Text

Application for Amend to License NPF-42,revising TS 3/4.2.4, Quadrant Power Tilt Ratio & Associated Bases, to Clarify Required Actions for Limiting LCO & Other Change Consistents W/Ts Conversion Application Previously Submitted
	ML20202D117
Person / Time
Site:	Wolf Creek
Issue date:	02/04/1998
From:	Muench R; WOLF CREEK NUCLEAR OPERATING CORP.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20202D123	List: ML20202D117; ML20202D125;
References
	ET-98-0007, ET-98-7, NUDOCS 9802130122
	Download: ML20202D117 (17)
	v • d • e

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h W@) NUCLEAR OPERATING LF CREEK Richard A. Muench i

Vee President Engineering February 4, 1998 ET 90-0007 U. G. Nuclear Regulatory Commission ATTN Document Control Desk Mail Station P1-137 Washington, D. C. 20555

Reference:

1) Letter dat6d April 3, 1997, from E. W. Herschoff, NRC to N. S. Carns, WCNOC

2) Letter ET 97-0050, dated May 15, 1997, from R. A. Muench, WCNOC to NRC Subject Docket No. 50-482: Proposed Revision to Technical Specification 3/4.2.4, Quadrant Power Tilt Ratio Gentlemen This letter transmits an application for amendment to Facility Operating License No. NPF-42 for Wolf Creek Generating Station (WCGS).

This request proposes to revise Technical Specification 3.2.4, Quadrant Power Tilt Ratio, and associated' Bases, to clarify the required Actions for the Limiting Condition for Operation (LCO) and other changes consistent with the Technical Specification Conversion application previously submitted by Reference 2.

The proposed revisions would (a)

Revise the Action for determining QUADRANT POWER TILT RATIO (QPTR) when QPTR is above the LCO-limit.

(b)

Revise the completion time for resetting the Power Range Neutron Flux-High Trip Setpoints af ter Or'R is determined to be above the LCO limit.

(c)

Delete the Actions requiring QPTR to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , QPTR to be verified during a return to power operation, resetting the Power Range Neutron Flux-High trip setpoint to less than 554 following a power reduction to 50% RATED THERMAL POWER or below, and Actions for QPTR in excess of 1.09.

Other changes to make the QUADRANT POWER TILT RATIO LCO and Actions consistent with those previously submitted by Reference 2 and proposed industry travelers.

This license amendment request will clarify previous concerns identified in Reference 1.

These concerns related to a

Technical Specification Clarification for Technical Specification 3.2.4 and the NRC belief that our interpretation was nonconservative.

Implementation of the changes proposed in this license amendment request eliminate any confusion associated with the Actions required to be taken when QPTR exceeds 1.02.

I 9802130122 980204 g'[ f DR ADOCK 0500 2

PO Box 411 i Burhngton KS 66839 / Phone: (316) 364-8831 An Equal Oppetundy Employer M F HC vet L

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ET 90-0007 P:g3 2 of 2

'A Saf'ety Evaluation is provided in Attachment It a No Significant Hazards Consideration Determination, in Attachment II.

Attachment III is the.related

' Environmental Impact Determination.

Marked up pages are provided in Attachment IV (for current Technical Specifications and Bases) and in Attachment V (for_ Improved Technical Specifications and Bases submitted by -

Reference 2).

In accordance'with 10 CFR 50.91, a copy of-this~ application, with attachments, is being provided to-the designated _ Kansas State Official.

This proposed revision to the WCGS Technical Specifications will be fully implemented within 60 days of formal NRC approval.

If you have any questions concerning this matter, pleass ccntact me at (316) 364-8031, extension 4034, or Mr. Michael J. Angus, at extension 4077.

Very truly yours, Y (Alk Richar A. Muenen RAM /jad Attachments:

I

- Safety Evaluation II

- No-Significant Hazards Consideration Determination i

III - Environmental Impact Determination IV-

- Proposed Current' Technical Specification Change V.

