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Improved Technical Specifications, Volume 7, Revision 0, ITS Section 3.2, Power Distribution Limits.
	ML051990461
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Site:	Monticello
Issue date:	06/29/2005
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IMPROVED TECHNICAL SPECIFICATIONS MONTICELLO NUCLEAR GENERATING PLANT VOLUME 7 ITS Section 3.2, Power Distribution Limits Committed to Ncer Excller //

Attachment 1, Volume 7, Rev. 0, Page 1 of 73 ATTACHMENT I VOLUME 7 MONTICELLO IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 0.*

Attachment 1, Volume 7, Rev. 0, Page 1 of 73

Attachment 1, Volume 7, Rev. 0, Page 2 of 73 LIST OF ATTACHMENTS

1. ITS 3.2.1

2. ITS 3.2.2

3. ITS 3.2.3

4. Improved Standard Technical Specifications (ISTS) not adopted in the Monticello ITS Attachment 1, Volume 7, Rev. 0, Page 2 of 73

Attachment 1, Volume 7, Rev. 0, Page 3 of 73 ATTACHMENT 1 ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Attachment 1,Volume 7, Rev. 0, Page 3 of 73

Attachment 1,Volume 7, Rev. 0, Page 4 of 73 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 7, Rev. 0, Page 4 of 73

C C CI ITS 3.2.1 ITS 3.0 LIMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REOUIREMENTS 3.11 REACTOR FUEL SSEMBLIES 4.11 REACTOR FUELASSEMB IES AnDricabiliv: / *Agglicablift/*

The Limiting for Operation associated vith 0 Indltons e W fuel rods app to those parameters which monitor the The Surveitlance Refuel apply to the paratnelers rod operatn conditions. which monitor the fel I operatng conditons. 0 3

Oblective: Oblect~ve: /

0 assureobpe lyerormancgeCon ditions for Operaton Is to The objective of th Surveiltance Requirements Is to specify 0 the type and freo nov of surveillance to be applied to the I B202fo2m: fuel ro~ds. Y A A. Averacie Planar Linear Ileat Generation Rate -4

( S12ecifiatlorrs:.

A. Averaoe Planar Lfnear Heat Generatlon Rate (APLHGRI 0 0

LCO 3.2.1 A LHG eacn 9 0

-o ction o averaoe hail not exceed the applicable limiting SR The APLHGfor each ai values specified In the Core Operatng Limits Report. 3.2.1.1 shall be determinedaly poverasur CD during reactor operation at '25% rated them r. 0 wnennahcalt~llion EerequredIERPHGRfor each tyeof fuel asa udlnoavaglnr .

U exosr shall not ecethlilnve( frhemost_ -U limitini lattice (excuil aua raingpofe In CD the 5re Operating isReot / 0CD)

-0 V ~uinq oneiueirlalio lodowreratlo[L thre

\\APLHGR limiting conditbon for operation 1Lgar eaJY"eo

\hall not exceed the most limiting of:

-4 I\ a. Tefibovevaluesm41'1ipliedbyO.80fo GE11 and -4

\ E tue an o'go GE14 fuel, or

b. Tl bove values rtulipried by the aproprale flow ad powver depenbtcreiofa s provded In t)eCore Operatig ris eot 3.11/4.11 211 10102102 Amendment No. 54, 70, 28, 07, 109, 131 Page 1 of 2

c C ITS 3.2.1 ITS 3.0 UMITING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS If at any time during power operation. Ris determined l that the APLHGR limiting condition for operation Is being exceeded acton shall be initiled within 15 minut to -

ACTION A res ore ration to within the Pobscnrdiibe

0) Surveliloce mid corresp nding acton sh contin 0)

L luntil rei cor operaton Islfn the the APLHGR Isnot returned to within the prescribed limits within two hours geduce thermal power to less C)

CD ACTION B tan 25% within the next four hours.

B. Unear Heat Generation Rate (iGR1 B. Linear Heat Generaton Rate (LHGR) 0 During power operation, the LHGR shall be less than or The LHGR shall be checked daily during reactor equal to the limits specified in the Core Operating Umils operation at 2 25% of rated thermal power. :-4 Report.

f See ITS 3.2.3}

CD If at any time during operation Itis determined that the

-4 limiting value for LHGR is being exceeded, action shalt 0 be Initiated within 15 minutes to restore operation to within the prescribed limits. Surveillance and 0) corresponding action shall continue until reactor CD operation Is within the prescribed limits. If the LHGR Is CD not returned to within the prescribed limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . reduce thermal power to less than 25% within the -4 A) next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

(a CD)

CD CD 0

-4 3.1114.11 212 2J16/00 Amendment No. 4344 -0, 109 Page 2 of 2

Attachment 1, Volume 7, Rev. 0, Page 7 of 73 DISCUSSION OF CHANGES ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.11.A states that the APLHGR should not exceed limits during "power operation," which is defined in CTS 1.0.0 as "above 1% rated thermal power."

However, CTS 3.11 .A only states to reduce thermal power to "less than 25%" if the APLHGR LCO is being exceeded and the APLHGRs are not returned to within limits within the specified time. ITS LCO 3.2.1 is applicable at THERMAL POWER > 25% RTP. ITS 3.2.1 ACTION B requires a THERMAL POWER reduction to < 25% RTP if the APLHGR(s) are not restored to within limits within the specified time limit of ACTION A. This changes the CTS by changing the -

Applicability from > 1% rated thermal power to > 25% RTP.

The purpose of the CTS 3.11.A is to ensure the APLHGRs are within limits when required. This changes the CTS by changing the Applicability from "power operation" to"> 25% RTP." This change is acceptable because at THERMAL POWER levels < 25% RTP the reactor is operating with substantial margin to the APLHGR limits. For this reason there is no need to monitor APLHGRs when THERMAL POWER is < 25% RTP. This is also consistent with the Surveillance Frequency in CTS 4.11.A, which states to monitor APLHGR at > 25% rated thermal power. This change simply aligns the Applicability with the CTS default action and Surveillance Frequency, and is therefore considered administrative.

