ML20086G474

Application for Amend to License DPR-40,revising TS Sections 1-5 to Implement Core Operational Limits Rept,Per Generic Ltr 88-16

ML20086G474
Person / Time
Site:	Fort Calhoun
Issue date:	11/27/1991
From:	OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20086G466	List: ML20086G462 ML20086G474 ML20086G647
References
GL-88-16, NUDOCS 9112050125
Download: ML20086G474 (13)

Text

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BEFORE THE tlNITED STATES NUCLEAR REGULATORY C0HNISSION in the Matter of Omaha Public Power District ) Docket No. 50 285 '

(fort Calhoun Station )

Unit No. 1) )

APPLICATION FOR AMENDMENT Of OPERATING LICENSE Pursuant-to Section 50.90 of the regulations of the U. S. Nuclear Regulatory Conunission ("the Commission"), Omaha Public Power District, holder of Facility Operating License No. DPR-40, herewith requests that Sections 1,2,3,4 and 5 of the Technical Specifications set forth in Appendix A to that License be amended to implement the Core Operating Limits Report in accordance with Generic Letter 88-16.

Th6 proposed changes in Technical Specifications are set forth in Attachment C to this Application. A Discussion, Justification and No Significant Hazards Consideration Analysis, which demonstrates that the proposed changes do not involve significant hazards considerations, is attached. The proposed changes in specifications would not authorize any l

change in the types or any increase in the amounts of effluents or any l change in the authorized power level of the facility.

WHEREFORE, Applicant respectfully requests that Sections 1,2,3,4 and 5 of Appendix A to f acility Operating 1.icense No. DPR-40 be amended in the form attached hereto as Attachment C.

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., A copy of this Application, including its attachments, has been sub-mitted to the Director Nebraska State Division of Radiological Health, as required by 10 CFR 50.91.

9 OMAHA PUBLIC POWER DISTRIC1 By f

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Acting Division Manager Nuclear Operations Subscribed and sworn to before me this 1~} day of November,1991, h,hb>o.I)/Qlull-u> juntwsom.sii.en*,,u ejr .J.M.,'h Notary Public

VNi1ED STA1ES Of AMERICA NUCLEAR REGULATORY COMMISSION In the Hatter of Omaha Public Power District ) Docket No. 50 285 (Fort Calhoun Station )

Unit No. 1) )

EflDAVIT T. L. Patterson, being duly sworn, hereby deposes and says that he is the Acting Division Manager - Nucicar Operations of the Omaha Public Power District; that as such he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached information concerning the Application for Amendment dated 11/27/91, concerning implementation of a Core Operating Limits Report; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information, and belief.

- k Acting Division' Manager h --  %

Nuclear Operations STATE Of NEBRASKA)

) ss COUNTY Of DOUGLAS)

Subscribed and sworn to before me, a Notary Public in and for the State of Nebraska on this 2~) day of November, 1991

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1. \M} b41Mnt [JJ21og *1 Notary Public ~ NibME1VA ' " " L' "gANs l

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CEE_Qperatiaa limittlepri Discussion, Justification and No Significant Hazards Analysis  ;

Qiscussion & Justificati2D The proposed changes enclostd with this application for amendment to the fort Calhoun Station Unit No. 1 Technical Specifications request the removal of cycle s)ecif t' operating limits and the institution of the Core Operating Limits Report, in accordance with Generic Letter 88 16.

Omaha for eachPublic Power operating District cycle (OPPD)Calhoun Station Unit No. I using NRCpresently gene for fort approved methods. For each cycle, OPPD typically generates and the NRC reviews proposed Technical Specification changes to the cycle-specific limits.

This )rocess represents an administrative burden on both the NRC staff and OPPD Jecause the limits are similar and the methods are the same for each  ;

cycle. The NRC has recoanized this burden and has encouraged licensees '

through Generic Letter 88-16, " Removal of C Technical Specifications", to remove cyclespecific ycle Specific Parameter limits from their Limits from technical specifications and include them in a defined formal report.

The cycle-specific operating limits will continue to be calculated for each cycle using NRC approved methods. The cycle specific operating limits will be documented and provided to the NRC in the Core Operating limits Report (COLR).