- Proposed Improved Technical Specification Change cet V. L. Cooper (KDHE), w/a W. D.-Johnson (NRC), w/a E. W. Herschoff (NRC), w/a J. F. Ringwald (NRC), w/a J. C. Stone (NRC), w/a L

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Richard A.'. Muer,ch, L of lawful-age, being first duly sworn upon oath says that: -

s he im Vicel Pre sident ' Engineering of ' Wolf.. Creek Nuclear. Operating Corporation; 4 that he has read the, foregoing document and knows ' the content ' thereof; that i

he r has -executed that ~same for and. on behalf of said Corporation with full power'and authority,to do so; and that the facts-therein stated"are true and 11 correct'to the best of his knowledge, information and belief.

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ATTACHMENT I SAFETY EVALUATION

' Attechment I to ET 98-0007' Pcg3 2 of 7 4

Safety Evaluatic.

Proposed Chaneos This' license amendment request proposes to w.ase Wolf. Creek Generating Station n(WCGS) Technical -Specification 3.2.4, QUADRANT POWER TILT RATIO. The proposed revisions-would clarify the required Actions._for the Limiting Condition for Operation (LCO) and other changes consistent with.the Technical Specification: Conversion application previously submitted _as part of the WCGS Technical = Specification conversion application via-letter = ET r 97-0050, - dated May 15, 1997 and proposed industry travelers to NUREG-1431, Rev. 1, " Standard Technical Specifications, Westinghouse Plants."

Specifically,-the1 proposed changes ares e ' Reviso the Action for determining QUADRANT POWER TILT RATIO (QPTR) to at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , instead of once per hout until QPTR is reduced-to within limit or THERMAL POWER is reduced to less than 50%.

e-Revise the completion time hours for resetting the Power Range Neutron Flux-High trip setpoints from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months af ter. the power reduction following QPTR measurements. to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months af ter QPTR is determined to be outside - the limit.

' Delete the Actions (a.3., a.4.)~for-verifying QPTR to be restored within 24 e

nours and for - identifying and correcting the cause -of the out-of-limit condition priot -to increasing - THERMAL POWER.

New required Actions are added to confirm that. the Heat - Flux Hot Channel Factor and Nuclear Enthalpy Rise Hot Channel Factor-is within its limit and to reevaluate the safety analyses and normalize excore detectors.

Deletion of the Actions for QPTR in excess of'1.09.

The associated Bases section-would also be revised.to reflect these changes by including relevant details-from the applicable Bases sections submitted in the Technical; Specification Conversion application.

maokoround

? QPTR Lis < defined by the - Technical Specifications (Definition 1.25) as "the ratio offthe maximum upper excore detector calibrated output to the average of thet upper excore detector calibrated outputs, or the ratio of the maximum lower - excore detector calibrated output to the average of'the lower excore Jdetector-calibrated outputs,--whichever is. greater.

With one excore detector inoperable, the. remaining-three detectors shall be used for computing the average." This calculation looks at the radial flux tilt in the upper part of

= the core as. determined by the four Power Range upper detectors, and at the radial-flux tilt in_the lower part of the core as determined by the four Power

! Range lower detectors.- The OPTR is the greater of the two flux tilts.

The

. QPTP,1%it ensures that the gross radial power distribution remains consistent

with: the design values used in. the. safety analyses.

Precise radial power distribution measurements are - made during 'startup testing, af ter refueling,

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and periodically during. power operation.

Inf Inspection iReport 50-482/96021, the NRC review of Technical Specification Clarification _026-85_ indicated that the clarification provided -guidance contrary to Technical Specification requirements and could have resulted in

=non-compliance.

The inspection report states:

" Technical Specification Clarification 026-85 allowed -increasing power while - the quadrant power tilt

ratio' exceeded a prescribed limit.

This clarification involved a change to

Attcchmont I to ET 98 0007 Pcg3 3 of 7 Technipal Specification 3.2.4.a.4 which prohibited increasing power with the quadrant power tilt ratio greater than the prescribed limit."

WCNOC provided additional information in a letter dated January 22, 1997 (WO 97-0017) and concluded that the clarification does not violate nor constitute a change to Technical Specification 3.2.4.

