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| issue date = 05/25/1995 | | issue date = 05/25/1995 | ||
| title = Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Incorporate Cycle & Burnup Dependent Peaking Factor Penalty | | title = Application for Amends to Licenses DPR-58 & DPR-74.Amends Would Incorporate Cycle & Burnup Dependent Peaking Factor Penalty | ||
| author name = | | author name = Fitzpatrick E | ||
| author affiliation = INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG | | author affiliation = INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG | ||
| addressee name = | | addressee name = | ||
Line 14: | Line 14: | ||
| document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS | | document type = OPERATING LICENSES-APPLIATION TO AMEND-RENEW EXISTING, TEXT-LICENSE APPLICATIONS & PERMITS | ||
| page count = 11 | | page count = 11 | ||
| project = | |||
| stage = Request | |||
}} | }} | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:RIG RITY | ||
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)S ACCESSION NBR: 9505310313 DOC.DATE: 95/05/25 NOTARIZED: | ~PCCELERATED RIDS l~ | ||
YES DOCKET FACIL:50-315 Donald C.Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C.Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH.NAME~AUTHOR AFFILIATXON FITZPATRICK,E. | Pl<OCI'.SSIiG) | ||
Xndiana Michigan Power Co.(formerly Indiana&Michigan Ele p RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) | REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS) | ||
S ACCESSION NBR: 9505310313 DOC. DATE: 95/05/25 NOTARIZED: YES DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME ~ AUTHOR AFFILIATXON FITZPATRICK,E. Xndiana Michigan Power Co. (formerly Indiana & Michigan Ele p RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk) | |||
==SUBJECT:== | ==SUBJECT:== | ||
Application for amends to licenses DPR-58&DPR-74.Amends would incorporate cycle&burnup dependent peaking factor penalty.DISTRIBUTION CODE: AOOID COPIES RECEIVED:LTR jENCL 2 SIZE:&+/ | Application for amends to licenses DPR-58 & DPR-74.Amends would incorporate cycle & burnup dependent peaking factor penalty. | ||
DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution jENCL 2 SIZE: &+/ 0 NOTES: | |||
PLEASE IHELP US TO REDUCE iVKSTE!CONTACTTIIE DOCL'ifEY'I'CONTROL DESK, ROOM PI.37 (EXT.564.0083)TO ELIXIR l.PATE YOUR | RECIPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 7 HICKMAN,J 1 1 XNTE 'ENTE | ||
Indiana Michigan Power Company P.O.Box 16631 Columbus, OH 43216 May 25, 1995 AEP;NRC:1071T Docket Nos.: 50-315 50-316 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C, 20555 Gentlemen: | * 01 1 1 NRR/DE/EMCB 1 1 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC NRC PDR 1 1 D | ||
Donald C.Cook Nuclear Plant Units 1 and 2 TECHNICAL SPECIFICATION 3.2.6 CHANGE Fq PENALTY, Fps ON ALLOWABLE POWER LEVEL TO BE BURNUP DEPENDENT AND SPECIFY THE VALUE IN THE CORE OPERATION LIMIT REPORT This letter and its attachments constitute an application for amendment of the technical specifications (T/Ss)for Donald C.Cook Nuclear Plant Units 1 and 2.Specifically, we propose to modify the T/Ss to incorporate a cycle and burnup dependent peaking factor penalty (Fp).Since the value of Fp will typically change each fuel cycle, we propose to specify the value of Fp in the Core Operating Limits Report (COLR).Your staff's safety evaluation in November 1993 of WCAP-10216-P, Rev.1,"Relaxation of Constant Axial Offset Control-F<Surveillance Technical Specification," found the proposed revision to the Fo surveillance acceptable. | 0 U | ||
Our proposed changes satisfy the requirements stated in the safety evaluation by penalizing Fo in the allowable power level T/S (3.2.6).Attachment 1 provides a detailed description of the proposed changes, justification for the changes, and our determination of no significant hazards consideration performed pursuant to 10 CFR 50,92.Attachment 2 contains the existing T/S pages marked to reflect the proposed changes.Attachment 3 contains the proposed revised T/S pages.Attachment 4 contains an example of how the proposed change would be represented in the COLR. | N NOTE TO ALL"RIDS" RECIPIENTS: | ||
