Protecting People and the EnvironmentUNITED STATES NUCLEAR REGULATORY COMMISSION
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
January 31, 1996
NRC GENERIC LETTER 96-03: RELOCATION OF THE PRESSURE TEMPERATURE LIMIT CURVES
AND LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM
LIMITS
Addressees
All holders of operating licenses or construction permits for nuclear power
reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this generic letter to
advise licensees that they may request a license amendment to relocate the
pressure temperature (P/T) limit curves from their plant technical
specifications (TS) to a pressure temperature limits report (PTLR) or a
similar document. The low temperature overpressure protection (LTOP) system
limits may also be relocated to the same document at the discretion of the
licensee.
Description of Circumstances
During the development of the improved standard technical specifications
(STS), a change was proposed to relocate the P/T curves and LTOP setpoint
curves and values currently contained in the TS to a licensee-controlled
document. As one of the improvements to the STS, the NRC staff agreed with
the industry that the curves and setpoints may be relocated outside the TS to
a licensee-controlled document so that the licensee could maintain these
limits efficiently and at a lower cost, provided that the parameters for
constructing the curves and setpoints are derived using a methodology approved
by the NRC.
Discussion
Technical specifications include limiting conditions for operation (LCOs) that
establish P/T and LTOP system limits for the reactor coolant system. The
limits are defined by figures and values that provide an acceptable range of
operating temperatures and pressures for heatup, cooldown, low temperature
overpressure, criticality, and inservice leak and hydrostatic testing
conditions. These parameters are generally valid for a specified number of
effective full-power years or for a specified fluence period (the period for
which the curves are calculated to be applicable).
License amendments are generally required at the end of the effective period
for P/T limit curves or when surveillance specimens are withdrawn and tested.
Also, each time the P/T curves are revised, the LTOP system must be
9601290350. GL 96-03
January 31, 1996
Page 2 of 4
reevaluated to ensure that its functional requirements can still be met.
Processing amendment requests for changes to TS that are developed using an
accepted methodology places an unnecessary burden on licensee and NRC
resources. An alternative approach for controlling these limits was proposed
during the development of the improved STS. This approach, like the one used
for the core operating limits, would relocate the P/T curves and LTOP setpoint
curves or values to a PTLR or a similar document and would reference that
document in the affected LCOs and bases.
The methodology used to determine the P/T and LTOP system limit parameters
must comply with the specific requirements of Appendices G and H to Part 50 of
Title 10 of the Code of Federal Regulations (10 CFR), be documented in an NRC-
approved topical report or in a plant-specific submittal, and be incorporated
by reference into the TS. Subsequent changes in the methodology must be
approved by a license amendment; 10 CFR 50.59 does not apply.
Requested Information
Licensees and applicants who choose to adopt this line item improvement are
encouraged to propose changes that are consistent with the attached guidance.
However, licensees may propose changes, with justification, that differ from
this guidance. The guidance requires that the licensee be able to reference a
methodology for developing the curves and setpoints that has been approved by
the NRC, develop a PTLR or a similar document that contains the figures,
values, parameters, and any explanations derived from the methodology, and
make appropriate changes to the applicable sections of the TS. The NRC
project manager for the facility will review the amendment requests that
conform to the guidance in this generic letter and will coordinate the
appropriate staff review of the methodology proposed for calculating the P/T
limit curves and LTOP system limits. Amendment requests that do not conform
to the guidance in this generic letter will require additional review time.
Required Response
Licensees and applicants who choose to adopt this line item improvement are
asked to submit the requested information described above to the U.S. Nuclear
Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555-0001.
. GL 96-03
January 31, 1996
Page 3 of 4
Backfit Discussion
Any action by licensees to propose changes to TS in accordance with the
guidance in this generic letter is voluntary and, therefore, is not a backfit
under 10 CFR 50.109. The staff, therefore, did not perform a backfit
analysis.
Federal Register Notification
The staff published a notice of opportunity for public comment in the
Federal Register (60 FR 28805) on June 2, 1995.
Paperwork Reduction Act Statement
The voluntary information collections contained in this request are covered by
the Office of Management and Budget clearance number 3150-0011, which expires
on July 31, 1997. The public reporting burden for this collection of
information is estimated to average 40 hours per response, including the time
for reviewing instructions, searching existing data sources, gathering and
maintaining the data needed, and completing and reviewing the collection of
information. Send comments regarding this burden estimate or any other aspect
of this collection of information, including suggestions for reducing this
burden, to the Information and Records Management Branch (T-6 F33),
U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and to the
Desk Officer, Office of Information and Regulatory Affairs, NEOB-10202
(3150-0011), Office of Management and Budget, Washington, D.C. 20503.
The following information, although not requested under the provisions of
10 CFR 50.54(f), would help the NRC to evaluate licensee cost to propose TS
changes in accordance with this generic letter:
1. licensee staff time and costs to prepare the requested reports and
documentation and
2. an estimate of the long-term costs or savings accruing from the response
to this generic letter.
