CPSES-200500919, (CPSES) License Amendment Request (LAR) 05-002, Revision to Technical Specification (TS) 5.6.5, Core Operating Limits Report (Colr).

(CPSES) License Amendment Request (LAR)05-002, Revision to Technical Specification (TS) 5.6.5, Core Operating Limits Report (Colr).

ML051230317
Person / Time
Site:	Comanche Peak
Issue date:	04/27/2005
From:	Blevins M, Madden F TXU Generation Co, LP, TXU Power
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CPSES-200500919, TXX-05087
Download: ML051230317 (15)

Text

-hTXU "9Power TXU Power Mike Blevins Comanche Peak Steam Senior Vice President & Ref

1 OCFR50.90 Electric Station Chief Nuclear Officer P. O. Box 1002 (EO1)

Glen Rose, TX 76043 Tel: 254 897 5209 Fax: 254 897 6652 mike.bevinsetxu.com CPSES-200500919 Log # TXX-05087 File # 00236 April 27, 2005 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50445 AND 50-446 LICENSE AMENDMENT REQUEST (LAR)05-002 REVISION TO TECHNICAL SPECIFICATION (TS) 5.6.5, "CORE OPERATING LIMITS REPORT (COLR)"

Gentlemen:

Pursuant to 10CFR50.90, TXU Generation Company LP (TXU Power) hereby requests an amendment to the CPSES Unit 1 Operating License (NPF-87) and CPSES Unit 2 Operating License (NPF-89) by incorporating the attached change into the CPSES Unit 1 and 2 Technical Specifications.

The proposed change will revise TS 5.6.5 entitled "Core Operating Limits Report (COLR)." This proposed amendment to the CPSES Unit 1 and 2 Technical Specifications is a request to make administrative changes to incorporate an NRC-approved analytical method used to determine the core operating limits. This analytical method can be used to support the reconstitution method of replacing failed or damaged fuel rods in Westinghouse-supplied fuel assemblies.

Attachment 1 provides a detailed description of the proposed changes, a safety analysis of the proposed changes, TXU Power's determination that the proposed changes do not involve a significant hazard consideration, a regulatory analysis of the proposed changes and an environmental evaluation. Attachment 2 provides the affected Technical Specification pages marked-up to reflect the proposed changes.

Attachment 3 provides retyped Technical Specification pages that incorporate the requested changes.

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance _.\l;iIi \

Callaway

• Comanche Peak

• Diablo Canyon

• Palo Verde

• South Texas Project

• Wolf Creek

TXX-05087 Page 2 of 2 The reconstitution method of fuel assembly repair may be used during the CPSES Unit 1 Refueling Outage 11, scheduled to begin on October 8, 2005. The approval of this proposed amendment is requested by October 1, 2005, to be implemented within 90 days of the issuance of the license amendment.

In accordance with 10CFR50.91(b), TXU Power is providing the State of Texas with a copy of this proposed amendment.

This communication contains no new or revised commitments.

Should you have any questions, please contact Mr. J. D. Seawright at (254) 897-0140.

1 state under penalty of perjury that the foregoing is true and correct.

Executed on April 27, 2005.

Sincerely, TXU Generation Company LP By: TXU Generation Management Company LLC Its General Partner Mike Blevins By: lg)/7 red W. Madden Director, Regulatory Affairs JDS Attachments: 1. Description and Assessment

2. Markup of Technical Specifications pages

3. Retyped Technical Specification Pages c - B. S. Mallett, Region IV Ms. Alice Rogers M. C. Thadani, NRR Bureau of Radiation Control Resident Inspectors, CPSES Texas Department of Public Health 1100 West 49th Street Austin, Texas 78756-3189

