ML020180190

Issuance of Amendment (Tac. MB1638) Relocation of Cycle Specific Parameters to the Core Operating Limits Report

ML020180190
Person / Time
Site:	Wolf Creek
Issue date:	03/28/2002
From:	Donohew J NRC/NRR/DLPM/LPD4
To:	Maynard O Wolf Creek
References
TAC MB1638
Download: ML020180190 (14)

Text

March 28, 2002 Mr. Otto L. Maynard President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KS 66839

SUBJECT:

WOLF CREEK GENERATING STATION - ISSUANCE OF AMENDMENT RE:

RELOCATION OF CYCLE SPECIFIC PARAMETERS TO THE CORE OPERATING LIMITS REPORT (TAC NO. MB1638)

Dear Mr. Maynard:

The Commission has issued the enclosed Amendment No. 144 to Facility Operating License No. NPF-42 for the Wolf Creek Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated April 3, 2001 (ET 01-0008), as supplemented on October 22 and December 18, 2001 (ET 01-0030 and -0036), and March 7, 2002 (GC 02-0011).

The amendment relocates certain reactor coolant system cycle-specific parameter limits from the TSs to the Core Operating Limits Report (COLR), and thus expands the COLR.

Additionally, TS 5.6.5, Core Operating Limits Report (COLR)," is revised to allow topical reports to be identified by title and number only.

A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-482

Enclosures:

1. Amendment No. 144 to NPF-42

2. Safety Evaluation cc w/encls: See next page

March 28, 2002 Mr. Otto L. Maynard President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation Post Office Box 411 Burlington, KA 66839

SUBJECT:

WOLF CREEK GENERATING STATION - ISSUANCE OF AMENDMENT RE:

RELOCATION OF CYCLE SPECIFIC PARAMETERS TO THE CORE OPERATING LIMITS REPORT (TAC NO. MB1638)

Dear Mr. Maynard:

The Commission has issued the enclosed Amendment No. 144 to Facility Operating License No. NPF-42 for the Wolf Creek Generating Station. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated April 3, 2001 (ET 01-0008), as supplemented on October 22 and December 18, 2001 (ET 01-0030 and -0036), and March 7, 2002 (GC 02-0011).

The amendment relocates certain reactor coolant system cycle-specific parameter limits from the TSs to the Core Operating Limits Report (COLR), and thus expands the COLR.

Additionally, TS 5.6.5, Core Operating Limits Report (COLR)," is revised to allow topical reports to be identified by title and number only.

A copy of our related Safety Evaluation is enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely,

/RA/

Jack Donohew, Senior Project Manager, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-482 DISTRIBUTION PUBLIC GHill (2)

Enclosures:

1. Amendment No. 144 to NPF-42 PDIV-2 Reading LHurley, RIV

2. Safety Evaluation RidsNrrDlpmLpdiv(SRichards) DBujol, RIV RidsNrrPMJDonohew cc w/encls: See next page RidsNrrLAEPeyton RidsOgcRp RidsAcrsAcnwMailCenter WBeckner FAkstulewicz Anthony Attard WJohnson, RIV

• See previous concurrence TS: ML020930466 ACCESSION NO.: ML020180190 PKG: ML020920452 Nrr-058 OFFICE PDIV-2/PM PDIV-2/LA SRXB/SC OGC PDIV-2/SC NAME JDonohew EPeyton FAkstulewicz* RWiesman* SDembek DATE 3/27/2002 3/27/02 02/26/2002 03/25/2002 3/28/02 OFFICIAL RECORD COPY

Wolf Creek Generating Station cc:

Jay Silberg, Esq. Vice President Operations Shaw, Pittman, Potts & Trowbridge Wolf Creek Nuclear Operating Corporation 2300 N Street, NW P. O. Box 411 Washington, D.C. 20037 Burlington, KS 66839 Regional Administrator, Region IV Superintendent Licensing U.S. Nuclear Regulatory Commission Wolf Creek Nuclear Operating Corporation 611 Ryan Plaza Drive, Suite 1000 P.O. Box 411 Arlington, TX 76011 Burlington, KS 66839 Senior Resident Inspector U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Resident Inspectors Office P. O. Box 311 8201 NRC Road Burlington, KS 66839 Steedman, MO 65077-1032 Chief Engineer Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027 Office of the Governor State of Kansas Topeka, KS 66612 Attorney General Judicial Center 301 S.W. 10th 2nd Floor Topeka, KS 66612 County Clerk Coffey County Courthouse Burlington, KS 66839 Vick L. Cooper, Chief Radiation Control Program, RCP Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366

WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 144 License No. NPF-42

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Wolf Creek Generating Station (the facility)

Facility Operating License No. NPF-42 filed by the Wolf Creek Nuclear Operating Corporation (the Corporation), dated April 3, 2001, as supplemented by letters dated October 22 and December 18, 2001, and March 7, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and Paragraph 2.C.(2) of Facility Operating License No. NPF-42 is hereby amended to read as follows:

2. Technical Specifications The Technical Specifications (TSs) contained in Appendix A, as revised through Amendment No. 144, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated in the license. The Corporation shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. The license amendment is effective as of its date of issuance and shall be implemented, including relocating the requirements from the TSs to the Core Operating Limits Report, as specified in the licensees letters of April 3, October 22, and December 18, 2001, and March 7, 2002, and the Safety Evaluation attached to this amendment, prior to the startup from Refueling Outage 12, which is scheduled for the Spring of 2002.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Stephen Dembek, Chief, Section 2 Project Directorate IV Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: March 28, 2002

ATTACHMENT TO LICENSE AMENDMENT NO. 144 FACILITY OPERATING LICENSE NO. NPF-42 DOCKET NO. 50-482 Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change. The corresponding overleaf pages are provided to maintain document completeness.

REMOVE INSERT 2.0-1 2.0-1 2.0-2 ---

3.3-19 3.3-19 3.3-20 3.3-20 3.4-1 3.4-1 3.4-3 3.4-3 3.4-4 3.4-4 5.0-27 5.0-27 5.0-28 5.0-28 5.0-29 5.0-29

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 144 TO FACILITY OPERATING LICENSE NO. NPF-42 WOLF CREEK NUCLEAR OPERATING CORPORATION WOLF CREEK GENERATING STATION DOCKET NO. 50-482

1.0 INTRODUCTION

By letter dated April 3, 2001, as supplemented by letters dated October 22 and December 18, 2001, and March 7, 2002, Wolf Creek Nuclear Operating Corporation (the licensee) requested changes to the Technical Specifications (TSs) for Wolf Creek Generating Station (WCGS) to (1) relocate cycle-specific reactor coolant system (RCS) related parameter limits in the TSs to the Core Operating Limits Report (COLR), and (2) modify the list of topical reports in TS 5.6.5, "Core Operating Limits Report" by identifying the report by only their titles and numbers. The parameter limits proposed to be relocated to the COLR are in the following TSs:

! TS 2.1.1, "Reactor Core Safety Limits;"

! TS Table 3.3.1-1, "Reactor Trip System Instrumentation;" and

! TS 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits."

Figure 2.1.1-1 of TS 2.1.1 would also be replaced by more specific safety limits for departure from nucleate boiling ratio (DNBR) and peak fuel centerline temperature.

The additional information in the supplemental letter of March 7, 2002, does not expand the scope of the application as noticed, clarifies the proposed changes given in the application, and does not change the NRC staffs original proposed no significant hazards consideration determinations published in the Federal Register on May 2, 2001 (66 FR 22036) and February 5, 2002 (67 FR 5342). The second Federal Register notice was published because the supplemental letter of October 22, 2001, added an additional proposed change to relocate TS 2.1.1, "Reactor Core Safety Limits," to TS 5.6.5.a.

