFR 50.59. If the licensee's evaluation of the change determines that NRC prior review is necessary, a license amendment will be required.

Some NRC-approved methods referenced in the COLR, such as those related to Surveillance Requirement testing or TS mitigating actions, may not be a method of evaluation as defined in 10 CFR 50.59 and changes cannot be made under 10 CFR 50.59. Those methods will continue to be listed in the TS COLR section and changes to those methods will require NRC prior approval.

A complete list of the NRC-approved methods (including revision numbers and dates) used to calculate core operating limits will be included in the licensee-issued COLRs, which are also provided to the NRC.

The proposed change is justified because:

• Evaluating Changes to COLR Methods Under 10 CFR 50.59 Protects Plant Safety.

• Evaluating Changes to COLR Methods Under 10 CFR 50.59 Is Consistent with the Regulations.

• Licensees Have the Expertise to Evaluate Changes to COLR Methods.

3.1. Evaluating Changes to COLR Methods under 10 CFR 50.59 Protects Plant Safety Licensee UFSARs describe many NRC-approved methods that are used to perform calculations that assure plant safety. Most of those methods are not listed in TS 5.6.3 because the results of the calculations are not TS limits that appear in the COLR. For example, containment overpressure analyses, turbine missile analyses, and dose assessment methods utilize NRC-approved methods and verify that safety limits and design basis assumptions are met.

Revision or replacement of those methods is evaluated under 10 CFR 50.59. If prior NRC review is required, a license amendment is submitted. If not, the licensee may make the change under the authority given in 10 CFR 50.59.

The use of 10 CFR 50.59 to evaluate method changes has been in effect for over 20 years and is understood by licensees. Changes to methods of evaluation used for establishing core operating limits will be made using the process described in 10 CFR 50.59. If it is determined that a proposed change is a departure from a method of evaluation as defined in paragraph (a)(2), the licensee will obtain a license amendment pursuant to 10 CFR 50.90 prior to implementing the proposed change. It is incumbent upon the licensee to ensure the methods have been approved by the NRC for the intended application and the applicable conditions and limitations are satisfied.

The NRC is provided a summary of completed 10 CFR 50.59 evaluations periodically by each licensee. In addition, the NRC periodically reviews the licensee's implementation of 10 CFR 50.59 as part of the NRC inspections conducted under the Reactor Oversight Process.

Finally, the NRC will receive a list of the TS limits and the NRC-approved methods used to calculate those limits in the submitted COLRs.

Page 8

DRAFT TSTF-588, Rev. 0 The methods of evaluation listed in TS 5.6.3 are no more safety significant or complex than other NRC-approved methods used by licensees that are not cited in the TS, and the ability to evaluate changes under 10 CFR 50.59 is precluded only because they are listed in the TS. Submitting a license amendment to obtain NRC prior approval of the use of an NRC-approved method does not have a significant effect on safety because the information provided to the NRC in the license amendment request is similar to the information that a licensee is required to evaluate when applying 10 CFR 50.59. The NRC-approved method is not changed, the determination of applicability does not change, and the implementation of the conditions and limitations does not change simply because a license amendment is not submitted. The only change is that the NRC no longer performs a prior review of this information for every change to a COLR method and instead performs a prior review only for those changes that are not a method of evaluation as defined in 10 CFR 50.59, or are a change to a method of evaluation that cannot be performed under 10 CFR 50.59 without prior NRC approval.

Currently, licensees may make some changes to COLR methods without NRC prior review. For example, the TS for approximately half of the BWR fleet primarily reference the GE GESTAR document in their COLR list without a revision number or date. Use of new or revised methods referenced in the GESTAR are made without a license amendment. Also, approximately two-thirds of US plants have removed the revision numbers and approval dates from the list of approved methods in the TS. That removal permits the use of a different revision of the methods for those plants under 10 CFR 50.59 without prior NRC approval. There is no evidence that those allowances have a negative effect on plant safety.

There are other regulatory changes that have resulted in items controlled in the TS being moved to licensee control. The 1993 addition of 10 CFR 50.36, "Technical Specifications," paragraph (c)(2)(ii) criteria resulted in approximately one-third of the TS being placed under licensee control with changes being evaluated under 10 CFR 50.59. GL 93-08, "Relocation of Technical Specification Tables of Instrument Response Time Limits," and GL 95-10, "Relocation of Selected Technical Specifications Requirements Related to Instrumentation," also moved information from the TS to licensee control under 10 CFR 50.59. There is no evidence that those changes had a negative effect on plant safety.