Therefore, this change is considered a presentation preference change only and, as such, is considered an administrative change.

A.3 CTS 3.11.A states "Surveillance and corresponding action shall continue until reactor operation is within the prescribed limits." ITS 3.2.1 does not include this statement. This changes the CTS by deleting this statement.

The purpose of this CTS 3.11.A statement is to identify the importance of monitoring the APLGHRs to verify they are restored to prescribed limits. After they are within limits, it is obvious that the action can be exited. This change is acceptable because ITS LCO 3.0.1 and LCO 3.0.2 have been added to the TS as indicated in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.1 states "LCOs shall be met during the MODES or other specified conditions in the Applicability," and LCO 3.0.2 states "Upon discovery of.a failure to meet an LCO, the Required Actions of the associated Conditions shall be met" and "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required." The CTS 3.11.A guidance is provided in the ITS generic guidelines of LCO 3.0.1 and LCO 3.0.2. In addition, the only way to confirm the APLHGRs have been restored to within limits is to perform a Surveillance; thus, it is not necessary to Monticello Page 1 of 4 Attachment 1, Volume 7, Rev. 0, Page 7 of 73

Attachment 1, Volume 7, Rev. 0, Page 8 of 73 DISCUSSION OF CHANGES ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) be specifically stated. Therefore, this change is considered a presentation preference change only and, as such, is considered an administrative change.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3- Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.11 .A specifies the limits for APLHGRs for "two loop" and "one loop" operation. For two loop operation, the APLGHR limits are specified "for each type of fuel as a function of average planar exposure." For one loop operation, the APLGHR limits are specified "for each type of fuel" and shall not exceed "the most limiting of a. The above values multiplied by 0.80 for GE11 and GE12 fuel and 0.90 for GE14 fuel, or b. The above values multiplied by the appropriate flow and power dependent correction factors provided in the Core Operating Limits Report." In addition CTS 4.11 .A states the APLHGR "for each type of fuel as a function of average planar exposure" shall be determined.

ITS 3.2.1 states "All APLHGRs shall be less than or equal to the limits specified in the COLR." ITS SR 3.2.1.1 requires verification of all APLGHRs are less than or equal to the limits specified in the COLR. This changes the CTS by relocating the details that the APLHGRs limits are specified for "one" and "two" loop operation, that the two loop APLHGR limits are specified "for each type of fuel as a function of average planar exposure," and that the single loop APLHGRs limits "for each type of fuel" shall not exceed "the most limiting of a. The above values multiplied by 0.80 for GE11 and GE12 fuel and 0.90 for GE14 fuel, or b. The above values multiplied by the appropriate flow and power dependent correction factors provided in the Core Operating Limits Report" to the Bases.

The removal of these details for evaluating APLGHR Surveillance Requirements from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS LCO 3.2.1 still retains the requirement that "All APLHGRs shall be less than or equal to the limits specified in the COLR" and ITS SR 3.2.1.1 requires verification that "all APLHGRs are less than or equal to the limits specified in the COLR." Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail Monticello Page 2 of 4 Attachment 1, Volume 7, Rev. 0, Page 8 of 73

Attachmnent 1, Volume 7, Rev. 0, Page 9 of 73 DISCUSSION OF CHANGES ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA.2 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.11 .A states 'When hand calculations are required, the APLHGR for each type of fuel as a function of average planar exposure shall not exceed the limiting value for the most limiting lattice (excluding natural uranium) provided in the Core Operating Limits Report."

ITS LCO 3.2.1 states "All APLHGRs shall be less than or equal to the limits specified in the COLR." This changes the CTS by relocating the hand calculation APLHGR limits to the COLR.

The removal of these cycle-specific parameter limits from the Technical Specifications and their relocation into the COLR is acceptable because these limits are developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, Removal of Cycle-Specific Parameter Limits From the Technical Specifications, that this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains requirements and Surveillances that verify that the cycle-specific parameter limits are being met.

ITS 3.2.1 LCO requires, "All APLHGRs shall be less than or equal to the limits specified in the COLR," and ITS SR 3.2.1.1 requires verification that "all APLHGRs are less than or equal to the limits specified in the COLR." Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.3, "Core Operating Limits Report." ITS 5.6.3 ensures the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits) of the safety analysis are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the Technical Specifications.

LA.3 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.11 .A states that if at any time during power operation it is determined that the APLHGR limiting condition for operation is being exceeded, "action shall be initiated within 15 minutes to restore operation to within the prescribed limits." ITS 3.2.1 does not include this 15 minute action.

This changes the CTS by relocating the procedural detail that "action shall be initiated within 15 minutes to restore operation to within the prescribed limits" to the Bases in the form of a discussion that "prompt action should be taken to restore the APLHGR(s) to within the required limits."

The removal of this detail for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to restore the APLHGRs to within limits in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , consistent with the CTS actions. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly Monticello Page 3 of 4 Attachment 1, Volume 7, Rev. 0, Page 9 of 73

Attachment 1, Volume 7, Rev. 0, Page 10 of 73 DISCUSSION OF CHANGES ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.11.A requires the APLHGR to be determined daily during reactor operation at > 25% rated thermal power. ITS SR 3.2.1.1 requires the same verification "once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 25% RTP and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter." This changes the CTS by allowing the reactor to reach and exceed a THERMAL POWER level of 25% RTP without completing the Surveillance.

The purpose of CTS 4.11.A is to ensure all APLHGRs are within limits before THERMAL POWER is > 25% RTP. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of fuel reliability. This change allows the plant to increase THERMAL POWER > 25% RTP without completing the Surveillance. However, after 25% RTP is achieved the verification must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Monticello Page 4 of 4 Attachment 1, Volume 7, Rev. 0, Page 10 of 73

Attachment 1, Volume 7, Rev. 0, Page 11 of 73 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 11 of 73

Attachment 1, Volume 7, Rev. 0, Page 12 of 73 APLHGR 3.2.1 CTS 3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) 3.11A LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR.