2.0 BACKGROUND

Guidance on the relocation of cycle-specific TS parameters to the COLR was developed by the staff and provided to all power reactor licensees and applicants by Generic Letter (GL) 88-16, "Removal of Cycle-Specific Parameter Limits from Technical Specifications," dated October 3, 1988. In the GL, the staff stated that license amendments are generally required every refueling outage to update the cycle-specific parameter limits in the TSs; however, there are methodologies developed for the licensee to determine these cycle-specific parameters that

have been reviewed and approved by the staff. As a consequence, the NRC review of proposed changes to the TSs to update these parameter limits is primarily limited to the confirmation that the updated limits were calculated by the approved methodology and consistent with the appropriate plant-specific safety analysis. The creation of the COLR was to place the NRC-approved methodologies in the TSs and allow licensees to make changes using these methodologies to update the parameter without requiring a change to the TSs. If the limits are updated using an NRC-approved methodology, the license amendment process is an unnecessary burden on the licensee and the staff.

The licensee stated that its justification to expand the COLR was provided in Westinghouse Energy System Topical Report WCAP-14483-A, Generic Methodology for Expanding Core Operating Limits Report," dated November 1995, which was approved by NRC for referencing by the staff on January 19, 1999. The staffs letter and safety evaluation approving the use of the topical report was issued January 19, 1999, and is included in the beginning of the topical report. The topical report addresses the relocation of the (1) reactor core safety limits figure, (2) overtemperature T (OTDT) and overpower T (OPDT) setpoint parameter values for reactor trip instrumentation, and (3) DNB parameter limits in the TSs to the COLR. The topical report provides changes to plant TSs to relocate the above three TS requirements to the COLR which have been reviewed and approved by the staff.

The staff has approved WCAP-14483-A as an acceptable method to relocate these TS requirements to the COLR consistent with GL 88-16. The staff incorporated the generic methodology for expanding the COLR of WCAP-14483-A into NUREG-1431, the Improved Standard Technical Specifications for Westinghouse Plants, which is the standard that the Wolf Creek TSs are based upon. In TSTF-339, Revision 2, the relocation of the (1) reactor core safety limits figure, (2) overtemperature T (OTDT) and overpower T (OPDT) setpoint parameter values for reactor trip instrumentation, and (3) DNB parameter limits in the TSs to the COLR in WCAP-14483-A were approved by the staff for NUREG-1431. These are the changes for TSs 2.1.1, 3.3.1, and 3.4.1 that the licensee has proposed in its application.

3.0 EVALUATION In its application, the licensee proposed relocating the following requirements in the TSs to the COLR:

1. TS 2.1.1, "Reactor Core Safety Limits," would be revised by relocating Figure 2.1.1-1, "Reactor Core Safety Limits," to the COLR and replacing the figure by more specific safety limits for DNBR and peak fuel centerline temperature.

The licensee stated that relocating the DNB parameters limit values to the COLR allows the flexibility to utilize the available margins to increase cycle operating margins and improve core reload designs without the requirement of cycle-specific license amendments. This results in a more complete COLR containing not only cycle-specific core reload related parameters, but also cycle-specific operating condition parameters. Thus, the safety analyses could credit the actual cycle-specific operating condition in the same way that the core reload designs currently do. The COLR and safety analyses will more closely reflect the cycle specific conditions for which the plant control and protection systems are set for a given cycle.

The licensee also stated that (1) the methodology used to calculate Figure 2.1.1-1 is in Wolf Creek Nuclear Operating Corporation (WCNOC) Topical Report NSAG-007, "Reload Safety Evaluation Methodology for the Wolf Creek Generating Station," which has been reviewed and approved by the NRC on March 10, 1993, and (2) the existing specification for the COLR in TS 5.6.5 requires the NSAG-007 report to be used as one of the analytical methods to determine the core operating limits in the COLR.

The changes proposed by the licensee are consistent with the changes identified in WCAP-14483-A for deleting TS Figure 2.1.1-1 that were reviewed and approved by the staff.

The methodology used to determine the figure that would be in the COLR is the NSAG-007 report. This report is listed in the COLR and TS Section 5.6.5.b. The licensee stated in its application that the proposed requirements in Modes 1 and 2 for the DNBR and peak fuel centerline temperature (i.e., the proposed TSs 2.1.1.1 and 2.1.1.2) are the design basis limits for the plant and are the limits that must be satisfied for Condition I and II transients.

