NOC-AE-02001315, Conditional Exemption from Measurement of End of Life Moderator Temperature Coefficient

Conditional Exemption from Measurement of End of Life Moderator Temperature Coefficient

ML021540288
Person / Time
Site:	South Texas
Issue date:	05/23/2002
From:	Sheppard J South Texas
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NOC-AE-02001315, STI: 31439855
Download: ML021540288 (22)

Text

Nuclear Operating Company South Taws Pro/ect Electric Generating Station P.O Box 289 adsworth, Tew 77483 Awv May 23, 2002 NOC-AE-02001315 10CFR50.90 U. S. Nuclear Regulatory Commission Attention: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852 South Texas Project Units 1 and 2 Docket Nos. STN 50-498 and STN 50-499 License Amendment Request Conditional Exemption from Measurement of End of Life Moderator Temperature Coefficient

Reference:

Letter, S.M. Head to NRC Document Control Desk, "Response to NRC Regulatory Issue Summary 2001-21," dated January 17, 2002 (NOC-AE-02001243)

Pursuant to 10CFR50.90, STP Nuclear Operating Company (STPNOC) hereby requests an amendment to the Technical Specifications (TS). The proposed changes would revise the near end of life (EOL) Moderator Temperature Coefficient (MTC) Surveillance Requirement 4.1.1.3.b by placing a set of conditions on core operation, which if met, would allow exemption from the required MTC measurement. The conditional exemption will be determined on a cycle specific basis by considering the margin predicted to the surveillance requirement MTC limit and the performance of other core parameters, such as beginning of life (BOL) MTC measurements and the critical boron concentration as a function of cycle length. The conditional exemption would improve plant availability and minimize disruptions to normal plant operations. Plant safety criteria will not be compromised by the conditional exemption of this one measurement.

No changes to the TS Bases will be required as a result of the proposed amendment. to this letter provides a No Significant Hazards Consideration Determination and provides the current TS pages marked up with the proposed changes. Attachment 3 provides the retyped TS pages. Typical revised pages from a Core Operating Limits Report are provided in Attachment 4 for information only.

The Plant Operations Review Committee and the Nuclear Safety Review Board have reviewed the proposed changes. STPNOC has notified the State of Texas in accordance with 10CFR50.91(b).

This amendment request was included as part of the fourteen plant-specific submittals identified for fiscal year 2002 (refer to the referenced letter). STPNOC requests approval of the proposed amendment by November 30, 2002. Once approved, the amendment shall be implemented STI: 31439855

NOC-AE-02001315 Page 2 of 3 within 30 days. This approval schedule request is based on a desire to avoid the plant perturbation and expense of a Unit 1 MTC measurement near the end of cycle 11, and on the fact that WCAP-13749-P-A appears as a reference in this license application. The NRC has found the WCAP acceptable for referencing in license applications. STPNOC has also proposed an enhancement that would reduce the regulatory burden of using the WCAP in Section 4 of .

If there are any questions regarding this proposed amendment, please contact Mr. Scott Head at (361) 972-7136 or me at (361) 972-8757.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on __/______ ___

J.!I Sheppard Vice President, Engineering & Technical Services kaw Attachments:

1. Licensee's Evaluation

2. Proposed Technical Specification Changes (Mark-ups)

3. Proposed Technical Specification Pages (Retyped)

4. Typical Revised Core Operating Limits Report Pages (For Information Only)

NOC-AE-02001315 Page 3 of 3 cc:

(paper copy) (electronic copy)

Ellis W. Merschoff A. H. Gutterman, Esquire Regional Administrator, Region IV Morgan, Lewis & Bockius LLP U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 M. T. Hardt/W. C. Gunst Arlington, Texas 76011-8064 City Public Service U. S. Nuclear Regulatory Commission Mohan C. Thadani Attention: Document Control Desk U. S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike R. L. Balcom Rockville, MD 20852 Reliant Energy, Inc.