The NRC subsequently determined that the wording in the Technical Specifications supported our position, however, the NRC continued to believe that our clarification was non-conservative.

In a telecon on May 8, 1997, WCNOC provided information concerning the proposed wording in the Technical Specification Conversion application and indicated that a license amendment request would be considered for the current technical specifications.

Evaluation The proposed changes to the technical specification requirements for the QPTR are discussed and evaluated individually in the following paragraphs.

1.

Requirements for Determining QPTR The Action to calculate OPTR once per hour until THERMAL POWER was reduced to less than 50% RATED THERMAL POWER (RTP) when QPTR exceeds the LCO requirements would be deleted and replaced by a new requirement to determine QPTR at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The required Action to determine QPTR at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months would be performed after reducing THERMAL POWER per requ! red Action a.1.

This change represents a reduction in requirements for monitoring and reducing power.

With QPTR not within limit, the current Action is to perform a calculation of QPTR at least once per hour until either the QPTR is restored to within limit or THERMAL POWER is reduce to less than 50% RTP.

The proposed change would require QPTR to be calculated at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and continue to reduce THERMAL POWER by at least 3% for each 1% that OPTR exceeds the limit until either QPTR is restored to within its limit or 50% RTP is achieved.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months frequency is sufficient because, as stated in the NUREG-1431, Rev. 1 Bases, further changes in QPTR would be relatively slow.

The once per hour frequency is excessive considering the slow rate of flux change and the potential to divert the attention of control room operators from corrective action with respect to QPTR.

Current Action a.2.b) is revised to make reducing the Power Range Neutron Flux-High trip setpoints into a s3parate required Action (discussed further in item 2) and to clarify that any required THERMAL POWER reduction be completed within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months af ter each OPTR determination.

The completion time of the Action is revised in order to make it clear if the once per 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months QPTR determination specified in the proposed Action a.2.

determines that an additional reduction in power is required below the level initially determined by proposed Action a.1, then 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is allowed to complete the additional power reduction.

The proposed change also removes confusion between which QPTR determinations apply to subsequent steps in Action a.

The proposed change would ensure that the most current QPTR determination applies to the subsequent steps.

The proposed changes would retain the 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months requirement to reduce power proportionally to the percent that QPTR exceeds its limit.

This would result in a power reduction that provides additional margin to fuel design limits during a flux tilt condition to assure that design limits are not challenged by local flux peaking.

These design margins are set conservatively and provide further assurance that operation in accordance with the required Actions would not challenge fuel design limits.

The above changes are consistent with NUREG-1431, Rev.

1, including industry travelers and were included in the WCGS Technical Specification Conversion application.

Attechm:nt 1 to ET 90-0007 Paga 4 of 7 l

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Coppletion Time for Resetting the Power Range Neutron Flux-High Trip 9

Setpoints Wit QPTR not within limit, current Action a.2 requires that THERMAL POWER and the Power Range Neutron Flux-High trip sett <ints be reduced.

Two hours are currently allowed for power reduction and an additional four hours are allowed for the completion of the setpoint reduction.

A completion time of 72 bours to reduce the trip setpoints, as proposed, will allow time to reduce reactor power, perform the required QPTR determination, and permit orderly resetting of the high flux trip channel setpoints.

During the trip setpoint change, there is increased potential for human error resulting in a plant transient.

Providing additional time should reduce the chances that a human error initiated transient will occur.

In addition, the reactor power would be reduced within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if required; this would provide additional margin to fuel design limits while the setpoint changes were being performed.

A reduction of the Power Range Neutron Flux-High trip setpoints by 2 31 for each 1% by which OPTR exceeds 1.00, is a conservative action for protection against the consequences of severe transients with potentially unanalyzed power distributions.

The above changes are included in the WCGS Technical Specification Conversion application and are consistent with changes proposed to NUREG-1431, Rev. 1, by industry travelers.

3.