3.11A APPLICABILITY: THERMAL POWER 2 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.11A A. Any APLHGR not within A.1 Restore APLHGR(s) to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. within limits.

3.11A B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to < 25% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.11A SR 3.2.1.1 Verify all APLHGRs are less than or equal to the Once within limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 25% RTP AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter BWR/4 STS 3.2.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 12 of 73

Attachment 1, Volume 7, Rev. 0, Page 13 of 73 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

None Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 13 of 73

Attachment 1, Volume 7, Rev. 0, Page 14 of 73 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 14 of 73

Attachment 1, Volume 7, Rev. 0, Page 15 of 73 APLHGR B 3.2.1 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

BASES BACKGROUND The APLHGR is a measure of the average LHGR of all the fuel rods in a Ine fuel assembly at any axialrlocation. Limits on the APLHGR are specified (

to ensure that the fuel design limits identified in Reference 1 are not exceeded during anticipated operational occurrences (AOOs) and that the peak cladding temperature (PCT) during the postulated design basis loss of coolant accident (LOCA) does not exceed the limits specified in 10 CFR 50.46.

APPLICABLE The analytical methods and assumptions used in evaluating the fuel SAFETY design limits are presented in References I and 2. The analytical ANALYSES methods and assumptions used in evaluating Design Basis Accidents (DBAs), anticipated operational transients, and normal operation that determine the APLHGR limits are presented in References 1, 2, 3, 4, 5, 6, 10a I.

d . IO 7, 8, 9, and in Fuel design evaluations are performed to demonstrate that the 1% limit on the fuel cladding plastic strain and other fuel design limits described in Reference 1 are not exceeded during AOOs for operation with LHGRs up to the operating limit LHGR. IAP nits are equivalent 19theRGR Ilimitfreach fuel rod div~id te local peaking fakpopoe fuel 0 asembly. APLHGR limits are developed as a function of exposure and the various operating core flow and power states to ensure adherence to (3

fuel design limits during the limiting AOOs (Refs. A,6E*nd 7J. Flow 0 dependent APLHGR limits are determined using the three dimensional FW1 BWR simulator code (Reft0 to analyze slow flow runout transients. The flow dependent multiplier, MAPFACf, is dependent on the maximum core 0

flow runout capability. The maximum runout flow is dependent on the existing setting of the core flow limiter in the Recirculation Flow Control System.

Based on analyses of limiting plant transients (other than core flow increases) over a range of power and flow conditions, power dependent multipliers, MAPFACp, are also generated. Due to the sensitivity of the transient response to initial core flow levels at power levels below those at which turbine stop valve closure and turbine control valve fast closure scram trips are bypassed, both high and low core flow MAPFACp limits are provided for operation at power levels between 25% RTP and the previously mentioned bypass power level. The exposure dependent APLHGR limits are reduced by MAPFACp and MAPFACf at various operating conditions to ensure that all fuel design criteria are met for normal operation and AOOs. A complete discussion of the analysis code is provided in Referenced {I (i)

BWRI4 STS B 3.2.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 15 of 73

Attachment 1, Volume 7, Rev. 0, Page 16 of 73 APLHGR

{ All changes are '1' unless otherwise noted } B 3.2.1 BASES APPLICABLE SAFETY ANALYSES (continued)

LOCA analyses are then performed to ensure that the above determined APLHGR limits are adequate to meet the PCT and maximum oxidation limits of 10 CFR 50.46. The analysis is performed using calculational models that are consistent with the requirements of 10 CFR 50, A ~endix K. A complete discussion of the analysis code is provided in Referenced. The PCT following a postulated LOCA is a function of the average heat generation rate of all the rods of a fuel assembly at any axial location and is not strongly influenced by the rod to rod power distribution within an assembly [The AP limits specifi equivIl e LHGR of the hig powered fue assumed in the]

A analysis divided bv itsal eakin factor. A conservative multiplier is applied to the LHGR assumed in the LOCA analysis to account for the uncertainty associated with the measurement of the APLHGR. l 14-1 For singl recirculation loop operation, the MAPFAC multiplier is limited to a maximum (R . This maximum limit is due to the conservative analysis assumption of an earlier departure from nucleate boiling with one recirculation loop available, resulting in a more severe cladding heatup during a LOCA. foreach tope offuel as a function of average The APLHGR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii). planarexposure LCO The APLHGR limits specified in the COLRlare the result of the fuel design, DBA, and transient analyses. For two recirculation loops operating, the limit is determined by multiplying the smaller of the MAPFACp and MAPFACf factors times the exposure dependent APLHGR limits. With only one recirculation loop in operation, in conformance with the requirements of LCO 3.4.1, "Recirculation Loops Operating," the limit 0.80and0.

rINS ERT2 is determined by multiplying the exposure dependent APLHGR limit b r; the smaller of either MAPFACp, MAPFACfj , where (D-1 eenetermined by a specific sing e recirculation loop analysis (Ref. 5).

APPLICABILITY The APLHGR limits are primarily'derived from fuel design evaluations and LOCA and transient analyses that are assumed to occur at high power LI Te-vels. Design calculations (-R-ef) and operating experience have shown that as power is reduced, the margin to the required APLHGR NEDO-30492.P limits increases. This trend continues down to the power range of 5% to 15% RTP when entry into MODE 2 occurs. When in MODE 2, the intermediate range monitor scram function provides prompt scram initiation during any significant transient, thereby effectively removing any APLHGR limit compliance concern in MODE 2. Therefore, at THERMAL POWER levels < 25% RTP, the reactor is operating with substantial margin to the APLHGR limits; thus, this LCO is not required.

BWR/4 STS B 3.2.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 16 of 73

Attachment 1, Volume 7, Rev. 0, Page 17 of 73 B 3.2.1 Q3 INSERT 1 0.80 for GE11 and GE12 fuel and 0.90 for GE14 fuel Q INSERT 2 0.80 for GE11 and GE12 fuel and 0.90 for GE14 fuel Insert Page B 3.2.1-2 Attachment 1, Volume 7, Rev. 0, Page 17 of 73

Attachment 1, Volume 7, Rev. 0, Page 18 of 73 APLHGR B 3.2.1 BASES ACTIONS A.1 If any APLHGR exceeds the required limits, an assumption regarding an initial condition of the DBA and transient analyses may not be met.