ATTACHMENT 1 to TXX-05087 DESCRIPTION AND ASSESSMENT

Attachment 1 to TXX-05087 Page 1 of 8 LICENSEE'S EVALUATION

4.0 TECHNICAL ANALYSIS

5.0 REGULATORY SAFETY ANALYSIS 5.1. No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements

7.0 REFERENCES

to TXX-05087 Page 2 of 8

1.0 DESCRIPTION

By this letter, TXU Power requests an amendment to the CPSES Unit 1 Operating License (NPF-87) and CPSES Unit 2 Operating License (NPF-89) by incorporating the attached change into the CPSES Unit 1 and 2 Technical Specifications. The proposed change, LAR 05-002, is a request to make administrative changes to incorporate an NRC-approved analytical method used to determine the core operating limits. This analytical method can be used to support the reconstitution method of replacing failed or damaged fuel rods in Westinghouse-supplied fuel assemblies.

No changes to the CPSES Final Safety Analysis Report nor the Technical Specification Bases are anticipated at this time as a result of this License Amendment Request.

The proposed change has been reviewed, and it has been determined that no significant hazards consideration exists, as defined in 10 CFR 50.92. In addition, it has been determined that the change qualifies for categorical exclusion from an environmental assessment as set forth in 10 CFR 51.22(c)(9); therefore, no environmental impact statement or environmental assessment is needed in connection with the approval of the proposed change.

2.0 PROPOSED CHANGE

The proposed change would revise the CPSES Units I and 2 Technical Specifications as follows:

Revise TS 5.6.5b to add the following approved analytical method:

WCAP-103060-P-A, "Westinghouse Fuel Assembly Reconstitution Evaluation Methodology."

The Core Operating Limits Report (COLR) will contain the complete identification for each of the TS referenced topical reports used to prepare the COLR (i.e., report number, title, revision, date, and any supplements).

3.0 BACKGROUND

Reload core configurations are typically developed many months prior to the scheduled refueling outage where that configuration will be implemented. Failed or damaged fuel rods identified in fuel assemblies intended to be re-used in the core jeopardize the usability of the affected fuel assemblies, potentially resulting in time-consuming and costly redesigns of the reload core configuration. Expediting the significant analytical efforts required to redesign the reload core and validate the acceptability of the reload core design against the accident analysis requirements also poses significant human performance challenges. Fuel assembly reconstitution is a process where failed or damaged fuel rods are replaced with solid "filler" rods, typically composed of either

Attachment I to TXX-05087 Page 3 of 8 stainless steel or a zirconium alloy. The filler rod is dimensionally equivalent to a fuel rod but has different physical properties (e.g., weight and stiffness). The reconstituted fuel assembly can then be returned to service, resulting in minimal changes to the reload core configuration for the upcoming cycle of operation.

Generic Letter 90-02, Supplement 1, "Alternative Requirements for Fuel Assemblies in the Design Features Section of Technical Specifications" (Reference 7.1), was issued to clarify the limitations on the application of NRC-approved analytical methods and to provide a model technical specification consistent with realistic fuel assembly reconstitution configurations. The current CPSES Technical Specification Section 4.2.1 contains verbiage similar to that recommended in the Generic Letter and incorporated in Revision 3 to NUREG 1431, "Standard Technical Specifications, Westinghouse Plants" (Reference 7.2). The specific verbiage in the CPSES Technical Specifications is "Limited substitutions of zirconium alloy or stainless steel filler rods for fuel rods, in accordance with approved applications of fuel rod configurations, may be used." Thus, the CPSES Technical Specification Section 4.2.1 is compliant with the Generic Letter and the Standard Technical Specifications.

Further, as described in the Generic Letter, where "filler rods fuel configurations are to be proposed for use, the staff encourages licensees and fuel vendors to submit generic topical reports that justify the specified fuel configurations with filler rods and that define and justify the analytical methods for core analysis to support fuel reconstitution." To that end, the current fuel vendor used by CPSES, Westinghouse Electric Company, has developed a generic topical report justifying the analytical methods used for core analysis to support fuel reconstitution. This topical report, WCAP-13060-P-A, "Westinghouse Fuel Assembly Reconstitution Evaluation Methodology" (Reference 7.3) was submitted for NRC review and approved for use for fuel assembly reconstitution for reload applications. As concluded in the Waiver of CRGR Review of WCAP-13060-P Safety Evaluation, the reconstitution methodology does not present any new methodology, it merely presents another application of an existing and approved methodology.