Delete the Actions (a.3.,

a.4.) for verifying QPTR to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and for identifying and correcting the cause of the out-of-limit condition prior to increasing THERMAL POWER Current required Action a.3.,

which verifies QPTR to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after exceeding the limit or reduce power to less than 50% RTP and to reset the Power Range Neutron Flux-High trip setpoints after a required reduction to less than or equal to 55% RTP, would be deleted.

Current required Action a.4.,

which requires icaatifying and correcting the cause of the out-of-limit condition prior to increasing THERMAL POWER, would also be deleted.

The proposed change would replace these Actions with the following new Actions:

a.3.

for QPTR out of limit, including requirements for measuring Heat Flux Hot Channel Factor Fo(Z) and Nuclear Enthalpy Rise Hot Channel Factor F"an within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions from a THERMAL POWER reductio 1 required by Action a l.

a.5 for OPTR out of limit, including requirements to reevaluate the safety analyses and confirm that the results remain valid prior to increasing THERMAL POWER and Power Range Neutron Flux-High trip setpoints above the limits of Action a.l. and a.4.

a.6 - for OPTR out of limit, including requirements to normalize the excore detectors to restore OPTR to within limit prior to increasing THERMAL POWER above the limit of Action a.l.

a.?

after normalizing excore detectors, the Action is required to be performed to measure Heat Flux Hot Channel Factor Fo(Z) and Nuclear Enthalpy Rise Hot Channel Factor F"an within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium _ conditions not to exceed _48 hours after increasing THERMAL POWER above the limit of Action a.l.

Attachmtnt I to ET 98-0007 Paga 5 of 7 The ptoposed change focuses on maintaining peaking factors rg(Z) and r",

within limits rather than the QPTR.

This is appropriate because QPTR is a monitored parameter that is indicative of peaking iactor problems.

The proposed change requires verification that rg(Z) and r"o are within limits within-24 hours after achieving equilibrium conditions by performing Surveillance Requirements that can directly measure flux shapes in the core.

If r (Z) and r"o are not within limits, the Conditions for those technical o

specifications _ will specify additional requirud actions.

Since the peaking factors are of prime importance, the proposed changes will ensure that the power distribution remains consistent with the initial conditions assumed in the safety analyses.

The proposed change also allows o rification of the peaking f actors after a power change within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions with THERMAL POWER reduced by Action a.1.

Depending on the scenario by which QPTR came to exceed its limit, the time required to (a) achieve equilibrium (steady state) conditions under which flux mapping can be performed, (b) perform the flux map, and (c) analyze the flux map, could exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

A significant f raction of the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months completion time could be required to achieve the equilibrium conditions necessary to begin flux mapping.

The proposed delay (i.e.,=allowiseg time to achieve equilibrium conditions) is reasonable because when QPTR exceeds its limit, Action a.1 requires a reduction of THERMAL POWER to at least 3% from RTP for each 1% of indicated QPTR greater than 1.00 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This would result in a power reduction that would provide additional margin to fuel design limits during a flux tilt condition to assure that design limits are not challenged by local flux peaking.

These design margins are - set conservatively and provide further assurance that operation in accordance with the Actions would not challenge fuel design limits.

The proposed changes also would eliminate the requirement to reduce the Power Range Neutron Flux-High trip setpoints to less than or equal to 55% within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of reaching 50% RTP.

This chang" is acceptable on the basis that the proposed changes would still require tno Power Range Neutron riux-High trip setpoints to be reduced to greater than or equal to 3% below RTP for each 1%

of QPTR greater than 1.00 as discussed above.

The acceptability of changing the completion time from four hours to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months has previously been discussed.

The above changes are consistent with NUREG-1431, Rev.

1, and proposed industry travelers and were included in the WCGS Technical Specification Conversion application.

Some additional changes are identified in Attachment V for the Improved Technical Specifications and have been incorporated into the proposed changes to the current technical specifications.

These additional changes are the subject of a proposed traveler and are discussed below.

4.-

Deletion of the Actions for OPTR in excess of 1.09 Actions involving QPTRs exceeding 1.09 would be deleted.

