ML20128F868

Application for Amends to Licenses NPF-2 & NPF-8,relocating cycle-specific Core Operating Parameter Limits to Colr. Proposed Changes Based on Guidance Found in NRC GL 88-16, WOG-90-016,NUREG-1431 & VEGP COLR Approved by NRC

ML20128F868
Person / Time
Site:	Farley
Issue date:	09/30/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128F871	List: ML20128F868 ML20128F882
References
RTR-NUREG-1431 GL-88-16, NUDOCS 9610080255
Download: ML20128F868 (8)

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i Soutnzrn Nucitar Operating Company Post Office Box 1295 l

Birmingham, Alabama 35201 Telzphone (205) 8G8-5131 L

Dave Morey Vice President Southern Nudear Operating Company .

l Farley Project s e m M c syst m September 30, 1996 Docket Nos.: 50-348 10 CFR 50.90 50-364 U. S. Nuclear Regulatory Commission 1 ATFN.: Document Control Desk l Washington, DC 20555 l Joseph M. Farley Nuclear Plant l Technical Specifications Change Request Core Operatine Limits Reoort Ladies and Gentlemen:

In accordance with the provisions of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) l proposes to amend the Farley Unit I and Unit 2 Technical Specifications by re-locating the cycle-l specific core operating parameter limits to the Core Operating Limits Report (COLR). The l proposed amendment also includes changes to the bases associated with certain specifications affected by COLR, and the admmistrative requirements for the Peaking Factor Limit Report, which I

will be superseded by the COLR. The proposed changes are based on the guidance found in NRC Generic Letter 88-16, " Removal Of Cycle-Specific Parameter Limits From Technical

. Specifications," Westinghouse Owners Group letter WOG-90-016, " Core Operating Limits Report l License Amendment Submittal," NUREG 1431," Standard Technical Specifications Westinghouse Plants," and Vogtle Electric Generating Plant COLR approved by the NRC.

The cycle-specific core operating parameter limits are calculated using NRC-approved methodologies. These limits are evaluated each cycle as a part of the core reload design process. On l occasion, some limits must be revised to reflect changes to cycle-specific variables. This proposed amendment will relieve an unnecessary administrative burden on both the NRC and SNC associated with processing cycle-specific Technical Specifications amendments to accommodate core reloads which may require changes to these limits. Such changes will be reviewed in accordance with the requirements of 10 CFR 50.59 and documented in the cycle-specific COLR, which will be provided to the NRC on a cycle by cycle basis.

As denoted in 10 CFR 50.92(c), SNC has determined the proposed changes to the Technical Specifications do not involve a significant hazards consideration. The basis for this determination is provided by the evaluation in Attachment I. SNC has also determined that the proposed changes will not significantly affect the quality of the human environment. A copy of the proposed changes has i been sent to Dr. D. E. Williamson, the Alabama State Designee, in accordance with 10 CFR 50.91 l (bXI).

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U. S. Nuclear Regulatory Commission Page 2 l

l l Awkmant II includes the proposed Technical Specifications changes. 'Ihe marked-up and typed pages are based in-part on current Technical Specifications and in-part on the licensing amendments l associated with the revision to the core limits and OTAT & OPAT setpoints and implementation of l Relaxed Axial Offset Control (RAOC). (Reference SNC letter dated June 12,1996, r.nd NRC l letters dated September 3 and September 10,1996.) Attachment III provides an exampic Farley COLR for one unit.

l It is respectfLily requested that the NRC review and approve the proposed Technical Specifications I

changes by February 28,1997. The Unit I license amendment should become effective prior to entry into Mode 5 following the next scheduled refueling outage, which is scheduled to begin in March 1997. The Unit 2 License amendment should become effective anytime followmg receipt of l the NRC approved COLR amendment request at SNC's discretion, but must be implemented prior l to entry into Mode 5 following the refueling outage scheduled to begin in March 1998. Should you j have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY h h ]lL<hf Dave Morey Sworn to and subscribed before me this. To day of f A 1996 Y '

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! Attachments cc: Mr. S. D. Ebncter, Region II Administrator Mr. J. I. Zimmerman, NRR Senior Project Manager Mr. T. M. Ross, FNP Sr. Resident Inspector Dr. D. E. Williamson, State Department of Public Health i

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1 ATTACHMENT I -

FARLEY NUCLEAR PLANT TEbHNICAL SPECIFICATION CHANGE REQUEST CORE OPERATING UNITS REPORT 10 CFR 50.92 SIGNIFICANT HAZARDS EVALUATION l

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FARLEY NUCLEAR PLANT I

REQUEST FOR TECHNICAL SPECIFICATIONS CHANGE CORE OPERATING LIMITS REPORT (COLR) 10 CFR 50.92 EVALUATION l

Background

Generic Letter 88-16, dated October 4,1988, was issued to encourage liceamaan to prepare changes to Technical Speci6 cations related to cycle-speedic parameters These Technical Spacineadaa_= changes will relocate cycle-specific parameter limits from Techmcal Spacine= dons to the COLR. Presently, the parameter limits in the Farley Nuclear Plant (FNP) Technical Speci5 cations are calculated using NRC-appsoved methodologies. These limits are evaluated for every reload cycle and may be revised l periodically as appropnate to reGect changes to cycle-specinc vanables. This is an admmiserative burden on both the NRC and Southern Nuclear Operstmg Company (SNC).