In the supplemental letter of December 18, 2001, the licensee stated that the replacement safety limits for the DNBR and the peak fuel centerline temperature are the correct limits for WCGS.

Based on the above, the staff concludes that the proposed changes to TS 2.1.1 are acceptable.

In addition, the proposed changes to TS 2.1.1 are consistent with TSTF-339, Revision 2.

2. TS 3.3.1, Table 3.3.1-1, "Reactor Trip System Instrumentation," would be revised to relocate the OTDT and OPDT trip constant (K) values, the dynamic compensation time

() values, and the breakpoint and slope values for the f(I) penalty functions to the COLR.

The licensee stated that placing these setpoints in the COLR allows them to be based on cycle-specific core design parameters, which are verified on a cycle-specific basis, thereby avoiding the necessity of overly conservative TS limits. The NRC has previously approved the relocation of the OTDT and OPDT setpoint parameter values to the COLR for the Catawba, McGuire and Seabrook Nuclear Stations. Placing these setpoints in the COLR allows them to be based on cycle-specific core design parameters, which are verified on a cycle-specific basis, thereby avoiding the necessity of TS limits being too conservative.

The changes proposed by the licensee are consistent with the approved changes identified in WCAP-14483-A for relocating parameter values in the OTDT and OPDT equations in Table 3.3.1-1. The applicable NRC-approved setpoint methodology is in WCAP-8745-P-A, "Design Bases for the Thermal Power T and Thermal Overtemperature T Trip Functions,"

dated September 1986. The licensee has proposed to add this reference to the list of NRC-approved analytical methods in TS 5.6.5.b.

Based on the above, the staff concludes that the proposed changes to Notes 1 and 2 of TS Table 3.3.1-1 to relocate parameters to the COLR are acceptable. In addition, the proposed changes to TS Table 3.3.1-1 are consistent with TSTF-339, Revision 2.

An "=" symbol is also proposed to be added to the f(I) penalty functions in Note 1 of Table 3.3.1-1 for OTDT. The equal symbol is needed to denote that the f(I) penalty equals the functions to the right of the f(I) symbol on the bottom of the page for Note 1. Because the

"=" symbol is needed and does not affect the value of the f(I) penalty, the staff concludes that the proposed change is acceptable.

In its application, the licensee proposed to change the "+" sign in front of the term (qt - qb) of the f(I) penalty functions in Note 1 of Table 3.3.1-1 for OTDT. In the letter of March 7, 2002, the licensee stated that the current "+" is not in error and should remain the "+" sign, because to change the "+" sign would result in an inconsistent application of the breakpoints and slopes.

Therefore, the "+" sign will remain in the f(I) penalty functions.

3. TS 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits," would be revised to relocate the pressurizer pressure and the RCS average temperature (tavg) to the COLR. The licensee stated that the proposed change to the Applicability Note provides consistency in the Note with NUMARC 93-03, "Writers Guide for the Restructured Technical Specifications," and NUREG-1431, Revision 1, "Standard Technical Specifications Westinghouse Plants." The current TSs for the plant are based on this standard.

The limits for pressurizer pressure, RCS average temperature, and RCS total flow rate would be relocated from TS 3.4.1 to the COLR. However, the minimum RCS total flow rate of 371,400 gpm, based on the maximum analyzed steam generator tube plugging, would be retained in Surveillance Requirement (SR) 3.4.1.4 to assure that a lower RCS total flow rate than approved by the NRC will not be used. Because this minimum value is retained in the TSs, any reduction in the RCS flow rate would have to be reviewed by the NRC. The proposed changes to TS 3.4.1 are consistent with WCAP-14483-A. Also, items a and b in the Note below the Applicability for the limiting condition for operation (LCO) would be moved to the right to be consistent with the format for the TSs; there is no change to the statements made in the Note.

The licensee stated that the analytical methods that address the limits in TS 3.4.1 are in WCNOC Topical Report TR 00-0025 WO1, "Core Thermal Hydraulic Analysis Methodology for the Wolf Creek Generating Station," and WCNOC Topical Report NSAG-006, "Reload Safety Evaluation Methodology for the Wolf Creek Generating Station." These topical reports are references 1 and 3 in TS 5.6.5.b.