. GL 96-03
January 31, 1996
Page 4 of 4
If you have any questions about this matter, please contact the technical
contact listed below or the appropriate Office of Nuclear Reactor Regulation
(NRR) project manager.
signed by
Dennis M. Crutchfield, Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Maggalean W. Weston, NRR
(301) 415-3151
Internet:mww@nrc.gov
Attachments:
1. Guidance for a Proposed License Amendment
to Relocate the Pressure Temperature
Limit Curves and Low Temperature
Overpressure Protection System Limits
2. Model Safety Evaluation
3. Model Technical Specifications:
a. Definitions
b. Pressure Temperature Limits
c. Low Temperature Overpressure Protection System
d. Administrative Controls
4. List of Recently Issued Generic Letters
. Attachment 1
GL 96-03
January 31, 1996
Page 1 of 7
GUIDANCE FOR A PROPOSED LICENSE AMENDMENT
TO RELOCATE THE PRESSURE TEMPERATURE LIMIT CURVES
AND LOW TEMPERATURE OVERPRESSURE PROTECTION SYSTEM LIMITS
INTRODUCTION
This attachment to the generic letter contains guidance for preparing a
license amendment request to modify the technical specifications (TS) to
relocate the pressure temperature (P/T) limit curves and low temperature
overpressure protection (LTOP) system limits currently contained in the plant
TS to a pressure temperature limits report (PTLR) or a similar document. This
alternative was based on a change included in the improved standard technical
specifications (STS) to remove the P/T limit curves and LTOP system limits
from the TS and relocate them to a PTLR or a similar document to reduce the
number of amendment requests associated with changes to these curves and
limits. Since an amendment request must be submitted whenever a change is
made to the TS, the relocation of the P/T curves and LTOP system limits will
result in a resource savings for the licensees and the NRC by eliminating
unnecessary license amendment requests for changes to the P/T limit curves and
LTOP system limits in TS. To relocate the P/T curves and LTOP system limits
from the TS, the licensee must be able to reference a methodology approved by
the NRC for deriving the parameters used for constructing the curves and
setpoints, develop a PTLR or a similar document, and make appropriate changes
to the applicable sections of the TS.
In evaluating the relocation, the NRC staff concluded that, while it is
essential to safety to operate the plant within the bounds of P/T limits and
to satisfy the regulations that ensure the integrity of the reactor coolant
pressure boundary (RCPB), the periodic adjustment of those limits to account
for time-dependent parametric changes could be calculated in accordance with a
methodology approved by the NRC. Criterion 2 of both 10 CFR Part 50, which
was published in the Federal Register (58 FR 39132) on July 22, 1993, and
10 CFR 50.36(c)(2)(ii)(B), which was published in the Federal Register
(60 FR 36953) on July 19, 1995, require that the TS include operating
restrictions (P/T limits) needed to preclude unanalyzed accidents and
transients. However, once the methodology is approved, the licensee may
modify the figures, values, and parameters without the need for a license
amendment and without affecting nuclear safety, provided that these changes
are determined using the approved methodology and are consistent with all
applicable limits of the plant design assumptions as stated in the final
safety analysis report (FSAR). Additionally, the licensee must submit to the
NRC a formal PTLR or a similar document containing the figures, values, and
parameters derived from the application of the methodology approved by the
NRC. This reporting requirement augments a reporting requirement that is
already in effect. Section III of Appendix H to 10 CFR Part 50 currently
requires a summary technical report of data relating to capsule withdrawal and
specimen test results. Application of these results will also be included in
the PTLR. This report will allow the NRC staff to continue monitoring the
. Attachment 1
GL 96-03
January 31, 1996
Page 2 of 7
status of the structural integrity of the reactor vessel even through prior
NRC approval of the changes to these limits would not be required if the
limits do not involve an unreviewed safety question.
A provision was also added to the "Administrative Controls" section of the TS
indicating that the figures, values, and parameters for inclusion in the PTLR
will be verified after each reactor vessel fluence period or when surveillance
specimens are withdrawn and tested and the PTLR submitted to the NRC. Hence,
the staff can confirm proper application of the methodology approved by the
NRC. Further, the PTLR will be referenced in the TS so that the same degree
of control on plant operation will be maintained. As a result, this
alternative provides the same assurance of compliance with design
specifications as before, yet removes the unnecessary burden on both plant and
NRC staff of processing amendment requests.
DISCUSSION
Technical specifications include limiting conditions for operation (LCOs) that
establish P/T limits for the reactor coolant system (RCS). This system is
designed to withstand the effects of cyclic loads resulting from system
temperature and pressure changes. These cyclic loads are introduced by normal
load transients, reactor trips, startup and shutdown operations, and
hydrostatic and leak rate tests. During startup and shutdown, the rates of
temperature and pressure changes are limited so that the maximum specified
heatup and cooldown rates are consistent with the design assumptions and
satisfy operating limits that provide a wide margin of safety to brittle
failure of the reactor vessel. The P/T limits are periodically modified as
the reactor vessel material toughness decreases as a result of material
embrittlement caused by neutron irradiation. The periodic modifications are
necessary when the applicable effective full-power years (EFPYs) or fluence
period for the P/T limits contained in the TS are about to expire or when the
reactor vessel material surveillance data indicate an increase in the nil-
ductility transition reference temperature (RTNDT).