Richard A. Ratliff A. Ramirez Bureau of Radiation Control City of Austin Texas Department of Health 1100 West 49th Street C. A. Johnson Austin, TX 78756-3189 AEP - Central Power and Light Company Cornelius F. O'Keefe Jon C. Wood U. S. Nuclear Regulatory Commission Matthews & Branscomb P. O. Box 289, Mail Code: MN116 Wadsworth, TX 77483 C. M. Canady City of Austin Electric Utility Department 721 Barton Springs Road Austin, TX 78704

NOC-AE-02001315 Attachment 1 Licensee's Evaluation

NOC-AE-02001315 Attachment 1 Page 1 of 6 LICENSEE'S EVALUATION

1.0 DESCRIPTION

This letter is a request to amend Operating Licenses NPF-76 and NPF-80 for South Texas Project (STP) Units 1 and 2. The proposed changes would revise the near-end of life (EOL) Moderator Temperature Coefficient (MTC) Surveillance Requirement 4.1.1.3.b by placing a set of conditions on core operation, which if met, would allow exemption from the required MTC measurement. The conditional exemption will be determined on a cycle-specific basis by considering the margin predicted to the surveillance requirement MTC limit and the performance of other core parameters, such as beginning of life (BOL) MTC measurements and the critical boron concentration as a function of cycle length. The conditional exemption would improve plant availability and minimize disruptions to normal plant operations. Plant safety criteria will not be compromised by the conditional exemption of this one measurement. No changes to the TS Bases will be required as a result of the proposed amendment.

STP Nuclear Operating Company (STPNOC) requests approval of the proposed amendment by November 30, 2002. Once approved, the amendment shall be implemented within 30 days.

2.0 PROPOSED CHANGE

S Specifically, the proposed changes include the following:

" SR 4.1.1.3b is modified to suspend the MTC measurement if the model benchmark criteria and Revised Prediction specified in the Core Operating Limits Report (COLR) are satisfied.

"* WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," is added to the list of references for the COLR in TS 6.9.1.6.b.

3.0 BACKGROUND

One of the controlling parameters for power and reactivity increases is the MTC. The requirements of Technical Specification (TS) 3.1.1.3 ensure that the MTC remains within the bounds used in the applicable Updated Final Safety Analysis Report (UFSAR)

Chapter 15 accident analysis. This, in turn, ensures inherently stable power operations during normal operation and accident conditions.

The TS place both Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) constraints on the MTC, based on the accident analysis assumptions

NOC-AE-02001315 Attachment 1 Page 2 of 6 for the moderator density coefficient. A positive moderator density coefficient corresponds to a negative MTC. The most negative MTC LCO limit requires that the MTC be less negative than the specified limit for the all rods withdrawn, EOL, rated thermal power condition. To demonstrate compliance with the most negative MTC LCO, the surveillance requires verification of the MTC after 300 ppm equilibrium boron concentration is reached. Because the Hot Full Power (HFP) MTC value will gradually become more negative with further core burnup and boron concentration reduction, a 300 ppm MTC surveillance value should necessarily be less negative than the EOL LCO limit. To account for this effect, the 300 ppm MTC surveillance value is sufficiently less negative than the EOL LCO limit value, providing assurance that the LCO limit will be met as long as the 300 ppm MTC surveillance criterion is met.

Currently, the Technical Specifications require measurements of MTC at BOL to verify the most positive MTC limit and near-EOL to verify the most negative MTC limit. At BOL, the measurement of the isothermal temperature coefficient is relatively simple to perform since it is done at hot zero power isothermal conditions and is not complicated by changes in the enthalpy rise or the presence of xenon. The measurement made near EOL is performed at or near HFP conditions. MTC measurements at HFP are more difficult to perform due to:

• small variations in soluble boron concentration

• changes in xenon concentration and distribution

• changes in fuel temperature

• and changes in enthalpy rise created by small changes in the core average power during the measurement. Changes in each of these parameters must be accurately accounted for when reducing the measurement data, or additional measurement uncertainties will be introduced. Even though these additional uncertainties may be small, the total reactivity change associated with the swing in moderator temperature is also relatively small. The resulting MTC measurement uncertainty created by even a small change in power level can then become significant and, if improperly accounted for, can yield misleading measurement results.