f I U.S.Nuclear Regulatory Commission | PLEASE IHELP US TO REDUCE iVKSTE! CONTACTTIIE DOCL'ifEY'I'CONTROL DESK, ROOM PI.37 (EXT. 564.0083 ) TO ELIXIR l.PATE YOUR NAifLITROif DIS'I'RIB U'I'ION LIS'I'S I'OR DOCI.'%l EN'I'S YOI 'ON"I'ITl'.D! | ||
In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health.Sincerely, p~'.E.Fitzpatrick | TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 11 | ||
~Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS~~4 DAY OF 1995 Notary Public eh Attachments CC: A.A.Blind G.Charnoff J.B.Martin NFEM Section Chief NRC Resident Inspector-Bridgman J.R.Padgett | |||
'l I'I | 0 Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 May 25, 1995 AEP;NRC:1071T Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C, 20555 Gentlemen: | ||
Update reference to WCAP-10216-P, June 1983, to WCAP-10216-P-A, Revision 1A, February 1994.3.Units 1 and 2, COLR, Section 2.8.3: Specify the burnup dependent values of F>instead of referring to the value in T/S 3.2.6 (see Attachment 4).REASON AND JUSTIFICATION FOR CHANGES The F<and allowable power level (APL)T/S surveillances are required every 31 effective full power days (EFPDs).To take into account the possibility that F<may increase between flux maps, provisions are provided in the T/Ss to accommodate such occurrences. | Donald C. Cook Nuclear Plant Units 1 and 2 TECHNICAL SPECIFICATION 3.2.6 CHANGE Fq PENALTY, Fps ON ALLOWABLE POWER LEVEL TO BE BURNUP DEPENDENT AND SPECIFY THE VALUE IN THE CORE OPERATION LIMIT REPORT This letter and its attachments constitute an application for amendment of the technical specifications (T/Ss) for Donald C. Cook Nuclear Plant Units 1 and 2. Specifically, we propose to modify the T/Ss to incorporate a cycle and burnup dependent peaking factor penalty (Fp). Since the value of Fp will typically change each fuel cycle, we propose to specify the value of Fp in the Core Operating Limits Report (COLR). | ||
The T/Ss require that F<(Z)/K(Z) be compared to the previous flux map, and | Your staff's safety evaluation in November 1993 of WCAP-10216-P, Rev. 1, "Relaxation of Constant Axial Offset Control - F< | ||
Westinghouse Electric Corporation (Westinghouse) has discovered cases where predicted F<increases more than 2 percent, causing the 2 percent penalty to be non-conservative. | Surveillance Technical Specification," found the proposed revision to the Fo surveillance acceptable. Our proposed changes satisfy the requirements stated in the safety evaluation by penalizing Fo in the allowable power level T/S (3.2.6). | ||
These cases are generally at beginning of cycle (BOC)burnups and the effects taper off before reaching the point of least amount of F<margin.Since the T/Ss only allow for a 2 percent penalty to be applied, weekly F<measurements have to be taken during the BOC to ensure that T/S surveillances are satisfied. | Attachment 1 provides a detailed description of the proposed changes, justification for the changes, and our determination of no significant hazards consideration performed pursuant to 10 CFR 50,92. Attachment 2 contains the existing T/S pages marked to reflect the proposed changes. Attachment 3 contains the proposed revised T/S pages. Attachment 4 contains an example of how the proposed change would be represented in the COLR. | ||
Westinghouse revised WCAP-10216-P-A, to address predicted F<increases of more than 2 percent, which was accepted in the NRC safety evaluation dated November 26, 1993.The revision to the WCAP specifies two options for incorporating changes in the T/Ss to accommodate Fz of greater than 2 percent.The options are to make Fz burnup dependent and move it in COLR, or to add a penalty to the V(Z)function.We have chosen to incorporate the option which speci.fies use of a burnup dependent Fp that will be specified in the COLR.The burnup dependent Fp T/S changes presented in WCAP-10216-P-A, Rev.1A, address application of the penalty in the Fo T/S.Cook Nuclear Plant T/Ss utilize Fp as it is applied to F<in the allowable power level (APL)T/Ss.Since the APL calculation is dependent on the value of F>, the protection against an increasing F<is identical to that in the recommended T/S changes specified in WCAP-10216-P-A, Rev.1A. | |||