As required by Appendix G to 10 CFR Part 50, operating P/T limits are
calculated and adhered to by plant operations personnel to ensure that
fracture toughness requirements for the RCPB are maintained. Further, in
accordance with Appendix H to 10 CFR Part 50, specimens of reactor vessel
material are installed near the inside reactor vessel wall and are withdrawn
on a schedule to provide data on the effects of radiation fluence and the
thermal environment on the vessel material. These data are used to adjust the
P/T limits, as necessary, to compensate for the shift in material transition
temperature as indicated by tests on the withdrawn specimens. The withdrawal
and analysis of the specimens, and resulting revision of the P/T limit curves,
make up the requirements necessary to compensate for the shift in material
transition temperature. This ensures that the reactor vessel is operated at
high enough temperatures to preclude brittle fracture of the vessel material.
. Attachment 1
GL 96-03
January 31, 1996
Page 3 of 7
The LTOP system controls RCS pressure at low operating temperatures so that
the integrity of the RCPB is not compromised by violating the P/T limits of
Appendix G to 10 CFR Part 50. The LTOP system provides overpressure
protection by limiting coolant input capability and having adequate pressure
relief capacity. Each time the P/T limit curves are revised, the LTOP system
must be reevaluated to ensure that its functional requirements can still be
met. LTOP system limits may be relocated to the PTLR or retained in the TS.
The LTOP system for pressure relief typically consists of two power-operated
relief valves (PORVs), two residual heat removal (RHR) suction relief valves,
or a combination of both. Some plants have only one PORV. The LTOP system
limits consist of PORV and RHR relief valve setpoints. The RHR suction relief
valves do not have variable pressure lift setpoints as the PORVs do and,
therefore, are still addressed in the TS. As designed for the LTOP system,
each PORV is signaled to open if the RCS pressure approaches a limit
determined by the LTOP system actuation logic. This logic monitors both RCS
temperature and RCS pressure to determine when a condition not acceptable in
the PTLR is approached. The PORV setpoints may be included in the PTLR and
should be updated when the revised P/T limits conflict with the LTOP system
limits. LTOP requirements do not apply to boiling water reactors.
REQUIREMENTS FOR RELOCATING THE CURVES AND SETPOINTS
Relocation of the curves and setpoints to a licensee-controlled document
requires three separate licensee actions. The licensee must (1) have a
methodology approved by the NRC to reference in its TS; (2) develop a report
such as a PTLR or a similar document to contain the figures, values,
parameters, and any explanation necessary; and (3) modify the applicable
sections of the TS accordingly.
. Methodology and PTLR
The first two of the three requirements for relocating the P/T curves and LTOP
system limits are an NRC-approved methodology and the associated reporting
requirements in the PTLR. The methodology will consist of only those methods
used for calculation, not the calculations themselves. The PTLR will consist
of the explanations, figures, values, and parameters derived from the
calculations. Since the PTLR will be provided to the NRC upon issuance after
each fluence period or EFPYs and after approval of the methodology, a PTLR
should be provided when the methodology is submitted so that questions
regarding the content and format of the PTLR can be addressed prior to its
formal completion.
The following table shows the relationship between the provisions, if
applicable, specified in the STS for the approved methodology and the
requirements to be included in the methodology and the PTLR. The provisions
for the methodology are those shown in the "Administrative Controls" section
of the STS. . Attachment 1
GL 96-03
Janaury 31, 1996
Page 4 of 7
REQUIREMENTS FOR METHODOLOGY AND PTLR
PROVISIONS FOR METHODOLOGY
FROM ADMINISTRATIVE CONTROLS
SECTION IN STS.MINIMUM REQUIREMENTS TO
BE INCLUDED IN
METHODOLOGY.MINIMUM REQUIREMENTS TO
BE INCLUDED IN PTLR.1.The methodology shall
describe how the neutron
fluence is calculated
(reference new regulatory
guide when it is issued)..Describe transport
calculation methods
including computer codes
and formulas used to
calculate neutron
fluence. Provide
references..Provide the values of
neutron fluences that are
used in the adjusted
reference temperature
(ART) calculation..2.The Reactor Vessel
Material Surveillance
Program shall comply with
Appendix H to 10 CFR Part
50. The reactor vessel
material irradiation
surveillance specimen
removal schedule shall be
provided, along with how
the specimen examinations
shall be used to update
the PTLR curves..Briefly describe the
surveillance program.
Licensee transmittal
letter should identify by
title and number report
containing the Reactor
Vessel Surveillance
Program and surveillance
capsule reports.
Topical/generic report
contains placeholder
only. Reference Appendix
H to 10 CFR Part 50..Provide the surveillance
capsule withdrawal
schedule, or reference by
title and number the
documents in which the
schedule is located.
Reference the
surveillance capsule
reports by title and
number if ARTs are
calculated using
surveillance data. .3.Low temperature
overpressure protection
(LTOP) system limits
developed using NRC-
approved methodologies
may be included in the
PTLR. .Describe how the LTOP
system limits are
calculated applying
system/thermal hydraulics
and fracture mechanics.
Reference SRP Section
5.2.2; ASME Code Case
N-514; ASME Code,
Appendix G, Section XI as
applied in accordance
with 10 CFR 50.55. .Provide setpoint curves
or setpoint values.
.4. The adjusted reference
temperature (ART) for
each reactor beltline
material shall be
calculated, accounting
for irradiation
embrittlement, in
accordance with
Regulatory Guide 1.99,
Revision 2..Describe the method for
calculating the ART using
Regulatory Guide 1.99,
Revision 2.