Each measurement of MTC requires several hours at less than full power operation (as a buffer to measurement-induced transients) and requires additional manpower. This presents a perturbation to normal operation and to the reactor itself. An alternate method is proposed for use at STP to improve availability and minimize disruption to normal plant operations. The MTC measurement is replaced by a design calculation of the core MTC if predefined requirements are met.

The proposed change would allow modification of the EOL MTC surveillance requirement by placing a set of conditions on core operations. If these conditions are met, i.e., the specified revised prediction of the MTC and limits for several core parameters measured during the cycle are within specified bounds, the surveillance measurement would not be required.

NOC-AE-02001315 Attachment 1 Page 3 of 6

4.0 TECHNICAL ANALYSIS

The conditional exemption from the HFP near-EOL 300 ppm MTC measurement does not impact the safe operation of STP. The safety analysis assumption of a constant moderator density coefficient and the actual value assumed will not change. The TS Bases for and values of the most negative MTC limiting condition for operation and for the surveillance requirement are not altered. Instead, a revised prediction is compared to the surveillance MTC to determine if the limit is met. The method for calculating the revised prediction is consistent with the approved methodology of WCAP-13749-P-A (Reference 1).

The methodology for the proposed change was submitted to the NRC as Westinghouse topical report WCAP-13749 in May 1993. In October 1996, the NRC determined the report to be acceptable for referencing in license applications to the extent specified and under the limitations stated in the Brookhaven technical evaluation report and the NRC staff's safety evaluation report. Reference 1 includes all of these documents.

The topical report was approved by the NRC with two requirements:

"* only PHOENIX/ANC calculation methods are used for the individual plant analyses relevant to determinations for the EOL MTC plant methodology, and

"* the predictive correction is reexamined if changes in core fuel designs or continued MTC calculation/measurement data show significant effect on the predictive correction STP will meet both of these requirements. The PHOENIX/ANC calculation methods are used for the STP core designs. Prior to use of the conditional elimination technique, STP will confirm that core design changes and MTC calculation and measurement data do not show a significant effect on the predictive correction. If a significant effect is found, the use of the predictive correction will be re-examined.

All of the core performance benchmark criteria, which are confirmed from startup physics test results, from routine HFP boron concentration measurements, and from flux map surveillances performed during the cycle, must be met before the Revised Predicted MTC can be calculated per the prescribed algorithm in Reference 1.

Enhancement STPNOC is using NRC-approved WCAP-13749-P-A as the basis for this license amendment request. STPNOC will meet all of the technical requirements in the approved WCAP, but proposes an enhancement to reduce regulatory burden for both the NRC and the licensee. STPNOC proposes not to submit a "Most Negative Moderator Temperature Coefficient Limit Report" (the Report) to the NRC. There are two reasons for this. First, there is an inconsistency in the WCAP regarding the time frame of data collection and the submittal of the Report to the NRC. More importantly, the Report serves no apparent technical or business need. Each of these reasons is explained below.

NOC-AE-02001315 Attachment 1 Page 4 of 6 First, Section 3.3.3 of the WCAP states:

The Technical Specification Bases of the most negative MTC LCO and SR and the values of these limits are not altered. Instead, a revised prediction is compared to the SR MTC to determine if the SR limit is met. The revised prediction is simply the sum of the predicted HFP 300 ppm SR MTC plus an AFD correction factor plus a predictive correction term. This algorithm is summarized in Table 3-3.

Table D-2 of the WCAP states that the algorithm for determining the revised predicted near-EOL 300 ppm MTC is (emphasis added):

"The Revised Predicted MTC = Predicted MTC + AFD Correction + Predicted Correction" where "Predicted MTC is calculated from Figure 1 [Predicted HFP ARO 300 ppm MTC Versus Cycle Burnup] at the burnup correspondingto the measurement of 300 ppm at RTP conditions..."