Attachment D provides an example of this report for Cycle 13. The Technical Specifications will still require the plant to operate within the COLR limits and to take the appro)riate action should the limits be exceeded. OPPD plans to incor Manual. porate the C0.R into Volume 1 of the fort Calhoun Station Operating Attachment A provides a listing of the safety limits for each of the accidents considered on a cycle s)ecific basis, lhese safety limits are the same as those accepted by the NRC in previous cycles and will remain unchanged unless prior NRC approval is obtained. Attachment 8 provides a summary of proposed Technical Specification changes while Attachment C contains the detailed Technical Specification changes required to implement the proposed COLR. A discussion of the potential safety impacts and justification for the change is presented below.

Limiting Conditions for Operation (LCOs) and Limiting Safety System Settings (LSSSs) are develo)ed to maintain acceptable margins to the safety limits, for fort Calhoun t1ese limiting conditions are presented in Sections 1 and 2 of the Technical Specifications. The key element of the LSSS, designed s)ecifically to protect against violation of the safety limits on the DNBR and tie fuel centerline melt, as defined in Section 1 of the Technical Specifications, is the Thermal Margin / Low Pressure TM/LP) trip. The approved methodology used to define this trip utilizes cycle (dependent power distributions as opposed to the cycle independent bounding power distributions used at-other plants. For this reason this trip function has historically varied slightly from cycle to cycle, if the TM/LP trip was not determined in this manner, an unnecessarily overly conservative set of trip functions would be required to preclude separate proposed Technical Specification revision submittals each cycle. Operation with overly conservative setpoints would increase the probability of unnecessary reactor trips resulting in a situation which may decrease the overali safety of the plant.

Page 2 Other criteria in Section 1 of the fort Calhoun Technical Specifications are developed and implemented to assure that the plant conditions during off normal situatiens will not exceed the defined safety limits. These criteria include both cycle-specific reactor 3rotection system setpoints and acceptable fuel design limits. In no case do tle cycle specific parameters contained in Section I conflict with or exceed the defined safety limits. By operating within the limiting conditions and thus maintaining the safety limits in Attachment A, Fort Calhoun is assured that the limits in the COLR remain within the safety analysis envelope.

The LC0 limits in Section 2 are developed from cycle-specific inputs similar to the LSSS limits in Section 1. The core design an determine the maximum and f core inlet temperature peakin (T ), f,q oper as well as the refueling boron concentration, ut,ilizipgthecyclespecificoperatingparameters will generate the allowable F versuspowertradeoffcurve,theDNBandExcoreLHRMonitoringTents f,dttI5acceptablelinearheatratecurvefortheoperatingcycle.

an To generate the values and curves from the use of overly conservative bounding values would )enalize the operating margin, aotentially not allowing fort Calhoun to ac11 eve full power operations. 111s could have an adverse economic impact 0 OPPD.

The use of NRC approved reload analysis methodology topical reports does not permit substantial discretion on the part of OPPD in calculating the LC0 values nor does the NRC ap> roved methodology allow substantial engince.ing judgement on the part of tie analyst preparing the reload evaluation.

Therefore, assurance that the changes to the COLR are consistent with previously reviewed and approved methodology is maintained.

Basis For No Sianificant HalardLCmsident.120 The proposed changes to the Technical Specifications for the removal of cycle-specific operating limits does not involve a significant hazards considerations because the operation of the fort Calhoun Station in accordance with this change would not:

1. Involve a significant increase in the probability or the consequences of an accident previously evaluated.

The institution of a cycle specific operating limits report, consistent with the NRC recommendations of Generic letter 88-16, will not modify the methodology used in generating the limits nor the manner in which they are implemented. These limits will continue to be determined by analyzing the same postulated events as previously analyzed. The plant will continue to operate within the limits specified in the Core Operating Limits Report and will take the same corrective actions when or if these limits are exceeded as required by current Technical Saecifications. lnerefore, this amendment incorporating the Core Operating imits Report is administrative in nature and has been concluded not to increase the probability or consequences of an accident previously evaluated.

2. Create the possibility for an accident or malfunction of a different type than any previously evalbated, i

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Pago 3 l There setpoint arevalues no physleal alterations or changes to thetoimplementation the plant configuration [s andchangn of setpoin to limits associated with,this pro)osed amendment. No new or different kind of accident is created by tais administrative change because the aciual operation of the plant remains unchanged. Therefore, the possibility of  :

an accident or malfunction of a different type than any previously evaluated in the safety analysis report would ~not to created. ,

3. Involve a significant reduction in the margin of safety.

As indicated above the implementation of the proposed Core Operating consistent with the guidance of Generic letter 8816, makes ,

LimitsReport}stingsafetyanalysismethodologiesandtheresultinglimits use of the ex and setpoints for plant operation. Additionally, the safety analysis acceptance criteria for operations with this proposed change has not changed from that used in the current reload analysis. Therefore the margin of safety as defined in the basis for any Technical Specification is not reduced due to the implementation of the Core Operating Limits Report.