~~a Page 2 Incorporating a burnup dependent F<penalty in the COLR would allow application of the larger penalty, when necessary, to maintain a 31 EFPD surveillance schedule.Therefore, the weekly F<measurements would not be required to satisfy the T/S surveillance requirements. | f I | ||
10 CFR 50.92 EVALUATION Per 10 CFR 50.92, a proposed amendment. | |||
will not involve a significant hazards consideration if the proposed amendment does not: (1)involve a significant increase in the probability or consequences of'"an accident previously evaluated, (2)create the possibility of a new or different kind of accident from any accident previously evaluated, or (3)involve a significant reduction in a margin of safety.Criterion 1 The proposed changes will not involve a significant increase in the probability of an accident previously evaluated because the changes will not result in a change to any of the process variables that might initiate an accident.There are no physical changes to the plant associated with this T/S change.The consequences of an accident previously evaluated will not be increased because the changes increase the penalty applied to F<when it is measured to be increasing. | U. S. Nuclear Regulatory Commission AEP:NRC:1071T Page 2 We believe that the proposed changes will not result in (1) a significant change in the types of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure. | ||
F<and allowable power level (APL)T/S surveillance requirements are not being changed.Furthermore, allowing a cycle and burnup dependent F<penalty to be located in the COLR was accepted by the NRC in, a safety evaluation on WCAP-10216-P, Rev.1.CRITERION 2 The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated because the changes will involve no physical changes to the plant nor any changes in plant operations. | The proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee. | ||
Furthermore, the F<and APL T/S surveillance requirements are not being changed, and the change to the F<penalty is conservative. | In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health. | ||
CRITERION 3 The proposed amendment will not involve a significant reduction in a margin of safety.When the increased F<penalty is applied, it reduces the allowable power level, thus increasing the margin of safety. | Sincerely, p~'. | ||
ATTACHMENT 2 TO AEP:NRC:1071T EXISTING TECHNICAL SPECIFICATION PAGES MARKED TO REFLECT PROPOSED CHANGES}} | E. Fitzpatrick | ||
~ | |||
Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS ~~4 DAY OF 1995 Notary Public eh Attachments CC: A. A. Blind G. Charnoff J. B. Martin NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett | |||
'l says I try | |||
'I l ~~r J~ | |||
1 | |||
ATTACHMENT 1 TO AEP:NRC:1071T JUSTIFICATION AND 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS to AEP:NRC:1071T Page 1 DESC IPTION OF CHANGES J | |||
: 1. Units 1 and 2, technical specification (T/S) 3.2.6: | |||
Where Fz is set equal to 1.02, modify to state that Fp is a burnup dependent penalty specified in the Core Operating Limits Report (COLR). | |||
: 2. Units 1 and 2, T/S 6.9.1.9.2.c: | |||
Update reference to WCAP-10216-P, June 1983, to WCAP-10216-P-A, Revision 1A, February 1994. | |||
: 3. Units 1 and 2, COLR, Section 2.8.3: | |||
Specify the burnup dependent values of F> instead of referring to the value in T/S 3.2.6 (see Attachment 4). | |||
REASON AND JUSTIFICATION FOR CHANGES The F< and allowable power level (APL) T/S surveillances are required every 31 effective full power days (EFPDs). To take into account the possibility that F< may increase between flux maps, provisions are provided in the T/Ss to accommodate such occurrences. The T/Ss require that F<(Z)/K(Z) be compared to the previous flux map, and increase, then additional action must be taken. | |||
if it is found to Either a 2 percent penalty is applied to F~, or no penalty is applied, but Fo measurements must be taken every 7 EFPDs until two successive flux maps indicate that F<(Z)/K(Z) is not increasing. | |||