.Identify both the
limiting ART values and
limiting materials at the
1/4t and 3/4t locations
(t = vessel beltline
thickness).
PWRs - identify RTPTS
value in accordance with
10 CFR 50.61..5.The limiting ART shall be
incorporated into the
calculation of the
pressure and temperature
limit curves in
accordance with NUREG-
0800, SRP Section 5.3.2,
Pressure-Temperature
Limits..Describe the application
of fracture mechanics in
constructing P/T curves
based on ASME Code,
Appendix G, Section XI,
and SRP Section 5.3.2. .Provide the P/T curves
for heatup, cooldown,
criticality, and
hydrostatic and leak
tests..6.The minimum temperature
requirements of Appendix
G to 10 CFR Part 50 shall
be incorporated into the
pressure and temperature
limit curves..Describe how the minimum
temperature requirements
in Appendix G to 10 CFR
Part 50 are applied to
P/T curves..Identify minimum
temperatures on the P/T
curves such as minimum
boltup temperature and
hydrotest temperature..7.Licensees who have
removed two or more
capsules should compare
for each surveillance
material the measured
increase in reference
temperature (RTNDT) to
the predicted increase in
RTNDT; where the
predicted increase in
RTNDT is based on the
mean shift in RTNDT plus
the two standard
deviation value (2å.)
specified in Regulatory
Guide 1.99, Revision 2.
If the measured value
exceeds the predicted
value (increase in RTNDT
+ 2å.), the licensee
should provide a
supplement to the PTLR to
demonstrate how the
results affect the
approved methodology..Describe how the data
from multiple
surveillance capsules are
used in the ART
calculation.
Describe procedure if
measured value exceeds
predicted value.
WHEN OTHER PLANT DATA ARE
USED
1. Identify the source(s)
of data when other plant
data are used.
2.a Identify by title
and number the safety
evaluation report that
approved the use of data
for the plant. Justify
applicability.
OR
2.b Compare licensee
data with other plant
data for both the
radiation environments
(e.g., neutron spectrum,
irradiation temperature)
and the surveillance test
results. .Provide supplemental data
and calculations of the
chemistry factor in the
PTLR if the surveillance
data are used in the ART
calculation.
Evaluate the surveillance
data to determine if they
meet the credibility
criteria in Regulatory
Guide 1.99, Revision 2.
Provide the results.. Attachment 1
GL 96-03
January 31, 1996
Page 6 of 7
. Technical Specifications
The following changes must be made to the plant TS to complete the three
requirements for relocating the curves and setpoints to an alternative
document.
Three separate actions are necessary to modify the plant TS: (1) "Definitions"
- the addition of the definition of a named formal report (PTLR or a similar
document) that would contain the explanations, figures, values, and parameters
derived in accordance with an NRC-approved methodology and consistent with all
of the design assumptions and stress limits for cyclic operation; (2) LCOs -
the addition of references to the PTLR noting that the P/T limits shall be
maintained within the limits specified in the PTLR; and (3) "Administrative
Controls" - the addition of a reporting requirement to submit the PTLR to the
NRC, when it is issued, for each reactor vessel fluence period.
1. Definitions
Section 1.0, "Definitions," should contain the following language:
PRESSURE TEMPERATURE LIMITS REPORT (PTLR)
The PTLR is the unit-specific document that provides the reactor
vessel P/T limits and setpoints, including heatup and cooldown
rates, for the current reactor vessel fluence period. These P/T
limits shall be determined for each fluence period or effective
full-power years (EFPYs) in accordance with
Specification 5.X.X.X. Plant operation within these operating
limits is addressed in LCO 3.X.X, "RCS Pressure and Temperature
(P/T) Limits," and LCO 3.X.X, "Low Temperature Overpressure
Protection (LTOP) System."
2. Limiting Conditions for Operation (LCOs) and Bases
LCO 3.X.X, "RCS Pressure and Temperature (P/T) Limits," and LCO 3.X.X, "Low
Temperature Overpressure Protection (LTOP) System," must reference the PTLR
as the document where the limits and curves can be found as demonstrated in
the attached model TS. The bases for these LCOs should be modified
accordingly.
3. Administrative Controls
Section 5.X, "Administrative Controls," Subsection 5.X.X, "Reporting
Requirements," must contain the following information:
. Attachment 1
GL 96-03
January 31, 1996
Page 7 of 7
Section 5.X.X.X Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE
LIMITS REPORT (PTLR)
a. RCS pressure and temperature limits for heatup, cooldown, LTOP,
criticality, and hydrostatic testing as well as heatup and cooldown
rates shall be established and documented in the PTLR for the
following: [The individual specifications that address RCS pressure
and temperature limits must be referenced here.]
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(s):
[Identify the NRC staff approval document(s) by date.]
c. The PTLR shall be provided to the NRC upon issuance for each reactor
vessel fluence period or EFPYs and for any revision or supplement
thereto.