The Generic letter provided guidana for relocation of certain cycle '-i= '- =t core operating limits from the FNP Technical Specifications. The COIJL is being established at FNP in accordance with GL 88-16 l to avoid the annanaamary burden of changing limits which are developed using an NRC-epproved i

methodology. This approach would allow changes to the values of core operating limits without prior approval (i.e., license amendment) by the NRC, so long as NRC-approved methodologies for the parameter limit calculations are followed. Revisions to core operating limits due to the FNP core reloads or other changes would involve a safety review in accordance with the requirements of 10 CFR 50.59.

The revised Administrative Controls section of this license amendment request identifies the methodologies used to determine each par =~e limit proposed for inclusion in the COLR. These ,

I methodologies are currently deed to calculate the limits for each FNP core reload design, or when any other revisions are made that affect the core operating limits. The methadalogies have been approved by the NRC.

Proposed Channes The proposed Technical Sparinea' ions changes concern the relocation of seve al cycle-specific core operating limits for FNP from the Technical Specifications to the COLR. A new definition of the COLR will be added to the Technical Specifications. Additionally, certain individual Technical Specifications will be modified to note that cycle-specific parameter limits are contained in the COLR. A COLR paragraph will be added to the Admimstrative Controls section of the Technical Sp~ ineations to replace the Peaking Factor Limit Report (6.9.1.11). An example of the FNP COLR is also provided. Future reoorts, or report revisions, will be provided to the NRC upon issuana to allow continued trending of the

@e-specific paramasers by the NRC.

The proposed changes will reference the COLR for spectfic parameters and will ensure that cycle-spectfic parameters are maatamad within the limits of the COLR. 'Ihe cycle-specific parameter limits proposed for relocation to the COLR as part of this license amendment include the following:

(a) 3/4.1.1.1 Shutdown Margin for Modes 1,2,3 and 4 (b) 3/4.1.1.2 Shutdown Margin for Mode 5 (c) 3/4.1.1.3 Moderator Temperature Coefficient (d) 3/4.1.3.5 Shutdown Rod Insertion Limit (e) 3.1.3.6 Control Rod Insertion Limits (f) 3.2.1 Axial Flux Difference (g) 3/4.2.2 Heat Flux Hot Channel Factor - F,(z) l (h) 3.2.3 Nuclear Enthalpy Hot Channel Factor - F"AH Page1

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] The proposed changes are consistent with the requirements of 10 CFR 50.36 and the Staffs proposed j policy for improving Techmcal Specifications, delineated in SECY-86-10. "P--ndations for ,

i Improvmg Techmcal Specifications." The policy allows process variables such as core operational limits to be controlled by specifymg them numerically in the Techmcal Specifications or by specifying the j method of r=l~'aia: their numerical values, if the staff Ands that the correct limits will be followed in i operating the plant. The proposed revision referenas the NRC-approved calculataon methodologies. The j devv5==^ of cycle-specific core operating limits will continue to be performed by the referenced

! methodologies which have been accepted by the NRC. In addition, the requested changes are consistent with those previously approved by the NRC for Vogtle Electnc Generating Plant under Docket

Nos. 50-424 and 50-425 (NRC letter dated July 30,1990), which has a similar core design.

1 i The proposed changes to the Technical Specifications are considered to be improvaments and are

! consissent with the NRC stated policy for improving Technical Specifications (52 FR 3788, February 6, 1

1987).

Analysis j The current Technical Saaeinea'iaas method of controlling reactor physics parameters to ensure conformanz to 10 CFR 50.36 (which requires the lowest functional nerformance levels ==='#ta for i continued safe operation) is to specify the values desertmnarl to be within the ==~- criteria using an

} NRC-approved calculation methodology. As previously discusser'., the methodologies for ent~1*iag these i

parameter limits have been reviewed and approved by the NRC :ad are consistent with the applicable analyses presented in the FNP Final Safety Analysis Report (FSAR).

The removal of cycle daaaada=* variables (i.e., limits) from the Technical Specifications has no impact upon plant operation or safety. No safety related equipment, safety function, or plant operations will be altered as a result of this propbsed change. Since the applicable limits will be maintained and the Technical Si+SIMons will continue to require operation within the core operational limits calculated by these NRC-approved methodologies, this proposed change is administrative in nature Appropriate actions to be taken iflimits are violated will also remain in the Technacal Saarin cations This proposed change will allow FNP to administratively control the cycle-specific parameters within the acceptable limits and will assure conformance to 10 CFR 50.36 by using the approved methadalogy instead of spectfymg Techmcal Specifications values. 'llie COLR will document the specific i,-i =;

limits resulting from FNP calculations, including mid-cycle or other revisions to parameter values.

