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Home       > Electronic Reading       Room       > Document       Collections       > Generic       Communications >       Generic       Letters >       1996       > Gl96003 
				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.