Westinghouse Electric Corporation (Westinghouse) has discovered cases where predicted F< increases more than 2 percent, causing the 2 percent penalty to be non-conservative. These cases are generally at beginning of cycle (BOC) burnups and the effects taper off before reaching the point of least amount of F< margin. Since the T/Ss only allow for a 2 percent penalty to be applied, weekly F< measurements have to be taken during the BOC to ensure that T/S surveillances are satisfied. | |||
Westinghouse revised WCAP-10216-P-A, to address predicted F< increases of more than 2 percent, which was accepted in the NRC safety evaluation dated November 26, 1993. The revision to the WCAP specifies two options for incorporating changes in the T/Ss to accommodate Fz of greater than 2 percent. The options are to make Fz burnup dependent and move it in COLR, or to add a penalty to the V(Z) function. We have chosen to incorporate the option which speci.fies use of a burnup dependent Fp that will be specified in the COLR. | |||
The burnup dependent Fp T/S changes presented in WCAP-10216-P-A, Rev. 1A, address application of the penalty in the Fo T/S. Cook Nuclear Plant T/Ss utilize Fp as it is applied to F< in the allowable power level (APL) T/Ss. | |||
Since the APL calculation is dependent on the value of F>, the protection against an increasing F< is identical to that in the recommended T/S changes specified in WCAP-10216-P-A, Rev. 1A. | |||
~ ~ a Page 2 Incorporating a burnup dependent F< penalty in the COLR would allow application of the larger penalty, when necessary, to maintain a 31 EFPD surveillance schedule. Therefore, the weekly F< measurements would not be required to satisfy the T/S surveillance requirements. | |||
10 CFR 50.92 EVALUATION Per 10 CFR 50.92, a proposed amendment. will not involve a significant hazards consideration if the proposed amendment does not: | |||
(1) involve a significant increase in the probability or consequences of | |||
'"an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety. | |||
Criterion 1 The proposed changes will not involve a significant increase in the probability of an accident previously evaluated because the changes will not result in a change to any of the process variables that might initiate an accident. There are no physical changes to the plant associated with this T/S change. The consequences of an accident previously evaluated will not be increased because the changes increase the penalty applied to F< when it is measured to be increasing. F< and allowable power level (APL) T/S surveillance requirements are not being changed. Furthermore, allowing a cycle and burnup dependent F< penalty to be located in the COLR was accepted by the NRC in, a safety evaluation on WCAP-10216-P, Rev. 1. | |||
CRITERION 2 The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated because the changes will involve no physical changes to the plant nor any changes in plant operations. Furthermore, the F< and APL T/S surveillance requirements are not being changed, and the change to the F< penalty is conservative. | |||
CRITERION 3 The proposed amendment will not involve a significant reduction in a margin of safety. When the increased F< penalty is applied, it reduces the allowable power level, thus increasing the margin of safety. | |||
ATTACHMENT 2 TO AEP:NRC:1071T EXISTING TECHNICAL SPECIFICATION PAGES MARKED TO REFLECT PROPOSED CHANGES}} |
Latest revision as of 04:10, 16 November 2019
ML17332A766 | |
Person / Time | |
---|---|
Site: | Cook |
Issue date: | 05/25/1995 |
From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
Shared Package | |
ML17332A767 | List: |
References | |
AEP:NRC:1071T, NUDOCS 9505310313 | |
Download: ML17332A766 (11) | |
Text
RIG RITY
~PCCELERATED RIDS l~
Pl<OCI'.SSIiG)
REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
S ACCESSION NBR: 9505310313 DOC. DATE: 95/05/25 NOTARIZED: YES DOCKET FACIL:50-315 Donald C. Cook Nuclear Power Plant, Unit 1, Indiana M 05000315 50-316 Donald C. Cook Nuclear Power Plant, Unit 2, Indiana M 05000316 AUTH. NAME ~ AUTHOR AFFILIATXON FITZPATRICK,E. Xndiana Michigan Power Co. (formerly Indiana & Michigan Ele p RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Application for amends to licenses DPR-58 & DPR-74.Amends would incorporate cycle & burnup dependent peaking factor penalty.