In summary, removing from the TS the COLR methods of evaluation which may be changed under 10 CFR 50.59 will maintain plant safety and reduce unnecessary regulatory burden.

3.2. Evaluating Changes to COLR Methods under 10 CFR 50.59 is Consistent with the Regulations The proposed change satisfies the requirements in 10 CFR 50.36. GL 88-16 stated:

The current method of controlling reactor physics parameters to assure conformance to 10 CFR 50.36 is to specify the specific value(s) determined to be within specified acceptance criteria (usually the limits of the safety analyses) using an approved calculation methodology. The alternative contained in this guidance controls the values of cycle-specific parameters and assures conformance to 10 CFR 50.36, which calls for specifying the lowest functional performance levels acceptable for continued safe operation, by specifying the calculation methodology and acceptance criteria. This permits operation at Page 9

DRAFT TSTF-588, Rev. 0 any specific value determined by the licensee, using the specified methodology, to be within the acceptance criteria. The Core Operating Limits Report will document the specific values of parameter limits resulting from licensee's calculations including any mid-cycle revisions to such parameter values.

Under the proposed change, the Core Operating Limits Reports submitted to the NRC will continue to document the specific values of the parameter limits resulting from licensee's calculations, and will specify the NRC-approved calculational methodology used to determine the limits. The staff's conclusion in GL 88-16 that 10 CFR 50.36 would continue to be met was not dependent on NRC prior approval of changes to the NRC-approved methodologies, but on providing the limits and associated methodologies in the submitted reports.

The proposed change is also consistent with the requirements of 10 CFR 50.59. When GL 88-16 was issued, 10 CFR 50.59 had no specific controls related to methods of evaluation and the questions to determine if a change was an "unreviewed safety question" did not relate to methods. The proposed TS in the GL contained a list of NRC-approved methods because there was no other applicable regulatory control method at that time.

In 1999, a new version of 10 CFR 50.59 was issued (64FR53582, October 4, 1999), and a new set of criteria was introduced, including Criterion viii, which stated:

"(c)(2) A licensee shall obtain a license amendment pursuant to Sec. 50.90 prior to implementing a proposed change, test, or experiment if the change, test, or experiment would:

(viii) Result in a departure from a method of evaluation described in the FSAR (as updated) used in establishing the design bases or in the safety analyses."

The Statements of Consideration for the rule change (64FR53599) explained, "The rule requirements for evaluation methods would allow for use of generic topical reports as not being a

'departure,' provided that the topical report is applicable to the facility, and is used within the terms and conditions specified in the approved topical report."

The Statements of Consideration also included an example of application of Criterion viii to methods that could result in a change to a TS limit in the COLR:

Example 3: The licensee wishes to change a non-LOCA FSAR Chapter 15 transient methodology. The methodology is being changed to a different vendor's NRC approved method. The new vendor's method has been approved generically for the particular reactor type (e.g., 2 loop PWR) and for the particular transient being analyzed. The analysis is being performed in accordance with all the applicable limitations and restrictions. The licensee can make this change without prior NRC approval because using a generically approved method for the purpose it was approved, while meeting all the limitations and restrictions, is not a "departure." Subsequent plant changes can then be evaluated using this new method and the other seven criteria in Sec. 50.59.

Page 10

DRAFT TSTF-588, Rev. 0 NEI 96-07, Section 4.3.8.2, "Guidance for Changing from One Method of Evaluation to Another," states (emphasis added):

The definition of 'departure' provides licensees with the flexibility to make changes under 10 CFR 50.59 from one method of evaluation to another provided that the new method is approved by the NRC for the intended application. A new method is approved by the NRC for intended application if it is approved for the type of analysis being conducted, and applicable terms, conditions and limitations for its use are satisfied.

NRC approval has typically followed one of two paths. Most reactor or fuel vendors and several utilities have prepared and obtained NRC approval of topical reports that describe methodologies for the performance of a given type or class of analysis. Through a safety evaluation report (SER), NRC approved the use of the methodologies for a given class of power plants. In some cases, the NRC has accorded generic approval of analysis methodologies. Terms, conditions, and limitations relating to the application of the methodologies are usually documented in the topical reports, the SER, and correspondence between the NRC and the methodology owner that is referenced in the SER or associated transmittal letter.