Based on the above, the staff concludes that the proposed changes to TS 3.4.1 are acceptable.

In addition, the proposed changes to TS 3.4.1 are consistent with TSTF-339, Revision 2.

4. TS 5.6.5, "Core Operating Limits Report," would be modified to add Specifications 2.1.1, 3.3.1 and 3.4.1 to the list of specifications for which parameter limits are in the COLR, and add the appropriate approved reference of WCAP-8745-P-A for the OTDT and OPDT trip functions.

Consistent with the proposed changes to TS Table 3.3.1-1, and Specification 3.4.1, the licensee has proposed to add Specification 3.3.1, Overtemperature T and Overpower T Trip Setpoints; Specification 3.4.1, Reactor Coolant System Pressure, Temperature, and Flow DNB

Limits; and Specification 2.1.1, Reactor Core Safety Limits to TS 5.6.5.a, which lists the specifications for which core operating limits shall be established. The licensee also proposed to add WCAP-8745-P-A, "Design Bases for the Thermal Power T and Thermal Overtemperature T Trip Function," to TS 5.6.5.b, which lists the documents containing the NRC-approved analytical methods used to determine the core operating limits listed in TS 5.6.5.a.

As stated by the licensee, WCAP-8745-P-A is the NRC-approved analytical methods for the OTDT and OPDT trip setpoints in TS Table 3.3.1-1. The NRC-approved analytical methods which will be used by the licensee to calculate Figure 2.1.1-1 are in NSAG-007, which is listed in TS 5.6.5.b. For Specification 3.4.1, the analytical methods that address the limits in TS 3.4.1 are in the licensees topical reports TR 00-0025 WO1 and NSAG-006, which are references 1 and 3 in TS 5.6.5.b. Therefore, the staff concludes that the approved NRC methodology for the proposed additions to TS 5.6.5.a are contained in TS 5.6.5.b.

Based on this, the staff concludes that the proposed addition of Specifications 2.1.1, 3.3.1, and 3.4.1 to TS 5.6.5.a and the addition of Topical Report WCAP-8745-P-A to TS 5.6.5.b are acceptable.

5. TS 5.6.5, "Core Operating Limits Report," would be modified to revise the references to the topical reports listed in TS 5.6.5 to limit the references to the report number and title with a note that the COLR provides the complete citation of the report (i.e., report number, title, revision, date, and any supplements).

The licensee has also proposed to modify the reference to the documents listed in TS 5.6.5.b as the NRC-approved analytical methods used to determine the core operating limits listed in TS 5.6.5.a. The purpose is to have the references to the approved topical reports listed in TS 5.6.5.b be cited using the report number and title with the complete citation identification of the reports (i.e., report number, title, revision, date, and any supplements) listed in the COLR.

This would allow the licensee to immediately use the current topical report to determine a core operating limit in the COLR without having to request NRC approval to use a revised NRC-approved topical report. Because TS 5.6.5.b requires that the methodology must be previously reviewed and approved by the NRC, the licensee would not be able to use a revised topical report unless the NRC had approved its use.

There is, however, a problem with specifying only the topical reports in TS 5.6.5.b using the report number and title. The problem is that the NRC Safety Evaluation that approves the topical report may contain conditions on the use of the topical report that are not listed in the topical report. This is true for plant-specific topical reports, but not for vendor (e.g., owners groups) topical reports. The practice for approving vendor topical reports is that the topical reports are issued containing a copy of the NRC safety evaluation; therefore, the NRC-approved vendor topical report will contain any conditions specified in the safety evaluation.

For the plant-specific NRC-approved topical reports listed in TS 5.6.5.b, there are conditions in the NRC safety evaluations referenced in TS 5.6.5.b that are not in the plant-specific topical reports. Because the COLR is not part of the WCGS Updated Safety Analysis Report (USAR),

the staff requested the licensee to address if changes to the COLR would come under the change criteria of 10 CFR 50.59, as is required for changes to the plant as described in the USAR. The change criteria in 10 CFR 50.59 applied to changes in the COLR in terms of revising the list of topical reports would require consideration of the conditions in the NRC safety evaluations approving the plant-specific topical reports. The staff was concerned that the conditions in NRC safety evaluations for plant-specific topical reports would cease to be requirements on the licensee if TS 5.6.5.b was changed to only list the report number and title.