A complete discussion of how a reconstituted fuel assembly is addressed as part of the reload core configuration is provided in WCAP-13060-P-A. As may be inferred from the Waiver of CRGR Review, no special considerations for the reconstituted fuel assembly are required; the typical reload core configuration evaluations are performed, including the reconstituted fuel assemblies. In summary, no special considerations are required.

The aspects of the reload core configuration that are potentially affected by the inclusion of reconstituted fuel assemblies include the mechanical and nuclear design, as well as the effects on the loss of coolant accident (LOCA) and non-LOCA transient and accident analysis methods. The core thermal-hydraulic effects are addressed as part of the non-LOCA accident analysis methods.

The analytical methods used by TXU Power to determine the core operating limits have been previously reviewed and approved by the NRC. These methods are listed in to TXX-05087 Page 4 of 8 Technical Specification Section 5.6.5.b. In the following paragraphs, the potential effects of the reconstituted fuel assemblies on the evaluations supporting the reload core configuration, based on the analytical tools used by TXU Power, are described.

For the CPSES reload core configurations using Westinghouse-supplied fuel assemblies with mixing vane grids, the fuel rod and fuel assembly mechanical design evaluations are performed by Westinghouse using the same methodologies described in WCAP-1 3060-P-A. Therefore, these aspects of the WCAP are directly applicable to the CPSES reload core configurations.

The TXU Power nuclear design tools, their applications, and the uncertainties associated with their intended applications were qualified through an extensive set of comparisons to various test and commercial reactor core configurations. The application of these tools to the reconstituted fuel assembly configuration is within the set of conditions considered in the qualification. These nuclear design tools provide similar information as those tools referenced by Westinghouse in WCAP-13060-P-A. Fuel assembly reconstitution affects the total reactivity of the core and the local power peaking due to the redistribution of power within the assembly. Specifically, the nuclear design tools are used to predict key design parameters used in the cycle-specific accident analyses. For this specific application, the CPSES nuclear design tools were internally reviewed, and a demonstration exercise was performed to ensure that the tools did perform as expected, by comparison to similar evaluations presented in WCAP-13060-P-A. Consistent with the commitments in WCAP-13060-P-A, the actual core configuration, including any reconstituted fuel assemblies, will be evaluated for each cycle using the nuclear design tools approved for CPSES.

The LOCA analyses discussed in WCAP-13060-P-A are intended to bound several reload core configurations. As such, cycle-specific peak clad temperature (PCT) penalties were assigned, depending on the number of replaced damaged or failed fuel rods. These specific penalties are only appropriate for the Westinghouse ECCS evaluation models and are not applicable to the CPSES evaluation models.

The analytical methods used by TXU Power to analyze the large break and small break LOCAs for CPSES are listed in Technical Specification 5.6.5.b. In contrast with the approach described in WCAP-13060-P-A, the analyses of each of these LOCAs are performed on a cycle-specific basis. The effect of non-heat-producing filler rods on the LOCA analysis is limited to the slight increase in the average power in the fuel rods. This effect is explicitly considered as part of the normal reload core configuration process, which must demonstrate compliance with the acceptance criteria of 10 CFR 50.46. No special considerations are necessary to address the effects of reconstituted fuel assemblies on the conclusions of the LOCA analyses when using the CPSES LOCA methodologies.

The Westinghouse non-LOCA reload safety analyses, as described in WCAP-13060-P-A, use a reference analysis approach; i.e., a bounding analysis is performed, imposing limits on the values of various cycle-specific parameters to demonstrate compliance with the to TXX-05087 Page 5 of 8 relevant event acceptance criteria. Cycle-specific evaluations are performed to ensure that the parameter limits are met for a given reload core configuration. Compliance with the parameter limits are demonstrated using the nuclear design tools.