The requirements of Action b.

regarding QPTRs in excess of 1.09 due to misalignment of control rods are addressed by the requirements of Specification 3.1.3.2 for ensuring rod group misalignment limits.

Action-c. regarding QPTRs in excess of 1.09 due to other causes are replaced by the less restrictive requirements of Action a.

Action c. requires that the OPTR be calculated once per hour and that power be reduced to less than 50% RTP within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and the Power Range Neutron Flux-High trip setpoint be reduced within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

In addition, Action c.

requires identification and correction of the cause of the tilt condition and periodic verification that QPTR 'is within limits during any subsequent ascension to RTP.

With the deletion of Action c.,

the Action a.

requirements would = be implemented with QPTR limits in excess of 1.09.

The3e actions require (1) a 3% RTP reduction for each 1% of QPTR in excess of 1.00 within 2

Attachm2nt I to ET 98-0007 Pegs 6 of 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months of determining QPTR and a reduction in flux trip setpoints, (2) that QPTR be calculated only once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and (3) verification of peaking f actors prior to and following power ascension and a reevaluation of safety analyses prior to power ascension above the limits determined in Action a.1 and a.4.

The requirements of the proposed change are acceptable because (1) the QPTR would be expected to change slowly over time so a less frequent calculation of QPTR would be acceptable, (2) once control room personnel commence a power reduction, in accordance with the proposed changes, the effect of any flux tilt will tend to be mitigated by reducing the flux and establishing greater margin to fuel design limits, and the reduction of power would result in a plant transient that generally would be less severe than the reduction to less than 50% RTP as required by proposed Action c, and (3) the proposed Actions prior to and subsequent to power ascension provide assurance that power operation at or near RTP will be in accordance with the safety analyses.

This proposed change is consistent with NUREG-1431, Rev.

1, and industry travelers that were included in the WCGS - Technical Specification Conversion application.

5. Proposed changes to the Improved Technical Specifications ('TS).

Required Action A.6 is revised to add a new Note stating " Required Action A.7 shall be completed whenever Required Action A.6 is performed." to clarify that Required Action A.7 must be completed whenever Required Action A.6 is performed.

As discussed in Section 1.3 of the ITS, an ACTIONS Condition remain in effect and the Required Actions apply until the Condition no longer exists or the-unit is not within the LCO Applicability.

Therefore, when Required Action A.6 is completed, QPTR should be back within limit and the LCO may be exited. Adding this Note ensures that the peaking factors are verified after normalization of the excore detectors.

Additionally, Required Action A.6 is revised to state " Normalize excore detectors to restore QPTR to within limits."

NUREG-1431, Rev.

1, Required Action A.5 (ITS Required Action A.6) originally stated " Calibrate excore detectors to eliminate tilt."

A proposed traveler was generated changing the wording of this Action and the proposed traveler was subsequently revised after submittal of the conversion application.

Required Action A.5 in NUREG-1431, Rev.

1, states that the excore detectors shall be alibrated to show tero QPTR.

Normalization of QPTR to near 1.00 can be accomplished - by calibration of the Nuclear Instrumentation System (NIS) or through the use of constants to apply to indicated NIS currents. Thus, the absence of a tilt will manifest itself as QPTR-1.00 rather than zero since quadrant power tilt 's expressed as a ratio. Also, from a literal read standpoint the tilt cannot be restored to exactly 1.00, therefore, Required Action A.6 is modified to

" Normalize excore detectors to restore OPTR to within limit."

An industry traveler has been generated for these changes and been approved by the Westinghouse Owners Group MERITS mini-group.

Conclusion Based on the above discussions and the No Significant Hazards Consideration Determination presented in Attachment II, the proposed changes do not increase the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Updated Safety Analysis Report; or create a possibility for an accident or malfunction of a different. type than any previously evaluated in_the safety analyses report; or reduce the margin of safety as defined in the basis for any technical specification.