DISTRIBUTION CODE: AOOID TITLE: OR COPIES RECEIVED:LTR Submittal: General Distribution jENCL 2 SIZE: &+/ 0 NOTES:
RECIPIENT COPIES RECIPIENT COPIES XD CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL PD3-1 LA 1 1 PD3-1 PD 1 1 7 HICKMAN,J 1 1 XNTE 'ENTE
- 01 1 1 NRR/DE/EMCB 1 1 1 1 NRR/DSSA/SPLB 1 1 NRR/DSSA/SRXB 1 1 NUDOCS-ABSTRACT 1 1 OGC/HDS2 1 0 EXTERNAL: NOAC NRC PDR 1 1 D
0 U
N NOTE TO ALL"RIDS" RECIPIENTS:
PLEASE IHELP US TO REDUCE iVKSTE! CONTACTTIIE DOCL'ifEY'I'CONTROL DESK, ROOM PI.37 (EXT. 564.0083 ) TO ELIXIR l.PATE YOUR NAifLITROif DIS'I'RIB U'I'ION LIS'I'S I'OR DOCI.'%l EN'I'S YOI 'ON"I'ITl'.D!
TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 11
0 Indiana Michigan Power Company P.O. Box 16631 Columbus, OH 43216 May 25, 1995 AEP;NRC:1071T Docket Nos.: 50-315 50-316 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C, 20555 Gentlemen:
Donald C. Cook Nuclear Plant Units 1 and 2 TECHNICAL SPECIFICATION 3.2.6 CHANGE Fq PENALTY, Fps ON ALLOWABLE POWER LEVEL TO BE BURNUP DEPENDENT AND SPECIFY THE VALUE IN THE CORE OPERATION LIMIT REPORT This letter and its attachments constitute an application for amendment of the technical specifications (T/Ss) for Donald C. Cook Nuclear Plant Units 1 and 2. Specifically, we propose to modify the T/Ss to incorporate a cycle and burnup dependent peaking factor penalty (Fp). Since the value of Fp will typically change each fuel cycle, we propose to specify the value of Fp in the Core Operating Limits Report (COLR).
Your staff's safety evaluation in November 1993 of WCAP-10216-P, Rev. 1, "Relaxation of Constant Axial Offset Control - F<
Surveillance Technical Specification," found the proposed revision to the Fo surveillance acceptable. Our proposed changes satisfy the requirements stated in the safety evaluation by penalizing Fo in the allowable power level T/S (3.2.6).
Attachment 1 provides a detailed description of the proposed changes, justification for the changes, and our determination of no significant hazards consideration performed pursuant to 10 CFR 50,92. Attachment 2 contains the existing T/S pages marked to reflect the proposed changes. Attachment 3 contains the proposed revised T/S pages. Attachment 4 contains an example of how the proposed change would be represented in the COLR.
f I
U. S. Nuclear Regulatory Commission AEP:NRC:1071T Page 2 We believe that the proposed changes will not result in (1) a significant change in the types of any effluent that may be released offsite, or (2) a significant increase in individual or cumulative occupational radiation exposure.
The proposed changes have been reviewed by the Plant Nuclear Safety Review Committee and the Nuclear Safety and Design Review Committee.
In compliance with the requirements of 10 CFR 50.91(b)(l), copies of this letter and its attachments have been transmitted to the Michigan Public Service Commission and to the Michigan Department of Public Health.
Sincerely, p~'.
E. Fitzpatrick
~
Vice President SWORN TO AND SUBSCRIBED BEFORE ME THIS ~~4 DAY OF 1995 Notary Public eh Attachments CC: A. A. Blind G. Charnoff J. B. Martin NFEM Section Chief NRC Resident Inspector - Bridgman J. R. Padgett
'l says I try
'I l ~~r J~
1
ATTACHMENT 1 TO AEP:NRC:1071T JUSTIFICATION AND 10 CFR 50.92 ANALYSIS FOR CHANGES TO THE DONALD C. COOK NUCLEAR PLANT UNITS 1 AND 2 TECHNICAL SPECIFICATIONS to AEP:NRC:1071T Page 1 DESC IPTION OF CHANGES J
- 1. Units 1 and 2, technical specification (T/S) 3.2.6:
Where Fz is set equal to 1.02, modify to state that Fp is a burnup dependent penalty specified in the Core Operating Limits Report (COLR).