Based on the above considerations, it is OPPD's position that this amendment does not involve a significant hazards consideration as defined in 10CfR50.92 and the )roposed changes will not resuit in a condition which significantly alters tie impact of the station on the environment. Thus, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10CFR51.22 need be prepared. (c)(9) and pursuant to 10CIR51.22(b) no environmental assessment l

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Attachment A Ir3nsitat:JafetrLimiti i

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Page 5 AnticiotteLQperational Occurrence.1 Transient Safety Limits *

1. CEA Withdrawal MDNBR 2 CE 1 Correlation Limit and RCS pressure s 2750 psia

2. Doron Dilution MDNBR 1 CE 1 Correlation Limit and Time to criticality > Operator respon;c time

3. Excess load MDNBR 2 CE 1 Correlation Limit

4. Loss of Load MDNBR 2 CE-1 Correlation Limit and RCS pressure < 2750 psia

5. Loss of Flow MDNBR 2 CE 1 CorrelatTon Limit

6. CEA Drop HDNBR 2 CE-1 Correlation Limit i

• All anticipated operational occurrences have the safety limits of:

1. Minimum Departure from Nucleate Boiling Ratio (MDNBR)

2. No fuel pellet center line melting allowed.

E91tulaind Accidea11 Trans' ent Safoty Limits **

1. CEA Ejection 10CFR 100

2. MSLB 10CFR 100 3.-SGTR . 10CFR 100

4. Seized Rotor 10CFR 100

5. LOCA 10CFR 100

• • All postulated accidents have safety limits of 10 CFR 100. All attem)ts are made to comply with the "well within" criteria of the SRP, even t1ough fort Calhoun is not part of the SRP program.

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t Attachment B 3WMMU_DfiGliPilon of Tg.qhnicp.l_$peeificA112tLChangn

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f SMttil.Ecitr.itil01LQi__J e dtaittl__SDedfltal191LCh angel I

item icch. Spec. Description of Reason for Change 4

Jin. tieher Change i

1. - Page 111 Added new S)ecification 5.9.5 to la)1e of Contents  ;

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2. Page vitt Deleted figures Cycle specific limits were moved 13,24,25 to Core Operating Limits Report 2 6, 2-7, and 2 9 (COLR)  :

3. Page 2 Modified refueling Cycle-specific limit was moved  ;

boron concentration to COLR.

definition ,

4. Page 7 Modified f and f, Cycle specific limit was moved r.

definitionP to COLR.

5. - Page 8 Added definition for Core Operating Limits Report

6. Page 1 2 - Cycle specific limit was moved to ChangedvalueofI',lue 1.75 to. indicate va to 00lR.

provided in COLR. ,

Deleted reference,to Cycle specific parameters were moved' figure 1 3 and f, COLR.

7. figure 1-3 Deleted figure 1 3 Cycle-specific figure was moved to COLR.

8. Page 1-8 Deleted reference to Cycle specific fi Section figure 1 3 and P m were moved to COLgt re and P, equation '

1.3(4) formula

9. Page 1-10 Deleted Reference to Cycle specific figure was moved to Table 1-1 figure 1-3 - COLR.

10. Page 2-20 Changed 1900 pam boron Cycle-specific parameter was moved Section to reference tle refuel- COLR.

2.3(1)a ing baron concentration in COLR,

11. Page 2 22 Changed 1900 ppm boron Cycle-specific parameter was moved Basis to reference tie refuel- COLR. ~

ing boron concentration r in COLR.

- 12. Page 2-39 Changed 1900 p)m boron Cycle specific parameter was moved Basis to reference tie

refuel- COLR.

ing boron concentration in COLR.

13. Page 2 50a Changed reference from figure 2-4 was moved to COLR.

Section figure 2-4 to reference Reference changed to show 2.10.2(4) ColR. correct location of information.