Table D-3 of the WCAP provides an example worksheet for calculating the revised predicted near-EOL 300 ppm MTC. Two of the required data inputs for the worksheet (B.1 and B.2) are used to calculate the AFD correction term in the algorithm (emphasis added):

B. 1 Bumup of most recent HFP, equilibrium MWD/MTU conditions incore flux map B.2 Measured HFP AFD at burnup (B. 1)  % AFD Reference incore flux map I.D. Date:

However, Appendix A to the WCAP requires a new TS 6.9.1.7 to be added (emphasis added):

6.9.1.7 The most negative MTC limits shall be provided to the NRC Regional Administrator with a copy to the Director of Nuclear Reactor Regulation, Attention: Chief, Core Performance Branch, U. S. Nuclear Regulatory Commission, Washington, D. C. 20555, at least 60 days priorto the date the limit would become effective unless otherwise approved by the Commission by letter. This report will include the data requiredfor the determinationof the Revised Predictionof the 300 ppm/ARO/RTP MTC per WCAP-13749, "Safety Evaluation Supporting the Conditional Elimination of the Most Negative EOL Moderator Tempaerature Coefficient Measurement", May, 1993 (Westinghouse Proprietary).

NOC-AE-02001315 Attachment 1 Page 5 of 6 Because the Report would have to be submitted at least 60 days before reaching 300 ppm boron concentration, it cannot include the 300 ppm data required for determining the Revised Prediction. To meet the Report submittal requirement, the data to be used in calculating the revised predicted MTC may have to be taken 60 to 90 days prior to reaching 300 ppm boron. The WCAP does not provide any method for adjusting the revised predicted MTC to account for data collected 60 to 90 days prior to 300 ppm, nor does it provide justification for using such early data in the calculation. Therefore, the requirement to submit the Report and the requirements for the data that go into the report are inconsistent.

More importantly, the Report serves no apparent technical or business need. The applicability restrictions in the WCAP, the algorithm, and the acceptance criteria of the proposed Report would be included in the station procedure governing the EOL MTC surveillance. There is no compelling reason that this particular surveillance should require notifying the NRC prior to performing the surveillance procedure.

5.0 REGULATORY SAFETY ANALYSIS 5.1 No Significant Hazards Consideration STPNOC has determined whether a significant hazards consideration is involved with the proposed amendment by focusing on the three criteria set forth in 10CFR50.92 as discussed below:

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

Response: No The probability or consequences of accidents previously evaluated in the UFSAR are unaffected by this proposed change because there is no change to any equipment response or accident mitigation scenario. There are no additional challenges to fission product barrier integrity. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No No new accident scenarios, failure mechanisms, or limiting single failures are introduced as a result of the proposed change. The proposed change does not challenge the performance or integrity of any safety-related system. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

NOC-AE-02001315 Attachment 1 Page 6 of 6

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No The margin of safety associated with the acceptance criteria of any accident is unchanged. The proposed change will have no affect on the availability, operability, or performance of the safety-related systems and components. A change to a surveillance requirement is proposed, but the limiting conditions for operation required by the Technical Specifications are not changed.

The Technical Specifications Bases are founded in part on the ability of the regulatory criteria to be satisfied assuming the limiting conditions for operation are met for the various systems. Conformance to the regulatory criteria for operation with the conditional exemption from the near-EOL MTC measurement is demonstrated and the regulatory limits are not exceeded. Therefore, the margin of safety as defined in the TS is not reduced and the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, STPNOC concludes that the proposed amendment involves no significant hazards consideration under the criteria set forth in 10CFR50.92 and, accordingly, a finding of "no significant hazards consideration" is justified.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10CFR51.22(c)(9). Therefore, pursuant to 10CFR51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCE

1. WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement,"

March 1997

NOC-AE-02001315 Attachment 2 Proposed Technical Specification Changes (Mark-ups)

REACTIVITY CONTROL SYSTEMS No Change on This Page MODERATOR TEMPERATURE COEFFICIENT LIMITING CONDITION FOR OPERATION 3.1.1.3 The moderator temperature coefficient (MTC) shall be within the limits specified in the Core Operating Limits Report (COLR). The maximum upper limit shall be less than or equal to that shown in Figure 3.1-2a.