The applicable terms and conditions for the use of a methodology are not limited to a specific analysis; the qualification of the organization applying the methodology is also a consideration. Through Generic Letter 83-11, Supplement 13, the NRC has established a method by which licensees can demonstrate they are generally qualified to perform safety analyses. Licensees thus qualified can apply methods that have been reviewed and approved by the NRC, or that have been otherwise accepted as part of another plants licensing basis, without requiring prior NRC approval. Licensees that have not satisfied the guidelines of Generic Letter 83-11, Supplement 1, may, of course, continue to seek plant-specific approval to use new methods of evaluation. (emphasis added)

When considering the application of a methodology, it is necessary to adopt the methodology en toto and apply it consistent with applicable terms, conditions, and limitations. Mixing attributes of new and existing methodologies is considered a revision to a methodology and must be evaluated as such per the guidance in Section 4.3.8.1.

Regulatory Guide 1.187 did not take exception to this section of NEI 96-07.

3 Generic Letter 83-11, Supplement 1, Licensee Qualification for Performing Safety Analyses, June 24, 1999.

Page 11

DRAFT TSTF-588, Rev. 0 NEI 96-07, Section 4.3.8, "Does the Activity Result in a Departure from a Method of Evaluation Described in the UFSAR Used in Establishing the Design Bases or in the Safety Analyses?"

states (emphasis added):

Because 10 CFR 50.59 provides a process for determining if prior NRC approval is required before making changes to the facility as described in the UFSAR, changes to the methodologies described in the UFSAR also fall under the provisions of the 10 CFR 50.59 process, specifically criterion (c)(2)(viii). In general, licensees can make changes to elements of a methodology without first obtaining a license amendment if the results are essentially the same as, or more conservative than, previous results. Similarly, licensees can also use different methods without first obtaining a license amendment if those methods have been approved by the NRC for the intended application.

[T]he following changes are not considered departures from a method of evaluation described in the UFSAR: Use of a new NRC-approved methodology (e.g., new or upgraded computer code) to reduce uncertainty, provide more precise results or other reason, provided such use is (a) based on sound engineering practice, (b) appropriate for the intended application and (c) within the limitations of the applicable SER. The basis for this determination should be documented in the licensee evaluation. Use of a methodology revision that is documented as providing results that are essentially the same as, or more conservative than, either the previous revision of the same methodology or another methodology previously accepted by NRC through issuance of an SER.

In an August 4, 2011, letter to the TSTF, the NRC stated, "Maintaining a list of the methodologies in the TSs requires licensees to obtain NRC approval prior to editing the reference list. Among others, one reason that NRC approval is required prior to editing the reference list is so that the NRC staff can review the methodology and ensure that it is applicable to the facility of a given licensee. Additionally, the NRC staff can verify that the licensee has properly satisfied all implementation conditions and limitations associated with a given methodology." (Emphasis added.)

The 1999 rule change to 10 CFR 50.59 and its NRC-accepted implementing guidance specifically place those responsibilities on the licensee, not the NRC.

• NEI 96-07, Section 4.3.8.2, states that a licensee may make changes under 50.59 from one method of evaluation to another provided the new method is approved by the NRC for the intended application and the applicable terms, conditions, and limitations are satisfied.

• NEI 96-07 requires these criteria to be documented in the evaluation:

- "The licensee should address these and similar considerations, as applicable, and document in the 10 CFR 50.59 evaluation the basis for determining that a method is appropriate and approved for the intended application." (emphasis added)

- "Use of a new NRC-approved methodology (e.g., new or upgraded computer code) to reduce uncertainty, provide more precise results or other reason, Page 12

DRAFT TSTF-588, Rev. 0 provided such use is (a) based on sound engineering practice, (b) appropriate for the intended application and (c) within the limitations of the applicable SER. The basis for this determination should be documented in the licensee evaluation."

(emphasis added)

For previously NRC-approved methodologies, the 1999 change to 10 CFR 50.59 gave licensees, not the NRC, the responsibility for evaluating changes to methods to determine if the methods are applicable and that the conditions and limitations are met. Requiring NRC prior review of these items is inconsistent with 10 CFR 50.59.