Therefore, the proposed changes do not adversely l

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Attceta nt II to ET 90-0007 Peg) 1 of 5 ATTACHMENT II HO SIGNIFICANT HAZARD & CONSIDERATION DETERMINATION

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Attechaent :II ' to ET. 98-0007 Pcg3.Z of 5 e

No Significant Hazards Consideration Determination Proposed Changes This license amendment requesti,coposes to' revice ' Wolf Creek Generating Station (WCGS). Technical Specification 3.2.4, Quadrant Power Tilt Ratio..The proposed revisions would clarify. the i: required Actions for the -Limiting Condition for Operation (LCO)and -other changes consistent with the - Technical

. Specification Conversion application previously submitted as pcet of the WCGS Technical $pecification Conversion = application via. letter ET 0050, dated May 15, 1997 and proposed industry travelers--to NUREG-1431, _Rev.

1,

" Standard Technical Specifications, Westinghouse Plants."-

Specifically,--the proposed changes.are:

Revise. the Action for determining QUADRANT POWER TILT RATIO (OPTR) to.at least once per-12 hours, instead of=once per hour until QPTR is reduced to within limit or THERMAL POWER is reduced to less than 50%.

e. Revise the : completion time to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for resetting the Power Range Neutron Flux-High trip setpoints af ter QPTR is-determined to be above the LCO limit.

Delete the Actions ; (a.3., -a.4. )' for verifying QPTR to be restored within 24 -

V hours. and ~ for identifying and correcting the cause of the out-of-limit condition - prior " to increasing THERMAL POWER.

New required Actions are added : to confirm tnat the Heat ' Flux -Hot Channel Factor and Nuclear Enthalpy Rise = Hot Channel Factor is within its limit and to re-evaluate the

safety analyses and normalize excore detectors.

-l Deletion of the Actions for QPTR in excess of 1.09.

The associated Bases'section would also be? revised to reflect these changes by including relevant details fron-the :spplicable Bases sections submitted in the

.l Technical Specification Conversion application.

Application of Standards-The following' Standards identified in 10 CFR 50.92 have-besn used to determine

'whether the proposed - changes - involve a Significant Hazards Consideration.

Each of the identified proposed changes-is evaluated against the.three-EStandazds.

Standard-I - Involve a Significant Increase in the Probability or Consequences I

of an Accident Previously Evaluated

-1.

Reg.irements for Determining QPTR The Action to calculate OPTR once per hour until THERMAL POWER was reduced to less than 50% RATE'D THERMAL POWER (RTP) when QPTR exceeds the LCO requirements would be deleted and replaced by a new requirement to determine OPTR at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The proposed change involves only the compensatory measures to be taken should the i;TR be outside its limit.

The frequency with which QPTR is calculated is not assumed -in the initiating events for any accident previouely enluated.

-In addition, the change does not involve any new operating activ ties or hardware rsange.

Therefore, the proposed change would not significantly increase tL probability of an accident previously evaluated.

' Attachment II to'ET!98-0007 4-Pags 3 of.5-OnceITHERMAL--POWER hastbeentreduced appropriately in proportion to the amount

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that QPTR exceeds 1.00,- any additional change would be sufficiently slow that a7 12-hour: interval for recalculating QPTR will provide an adequate level of protection._

Therefore, the proposed change will not significantly increase the' consequences of any accident previously evaluated.

2.

Completion fime for Resetting lthe Power Range Neutron Flux-High Trip Setpoints-The proposed change ty allow.72_ hours for resetting the Power _ Range Neutron Flux-High trip setpoints involves only_ the compensatory measures to be taken-

's should the_ OPTR be outside its limit. ' These compensatory measures are _ not assumed inithe initiating events for any accident previously evaluated.

The preposed actions recognize' that the required reduction in power' (3% for wach

- 1Cof --indicated. QPTR in excess of - 1.00) _ provide adequate margin for fuel

-design.11mits so that consequences _ of assumed accidents would not: be significantly af fected.

Therefore,,tP 3 proposed change - will not adversely affect the probability or consequences _of any accident-previously evaluated.

Further, by permitting more time to perform resetting _the trip setpoints, the chances of a transient may be, reduced.

i 3.