The analytical methods used by TXU Power to analyze the non-LOCA transients and accidents for CPSES are listed in Technical Specification 5.6.5.b. In contrast with the approach described in WCAP-13060-P-A, the analyses of each of these transients and accidents are performed on a cycle-specific basis. In the CPSES methodologies, a system analysis is first performed to assess the global effects of the initiating event. A thermal-hydraulic, or subchannel analysis, is then performed to demonstrate compliance with the DNB event acceptance criterion.

Because of the geometric equivalency between the normal and reconstituted fuel assemblies, the system analyses are unaffected by reconstitution. No special considerations are necessary to address the effects of reconstituted fuel assemblies on the conclusions of the non-LOCA system analyses when using the CPSES non-LOCA methodologies.

Perhaps the largest potential effect of reconstitution lies within the core thermal-hydraulic, or subchannel, analyses used to demonstrate compliance with the DNB event acceptance criteria. In annular test geometry with smooth tubes, the presence of non-heat-producing walls leads to a cold wall effect that acts to decrease the DNB heat flux.

Cooler liquid concentrates near the unheated wall, and thus, the average channel fluid conditions calculated by a subchannel code may not be representative of the hotter fluid conditions surrounding the heat-producing fuel rods. As described in WCAP-13060-P-A, in reconstituted fuel assemblies, the total power production in affected subchannels is slightly reduced, such that the net effect on the critical heat flux is negligible.

Furthermore, as concluded in the WCAP, the turbulent mixing promoted by Westinghouse mixing vane grids effectively negates any cold wall effect.

The other potential effect of reconstitution within the subchannel analysis is associated with potential cross-flow and changes in the subchannel enthalpy deposition. However, as described in WCAP-1 3060-P-A, the flow and enthalpy distributions in the hot channel of a reconstituted assembly are not significantly different from those for a regular assembly. This conclusion is dependent on the use of Westinghouse mixing vane grids but is independent of the analytical tool and DNB correlation. As confirmation that the specific reconstitution pattern does not invalidate these conclusions, Westinghouse committed to confirm that the inclusion of solid replacement rods in a fuel assembly does not introduce significant radial gradients in the local hot subchannel flow and enthalpy.

Westinghouse committed to demonstrate this confirmation by comparing the results (i.e.,

the minimum DNBR) from a subchannel analysis using the actual reconstituted fuel assembly with an analysis assuming the original (un-reconstituted) configuration of the fuel assembly. A higher value of the minimum DNBR for the reconstituted assembly analysis is considered confirmation that no significant radial gradients in the local hot subehannel flow and enthalpy are introduced by the specific reconstituted configuration.

Attachment I to TXX-05087 Page 6 of 8 As previously noted, this approach is independent of the specific analytical tool and DNB correlation used. Using the tools approved for use at CPSES, TXU Power has performed a demonstration exercise using a reconstituted fuel assembly configuration presented in WCAP-13060-P-A. Consistent with the sample results presented in the WCAP, the DNBR for the reconstituted fuel assembly was calculated to be higher than for the original fuel assembly.

In summary, consistent with the guidance provided in Generic Letter 90-02, Supplement 1, Westinghouse has obtained NRC approval of a generic topical report that justifies the specified fuel configuration with filler rods and justifies the analytical methods for core analysis to support fuel reconstitution. TXU Power has reviewed this topical report, WCAP-13060-P-A, including all Requests for Additional Information and other supporting information, and concluded that the topical report can be applied using the NRC-approved methods developed for use at CPSES. The CPSES application includes the cycle-specific confirmations identified in the WCAP-13060-P-A.