. Attachment 2
GL 96-03
January 31, 1996
Page 1 of 5
MODEL SAFETY EVALUATION (SE)
Underscored blank spaces are to be completed on the basis of the applicable
facility information. The information in brackets should be used, as
applicable, on a plant-specific basis.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO
AMENDMENT NO. TO FACILITY OPERATING LICENSE NFP-
[UTILITY NAME]
[PLANT NAME], [UNIT ]
DOCKET NO. 50-
1.0 INTRODUCTION
By letter dated , 19 , [utility name] (the licensee) proposed changes
to the technical specifications (TS) for [plant name]. The requested changes
are the relocation of the pressure temperature (P/T) limit curves and low
temperature overpressure protection (LTOP) system limits to the [named plant-
specific report] and the referencing of that report in the affected limiting
conditions for operation and bases. The proposed changes also include the
addition of the [named plant-specific report] to the definitions section of
the TS and the addition of a new section to the reporting requirements in the
administrative controls section of the TS delineating the necessary reports.
Guidance on the proposed changes was developed by the Nuclear Regulatory
Commission (NRC) on the basis of a proposal by the owners groups during the
development of the improved standard technical specifications (STS). This
guidance was provided to all power reactor licensees and applicants by Generic
Letter YY-XX, dated , 19 .
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the Act) requires applicants for
nuclear power plant operating licenses to include TS as part of the license.
The Commission's regulatory requirements related to the content of TS are set
forth in 10 CFR 50.36. That regulation requires that the TS include items in
five specific categories: (1) safety limits, limiting safety system settings
and limiting control settings; (2) limiting conditions for operation;
(3) surveillance requirements; (4) design features; and (5) administrative
controls, and states also that the Commission may include such additional TS
as it finds to be appropriate. However, the regulation does not specify the
particular requirements to be included in a plant's TS.
The Commission has provided guidance for the contents of TS in its "Final
Policy Statement on Technical Specifications Improvements for Nuclear Power
Reactors" (Final Policy Statement), 58 FR 39132 (July 22, 1993), in which the
Commission indicated that compliance with the Final Policy Statement satisfies
Section 182a of the Act. In particular, the Commission indicated that certain. Attachment 2
GL 96-03
January 31, 1996
Page 2 of 5
items could be relocated from the TS to licensee-controlled documents,
consistent with the standard enunciated in Portland General Electric Co.
(Trojan Nuclear Plant), ASLAB-531, 9 NRC 263, 273 (1979). In that case, the
Atomic Safety and Licensing Appeal Board indicated that "technical
specifications are to be reserved for those matters as to which the imposition
of rigid conditions or limitations upon reactor operation is deemed necessary
to obviate the possibility of an abnormal situation or event giving rise to an
immediate threat to the public health and safety."
Consistent with this approach, the Final Policy Statement identified four
criteria to be used in determining whether a particular matter is required to
be included in the TS, as follows: (1) installed instrumentation that is used
to detect, and indicate in the control room, a significant abnormal
degradation of the reactor coolant pressure boundary; (2) a process variable,
design feature, or operating restriction that is an initial condition of a
design basis accident or transient analysis that either assumes the failure of
or presents a challenge to the integrity of a fission product barrier; (3) a
structure, system, or component that is part of the primary success path and
which functions or actuates to mitigate a design basis accident or transient
that either assumes the failure of or presents a challenge to the integrity of
a fission product barrier; (4) a structure, system, or component which
operating experience or probabilistic safety assessment has shown to be
significant to public health and safety. As a result, existing TS
requirements which fall within or satisfy any of the criteria in the Final
Policy Statement must be retained in the TS, while those TS requirements which
do not fall within or satisfy these criteria may be relocated to other
licensee-controlled documents.
3.0 EVALUATION
All components of the reactor coolant system (RCS) are designed to withstand
the effects of cyclic loads resulting from system pressure and temperature
changes. These loads are introduced by heatup and cooldown operations, power
transients, and reactor trips. In accordance with Appendix G to 10 CFR
Part 50, TS limit the pressure and temperature changes during RCS heatup and
cooldown within the design assumptions and the stress limits for cyclic
operation. These limits are defined by P/T limit curves for heatup, cooldown,
LTOP, and inservice leak and hydrostatic testing. Each curve defines an
acceptable region for normal operation. The curves are used for operational
guidance during heatup and cooldown maneuvering, when pressure and temperature
indications are monitored and compared to the applicable curve to determine
that operation is within the allowable region.. Attachment 2
GL 96-03
January 31, 1996
Page 3 of 5
[Reviewer Note: While the NRC is completing the rulemaking process for
revisions to 10 CFR 50.55a and 10 CFR Part 50, Appendix G, licensees using the
American Society of Mechanical Engineers Boiler and Pressure Vessel Code
Case N-514 must request an exemption from Appendix G. The following or
similar language should be included in the SE:
The licensee used the American Society of Mechanical Engineers Boiler and
Pressure Vessel Code Case N-514 and requested an exemption from Appendix G by
justifying why Appendix G cannot be met and demonstrating that a specific
exemption was warranted under 10 CFR 50.12.]
The LTOP system controls RCS pressure at low temperatures so that the
integrity of the reactor coolant pressure boundary is not compromised by
violating 10 CFR Part 50, Appendix G. [Reviewer Note: The following sentences
should be modified to identify the specific LTOP system being referred to in
the SE: The LTOP system for pressure relief, for most plants, consists of
power-operated relief valves (PORVs), residual heat removal suction relief
valves, or a combination of both. Some plants have one PORV. The LTOP system
limits consist of PORV and RHR setpoints. The RHR suction relief valves do
not have variable pressure and temperature lift setpoints like the PORVs and,
therefore, are still addressed in the TS.] The LTOP system is reevaluated
each time the P/T limit curves are revised to ensure that it meets its
intended function.