In its supplemental letter of December 18, 2001, the licensee addressed the staff's concern.

The licensee stated that the implementation of the process of a specified topical report includes the incorporation of the conditions specified in the NRC safety evaluation in the procedures written to perform the calculations for the values of the core operating limits, which are specified in TS 5.6.5.a. Also, the COLR document that is issued to NRC for each reload to meet TS 5.6.5.d will contain the list of topical reports with the NRC safety evaluation and, therefore, the conditions in the NRC safety evaluations would be part of the COLR document and a requirement on the licensee. The licensee also provided a list of the topical reports that are referenced in the USAR. The licensee considers that the plant changes due to reload activities would be required to be screened by the change criteria in 10 CFR 50.59 because they would affect the accident analysis in USAR Chapter 15. The licensee further stated that the changes to methodology in topical reports would be required to have a 10 CFR 50.59 evaluation performed based on Section 50.59(c)(2)(viii), which states that a licensee shall obtain a license amendment pursuant to Paragraph 50.90 prior to implementing a proposed change if the change would result in a departure from a method of evaluation described in the Final Safety Analysis Report (as updated) used in establishing the design basis or in the safety analyses. In other words, the licensee is stating that its reload activities, including changes to the COLR, are controlled through the licensee's design change process which requires 10 CFR 50.59 reviews for the changes because the licensee's reload activities are discussed in the USAR. Therefore, the licensee concluded in its letter that there is no need to make additional commitments beyond following 10 CFR 50.59 to apply the 10 CFR 50.59 change criteria to the revisions of NRC-approved topical reports. Following 10 CFR 50.59 would require the conditions in the NRC safety evaluations to be incorporated into the plant implementing procedures.

In reviewing the licensee's comments, the staff concludes that the licensee has provided sufficient justification that the change criteria of 10 CFR 50.59 apply to changes in the NRC-approved plant-specific topical reports. Based on this conclusion, the NRC practice to have the vendor topical reports incorporate the NRC safety evaluations approving the vendor topical reports, and the requirement in TS 5.6.5.b that only NRC-approved methodology can be used to calculate the core operating limits listed in TS 5.6.5.a, the staff concludes that the proposed change to only list the NRC-approved methodology by topical report number and title is acceptable.

6. Conclusion The staff concludes that the cycle-specific RCS-related parameters in TSs 2.1.1, 3.3.1, and 3.4.1 are not required to be in the TSs under 10 CFR 50.36, 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. Accordingly, they may be relocated from the TSs to the COLR. The staff

has reviewed the proposed TS revisions for WCGS, and finds them in conformance with WCAP-14483-A, and, therefore, acceptable. Based on the above evaluation, the staff also concludes that adding the "=" symbol to the f(I) penalty functions in Note 1 of TS Table 3.3.1-1 for OTDT and revising the list of specifications and references in TS Section 5.6.5 is acceptable. Based on this and the above evaluation, the staff concludes that the proposed amendment is acceptable. In addition, the proposed changes to TSs 2.1.1, 3.3.1, and 3.4.1 are consistent with TSTF-339, Revision 2.

The licensee agreed to incorporate the changes to the COLR and the TS Bases during the implementation of the amendment. Therefore, the implementation of the amendment will include: (1) the relocation of the requirements from Specifications 2.1.1, 3.3.1, and 3.4.1 to the COLR, and (2) the changes to the TS Bases, as specified in the licensees letters of April 3, October 22, and December 18, 2001, and March 7, 2002, and this safety evaluation, prior to the startup from Refueling Outage 12, which is scheduled for the latter part of March 2002.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Kansas State Official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(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

The Commission has concluded, based on the considerations discussed above, 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 the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Anthony Attard Jack Donohew Date: March 28, 2002