APPLICABILITY: Beginning of Life (BOL) limit - MODES 1 and 2* only**.

End of Life (EOL) limit - MODES 1, 2, and 3 only**.

ACTION:

a. With the MTC more positive than the BOL limit specified in the COLR, operation in MODES 1 and 2 may proceed provided:

1. Control rod withdrawal limits are established and maintained sufficient to restore the MTC to less positive than the BOL limit specified in the COLR within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. These withdrawal limits shall be in addition to the insertion limits of Specification 3.1.3.6;

2. The control rods are maintained within the withdrawal limits established above until a subsequent calculation verifies that the MTC has been restored to within its limit for the all rods withdrawn condition; and

3. A Special Report is prepared and submitted to the Commission, pursuant to Specification 6.9.2, within 10 days, describing the value of the measured MTC, the interim control rod withdrawal limits, and the predicted average core burnup necessary for restoring the positive MTC to within its limit for the all rods withdrawn condition.

b. With the MTC more negative than the EOL limit specified in the COLR, be in HOT SHUTDOWN within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

I

• With Ke, greater than or equal to 1.

• • See Special Test Exceptions Specification 3.10.3.

SOUTH TEXAS - UNITS 1 & 2 3/4 1-6 Unit 1 - Amendment No. 27 Unit 2 - Amendment No. 17

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.1.3 The MTC shall be determined to be within its limits during each fuel cycle as follows:

a. The MTC shall be measured and compared to the BOL limit specified in the COLR prior to initial operation above 5% of RATED THERMAL POWER, after each fuel loading; and

b. The MTC shall be measured at any THERMAL POWER and compared to the 300 ppm surveillance limit specified in the COLR (all rods withdrawn, RATED THERMAL POWER condition) within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm.* In the event this comparison indicates the MTC is more negative than the 300 ppm surveillance limit specified in the COLR, the MTC shall be remeasured, and compared to the EOL MTC limit specified in the COLR, at least once per 14 EFPD during the remainder of the fuel cycle.

0)

SOUTH TEXAS - UNITS 1 & 2 3/4 1-7 Unit 1 - Amendment No. 27 Unit 2 - Amendment No. 47

ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (Continued)

9. CENPD-397-P-A, Revision 01, "Improved Flow Measurement Accuracy Using Crossflow Ultrasonic Flow Measurement Technology," May 2000.

(Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt) 1Q., WcAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," March 1997, SProprietary)

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient.)

6.9.1.6.c The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

SOUTH TEXAS - UNITS 1 & 2 6-22a Unit 1 - Amendment No. 4-38 Unit 2 - Amendment No. 4-27

NOC-AE-02001315 Attachment 3 Proposed Technical Specification Pages (Retyped)

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS 4.1.1.3 The MTC shall be determined to be within its limits during each fuel cycle as follows:

a. The MTC shall be measured and compared to the BOL limit specified in the COLR prior to initial operation above 5% of RATED THERMAL POWER, after each fuel loading; and

b. The MTC shall be measured at any THERMAL POWER and compared to the 300 ppm surveillance limit specified in the COLR (all rods withdrawn, RATED THERMAL POWER condition) within 7 EFPD after reaching an equilibrium boron concentration of 300 ppm.* In the event this comparison indicates the MTC is more negative than I the 300 ppm surveillance limit specified in the COLR, the MTC shall be remeasured, and compared to the EOL MTC limit specified in the COLR, at least once per 14 EFPD during the remainder of the fuel cycle.