3.3. Licensees Have the Expertise to Evaluate Changes to COLR Methods The vendors and licensees that developed the NRC-approved methods currently listed in the COLR are most familiar with those methods and their use in conjunction with other core reload design tools, and, as a result, are best equipped to evaluate the effect of incorporating new methods into the core reload design process.

Licensees are fully capable of controlling methods in accordance with applicable regulations, including those methods used in the design of reload cores. Each licensee maintains an NRC-approved Quality Assurance Program (QAP) that describes how the requirements of Appendix B to 10 CFR Part 50, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," are met. Changes to the reload core design methods are subject to the requirements of Appendix B and the QAP to ensure that a reload core design will operate within the design and licensing requirements specified in a stations Updated Final Safety Analysis Report (UFSAR). Further, the QAP describes the broad-scope requirements for training and qualification of personnel.

The reload core design process is subject to Appendix B,Section III, which establishes the necessary elements for design control, and Section V, which requires documented instructions or procedures to ensure the design control requirements are satisfactorily accomplished. Design control requires that the applicable regulatory and design requirements be documented, and that design interfaces between participating design organizations be identified and controlled. Design changes must be subject to these measures.

Licensees and fuel vendors have established processes controlling the design, evaluation, and implementation of reload core designs. If changes to the methods used in evaluating the requirements are necessary, then they are reviewed against the provisions of 10 CFR 50.59 to determine if prior NRC review and approval is required.

Appendix B, together with the licensee QAP and supporting procedures, ensures that licensee staff have the training, qualifications, and expertise necessary to use and control reload core design methods.

The NRC performs periodic inspections and audits of licensee Appendix B and 10 CFR 50.59 programs. These inspections and audits provide an ongoing means of ensuring licensee capability to control changes to methods, including reload core design methods.

Page 13

DRAFT TSTF-588, Rev. 0 3.4. Control of COLR Analytical Methods Under the proposed change, the licensee will remove from the list of methods in the TS those methods of evaluation that may be changed under 10 CFR 50.59. A new requirement is added which requires all of the methods used to calculate core operating limits to be in the licensee-issued COLR. Criterion viii of 10 CFR 50.59 would require a license amendment prior to implementation of changes to a method of evaluation if:

(a) implementation of the activity changes a method of evaluation described in the UFSAR to another method (i.e., replaces or adopts a new method of evaluation) and the new method of evaluation had not been previously approved by the NRC for the intended application; or (b) implementation of the activity changes any of the elements of the currently specified method of evaluation described in the UFSAR (i.e., revises an existing UFSAR method of evaluation) and the results of the revised method are neither conservative nor essentially the same.

Paragraph (b) of the COLR TS is revised to require the submitted COLRs to list all analytical methods used to determine the COLR limits. Currently, only plants that do not list analytical method revision numbers and dates in the TS are required to include the list of methods in the submitted COLR. Requiring all submitted COLRs to list both the core operating limits and the methods used to calculate those limits is consistent with GL 88-16 and provides the NRC with oversight of the methods used.

3.5. Change to Oversight in lieu of Prior Approval The proposed change will provide the NRC staff with oversight of the TS limits and changes to the NRC-approved methods used to calculate the limits. As stated in GL 88-16, submittal of the COLR to the NRC would allow continued trending of this information. The cycle-specific limits and the NRC-approved methods will be listed in the submitted COLR. The NRC staff can, and has, asked questions regarding submitted COLRs.

The proposed change would not have a detrimental effect on the topical report review process.

Many, if not the majority, of topical reports reviewed by the NRC are not referenced in plant-specific TS COLR specifications. The NRCs review process routinely establishes the intended use and applicable terms, conditions, and limitations to permit evaluation of the use of these topical reports under 10 CFR 50.59. That same process may be applied to methods referenced in the COLR.

3.6. Applicability to Other Specifications The proposed change is applicable to other TS requirements, such as the Pressure/Temperature Limits Report (PTLR). The proposed change focuses on COLR methods, as the list of methods is typically much longer and more frequently changed than the PTLR. Whether changes to other TS are warranted will be considered after completion of this proposed change.