4.0 TECHNICAL ANALYSIS

The proposed change to the documents referenced in TS 5.6.5.b is administrative as it defines NRC-approved methods that will be used to establish cycle operating limits. The limits determined with the referenced methodologies will ensure that reload design, analysis, and plant operation, including the effects of fuel rod reconstitution, will remain within the regulatory requirements established for fuel assembly and core designs. TXU Power has reviewed the changes and determined that the documents referenced completely address the cycle specific reload design and analysis activities required to determine the core operating limits. All referenced methodologies have been approved by the NRC for the intended application.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration TXU Power has evaluated whether or not a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10CFR50.92, "Issuance of amendment," as discussed below:

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

Response: No The proposed change is administrative in nature and as such does not impact the condition or performance of any plant structure, system or component. The core operating limits are established to support Technical Specifications 3.1, 3.2, 3.3, 3.4, and 3.9. The core operating limits ensure to TXX-05087 Page 7 of 8 that fuel design limits are not exceeded during any conditions of normal operation or in the event of any Anticipated Operational Occurrence (AOO). The methods used to determine the core operating limits for each operating cycle are based on methods previously found acceptable by the NRC and listed in TS section 5.6.5.b. Application of these approved methods will continue to ensure that acceptable operating limits are established to protect the fuel cladding integrity during normal operation and AOOs. The requested Technical Specification change does not involve any plant modifications or operational changes that could affect system reliability, performance, or possibility of operator error. The requested change does not affect any postulated accident precursors, does not affect any accident mitigation systems, and does not introduce any new accident initiation mechanisms.

As a result, the proposed change to the CPSES Technical Specifications does not involve any increase in the probability or the consequences of any accident or malfunction of equipment important to safety previously evaluated since neither accident probabilities nor consequences are being affected by this proposed administrative change.

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

Response: No The proposed change is administrative in nature, and therefore does not involve any changes in station operation or physical modifications to the plant. In addition, no changes are being made in the methods used to respond to plant transients that have been previously analyzed. No changes are being made to plant parameters within which the plant is normally operated or in the setpoints, which initiate protective or mitigative actions, and no new failure modes are being introduced.

Therefore, the proposed administrative change to the CPSES Technical Specifications does not create the possibility of a new or different kind of accident or malfunction of equipment important to safety from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed change is administrative in nature and does not impact station operation or any plant structure, system or component that is relied to TXX-05087 Page 8 of 8 upon for accident mitigation. Furthermore, the margin of safety assumed in the plant safety analysis is not affected in any way by the proposed administrative change.

Therefore, the proposed change to the CPSES Technical Specifications does not involve any reduction in a margin of safety.

Based on the above evaluations, TXU Power concludes that the proposed amendment(s) present no significant hazards consideration under the standards set forth in IOCFR50.92(c) and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 Applicable Regulatory Requirements/Criteria The proposed changes will ensure that the fuel design and core operating limits determined for the operating cycles will be developed using NRC-approved methods identified in TS 5.6.5.b, which are based on applicable regulatory criteria. In conclusion, (1) there is reasonable assurance that the health and safety of the public will not be endangered by the operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

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

7.0. REFERENCES 7.1. Generic Letter 90-02, Supplement 1, "Alternative Requirements for Fuel Assemblies in the Design Features Section of Technical Specifications" 7.2. NUREG-1431 Volume 1, Revision 3, "Standard Technical Specifications, Westinghouse Plants," June 2004.

7.3. WCAP-1 03060-P-A, "Westinghouse Fuel Assembly Reconstitution Evaluation Methodology."

ATTACHMENT 2 to TXX-05087 PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

Page 5.0-34

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 Core ODerating Limits ReDort (COLR) (continued)

10) RXE-88-102-P-A, 'TUE-1 Departure from Nucleate Boiling Correlation", July 1992.

11) RXE-88-102-P, Sup. 1, "TUE-1 DNB Correlation - Supplement 1",

December 1990.