Therefore, the proposed change is in conformance with the requirements of 10 CFR 50.36.

Any changes to the COLR will be made in accordance with the prosisions of 10 CFR 50.59. From cycle to cycle, the COLR will be revised such that the appropriate core operating limits for the applicable cycle will apply. As such the FNP Techmcal Specifications will not be changed; however, the COLR will be provided to the NRC.

Determian'iaa of Si aine=at 14=7=eds Pursuant to 10 CFR 50.92, SNC has determined that operation of FNP in accordance with the proposed license amendment does not involve any significant hazards consiocration as defined by NRC regulations.

The following discussion describes how the proposed amendment satisfies each of the three standards of 10 CFR 50.92(c).

1) The proposed changes do not involve a significant increase in the probability or consequences of an accident presiously evaluated.

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i The removal of cycle-specific core operatmg limits from the FNP Tar haical Specifications has no influence or impact on the probability or consequenas of a Design i Basis Accident (DBA) occurrence. The cycle-specific core operating limits, although not in Techmcal Specifications, will be followed in the operation of FNP. The proposed  ;

amentiment retains the same required actions to be taken w' a n or iflimits are exceeded '

as stipulated by current Technical Specifications. In addition, the associated

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surveillance requirements are not altered by the proposed changes, j

Each accident analysis addressed in the FNP FSAR will be examinart with respect to i changes in cycle '-g= '=^ parameters, wiuch are ahaminant from applieneian of the NRC-approved reload design methodologies, to ensure that the transient evalustson of new reloads are boundarl by y.Jously arrapeart analyses. This exammatian. which will .

be performed per requ2ements of 10 CFR 50.59, ensures that future reloads will not ~

l involve a sigmficant increase in the probability or consequences of an accident i previously evaluated.

2) The proposed changes do not create the possibility of a new or different kind of accident i from any accident previously evaluated.  !

As stated earlier, the removal of the cycle-specific variables has no influena or impact, {

nor does it contribute in any way to the probability or consequences of an amident. No ,

safety-related equipment, safety function, or plant operation will be altered as a result of l this proposed change The cycle-specific variables are calculated using the NRC-approved methods and submitted to the NRC to allow the Staff to continue to trend the ) i values of these limits. The Technical Specifications will continue to require operation I within the required core operating limits and appropriate actions will be taken when or iflimits artf exceeded. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3) The proposed changes do not result in a significant reduction in the margin of safety.

The margin of safety is not affected by the removal of cycle-specific core operatmg limits from the Techmcal Specifications. The margin of safety presently provided by i

current Technical Specifications remains unchanged. Appropnate measures exist to control the values of these cycle-specific limits. He proposed asrenciment continues to require operation within the core limits, as obtained from the NRC-approved reload design methodologies. The required actions to be taken or iflimits are violated remain unchanged.

l The development of the limits for future reloads will continue to conform to those methods described in NRC-approved documentation. In addition, each future reload involves a 10 CFR 50.59 safety review to assure that operation of FNP within the cycle-specific limits will not involve a significant reduction in margin of safety. Therefore, the proposed changes are administrative in nature and do not impact the operatics of FNP in a manner that involves a reduction to the margin of safety.

Conclusion

Based on the preceding, the removal of cycle-specific parameters from the Technical Specifications to the j Core Operatmg Limit Report does not involve a significant hazards consideration per 10 CFR 50.92.

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i ATTACHMENT II .

FNP Unit 1 Technical Specifications Proposed Changed Pages List FNP Unit i Technical Specifications Marked-up Pages FNP Unit 1 Technical Specifications Typed Pages FNP Unit 2 Technical Specifications Proposad Changed Pages List FNP Unit 2 Technical Specifications Marked-up Pages FNP Unit 2 Technical Specifications Typed Pages l

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i FNP Unit 1 Technical Specifications COLRImplementation i

Channed Panes Umt 1 Revision 1

I Replace XM %b l Page 1-2 Replace 1 l Page 3/41-1 Replace Page 3/41-3 Replace Page 3/41-4 Replace Page 3/41-5 Replace Page 3/41-20 Replace l Page 3/41-21 Replace Page 3/41-22 . Replace Page 3/4 2-1 , Replace Page 3/4 2-2 Replace Page 3/4 2-3 Replace Page 3/4 2-4 Replace Page 3/4 2 Replace Page 3/4 2-7 Replace Page 3/4 2-8 Replace Page B 3/41-1 Replace l Page B 3/41-2 Replace Page B 3/41-3 Replace Page B 3/4 2-1 Replace Page B 3/4 2-2 Replace Page 6-19 Replace Page 6-19a Addition 1