Page 14

DRAFT TSTF-588, Rev. 0 3.7. Conclusion The proposed change will revise the TS requirements to be consistent with the regulations and to eliminate unnecessary NRC prior review when adopting NRC-approved methods.

4. REGULATORY EVALUATION The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(b) requires:

Each license authorizing operation of a utilization facility will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 ["Contents of applications; technical information"]. The Commission may include such additional technical specifications as the Commission finds appropriate.

Per 10 CFR 50.90, whenever a holder of a license desires to amend the license, application for an amendment must be filed with the Commission, fully describing the changes desired, and following as far as applicable, the form prescribed for original applications.

Per 10 CFR 50.92(a), in determining whether an amendment to a license will be issued to the applicant, the Commission will be guided by the considerations which govern the issuance of initial licenses to the extent applicable and appropriate.

Section IV, "The Commission Policy," of the "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58FR39132), dated July 22, 1993, states in part that improved STS have been developed and will be maintained for each NSSS owners group. The Commission Policy encourages licensees to use the improved STS as the basis for plant-specific Technical Specifications." The industry's proposal of travelers and the NRC's approval of travelers is the method used to maintain the improved STS as described in the Commission's Policy. Following NRC approval, licensees adopt travelers into their plant-specific technical specifications following the requirements of 10 CFR 50.90. Therefore, the traveler process facilitates the Commission's policy while satisfying the requirements of the applicable regulations.

The regulation at 10 CFR 50.36(a)(1) also requires the application to include a "summary statement of the bases or reasons for such specifications, other than those covering administrative controls." The proposed traveler does not affect the Bases and, therefore, does not affect compliance with 10 CFR 50.36(a)(1).

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

Page 15

DRAFT TSTF-588, Rev. 0

5. REFERENCES

1. Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," October 4, 1988.

2. TSTF-363-A, Rev. 0, "Revise Topical Report references in ITS 5.6.5, COLR," April 13, 2000.

3. Letter from John R. Jolicoeur (NRC) to Technical Specifications Task Force, "Implementation of Travelers TSTF-363, Revision 0, Revise Topical Report References In ITS 5.6.5, COLR [Core Operating Limits Report], TSTF-408, Revision 1, Relocation Of LTOP [Low Temperature Overpressure Protection] Enable Temperature And PORV [Power-Operated Relief Valve] Lift Setting To The PTLR [Pressure-Temperature Limits Report],

And TSTF-419, Revision 0, Revise PTLR Definition And References In ISTS [Improved Standard Technical Specification] 5.6.6, RCS [Reactor Coolant System] PTLR, August 4, 2011 (ADAMS Accession No. ML110660285).

4. NEI 96-07, Revision 1, "Guidelines for 10 CFR 50.59 Implementation," November 2000 (ADAMS Accession No. ML00377115).

5. NRC Regulatory Guide 1.187, "Guidance for Implementation of 10 CFR 50.59, 'Changes, Tests, And Experiments'," Revision 2, June 2020.

Page 16

DRAFT TSTF-588, Rev. 0 Model Application

DRAFT TSTF-588, Rev. 0

[DATE] 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 DOCKET NO.PLANT NAME

[50/52]-[xxx]

SUBJECT:

Application to Revise Technical Specifications to Adopt TSTF-588, "Revise List of COLR Methods" Pursuant to 10 CFR 50.90, [LICENSEE] is submitting a request for an amendment to the Technical Specifications (TS) for [PLANT NAME, UNIT NOS.].

[LICENSEE] requests adoption of TSTF-588, "Revise List of COLR Methods," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] TS. TSTF-588 revises the list of NRC-approved methods in TS 5.6.3, "Core Operating Limits Report," (COLR).

The enclosure provides a description and assessment of the proposed changes. Attachment 1 provides the existing TS pages marked to show the proposed changes. Attachment 2 provides revised (clean) TS pages.

Once approved, the amendment shall be implemented within [90] days.

There are no regulatory commitments made in this application.

In accordance with 10 CFR 50.91, a copy of this application, with attachment, is being provided to the designated [STATE] Official.

[In accordance with 10 CFR 50.30(b), a license amendment request must be executed in a signed original under oath or affirmation. This can be accomplished by attaching a notarized affidavit confirming the signature authority of the signatory, or by including the following statement in the cover letter: "I declare under penalty of perjury that the foregoing is true and correct.