- 2. Units 1 and 2, T/S 6.9.1.9.2.c:
Update reference to WCAP-10216-P, June 1983, to WCAP-10216-P-A, Revision 1A, February 1994.
- 3. Units 1 and 2, COLR, Section 2.8.3:
Specify the burnup dependent values of F> instead of referring to the value in T/S 3.2.6 (see Attachment 4).
REASON AND JUSTIFICATION FOR CHANGES The F< and allowable power level (APL) T/S surveillances are required every 31 effective full power days (EFPDs). To take into account the possibility that F< may increase between flux maps, provisions are provided in the T/Ss to accommodate such occurrences. The T/Ss require that F<(Z)/K(Z) be compared to the previous flux map, and increase, then additional action must be taken.
if it is found to Either a 2 percent penalty is applied to F~, or no penalty is applied, but Fo measurements must be taken every 7 EFPDs until two successive flux maps indicate that F<(Z)/K(Z) is not increasing.
Westinghouse Electric Corporation (Westinghouse) has discovered cases where predicted F< increases more than 2 percent, causing the 2 percent penalty to be non-conservative. These cases are generally at beginning of cycle (BOC) burnups and the effects taper off before reaching the point of least amount of F< margin. Since the T/Ss only allow for a 2 percent penalty to be applied, weekly F< measurements have to be taken during the BOC to ensure that T/S surveillances are satisfied.
Westinghouse revised WCAP-10216-P-A, to address predicted F< increases of more than 2 percent, which was accepted in the NRC safety evaluation dated November 26, 1993. The revision to the WCAP specifies two options for incorporating changes in the T/Ss to accommodate Fz of greater than 2 percent. The options are to make Fz burnup dependent and move it in COLR, or to add a penalty to the V(Z) function. We have chosen to incorporate the option which speci.fies use of a burnup dependent Fp that will be specified in the COLR.
The burnup dependent Fp T/S changes presented in WCAP-10216-P-A, Rev. 1A, address application of the penalty in the Fo T/S. Cook Nuclear Plant T/Ss utilize Fp as it is applied to F< in the allowable power level (APL) T/Ss.
Since the APL calculation is dependent on the value of F>, the protection against an increasing F< is identical to that in the recommended T/S changes specified in WCAP-10216-P-A, Rev. 1A.
~ ~ a Page 2 Incorporating a burnup dependent F< penalty in the COLR would allow application of the larger penalty, when necessary, to maintain a 31 EFPD surveillance schedule. Therefore, the weekly F< measurements would not be required to satisfy the T/S surveillance requirements.
10 CFR 50.92 EVALUATION Per 10 CFR 50.92, a proposed amendment. will not involve a significant hazards consideration if the proposed amendment does not:
(1) involve a significant increase in the probability or consequences of
'"an accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety.
Criterion 1 The proposed changes will not involve a significant increase in the probability of an accident previously evaluated because the changes will not result in a change to any of the process variables that might initiate an accident. There are no physical changes to the plant associated with this T/S change. The consequences of an accident previously evaluated will not be increased because the changes increase the penalty applied to F< when it is measured to be increasing. F< and allowable power level (APL) T/S surveillance requirements are not being changed. Furthermore, allowing a cycle and burnup dependent F< penalty to be located in the COLR was accepted by the NRC in, a safety evaluation on WCAP-10216-P, Rev. 1.
CRITERION 2 The proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated because the changes will involve no physical changes to the plant nor any changes in plant operations. Furthermore, the F< and APL T/S surveillance requirements are not being changed, and the change to the F< penalty is conservative.
CRITERION 3 The proposed amendment will not involve a significant reduction in a margin of safety. When the increased F< penalty is applied, it reduces the allowable power level, thus increasing the margin of safety.
ATTACHMENT 2 TO AEP:NRC:1071T EXISTING TECHNICAL SPECIFICATION PAGES MARKED TO REFLECT PROPOSED CHANGES