The licensee-proposed changes to the TS are in accordance with the guidance in
Generic Letter YY-XX, as follows:
(1) The definitions section of the TS was modified to include a definition
of the [named report] to which the figures, values, and parameters for
P/T and LTOP system limits will be relocated on a unit-specific basis
in accordance with a methodology approved by the NRC that maintains
the acceptance limits and the limits of the safety analysis. As noted
in the definition, plant operation within these limits is addressed by
individual specifications.
(2) The following specifications were revised to replace the P/T and LTOP
system limits with a reference to the [named report] that provides
these limits:
[Provide list of specifications by number and title.]
(3) Specification [number], "[title]," was added to the reporting
requirements of the administrative controls section of the TS. This
specification requires that the [named report] be submitted, upon
issuance, to the NRC Document Control Desk with copies to the regional
administrator and resident inspector. The report provides the
explanations, figures, values, and parameters of the P/T and LTOP
system limits for the applicable effective period. Furthermore, this
specification requires that the figures, values, and parameters be . Attachment 2
GL 96-03
January 31, 1996
Page 4 of 5
established using the methodology approved by the NRC for this purpose
in [topical report or NRC letter approving a plant-specific
methodology] and be consistent with all the applicable acceptance
limits and the limits of the safety analysis.
Finally, the specification requires that all changes in values of
these limits be documented in the [named report] each effective period
and submitted upon issuance to the NRC.
Relocation of the P/T curves and LTOP setpoints does not eliminate the
requirement to operate in accordance with the limits specified in Appendix G
to 10 CFR Part 50. The requirement to operate within the limits in the named
report or pressure temperature limits report (PTLR) is specified in and
controlled by the TS. Only the figures, values, and parameters associated
with the P/T limits and LTOP setpoints are to be relocated to the PTLR. In
order for the curves and setpoints to be relocated to a PTLR, a methodology
for their development must be reviewed and approved in advance by the NRC.
The methodology to be approved by the NRC is to be developed in accordance
with GL 96-03. This generic letter delineates the requirements for both the
methodology and the PTLR including, but not limited to, the requirements of
Appendix G to 10 CFR Part 50. The PTLR review process requires that changes
to the methodology be approved by the NRC. Further, when changes are made to
the figures, values, and parameters contained in the PTLR, the PTLR is to be
updated and submitted to the NRC upon issuance.
On this basis, the NRC staff concludes that the licensee provided an
acceptable means of establishing and maintaining the detailed values of the
P/T limit curves and LTOP system limits. Further, because plant operation
continues to be limited in accordance with the requirements of Appendix G
to 10 CFR Part 50 and the P/T and LTOP system limits in the TS will be
established using a methodology approved by the NRC, these changes will not
impact plant safety.
The staff also concludes that the relocated requirements discussed above
relating to the P/T limits and LTOP system limits are not required to be in
the TS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act, and are
not required to obviate the possibility of an abnormal situation or event
giving rise to an immediate threat to the public health and safety.
Additionally, they do not fall within any of the four criteria set forth in
the Commission's Final Policy Statement, discussed above. Accordingly, the
staff concludes that the proposed changes are acceptable and that these
requirements may be relocated from the TS to the PTLR.
4.0 STATE CONSULTATION
The Commission consulted with the State of [ ]. No public comments were
received, and the State of [ ] did not have any comments.
. Attachment 2
GL 96-03
January 31, 1996
Page 5 of 5
5.0 ENVIRONMENTAL CONSIDERATION
The amendment involves changes to requirements with respect to use of facility
components located within the restricted area, as defined in 10 CFR Part 20,
changes with respect to surveillance requirements, and changes in
administrative procedures or requirements. The NRC staff determined that the
amendment involves no significant increase in the amounts and no significant
change in the types of any effluents that may be released off site and that
there is no significant increase in individual or cumulative occupational
exposure. The Commission made a determination that the amendment involves no
significant hazards consideration, which was published in the Federal Register
(53 FR ) on , 19 , and there has been no public comment regarding
such a finding. Accordingly, the amendment meets the eligibility criteria for
categorical exclusion set forth in 10 CFR 51.22(c)(9) and (c)(10). Pursuant
to 10 CFR 51.22(b), no environmental impact statement or environmental
assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
On the basis of the considerations discussed above, the NRC staff concludes
that (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 Commission's regulations,
and (3) the issuance of this amendment will not be inimical to the common
defense and security or to the health and safety of the public.
Principal Contributor: Maggalean W. Weston, TSB
Dated: , 19
. Attachment 3a
GL 96-03
January 31, 1996
Page 1 of 1
Definitions
1.1
1.0 USE AND APPLICATION
1.1 Definitions
ÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍ
-------------------------------------NOTE-------------------------------------
The defined terms of this section appear in capitalized type and are
applicable throughout these Technical Specifications and Bases.
------------------------------------------------------------------------------
Term Definition
PRESSURE AND The PTLR is the unit specific document that
TEMPERATURE LIMITS provides the reactor vessel pressure and
REPORT (PTLR) temperature limits, including heatup and cooldown
rates, for the current reactor vessel fluence period.