Executed on (date)." The alternative statement is pursuant to 28 USC 1746. It does not require notarization.]

Page 1

DRAFT TSTF-588, Rev. 0 If you should have any questions regarding this submittal, please contact [NAME, TELEPHONE NUMBER].

Sincerely,

[Name, Title]

Enclosure:

Description and Assessment Attachments: 1. List of Methods to be Removed from TS 5.6.3

2. Proposed Technical Specification Changes (Mark-Up)

[Attachment 2 is to be provided by the licensee and is not included in the model application.]

cc: NRC Project Manager NRC Regional Office NRC Resident Inspector State Contact Page 2

DRAFT TSTF-588, Rev. 0 ENCLOSURE DESCRIPTION AND ASSESSMENT

1.0 DESCRIPTION

[LICENSEE] requests adoption of TSTF-588, "Revise List of COLR Methods," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-588 revises the list of NRC-approved methods in TS 5.6.3, "Core Operating Limits Report," (COLR).

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation

[LICENSEE] has reviewed the safety evaluation for TSTF-588 provided to the Technical Specifications Task Force in a letter dated [DATE]. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-588. [As described herein,]

[LICENSEE] has concluded that the justifications presented in TSTF-588 and the safety evaluation prepared by the NRC staff are applicable to [PLANT, UNIT NOS.] and justify this amendment for the incorporation of the changes to the [PLANT] TS. presents a list of TS 5.6.3 methods that are proposed to be removed from the TS with a description why each is a method of evaluation subject to licensee control under 10 CFR 50.59, as well as verification that the method is described in the UFSAR or a commitment to add the description to the UFSAR.

---

PREPARER'S NOTE ------------------------------------------

If the current COLR does not list all analytical methods used to calculate the core operating limits, include the following.

((LICENSEE] will issue a revised COLR listing all analytical methods used to calculate core operating limits prior to implementation of the approved amendment.]

2.2 Variations

[LICENSEE is not proposing any variations from the TS changes described in TSTF-588 or the applicable parts of the NRC staffs safety evaluation dated [DATE.] [LICENSEE is proposing the following variations from the TS changes described in TSTF-588 or the applicable parts of the NRC staffs safety evaluation: describe the variations.]

[The [PLANT] TS utilize different [numbering][and][titles] than the STS on which TSTF-588 was based. Specifically, [describe differences between the plant-specific TS numbering and/or titles and the TSTF-588 numbering and titles.] These differences are administrative and do not affect the applicability of TSTF-588 to the [PLANT] TS.]

Page 3

DRAFT TSTF-588, Rev. 0

[The [PLANT] TS contain requirements that differ from the STS on which TSTF-588 was based but are encompassed in the TSTF-588 justification. [Describe differences and why TSTF-588 is still applicable.]

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

[LICENSEE] requests adoption of TSTF-588, "Revise List of COLR Methods," which is an approved change to the Standard Technical Specifications (STS), into the [PLANT NAME, UNIT NOS] Technical Specifications (TS). TSTF-588 revises the list of NRC-approved methods from TS 5.6.3, "Core Operating Limits Report," (COLR).

[LICENSEE] has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change revises the list of NRC-approved methods in the TS to remove those methods of evaluation that may be changed under 10 CFR 50.59.

The proposed change has no effect on plant structures, systems, and components (SSCs) and does not affect plant operation. As a result, the probability of any accident previously evaluated is not significantly increased. The TS continues to require that the core operating limits ensure all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits, transient analysis limits, and accident analysis limits) of the safety analysis are met. As a result, the consequences of accidents previously evaluated are not significantly increased. The analytical methods used to determine the consequences of previously evaluated accidents will be controlled under the applicable regulations, and any significant increase in consequences would require prior NRC approval.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change revises the list of NRC-approved methods in the TS to remove those methods of evaluation that may be changed under 10 CFR 50.59.

Page 4

DRAFT TSTF-588, Rev. 0 The proposed change will not change the design function or operation of the plant SSCs.

As a result, no new credible failure mechanisms, malfunctions, or accident initiators are introduced. The analytical methods used to determine core operating limits will be controlled in accordance with the regulations, and NRC prior approval of a change to an analytical method will be obtained if required.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change revises the list of NRC-approved methods in the TS to remove those methods of evaluation that may be changed under 10 CFR 50.59.