Therefore, prompt action should be taken to restore the APLHGR(s) to within the required limits such that the plant operates within analyzed conditions and within design limits of the fuel rods. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is sufficient to restore the APLHGR(s) to within its limits and is acceptable based on the low probability of a transient or DBA occurring simultaneously with the APLHGR out of specification.

B.1 If the APLHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought toga MODE or Q other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 2 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

They are compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

REFERENCES ;i E-2401 1-P-A "General Electric Standard Application for Reactor 0 Fuel" (latest a E d version -(revision specified In FTUlLSpecificabon 5.6.3) Xx BAR, Chapter SAR R[6 B ,TS B 321-3 140 Rev. 3.0, 03/3/ion 4.S AR,l Chaptdir [15] 6. U, Chapter 14A 3

15. [Plant spegfc s-tnloop o eain. ~i

16. (Plant spegih limit analyi]

BWR/4 STS B 3.2.1-3 Rev. 3.0, 03131/04 Attachment 1, Volume 7, Rev. 0, Page 18 of 73

Attachment 1, Volume 7, Rev. 0, Page 19 of 73 B 3.2.1 Q INSERT 3

7. NEDE-23785-P (A)Revision 1, "The GESTR-LOCA and SAFER Models for Evaluation of the Loss-of-Coolant Accident (Volume ll), SAFER/GESTR Application Methodology," October 1984.

Q INSERT 4

8. NEDC-30515, "GE BWR Extended Load Line Limit Analysis for Monticello Nuclear Generating Plant, Cycle 11," March 1984.

9. NEDC-31849P, including Supplement 1, "Maximum Extended Load Line Limit Analysis for Monticello Nuclear Generating Plant Cycle 15," June 1992.

Insert Page B 3.2.1-3 Attachment 1, Volume 7, Rev. 0, Page 19 of 73

Attachment 1, Volume 7, Rev. 0, Page 20 of 73.

APLHGR B 3.2.1 BASES REFERENCES (continued) N e-Monitor, Rod Block Monitor

7. [Plant Specific Average Powegr and Technical Spec improvements (ARTS) Program]. 0 NEDO-30130-A, "Steady State Nuclear Methods," May 1985.

NEDO-24154, 'Qualification of the One-Dimensional Core Transient Model for Boiling Water Reactors," October 1978 110. [Plant specifijE:f]Jos6ntacdt anavil 0 BWR/4 STS B 3.2.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 20 of 73

Attachment 1, Volume 7, Rev. 0, Page 21 of 73 B 3.2.1 10.

Q INSERT 5 NEDC-30492-P, "Average Power Range Monitor, Rod Block Monitor and Technical Specification Improvement (ARTS) Program for Monticello Nuclear Generating Plant," April 1984.

Q INSERT 6

13. GE-NE-187-02-0392, "Monticello Nuclear Generating Plant SAFER/GESTR-LOCA Analysis Basis Documentation," July 1993.

14. Supplemental Reload Licensing Report for Monticello Nuclear Generation Plant (version specified in the COLR).

Insert Page B 3.2.1-4 Attachment 1, Volume 7, Rev. 0, Page 21 of 73

Attachment 1, Volume 7, Rev. 0, Page 22 of 73 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The brackets are removed and the proper plant specific Information/value is provided.

3. Typographical/grammatical error corrected.

4. Editorial change made for clarity.

Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 22 of 73

Attachment 1, Volume 7, Rev. 0, Page 23 of 73 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 23 of 73

Attachment 1, Volume 7, Rev. 0, Page 24 of 73 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 24 of 73

Attachment 1, Volume 7, Rev. 0, Page 25 of 73 ATTACHMENT 2 ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Attachment 1, Volume 7, Rev. 0, Page 25 of 73

Attachment 1, Volume 7, Rev. 0, Page 26 of 73 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 7, Rev. 0, Page 26 of 73

C C C ITS ITS 2.0 UMITING CONDITIONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS C. Minimum Criftial PoWer Ratio LMCPRE SR C.

LCO 3.2.2 Al MCPRs shal be greater than or equal to the MCPR SR 0 5 Operating limits provided In the Core Operating Umits 3.2.2.1 0 Report.

b 0

-4 I. tadd proposed Rpplloilmty I If at any time during operation h Is determined that the 0 0

-o 0

ACTION A {

IImiting value for MCPR Is being exceelded lion al be Initia6d within 15 rninutes to esro ahin Ilia owmsrbed lirnSu ation l 0 d Add orooosed ITS SR 322.2 1 l--

-~~

rD (D

0 oeran sescibedi a aion s the continue until eaclo lmits I the steady state MCPR is not returned to wtthin the prescribed limits within two hoursrreduce thermal power to less 0 -4 ACTION B -a 2i win tenext four hours.

r- 0 tD 0 -4

-U 0

a 0-C' CD

-4

-4 213 9128/89 3.11/4.11 The next page Is 216 Amendment No.43.54 70, 99 Page 1 of 1

Attachment 1, Volume 7, Rev. 0, Page 28 of 73 DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.11.C does not state when the MCPR LCO is required to be met, however CTS 3.11 .C states "reduce thermal power to less than 25%" if the limiting value for MCPR is being exceeded and the MCPR is not returned to within limits within the specified time. ITS LCO 3.2.2 is applicable at THERMAL POWER

> 25% RTP. ITS 3.2.2 ACTION B requires a THERMAL POWER reduction to

< 25% RTP if the MCPR(s) are not restored to within limits within specified time limit of ACTION A. This changes the CTS by clearly specifying the Applicability as > 25% RTP.

