Practical Active Noise Control (ANC) systems typically require a restriction in their maximum output power, to prevent overdriving the loudspeaker and causing system instability. Recently, the minimum output variance filtered-reference least mean square (MOV-FxLMS) algorithm was shown to have optimal control under output constraint with an analytically formulated penalty factor, but it needs offline knowledge of disturbance power and secondary path gain. The constant penalty factor in MOV-FxLMS is also susceptible to variations in disturbance power that could cause output power constraint violations. This paper presents a new variable penalty factor that utilizes the estimated disturbance in the established Modified-FxLMS (MFxLMS) algorithm, resulting in a computationally efficient MOV-MFxLMS algorithm that can adapt to changes in disturbance levels in real-time. Numerical simulation with real noise and plant response showed that the variable penalty factor always manages to meet its maximum power output constraint despite sudden changes in disturbance power, whereas the fixed penalty factor has suffered from a constraint mismatch.