The calculated values in the COLR include controlling values of parameters that avoid exceeding regulatory or licensing limits. However, the TS continues to require that the calculated core operating limits ensure that all applicable limits of the safety analysis are met. Changes to any analytical methods used to determine COLR values are controlled by the regulations, and prior NRC approval will be obtained if required by the regulations. The TS Safety Limit values are not included in the COLR and are not affected by the proposed change.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, [LICENSEE] concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

3.2 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, or (ii) changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Page 5

DRAFT TSTF-588, Rev. 0 Enclosure 1 List of Methods to be Removed from TS 5.6.3 The following table identifies methods that are currently listed in TS 5.6.3 which are being removed from the TS and placed under licensee control.

Method NEI 96-07, Additional Discussion Described in Revision 1, UFSAR Method of Section or Evaluation Commitment Category* to Add to the UFSAR

• NEI 96-07, Method of Evaluation Categories:

1. Methods of evaluation used in analyses that demonstrate that design basis limits of fission product barriers are met (i.e., for the parameters subject to criterion 10 CFR 50.59(c)(2)(vii)).

2. Methods of evaluation used in UFSAR safety analyses, including containment, ECCS and accident analyses typically presented in UFSAR Chapters 6 and 15, to demonstrate that consequences of accidents do not exceed 10 CFR 100 or 10 CFR 50, Appendix A, dose limits.

3. Methods of evaluation used in supporting UFSAR analyses that demonstrate intended design functions will be accomplished under design basis conditions that the plant is required to withstand, including natural phenomena, environmental conditions, dynamic effects, station blackout and ATWS.

Page 6

DRAFT TSTF-588, Rev. 0 Technical Specifications Changes

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

[ The individual specifications that address core operating limits must be referenced here. ]

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR. Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59. Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE----------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the any Topical Report that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 the Topical Report(s) by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup Babcock & Wilcox STS 5.6-2 Rev. 5.0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

[ The individual specifications that address core operating limits must be referenced here. ]

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR. Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59. Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE----------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the any Topical Report that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 the Topical Report(s) by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, and hydrostatic testing, LTOP arming, and Westinghouse STS 5.6-2 Rev. 5.0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

[ The individual specifications that address core operating limits must be referenced here. ]

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR. Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59. Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE----------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the any Topical Report that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 the Topical Report(s) by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined assuming operation up to RATED THERMAL POWER such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling System (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup Combustion Engineering STS 5.6-2 Rev. 5.0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

[ The individual specifications that address core operating limits must be referenced here. The MCPR99.9% value used to calculate the LCO 3.2.2, "MCPR," limit shall be specified in the COLR. ]

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR. Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59. Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE----------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the any Topical Report that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 the Topical Report(s) by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup General Electric BWR/4 STS 5.6-2 Rev. 5.0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

[ The individual specifications that address core operating limits must be referenced here. The MCPR99.9% value used to calculate the LCO 3.2.2, "MCPR," limit shall be specified in the COLR. ]

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR. Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59. Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE----------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of the any Topical Report that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification for each of the Technical Specification referenced Topical Reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 the Topical Report(s) by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT

a. RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup General Electric BWR/6 STS 5.6-2 Rev. 5.0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

2.1.1, Reactor Core SLs 3.1.1, SHUTDOWN MARGIN (SDM) 3.1.3, Moderator Temperature Coefficient (MTC) 3.1.5, Shutdown Bank Insertion Limits 3.1.6, Control Bank Insertion Limits 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)

N 3.2.2, Nuclear Enthalpy Rise Hot Channel Factor (FH) 3.2.3, AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC) Methodology) 3.2.5, On-line Power Distribution Monitoring System (OPDMS)-Monitored Parameters 3.3.1, Reactor Trip System (RTS) Instrumentation 3.4.1, RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits 3.9.1, Boron Concentration

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, and shall be documented in the COLR. Licensees may make changes to analytical methods used to determine the core operating limits that do not require NRC approval pursuant to 10 CFR 50.59. Analytical methods that cannot be changed under 10 CFR 50.59 are specifically those described in the following documents:

---

REVIEWERS NOTE----------------------------------------

Licensees that have received prior NRC approval to relocate Topical Report revision numbers and dates to licensee control need only list the number and title of any Topical that cannot be changed under 10 CFR 50.59, and the COLR will contain the complete identification (i.e., report number, title, revision, date, and any supplements). See NRC ADAMS Accession No: ML110660285 for details.