These pressure and temperature limits shall be
determined for each fluence period in accordance with
Specification 5.6.6. Plant operation within these
operating limits is addressed in LCO 3.4.3, "RCS
Pressure and Temperature (P/T) Limits," and
LCO 3.4.12, "Low Temperature Overpressure Protection
(LTOP) System."
QUADRANT POWER TILT QPTR shall be the ratio of the maximum upper
RATIO (QPTR) excore detector calibrated output to the average of
the upper excore detector calibrated outputs, or the
ratio of the maximum lower excore detector calibrated
output to the average of the lower excore detector
calibrated outputs, whichever is greater.
RATED THERMAL POWER RTP shall be a total reactor core heat transfer
(RTP) rate to the reactor coolant of [2893] MWt.
REACTOR TRIP The RTS RESPONSE TIME shall be that time interval
SYSTEM (RTS) RESPONSE from when the monitored parameter exceeds its RTS
TIME trip setpoint at the channel sensor until loss of
stationary gripper coil voltage. The response time
may be measured by means of any series of sequential,
overlapping, or total steps so that the entire
response time is measured.
SHUTDOWN MARGIN (SDM) SDM shall be the instantaneous amount of reactivity by
which the reactor is subcritical or would be
subcritical from its present condition assuming:
. Attachment 3b
GL 96-03
January 31, 1996
Page 1 of 2
3.4 REACTOR COOLANT SYSTEM (RCS)
3.4.X RCS Pressure and Temperature (P/T) Limits
LCO 3.4.X RCS pressure, RCS temperature, and RCS heatup and cooldown rates
shall be maintained within the limits specified in the PTLR.
APPLICABILITY: At all times.
ACTIONS
CONDITION. REQUIRED ACTION. COMPLETION TIME.
A. ---------NOTE---------
Required Action A.2
shall be completed
whenever this
Condition is entered.
----------------------
Requirements of LCO
not met in MODE 1, 2,
3, or 4.
.
A.1 Restore parameter(s)
to within limits.
AND
A.2 Determine RCS is
acceptable for
continued operation.
.
30 minutes
72 hours.
B. Required Action and
associated Completion
Time of Condition A
not met.
.
B.1 Be in MODE 3.
AND
B.2 Be in MODE 5 with RCS
pressure
< [500] psig.
.
6 hours
36 hours...(continued).
C. ---------NOTE---------
Required Action C.2
shall be completed
whenever this
Condition is entered.
----------------------
Requirements of LCO
not met any time in
other than MODE 1, 2,
3, or 4.
.
C.1 Initiate action to
restore parameter(s)
to within limits.
AND
C.2 Determine RCS is
acceptable for
continued operation.
.
Immediately
Prior to
entering MODE 4
SURVEILLANCE REQUIREMENTS
SURVEILLANCE. FREQUENCY.
SR 3.4.X.X -------------------NOTE--------------------
Only required to be performed during RCS
heatup and cooldown operations and RCS
inservice leak and hydrostatic testing.
-------------------------------------------
Verify RCS pressure, RCS temperature, and
RCS heatup and cooldown rates are within
the limits specified in the PTLR.
.
30 minutes. Attachment 3c
GL 96-03
January 31, 1996
Page 1 of 6
3.4 REACTOR COOLANT SYSTEM (RCS)
3.4.X Low Temperature Overpressure Protection (LTOP) System
LCO 3.4.X An LTOP System shall be OPERABLE with a maximum of [one] [high
pressure injection (HPI)] pump [and one charging pump] capable
of injecting into the RCS and the accumulators isolated and
either a or b below.
a. Two RCS relief valves, as follows:
1. Two power operated relief valves (PORVs) with lift
settings within the limits specified in the PTLR,
or
[2. Two residual heat removal (RHR) suction relief
valves with setpoints ò [436.5] psig and
ó [463.5] psig, or]
[3. One PORV with a lift setting within the limits
specified in the PTLR and one RHR suction relief
valve with a setpoint ò [436.5] psig and
ó [463.5] psig].
b. The RCS depressurized and an RCS vent of ò [2.07] square
inches.
APPLICABILITY: MODE 4 when all RCS cold leg temperature is ó [275]øF,
MODE 5,
MODE 6 when the reactor vessel head is on.
----------------------------NOTE----------------------------
Accumulator isolation is only required when accumulator
pressure is greater than or equal to the maximum RCS
pressure for the existing RCS cold leg temperature allowed
by the P/T limit curves provided in the PTLR.
------------------------------------------------------------
. Attachment 3c
GL 96-03
January 31, 1996
Page 2 of 6
ACTIONS
CONDITION. REQUIRED ACTION. COMPLETION TIME.
A. Two or more [HPI]
pumps capable of
injecting into the
RCS.
.
A.1 Initiate action to
verify a maximum of
[one] [HPI] pump is
capable of injecting
into the RCS.
.
Immediately.ÚÄÄ
³B.Two or more charging
³ pumps capable of
³ injecting into the
³ RCS.
³
³
³
³
³
³
³
³
³
³
³
ÀÄÄ.
B.1 --------NOTE---------
Two charging pumps
may be capable of
injecting into the
RCS during pump swap
operation for
ó 15 minutes.
---------------------
Initiate action to
verify a maximum of
[one] charging pump
is capable of
injecting into the
RCS.
. ÄÄ¿
³
³
³
³
³
³
³
³
³
Immediately ³
³
³
³
³
³
ÄÄÙ .