The purpose of the CTS 3.11.C is to ensure the MCPRs are within limits when required. This changes the CTS by adding the explicit Applicability of "THERMAL POWER > 25% RTP." This change is acceptable because at THERMAL POWER levels < 25% RTP the reactor is operating with substantial margin to the MCPR limits. For this reason there is no need to monitor MCPRs when THERMAL POWER is < 25% RTP. This is also consistent with the Surveillance Frequency in CTS 4.11.C, which states to monitor MCPR at

> 25% rated thermal power. This change states the Applicability consistent with the CTS default action and Surveillance Frequency. Therefore, this change is considered a presentation preference change only and, as such, is considered an administrative change.

A.3 CTS 3.11.C states "Surveillance and corresponding action shall continue until reactor operation is within the prescribed limits." ITS 3.2.2 does not include this statement. This changes the CTS by deleting this statement.

The purpose of this CTS 3.11.C statement is to identify the importance of monitoring the MCPRs to verify they are restored to prescribed limits. After the MCPRs are within limits, it is obvious that the action can be exited. This change is acceptable because ITS LCO 3.0.1 and LCO 3.0.2 have been added to the Technical Specifications as described in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.1 states "LCOs shall be met during the MODES or other specified conditions in the Applicability," and LCO 3.0.2 states "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met" and "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required." The CTS 3.11.C guidance is provided in the ITS generic guidelines of LCO 3.0.1 and LCO 3.0.2. In addition, the only way to confirm the MCPRs have been restored to within limits and the LCO is being met is to perform a Surveillance; thus, it is not necessary to be specifically stated.

Monticello Page 1 of 4 Attachment 1, Volume 7, Rev. 0, Page 28 of 73

Attachment 1, Volume 7, Rev. 0, Page 29 of 73 DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Therefore, this change is considered a presentation preference change only and, as such, is considered an administrative change.

MORE RESTRICTIVE CHANGES M.1 CTS 4.11 .C does not specify a Surveillance Requirement to determine the MCPR limits after completion of scram time testing. ITS SR 3.-2.2.2 requires the determination of the MCPR limits once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.1, once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.2, and once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.4 (scram time testing Surveillances). This changes the CTS by adding ITS SR 3.2.2.2 to the Technical Specifications.

The purpose of ITS SR 3.2.2.2 is to determine the MCPR limits after performance of the scram time tests, since scram times can affect the MCPR limit. This change is acceptable because the transient analysis is allowed to take credit for conservatism in the scram speed performance, thus it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis. ITS SR 3.2.2.2 determines the value of x, which is a measure of the actual scram speed distribution compared with the assumed distribution. The MCPR operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4, "Control Rod Scram Times") and Option B (realistic scram times) analyses. The parameter Xmust be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1, SR 3.1.4.2, and SR 3.1.4.4 because the effective scram speed distribution may change during the cycle or after maintenance that could affect scram times. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due to the relatively minor changes in Xexpected during the fuel cycle. This change is more restrictive because it adds a Surveillance Requirement that prescribes explicit requirements to determine MCPR limits at the specified times.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.11 .C states that if at any time during power operation it is determined that the limiting value for MCPR is being exceeded, "action shall be initiated within 15 minutes to restore operation to within the prescribed limits." ITS 3.2.2 does not include this 15 minute action. This changes the CTS by relocating the procedural detail that "action shall be initiated within 15 minutes to restore operation to within the prescribed limits" to the Bases in the form of a discussion that "prompt action should be taken to restore the MCPR(s) to within the required limits."

Monticello Page 2 of 4 Attachment 1, Volume 7, Rev. 0, Page 29 of 73

Attachment 1, Volume 7, Rev. 0, Page 30 of 73 DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

The removal of this detail for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to restore the MCPRs to within limits in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , consistent with the CTS actions. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.11.C requires the MCPR to be determined daily during reactor operation at > 25% rated thermal power. ITS SR 3.2.2.1 requires the same verification 'once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 25% RTP and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter." This changes the CTS by allowing the reactor to reach and exceed a THERMAL POWER level of 25% RTP without completing the Surveillance.

The purpose of CTS 4.11.C is to ensure all MCPRs are within limits before THERMAL POWER is > 25% RTP. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of fuel reliability. This change allows the plant to increase THERMAL POWER > 25% RTP without completing the Surveillance. However, after 25% RTP is achieved the verification must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels: This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L.2 (Category 7- Relaxation Of-Surveillance Frequency, Non-24 Month Type Change) CTS 4.11 .C states MCPR shall be determined daily and "following any change in power level or distribution which has the potential of bringing the core to its operating MCPR." ITS SR 3.2.2.1 requires a similar daily verification, but does not include the additional Frequency based on a change in power level or distribution. This changes the CTS by deleting the requirement to verify MCPRs are within limits "following any change in power level or distribution which has the potential of bringing the core to its operating MCPR."

The purpose of the above described CTS 4.11.C Surveillance Frequency is to ensure MCPR is within limits when there is a potential for bringing the core to its operating MCPR limit. This change is acceptable because the new Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of fuel reliability. This condition is unlikely and the Surveillance would seldom be required. Therefore, the Surveillance Frequency has been deleted. This change Monticello Page 3 of 4 Attachment 1, Volume 7, Rev. 0, Page 30 of 73

Attachment 1, Volume 7, Rev. 0, Page 31 of 73 DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR) is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Monticello Page 4 of 4 Attachment 1, Volume 7, Rev. 0, Page 31 of 73

Attachment 1, Volume 7, Rev. 0, Page 32 of 73

.5-Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 32 of 73

Attachment 1, Volume 7, Rev. 0, Page 33 of 73 MCPR 3.2.2 MTS 3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR) 3.11.C LCO 3.2.2 All MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR.

3.11.C APPLICABILITY: THERMAL POWER 2 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.11.c A. Any MCPR not within A.1 Restore MCPR(s) to within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. limits.

-4 4 3.11.C B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to < 25% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.11.C SR 3.2.2.1 Verify all MCPRs are greater than or equal to the Once within limits specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 25% RTP AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter BWR/4 STS 3.2.2-1 Rev. 3.0, 03/31/04 Attachment 1,Volume 7, Rev. 0, Page 33 of 73

Attachment 1, Volume 7, Rev. 0, Page 34 of 73 MCPR 3.2.2 CTS SURVEILLANCE REQUIREMENTS (continued) .