[ Identify any NRC-approved methods used to determine core operating limits that cannot be changed under 10 CFR 50.59 by number, title, date, and NRC staff approval document or identify the staff Safety Evaluation Report for a plant specific methodology by NRC letter and date. ]

AP1000 STS 5.6-2 Rev. 0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6

[ 1. WCAP-9272-NP-A, Westinghouse Reload Safety Evaluation Methodology, July 1985 (Westinghouse Non-Proprietary).

(Methodology for Specifications 3.1.3 - Moderator Temperature Coefficient, 3.1.5 - Shutdown Bank Insertion Limits, 3.1.6 - Control Bank Insertion Limits, 3.2.1 - Heat Flux Hot Channel Factor, 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor, 3.2.3 - AXIAL FLUX DIFFERENCE, and 3.9.1 - Boron Concentration.)

2a. WCAP-8403, Power Distribution Control and Load Following Procedures -

Topical Report, September 1974 (Westinghouse Non-Proprietary).

(Methodology for Specification 3.2.3 - AXIAL FLUX DIFFERENCE (Constant Axial Offset Control).)

AP1000 STS 5.6-3 Rev. 0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR) (continued) 2b. T. M. Anderson to K. Kniel (Chief of Core Performance Branch, NRC)

January 31, 1980 -

Attachment:

Operation and Safety Analysis Aspects of an Improved Load Follow Package.

(Methodology for Specification 3.2.3 - AXIAL FLUX DIFFERENCE (Constant Axial Offset Control).)

2c. NUREG-0800, Standard Review Plan, U.S. Nuclear Regulatory Commission, Section 4.3, Nuclear Design, July 1981. Branch Technical Position CPB 4.3-1, Westinghouse Constant Axial Offset Control (CAOC), Rev. 2, July 1981.

(Methodology for Specification 3.2.3 - AXIAL FLUX DIFFERENCE (Constant Axial Offset Control).)

3. WCAP-10217-A, Revision 1A, Relaxation of Constant Axial Offset Control FQ Surveillance Technical Specification, February 1994 (Westinghouse Non-Proprietary).

(Methodology for Specifications 3.2.3 - AXIAL FLUX DIFFERENCE (Relaxed Axial Offset Control) and 3.2.1 - Heat Flux Hot Channel Factor (W(Z) surveillance requirements for FQ Methodology).)

4. WCAP-114747, Volumes 1-5, Westinghouse Code Qualification Document for Best Estimate Loss of Coolant Accident Analysis, Revision 2, March 1998 (Westinghouse Non-Proprietary).

(Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor.)

5. WCAP-12473-A, BEACON Core Monitoring and Operations Support System, August 1994, Addendum 1, May 1996 (Westinghouse Non-Proprietary), and Addendum 2, March 2001 (Westinghouse Non-Proprietary).

(Methodology for Specification 3.2.5 - OPDMS - Monitored Parameters.)

6. APP-GW-GLR-137, Revision 1, Bases of Digital Overpower and Overtemperature Delta-T (OPT/OTT) Reactor Trips, Westinghouse Electric Company LLC.

AP1000 STS 5.6-4 Rev. 0

TSTF-588, Rev. 0 DRAFT Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.3 CORE OPERATING LIMITS REPORT (COLR) (continued)

(Methodology for Specification 2.1.1 - Reactor Core Safety Limits, and Specification 3.3.1 - Reactor Trip System (RTS) Instrumentation.) ]

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Passive Core Cooling Systems limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

5.6.4 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. RCS pressure and temperature limits for heat up, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup and cooldown rates shall be established and documented in the PTLR for the following:

3.4.3, RCS Pressure and Temperature (P/T) Limits 3.4.14, Low Temperature Overpressure Protection (LTOP)

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in the following document:

WCAP-14040-A, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves.

(Limits for LCO 3.4.3 and LCO 3.4.14).

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluency period and for any revision or supplement thereto.

5.6.5 Post Accident Monitoring Report When a report is required by Condition B of LCO 3.3.17, Post Accident Monitoring (PAM) Instrumentation, a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

AP1000 STS 5.6-5 Rev. 0