• Measurement of the MTC in accordance with Surveillance Requirement 4.1.1.3.b may be suspended, provided that the benchmark criteria in WCAP-1 3749-P-A (refer to 6.9.1.6.b.10) and the Revised Prediction specified in the COLR are satisfied.

SOUTH TEXAS - UNITS 1 & 2 3/4 1-7 Unit 1 - Amendment No.

Unit 2 - Amendment No.

ADMINISTRATIVE CONTROLS CORE OPERATING LIMITS REPORT (Continued)

9. CENPD-397-P-A, Revision 01, "Improved Flow Measurement Accuracy Using Crossf low Ultrasonic Flow Measurement Technology," May 2000.

(Methodology for operating at a RATED THERMAL POWER of 3,853 Mwt)

10. WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," March 1997, (W Proprietary)

(Methodology for Specification 3.1.1.3 - Moderator Temperature Coefficient.)

6.9.1.6.c The core operating limits shall be determined so that all applicable limits (e.g., fuel thermal mechanical limits, core thermal-hydraulic limits, ECCS limits, nuclear limits such as shutdown margin, and transient and accident analysis limits) of the safety analysis are met.

SOUTH TEXAS - UNITS 1 & 2 6-22a Unit 1 - Amendment No.

Unit 2 - Amendment No.

NOC-AE-02001315 Attachment 4 Typical Revised Core Operating Limits Report Pages (For Information Only)

[ FOR INFORMATION ONLY Nuclear Operating Company

_AN AV Nr SOUTH TEXAS UNIT 1 CYCLE 11 CORE OPERATING LIMITS REPORT October 2001 Edited by C. A. Olson J. E. Skutch APPROVED:

J. J!Ake.rs, Maager Core Analysis B i

I FOR INFORMATION ONLY j

]

Westinghouse Electric Company LLC Nuclear Fuel P.O. Box 355 Pittsburgh, Pennsylvania 15230 Attachment to CAB-01-289, Rev. I

South Texas Unit 1 Cycle I FOR INFORMATION ' LY October 2001 2.3 MODERATOR TEMPERATURE COEFFICIENT (Specification 3.1.1.3):

2.3.1 The BOL, ARO, MTC shall be less positive than the limits shown in Figure 2.

2.3.2 The EOL, ARO, HFP, MTC shall be less negative than -6.12 x 10 4 Akfkl 0F.

2.3.3 The 300 ppm, ARO, HFP, MTC shall be less negative than -5.36 x 10W AW*/k/° (300 ppm Surveillance Limit).

where: BOL stands for Beginning-of-Cycle Life, EOL stands for End-of-Cycle Life, ARO stands for All Rods Out, HFP stands for Hot Full Power (100% RATED THERMAL POWER)

"HFPvessel average temperature is 592 'F.

[2.3,4 t":58-R-rE 2.4 RODINSERTION LIMITS (Specification 3.1.3.5 and 3.1.3.6):

2.4.1 All banks shall have the same Full Out Position (FOP) of at least 250 steps withdrawn but not exceeding 259 steps withdrawn.

2.4.2 The Control Banks shall be limited in physical insertion as specified in Figure 3.

2.4.3 Individual Shutdown bank rods are fully withdrawn when the Bank Demand Indication is at the FOP and the Rod Group Height Limiting Condition for Operation is satisfied (T.S. 3.1.3.1).

2.5 AXIAL FLUX DIFFERENCE (Specification 3.2.1):

2.5.1 AFD limits as required by Technical Specification 3.2.1 are determined by CAOC Operations with an AFD target band of +5, -10%.

2.5.2 The AFD shall be maintained within the ACCEPTABLE OPERATION portion

- of Figure 4, as required by Technical Specifications.