12) RXE-89-002-A, VIPRE-01 Core Thermal-Hydraulic Analysis Methods for Comanche Peak Steam Electric Station Licensing Applications", September 1993.

13) RXE-91-001-A, Transient Analysis Methods for Comanche Peak Steam Electric Station Licensing Applications", October 1993.

14) RXE-91 -002-A, Reactivity Anomaly Events Methodology",

October 1993.

15) ERX-2000-002-P, "Revised Large Break Loss of Coolant Accident Analysis Methodology', March 2000.

16) TXX-88306, "Steam Generator Tube Rupture Analysis", March 15, 1988.

17) RXE-91-005-A, "Methodology for Reactor Core Response to Steamline Break Events," February 1994.

18) RXE-94-001 -A, "Safety Analysis of Postulated Inadvertent Boron Dilution Event in Modes 3,4, and 5," February 1994.

19) RXE-95-001 -P-A, "Small Break Loss of Coolant Accident Analysis Methodology," September 1996.

20) Caldon, Inc. Engineering Report-80P, 'Improving Thermal Power Accuracy and Plant Safety While Increasing Operating Power level Using the LEFM4 System," Revision 0, March 1997 and Caldon Engineering Report - 160P, 'Supplement to Topical Report ER-80P: Basis for a Power Uprate With the LEFM P' System,"

Revision 0, May 2000.

21) ERX-2001-005-p, "ZIRLOTM Cladding and Boron Coating Models for TXU Electric s Loss of Coolant Accident Analysis Methodologies," October 2001.

22) WCAP-13060-P-A, "Westinghouse Fuel Assembly Reconstitution Evaluation Methodology," July, 1993.

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

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

(continued)

COMANCHE PEAK - UNITS 1 AND 2 5.0-34 Amendment No. 89

ATTACHMENT 3 to TXX-05087 RETYPED TECHNICAL SPECIFICATION PAGES Page 5.0-34

7. -X Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 Core Operating Limits Report (COLR) (continued)

10) RXE-88-102-P-A, "TUE-1 Departure from Nucleate Boiling Correlation", July 1992.

11) RXE-88-102-P, Sup. 1, "TUE-1 DNB Correlation - Supplement 1, December 1990.

12) RXE-89-002-A, "VIPRE-01 Core Thermal-Hydraulic Analysis Methods for Comanche Peak Steam Electric Station Licensing Applications", September 1993.

13) RXE-91 -001 -A, "Transient Analysis Methods for Comanche Peak Steam Electric Station Licensing Applications", October 1993.

14) RXE-91-002-A, "Reactivity Anomaly Events Methodology",

October 1993.

15) ERX-2000-002-P, "Revised Large Break Loss of Coolant Accident Analysis Methodology", March 2000.

16) TXX-88306, "Steam Generator Tube Rupture Analysis", March 15, 1988.

17) RXE-91-005-A, "Methodology for Reactor Core Response to Steamline Break Events," February 1994.

18) RXE-94-001 -A, Safety Analysis of Postulated Inadvertent Boron Dilution Event in Modes 3,4, and 5," February 1994.

19) RXE-95-001 -P-A, "Small Break Loss of Coolant Accident Analysis Methodology," September 1996.

20) Caldon, Inc. Engineering Report-80P, "Improving Thermal Power Accuracy and P1ant Safety While Increasing Operating Power level Using the LEFMSI System," Revision 0, March 1997 and Caldon Engineering Report - 160P, "Supplement to Topical Report ER-8OP: Basis for a Power Uprate With the LEFMz4'm System,"

Revision 0, May 2000.

21) ERX-2001-005-p, "ZIRLOTM Cladding and Boron Coating Models for TXU Electric s Loss of Coolant Accident Analysis Methodologies," October 2001.

22) WCAP-13060-P-A, "Westinghouse Fuel Assembly Reconstitution Evaluation Methodology," July, 1993.

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

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

(continued)

COMANCHE PEAK - UNITS 1 AND 2 5.0-34 Amendment No.