SURVEILLANCE FREQUENCY I-DOC MA1 SR 3.2.2.2 Determine the MCPR limits. Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.1 AND Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.2 AND Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.4 BWR/4 STS 3.2.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 34 of 73

Attachment 1, Volume 7, Rev. 0, Page 35 of 73 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

None Monticello Page I of I Attachment 1, Volume 7, Rev. 0, Page 35 of 73

Attachment 1, Volume 7, Rev. 0, Page 36 of 73 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 36 of 73

Attachment 1, Volume 7, Rev. 0, Page 37 of 73 MCPR B 3.2.2 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

BASES BACKGROUND MCPR is a ratio of the fuel assembly power that would result in the onset oIfboilingl to the actual fuel assembly power. The MCPR Safety Limit (SL) is set such that 99.9% of the fuel rods avoid'bo ing I the limit is not violated (refer to the Bases for SL 2.1.1 he operating ()

limit MCPR is established to ensure that no fuel damage results during anticipated operational occurrences (AOOs). Although fuel damage does not necessarily occur if a fuel rod actually experiencedfboilingltransitior (Ref. 1), the critical power at whichfboilingltransitiorl is calculated to occur has been adopted as a fuel design criterion.

The onset of transition boiling is a phenomenon that is readily detected during the testing of various fuel bundle designs. Based on these experimental data, correlations have been developed to predict critical bundle power (i.e., the bundle power level at the onset of transition boiling) for a given set of plant parameters (e.g., reactor vessel pressure, flow, and subcooling). Because plant operating conditions and bundle power levels are monitored and determined relatively easily, monitoring the MCPR is a convenient way of ensuring that fuel failures due to

~inadequate cooling do not occur.

APPLICABLE \Teanalytical methods and assumptions used in evaluating the A00sto SAFETY \etbihthe operating limit MCPR are presented in References 2,3, 4, ANALYSES 5, 67, a 8 To ensure that the MCPR SL is not exceeded during any 0 transient event that occurs with moderate frequency, limiting transients have been analyzed to determine the largest reduction in critical power ratio (CPR). The types of transients evaluated are loss of flow, increase in pressure and power, positive reactivity insertion, and coolant temperature decrease. The limiting transient yields the largest change in CPR (ACPR). When the largest ACPR is added to the MCPR SL, the required operating limit MCPR is obtained.

a78,9,and10 The MCPR operating limits derived from the transient analysis are dependent on the operating core flow and power state (MCPRf and MCPRp, respectively) to ensure adherence to fuel design limits during the worst transient that occurs with moderate frequency (Refs. n .

Flow dependent MCPR limits are determined by steady state thermal r hydraulic methods with key physics response inputs benchmarked using l the three dimensional BWR simulator code (Ref.rto analyze slow flow (0 runout transients. The operating limit is dependent on the maximum core flow limiter setting in the Recirculation Flow Control System.

BWR/4 STS B 3.2.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 37 of 73

Attachment 1, Volume 7, Rev. 0, Page 38 of 73 MCPR B 3.2.2 BASES APPLICABLE SAFETY ANALYSES (continued)

Power dependent MCPR limits (MCPRp) are determined mainly by the one dimensional transient code (RefR. Due to the sensitivity of the Q transient response to initial core flow levels at power levels below those at which the turbine stop valve closure and turbine control valve fast closure scrams are bypassed, high and low flow MCPRp operating limits are provided for operating between 25% RTP and the previously mentioned bypass power level.

The MCPR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The MCPR operating limits specified in the COLR are the result of the Design Basis Accident (DBA) and transient analysis. The operating limit MCPR is determined by the larger of the MCPRf and MCPRp limits.

APPLICABILITY The MCPR operating limits are primarily derived from transient analyses that are assumed to occur at high power levels. Below 25% RTP, the reactor is operating at a iJm 1,ecirculation pump speed and the K moderator void ratio is small. Surveillance of thermal limits below 25% RTP is unnecessary due to the large inherent margin that ensures that the MCPR SL is not exceeded even if a limiting transient occurs.

Statistical analyses indicate that the nominal value of the initial MCPR expected at 25% RTP is > 3.5. Studies of the variation of limiting transient behavior have been performed over the range of power and flow conditions. These studies encompass the range of key actual plant parameter values important to typically limiting transients. The results of these studies demonstrate that a margin is expected between performance and the MCPR requirements, and that margins increase as power is reduced to 25% RTP. This trend is expected to continue to the 5%o 15% power range when entry into MODE 2 occurs. When in M t eeprovide rapid scram initiation Q for any significant power increase transient; which effectively eliminates any MCPR compliance concern. Therefore, at THERMAL POWER levels

< 25% RTP, the reactor is operating with substantial margin to the MCPR limits and this LCO is not required.

ACTIONS A.1 If any MCPR is outside the required limits, an assumption regarding an initial condition of the design basis transient analyses may not be met.

Therefore, prompt action should be taken to restore the MCPR(s) to within the required limits such that the plant remains operating within analyzed conditions. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is normally sufficient to restore the MCPR(s) to within its limits and is acceptable based on the low probability of a transient or DBA occurring simultaneously with the MCPR out of specification.

BWR/4 STS B 3.2.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 38 of 73

Attachment 1, Volume 7, Rev. 0, Page 39 of 73 MCPR B 3.2.2 BASES ACTIONS (continued)

B.1 If the MCPR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The MCPR is required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 2 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

SR 3.2.2.2 Because the transient analysis takes credit for conservatism in the scram speed performance, it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis.

SR 3.2.2.2 determines the value of r, which is a measure of the actual scram speed distribution compared with the assumed distribution. The MCPR operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4, "Control Rod Scram Times") and Option B (realistic scram times) analyses. The parameter Xmust be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1, SR 3.1.4.2, and SR 3.1.4.4 because the effective scram speed distribution may change during the cycle or after maintenance that could affect scram times. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due to the relatively minor changes in Xexpected during the fuel cycle.