2.6 HEAT FLUX HOT CHANNEL FACTOR (Specification 3.2.2):

2.6.1 FQR" 2.55.

2.6.2 K(Z) is provided in Figure 5.

2.6.3 The F, limits for RATED THERMAL POWER (F,) within specific core planes shall be:

2.6.3.1 Less than or equal to 2.102 for all core planes containing Bank "D" control rods, and 2.6.3.2 Less than or equal to the appropriate core height-dependent value from Table 1 for all unrodded core planes.

2.6.3.3 PFP. = 0.2.

These F, limits were used to confirm that the heat flux hot channel factor FQ(Z) will be limited by Technical Specification 3.2.2 assuming the most-limiting axial power distributions expected to result for the insertion and removal of Control Banks C and D during operation, including the accompanying variations in the axial xenon and power distributions, as described in WCAP-8385. Therefore, these Fq limits provide assurance that the initial conditions assumed in the LOCA analysis are met, along with the ECCS acceptance criteria of 10 CFR 50.46.

3 SFOR INFORMATION ONLY

INSERT E 2.3.4 The Revised Predicted near-EOL 300 ppm MTC shall be calculated using the following algorithm from Reference 3.5:

Revised Predicted MTC = Predicted MTC + AFD Correction - Predictive Correction If the Revised Predicted MTC is less negative than the SR 4.1.1.3 b. limit of

-5.36 x 10-4 Akk/0 F, and all of the benchmark data contained in the surveillance procedure are met, then an MTC measurement in accordance with SR 4.1.1.3 b. is not required.

INSERT F 3.5 WCAP-13749-P-A, "Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement," March 1997, (W Proprietary)

South Texas Unit 1 Cycle I FOR INFORMATION ONLY October 2001 For Unit 1 Cycle 11, the L(Z) penalty is not applied (i.e., L(Z)

= 1.0 for all core elevations).

2.7 ENTHALPY RISE HOT CHANNEL FACTOR (Specification 3.2.3):

2.7.1 WITHOUT RCS Loop-specific Temperature Calibrations:

StandardFuelr FpR P = 1.46 T

VANTAGE 5H / RFA Fuel2 FAHRTP = 1.53 WITH RCS Loop-specific Temperature Calibrations:

StandardFuel Fe T p = 1.49 VANTAGE 5H / RFA Fuel FAH = 1.557 2.7.2 StandardFuel / VANTAGE 5H / RFA Fuel PFH = 0.3 2.8 DNB PARAMETERS (Specification 3.2.5):

2.8.1 The following DNB-related parameters shall be maintained within the following limits:3

a. Reactor Coolant System T,, _<595 01m,

b. Pressurizer Pressure, > 2200 psig,.

c. Minimum Measured Reactor Coolant System Flow > 403,000 gpm6 .

3.0 REFERENCES

3.1 Letter from R. A. Wiley (Westinghouse) to Dave Hoppes (STPNOC),

"Unit 1 Cycle 11 Core Operating Limits Report," 01TG-G-085, Rev. 1 (ST-UB-NOC-01002182, Rev. 1),

October2001.

3.2 NIJREG-1346, Technical Specifications, South Texas Project Unit Nos. 1 and 2.

3.3 STPNOC Calculation ZC-7035, Rev. 1, "Loop Uncertainty Calculation for RCS T.,

Instrumentation," October 19, 1998.

3.4 STPNOC Calculation ZC-7032, Rev. 3, "Loop Uncertainty Calculation for Narrow Range Pressurizer Pressure Monitoring Instrumentation," June 27, 2001.

Z Applies to Region 5.

2 Applies to Regions 104A 11A, 11B, 12A, 13A and 13B.

' A discussion of the processes to be used to take these readings is provided in the basis for Technical Specification 3.2.5.

4 Includes a 1.9 'F measurement uncertainty.

' Limit not applicable during either a Thermal Power ramp in excess of 5% of RTP per minute or a Thermal Power step in excess of 10% RTP. Includes a 10.7 psi measurement uncertainty as read on the QDPS display per Reference 3.4.

Includes a 2.8% flow measurement uncertainty.

4 FOR INFORMATION ONLY