C. An accumulator not
isolated when the
accumulator pressure
is greater than or
equal to the maximum
RCS pressure for
existing cold leg
temperature allowed in
the PTLR.
.
C.1 Isolate affected
accumulator.
.
1 hour... (continued).
D. Required Action and
associated Completion
Time of Condition [C]
not met.
.
D.1 Increase RCS cold leg
temperature to
> [275]øF.
OR
D.2 Depressurize affected
accumulator to less
than the maximum RCS
pressure for existing
cold leg temperature
allowed in the PTLR.
.
12 hours
12 hours.
E. One required RCS
relief valve
inoperable in MODE 4.
.
E.1 Restore required RCS
relief valve to
OPERABLE status.
.
7 days.
F. One required RCS
relief valve
inoperable in MODE 5
or 6.
.
F.1 Restore required RCS
relief valve to
OPERABLE status.
.
24 hours... (continued).
G. Two required RCS
relief valves
inoperable.
OR
Required Action and
associated Completion
Time of Condition A,
[B,] D, E, or F not
met.
OR
LTOP System inoperable
for any reason other
than Condition A, [B,]
C, D, E, or F.
.
G.1 Depressurize RCS and
establish RCS vent of
ò [2.07] square
inches.
.
8 hours
SURVEILLANCE REQUIREMENTS
SURVEILLANCE. FREQUENCY.
SR 3.4.X.X Verify a maximum of [one] [HPI] pump is
capable of injecting into the RCS.
.
12 hours.ÚÄÄ
³SR 3.4.X.X Verify a maximum of one charging pump is
³ capable of injecting into the RCS.
ÀÄÄ. ÄÄ¿
12 hours ³
³
ÄÄÙ.
SR 3.4.X.X Verify each accumulator is isolated.
.
12 hours.. (continued).ÚÄÄ
³SR 3.4.X.X Verify RHR suction valve is open for each
³ required RHR suction relief valve.
ÀÄÄ. ÄÄ¿
12 hours ³
³
ÄÄÙ.
SR 3.4.X.X -------------------NOTE--------------------
Only required to be performed when
complying with LCO 3.4.12.b.
-------------------------------------------
Verify RCS vent ò [2.07] square inches
open.
.
12 hours for
unlocked open
vent valve(s)
AND
31 days for
locked open
vent valve(s)
.
SR 3.4.X.X Verify PORV block valve is open for each
required PORV.
.
72 hours.ÚÄÄ
³SR 3.4.X.X Verify associated RHR suction isolation
³ valve is locked open with operator power
³ removed for each required RHR suction
³ relief valve.
ÀÄÄ. ÄÄ¿
31 days ³
³
³
³
ÄÄÙ.
SR 3.4.X.X -------------------NOTE--------------------
Not required to be met until 12 hours after
decreasing RCS cold leg temperature to
ó [275]øF.
-------------------------------------------
Perform a COT on each required PORV,
excluding actuation.
.
31 days.. (continued).
SR 3.4.X.X Perform CHANNEL CALIBRATION for each
required PORV actuation channel.
.
[18] months. Attachment 3d
GL 96-03
January 31, 1996
Page 1 of 2
5.0 ADMINISTRATIVE CONTROLS
5.6 Reporting Requirements
ÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍÍ
5.6.X 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: [The individual specifications that address
RCS pressure and temperature limits must be referenced
here.]
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 documents: [Identify the NRC staff
approval document by date.]
c. The PTLR shall be provided to the NRC upon issuance for
each reactor vessel fluence period and for any revision
or supplement thereto.
Reviewers' Notes: The methodology for the calculation of the
P-T limits for NRC approval should include the following
provisions:
1. The methodology shall describe how the neutron fluence is
calculated (reference new Regulatory Guide when issued).
2. The Reactor Vessel Material Surveillance Program shall
comply with Appendix H to 10 CFR Part 50. The reactor
vessel material irradiation surveillance specimen removal
schedule shall be provided, along with how the specimen
examinations shall be used to update the PTLR curves.
3. Low Temperature Overpressure Protection (LTOP) System
lift setting limits for the Power Operated Relief Valves
(PORVs), developed using NRC-approved methodologies may
be included in the PTLR.
4. The adjusted reference temperature (ART) for each reactor
beltline material shall be calculated, accounting for
radiation embrittlement, in accordance with Regulatory
Guide 1.99, Revision 2.
5. The limiting ART shall be incorporated into the
calculation of the pressure and temperature limit curves
in accordance with NUREG-0800 Standard Review Plan 5.3.2,
Pressure-Temperature Limits.
5.6.X Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS
REPORT (PTLR) (continued)
6. The minimum temperature requirements of Appendix G to 10
CFR Part 50 shall be incorporated into the pressure and
temperature limit curves.
7. Licensees who have removed two or more capsules should
compare for each surveillance material the measured
increase in reference temperature (RTNDT) to the predicted
increase in RTNDT; where the predicted increase in RTNDT is
based on the mean shift in RTNDT plus the two standard
deviation value (2åþ) specified in Regulatory Guide 1.99,
Revision 2. If the measured value exceeds the predicted
value (increase RTNDT + 2åþ), the licensee should provide a
supplement to the PTLR to demonstrate how the results
affect the approved methodology.