BWR/4 STS B 3.2.2-3 Rev. 3.0, 03131/04 Attachment 1, Volume 7, Rev. 0, Page 39 of 73

Attachment 1, Volume 7, Rev. 0, Page 40 of 73 MCPR B 3.2.2 BASES REFERE NCES 1. NUREG-0562, June 1979.

i2~-2401 1-P-A, "General Electric Standard Application for Reactor 0 Fuel"r(latest apepred version revision specfied I

/hlSAR,C Section 6.2.6 TSA~~R, @

5. AR, Chapter s 6.UAChpe 4.

16.

44

[Plant spepl-- elop operatin] 3 17- [Plant spedRsidfine limit analyss

8. [Plant specific Average Power onitor, Rod Block Monitor and Technical Spe provements (ARTS) Program].

NEDO-30130-A, "Steady State Nuclear Methods," May 1985. 0

'l. NEDO-24154, "Qualification of the One-Dimensional Core Transient Model for Boiling Water Reactors," October 1978.

BWR/4 STS B 3.2.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 40 of 73

Attachment 1, Volume 7, Rev. 0, Page 41 of 73 B 3.2.2

( 2 INSERT 1

7. NEDE-23785-P (A), Revision 1, 'The GESTR-LOCA and SAFER Models for Evaluation of the Loss-of-Coolant Accident (Volume ll), SAFER/GESTR Application Methodology," October 1984.

O_ INSERT 2

8. NEDC-30515, -GE BWR Extended Load Line Limit Analysis for Monticello Nuclear Generating Plant, Cycle 11," March 1984.

9.. NEDC-31849P, including Supplement 1, "Maximum Extended Load Line Limit Analysis for Monticello Nuclear Generating Plant Cycle 15," June 1992.

10.

Q INSERT 3 NEDC-30492-P, "Average Power Range Monitor, Rod Block Monitor and Technical Specification Improvement (ARTS) Program for Monticello Nuclear Generating Plant," April 1984.

Insert Page B 3.2.2-4 Attachment 1, Volume 7, Rev. 0, Page 41 of 73

Attachment 1, Volume 7, Rev. 0, Page 42 of 73 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2 BASES, MINIMUM CRITICAL POWER RATIO (MCPR)

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The brackets are removed and the proper plant specific information/value is provided.

3. Typographical/grammatical error corrected.

4. Editorial change made for clarity.

5. Changes made to be consistent with changes made to the Specification.

Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 42 of 73

Attachment 1, Volume 7, Rev. 0, Page 43 of 73 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 43 of 73

Attachment 1, Volume 7, Rev. 0, Page 44 of 73 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

There are no specific NSHC discussions for this Specification.

Monticello Page 1 of I Attachment 1, Volume 7, Rev. 0, Page 44 of 73

Attachment 1, Volume 7, Rev. 0, Page 45 of 73 ATTACHMENT 3 ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Attachment 1, Volume 7, Rev. 0, Page 45 of 73

Attachment 1, Volume 7, Rev. 0, Page 46 of 73 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 7, Rev. 0, Page 46 of 73

C C ITS 3.2.3 ITS ITS 3.0 IUMING CONDmONS FOR OPERATION 4.0 SURVEILLANCE REQUIREMENTS If at any time during power operation, it Is determined that the APLHGR limiting condition for operation Is being exceeded, action shall be InitIated within 15 minutes to C,

restore operation to within the prescribed limits.

SurveIllance and corresponding action shall continue See ITS3.2.1 } W 0i

0) until reactor operation Is within the prescribed limits. If El the APLHGR Is not returned to within the prescribed limits within two hours, reduce thermal power to less 0 0 than 25% within the next four hours.

B. LUnear Heat Generation Rate (MHGM1 B. Linear Heat Generation Rate G Add proposed SR 3.2.3.1 first Frequency 7) 0 LCO 3.2.3 During power o ration the LHGR shall be less than or SR 3.2.3.1 The LHGR shall be checked iy during reactor equal to the limis specified In the Core Operating Umits operation at 225% of rated thermal power.

Report. 0 r If at any time during operation it Is determined that the

-4 0)

ACTION l limiting value for LHGR Is bei exceedai ABWA hfated within 15 minutes torestore o eratlo within te prescribed lmitsurvelace oresqing action shcontInue until cto hil

-o -o 0

peratlIns within the p m iteI GR is not returned to within the prescribed limits within 2 to

-.4 MhouirsJeduc thermal power to less than 25% within the ACTION B 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CD ED CA) 0

-a CA) 3.11/4.11 212 216100 Amendment No. 43r54r70r 109 Page 1 of 1

Attachment 1, Volume 7, Rev. 0, Page 48 of 73 DISCUSSION OF CHANGES ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

ADMINISTRATIVE CHANGES A.1 In the conversion of the Monticello Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 3, "Standard Technical Specifications General Electric Plants, BWR/4" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A.2 CTS 3.11.B states that the LHGR should not exceed limits during "power operation," which is defined in CTS 1.0.0 as "above 1% rated thermal power."

However, CTS 3.11.B only states to reduce THERMAL POWER to "less than 25%" if the limiting values for LHGR is being exceeded and the LHGRs are not returned to within limits within the specified time. ITS LCO 3.2.3 is applicable at THERMAL POWER > 25% RTP. ITS 3.2.3 ACTION B requires a THERMAL POWER reduction to < 25% RTP if the LHGR(s) are not restored to within limits within the specified time limit of ACTION A. This changes the CTS by changing the Applicability from > 1% RATED THERMAL POWER > 25% RTP.

The purpose of the CTS 3.11.B is to ensure the LHGRs are within limits when required. This changes the CTS by changing the Applicability from "power operation" to "> 25% RTP." This change is acceptable since at THERMAL POWER levels < 25% RTP the reactor is operating with substantial margin to the LHGR limits. For this reason there is no need to monitor LHGRs when THERMAL POWER < 25% RTP. This is also consistent with the Surveillance Frequency in CTS 4.11.B, which states to monitor LHGR at > 25% RATED THERMAL POWER. This change simply aligns the Applicability with the CTS default action and Surveillance Frequency. Therefore, this change is considered a presentation preference change only and, as such, is considered an administrative change.