-Delete-of the Actions-(a43., a.4.):for verifying QPTRLto be rostored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ~and for identifying and correcting the cause of.the out-of-limit condition prior to increasing THERMAL POWER The proposed changes would delete current Actions a.3.

and a.4.

and add new Actions for QPTR out of limit including requirements ' for measuring : Fn(Z) ; and

'F a -prior-to and following a return to power and performing eafety analyses to = verify safety. requirements are met prior to -increasing power above the

_1 limits 'of = Action a.1.

The proposed changes involve _ only the compensatory

-measures to be taken should the QPTR be outside its limit. These compensatory.

measures are not assumed in the. initiating events for any accident 1previously evaluated.

Therefore,<the propossa change will not affect the probability or-consequences of any accident previously evaluated.

1

.4.

Deletion of the Actions for QPTR in excess of 1.09

~

The. proposed change would-delete the required Actions'for-QPTR in excess of 1.09 and Actions for OPTR. in excess of l.02 - are followed for Lall instances-

'where OPTR exceeds 1.02.

The proposed change involves only the compensatory.

measures to be takenishould the QPTR.be outside its limit. These compensatory measures are not assumed in the: initiating events for any accident previously s

evaluated. _ The. proposed actions recognize that the required reduction in powero (3% - for each -l% of-indicated OPTR --in excess of 1.00) - provide adequate margin for fuel design limits so that. consequences _of assumed accidents would not be significantly affected. Therefore,1the proposed change will not affect the1 probability or consequences oftany accident previously analyzed.

Standard II - Create the Possibility of a New or Different Kind of Accident' from any Previously Evalua*od l.

Requirements for Determining QPTR' The proposed change for calculating QPTR once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months does not involve a physical alteration.to.the plant or change the method by which any safety-

.related system performs its function.

The manner in which the plant would be

. operated would not be altered. Therefore, the proposed change will not create

(

tt.e possibility of a _ new or different kind of accident from any previously evaluated.

l 1

9 Attachment II to ET 98-0007 Page 4 of 5 t

R.

Completion Time for Resetting the Power Range Neutron Flux-High Trip Setpoints The proposed change to allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for resetting the Power Range Neutron Flux-High trip setpoints do not involve a permanent physical alteration to the plant; no new or different kinds of equipment will be installed.

The change would not alter the manner in which the plant would be operated only the timing of actions thac provide potential mitigation of accidents.

Thus, the

]

change would not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Delete the Actions (a.3., a.4.) for verifying QPTR to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and for identifying and correcting the cause of the out-of-limit condition prior to increasing THERMAL POWER The proposed changes would delete current Actions a.3.

and a.4.

and add new Actions for OPIA out of limit including requirements for measuring FotZ) and F% prior to and following a return to power and performing safety analyses to verify safety requirements are met prior to increasing power above the limits of Action a l.

The proposed changes do not involve a physical alteration to the plant; no new or different kinds of equipment would be installed.- The changes would not alter the manner in which the plant would be operated only the timing of actions that provide potential mitigation of accidents.

Thus, the changes would not create the possibility of a new or different kind of accident from any accident previously evaluated.

Deletion of the Actions for QPTR in excess of 1.09 The proposed change would delete the required Actions for QPTR in excess of 1.09 and Actions for QPTR in excess of 1.02 are followed for all instances where QPTR exceeds 1.02.

The proposed change does not involve a physical alteration to the plant or changes in the way in which the plant is operated.

The proposed change involves snly the compensatory measures to be taken should OPTR be outside its limit.

The assumptions of the accident analyses are unaffected by the proposed change.

Ne new permutations or event initiators are introduced by the proposed alternate methods of dealing with QPTRs in excess of 1.09.

Therefore, there is no possibility of a new or different kind of accident from any accident previously evaluated.

Standard III - Involve a Significant Reduction in the Margin of Safety 1.

Requirements for Determining QPTR The proposed change for calculating QPTR once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months does not change any accident analysis assumptions, init!11 conditions or results.