(d)i y ev- -ye8 per w y> w w w w w ege yiw=-(+- -ww-.,g-,.g,e. maw.-p3,--pyy9 my-w ay m,-ey--wgr-w+ip,e7.p--mmg. p.,-gy g- p grei'gy oisy9- 9 g w- ,g- g-g e , 9,w,--- y -

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lutmary Description of_Isdinical Specification Ch.an921 Item Tech. Spec. Description of Reason for Change

_ BA. thLmher Change

14. Page 2 50b Changed reference from figure 2 4 was moved to COLR.

Section figure 2-4 to reference Reference changed to show COLR. correct location of information.

2.10.2f (d)(iij2 ))

Section Changed reference from figure 2-4 was moved to COLR. I 2.10.2(4) figure 2 4 to reference Reference changed to show l (e)(1) CO[R. correct location of information. i P

15. Page 2-50c Changed reference from figure 2 4 was moved to COLR. '

Section figure 2-4 to reference Reference changed to show 2.10.2(7) COL R .- correct location of information.

16. Figure 2 4 Deleted figure Cycle-specific figure was moved to COLR 17 figure 2 5 Deleted figure Cycle-specific figure was moved to COLR

18. Figure 2 6 Deleted figure Cycle-specific figure was moved to COLR

19. figure 2-7 Deleted figure Cycle specific figure was moved to COLR

20. figure 2 9 Deleted figure Cycle specific figure was moved to COLR

21. Page 2 54 Changed reference to The cycle-specific figures were Scction figures 2 6 and 2-7 to moved to the COLR.

2.10.3(3) reference COLR.

22. Page 2-55 Revise basis to f and f ' limits moved to COLR.

Basis reference COLR TYgure 2'5 moved to COLR. .

lo f,, limits.

cation of f ,for and DeTete reference to figure 2 5 and reference C6LR figure for kw/f t.

23. Page 2-56 The reference to The. cycle-specific figures were Section figures 2-5 and moved to the COLR.

2.10.4(1) 2-6 were changed to reference the COLR figures.

24. Page 2-57 The references to Cycle.soccific figures were Section figures 2-6 and 2 9 moved to the COLR.

2.10.4(1)(c) were changed to reference the COLR.

The equation for maximum Technical Specifications have been

. power allowed was ciganged, to properly reference the deleted. F ,f anci Core Power limitation figure,"from COLR to provide i allowable power level.

,.-+ - . . . _ , , , . . _ , , - , _ . . . , . - , - . -. . - , . _ . . , --- y -- , - , , , , _ - - - , , _ _ _ . . _ ,v-,-_---. - . .. _ , . , , - , _ .-.z

i lumity_Reitr_jption of T.cittaical_SperHiqalign_Chan901 '

Item lech. Spec. Description of Reason for Change

.Ro. Number Change

25. Page 2 57a Cigangedlipitsof Cycle-specific limits were moved to Sections f, and f values COLR.

torefere,nceC0lR.

2.10.4 (2) Changed reference from figure 2 9 was moved to COLR.

and (3) figure 2 9 to reference COLR.

26. Page 2 57b Changed reference from figure 2-9 was moved to C0lR.

Section figure 2-9 to reference 2.10.4(4)(c) 00tR.

27. Page 2-57c Changed reference from Cycle-Specific Limit is provided by Section 543' f to reference COLR COLR.

2.10.4(5) for cold leg temperature.

Changed reference from figure 2-7 was moved to COLR.

Figure 2 7 to reference '

COLR.

Basis Basis reference to Basis needed to be consistent with figures 2 6 and 2 5 was Technical Specification requirements, changed to reference COLR.

Notes Deleted *** and added Notes are consistent with Technical (1). Specification text.

28. Page 2-57d Changed figure 2-5 to figure 2 5 was moved to COLR.

Basis reference COLR.

29. Page 2-57e Changed reference from figure 2-9 was moved to COLR.

Basis figure 2 9 to reference r COLR.

30. Page 2-62 Changed 1900 p>m boron Cycle-specific parameter was Section to reference t1e refuel- moved to COLR.

2.14(5) ing boron concentration in COLR.

31. Page 3-63a Changed reference from figure 2-6 was moved to COLR.

Section figure 2-6-to 3-10.4 reference COLR.

l 32. Page 4-4 Changed 1900 pim boron Cycle-Specific larameter i Section to reference tie refuel- was moved to C0_R.

4.4.2 ing boron concentration in COLR.

33. Pages 5 4 Added requirement for and 5-5 PRC to review all Changes to the COLR

34. 'Page 5-17a Added section 5.9.5 Add COLR requirements for analytical methods, implementation and distribution requirements.

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i ATTACHMENT C Technical Specificatipftchangg

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