The proposed change will continue to ensure that the plant is meintained in a safe condition while OPTR is in excess of its limit.

Additionally, calculating QPTR once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months as opposed to every hour while OPTR is in excess of its limit would avoid the diversion of personnel recources from corrective actions with rega rc' to meeting the LCO.

Therefore, the proposed change will not involve a significant reduction in any margin of safety.

-2.

Completion Time for Resetting the Power Range Neutron Flux-High Trip Setpoints The proposed change te allow 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for resetting the Power Range New.on Flux-High trip setpoints will continue to ensure that the plant is maintained in a safe condition within the envelope of the safety analyses while OPTR is in excess of its limit.

The proposed actions recognize that the required reduction in power (3% for each 1% of indicated QPTR in excess of 1.00) provide adequate mariin for fuel design limits so that consequences of assumed

Attachment II to ET 98-0007 Page 5 of 5 Accidents would not be significantly affected.

Therefore, the proposed change will not involve a significant reduction in any margin of safety.

3.

Delete the Actions (a.3.,

a.4.) for verifying QPTR to be restored within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and for identifying and correcting the cause of the out-of-limit condition prior to increasing THERMAL POWER The proposed changes would delete current Actions a.3.

and a.4.

and add new Actions for QPTR out of limit including requirements for measuring Fo(Z) and F"a prior to and following a return to power and performing safety analyses to verify safety requirements are.ne t prior to increasing power above the limits of Action a.l.

The proposed changes will continue to ensure that the plant is maintained in a ssfa condition within the envelope of the safety analysis while QPTR is in excess of its limit.

Therefore, the proposed changes will not involve a significant reduction in any margin of safety.

4.

Deletion of the Actions for QPiR in excess of 1.09 The proposed change would delete the required Actions for QPTR in excess of 1.09 and Action for QPTR in excess of 1.02 are followed for all instances where OPTR exceeds 3.02.

The proposed change will continue to ensure that the plant is maintained in a safe condition within the envelope of the safety ana3yses *4hile OPTR is in excess of its limit.

Whz.le dif ferent actions are

-taken in response to a QPTR in excess of 1.09, the proposed channe will assure that accident analyses assumptions continue to be met.

Therefore, the proposed changes will not involve a significant reduction in any margin of safety.

Conulusions Based on the above discussions, it has been determined that the requested technical specification revisions do not involve a significant increase in the probability of consequences of an accident or other adverse conditions over previous evaluations; or create the possibility of a new or different kind of accident or condition over previous evaluations; or involve a significant reduction in a margin of safety.

Therefore, the requested license amendment does not involve.a significant hazards consideration.

Att chment III to ET 98-0007 P ga 1 of 2 4

e k

ATTACHMENT III ENVIRONMENTAL IMPACT DETERMINATION

Attechmtnt'III to ET 90-0007-Paga.2 of-;2 Environmental Impact Determination 10 CFR - 51.22 (b) specifies _the criteria for - categorical exclusions from the

-requirement for a specific environmental assessment per 10 CFR 51.21.

This

-amendment request meets the criteria _'specified. in 10 CFR 51. 22 (c) (9) as specified below:-

~(1) the amendment involves no significant hazards consideration

-As demonstrated in Attachment II,_ the proposed changes do not involve any significant hazards consideration.

- (11)l _ there is no significant change in ~ the _ types or significant increase in the amounts of any effluents that may be released offsite None of the proposed changes-involves a change to the facility or operating procedures that would-cause an increase in the amounts of effluents or create new types of effluents.

(iii) there la no significant increase in individual or cumulative ocampational-radiation exposure The proposed changes relate to Actions associated with QPTR exceeding its-limit of 1.02.

These changes have no relation to occupational radiation exposure, either individual or cumulative.

Based on the. above, it is concluded that there will be no impact on the environment resulting from this change and the - change meete - the criteria specified in 10 CFR 51.22 for a categorical exclusion from the requirements of 10-CFR 51.21 relative'to requiring a specific environmental assessment by the Comcission.

s 9

ML20202D117

Text

Reference:

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