A.3 CTS 3.11.8 states "Surveillance and corresponding action shall continue until reactor operation is within the prescribed limits." ITS 3.2.3 does not include this statement. This changes the CTS by deleting this statement.

The purpose of this CTS 3.11.B statement is to identify the importance of monitoring the LGHRs to verify they are restored to prescribed limits. After they are within limits, it is obvious that the action can be exited. ITS LCO 3.0.1 and LCO 3.0.2 have been added to the Technical Specifications as indicated in the Discussion of Changes for ITS Section 3.0. ITS LCO 3.0.1 states " LCOs shall be met during the MODES or other specified conditions in the Applicability," and LCO 3.0.2 states "Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met" and "If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s),

completion of the Required Action(s) is not require." The CTS 3.11.8 guidance is provided in the ITS generic guidelines of LCO 3.0.1 and LCO 3.0.2. In addition, the only way to confirm the LHGRs have been restored to within limits is to perform a Surveillance; thus, it is not necessary to be specifically stated.

Monticello Page 1 of 3 Attachment 1, Volume 7, Rev. 0, Page 48 of 73

Attachment 1, Volume 7, Rev. 0, Page 49 of 73 DISCUSSION OF CHANGES ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Therefore, this change is considered a presentation preference change only and, as such, is considered an administrative change.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA.1 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.11 .B states that if at any time during power operation it is determined that the limiting value for LHGR limiting condition for operation is being exceeded, "action shall be initiated within 15 minutes to restore operation to within the prescribed limits." ITS 3.2.3 does not include this 15 minute action. This changes the CTS by relocating the procedural detail that "action shall be initiated within 15 minutes to restore operation to within the prescribed limits" to the Bases in the form of a discussion that "prompt action should be taken to restore the LHGR(s) to within the required limits."

The removal of this detail for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to restore the LHGRs to within limits in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , consistent with the CTS actions. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because a procedural detail for meeting Technical Specification requirements is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L.1 (Category 7- Relaxation Of Surveillance Frequency, Non-24 Month Type Change) CTS 4.11 .B requires the LHGR to be determined daily during reactor operation at > 25% rated thermal power. ITS SR 3.2.3.1 requires the same verification "once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 25% RTP and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter." This changes the CTS by allowing the reactor to reach and exceed a THERMAL POWER level of 25% RTP without completing the Surveillance.

The purpose of CTS 4.11.B is to ensure all LHGRs are within limits before THERMAL POWER is > 25% RTP. This change is acceptable because the new Monticello Page 2 of 3 Attachment 1, Volume 7, Rev. 0, Page 49 of 73

Attachment 1, Volume 7, Rev. 0, Page 50 of 73 DISCUSSION OF CHANGES ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of fuel reliability. This change allows the plant to increase THERMAL POWER > 25% RTP without completing the Surveillance. However, after 25% RTP is achieved the verification must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels. This change Is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Monticello Page 3 of 3 Attachment 1, Volume 7, Rev. 0, Page 50 of 73

Attachment 1,Volume 7, Rev. 0, Page 51 of 73 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 51 of 73

Attachment 1, Volume 7, Rev. 0, Page 52 of 73 LHGR 0 nal 3.2.3 Q

3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) (Op* nal) 0 3.11.6 LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

3.11.6 APPLICABILITY: THERMAL POWER 2 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.11.B A. Any LHGR not within A.1 Restore LHGR(s) to within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limits. limits.

3.11.B B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion POWER to < 25% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.11.6 SR 3.2.3.1 Verify all LHGRs are less than or equal to the limits Once within specified in the COLR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 2 25% RTP AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter BWR/4 STS 3.2.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 52 of 73

Attachment 1, Volume 7, Rev. 0, Page 53 of 73 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

1. This reviewer's type of note has been deleted. This is not meant to be retained in the final version of the plant specific submittal.

Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 53 of 73

Attachment 1, Volume 7, Rev. 0, Page 54 of 73 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 54 of 73

Attachment 1, Volume 7, Rev. 0, Page 55 of 73 LHGR 0O(nal B 3.2.3 Q

B 3.2 POWER DISTRIBUTION LIMITS B 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) (Op* nal) 0 BASES BACKGROUND The LHGR is a measure of the heat generation rate of a fuel rod in a fuel assembly at any axiaIl'Iocation. Limits on LHGR are specified to ensure that fuel design limits are not exceeded anywhere in the core during 0D normal operation, including anticipated operational occurrences (AOOs).

Exceeding the LHGR limit could potentially result in fuel damage and subsequent release of radioactive materials. Fuel design limits are specified to ensure that fuel system damage, fuel rod failure, or inability to cool the fuel does not occur during the anticipated operating conditions 4

identified in Reference 1.

0 APPLICABLE The analytical methods and assumptions used in evaluating the fuel SAFETY system design are presented in References I and 2. The fuel assembly ANALYSES is designed to ensure (in conjunction with the core nuclear and thermal hydraulic design, plant equipment, instrumentation, and protection system) that fuel damage will not result in the release of radioactive materials in excess of the guidelines of 10 CFR, Parts 20, 50, and 100.

The mechanisms that could cause fuel damage during operational transients and that are considered in fuel evaluations are:

a. Rupture of the fuel rod cladding caused by strain from the relative expansion of the U0 2 pelletand

b. Severe overheating of the fuel rod cladding caused by inadequate cooling.

A value ofM1°/1J plastic strain of the fuel cladding has been defined as the limit below which fuel damage caused by overstraining of the fuel 0

cladding is not expected to occur (Ref. 3).

0D Fuel design evaluations have been performed and demonstrate that the gl VJJ fuel cladding plastic strain design limit is not exceeded during continuous operation with LHGRs up to the operating limit specified in the COLR. The analysis also includes allowances for short term transient operation above the operating limit to account for AOOs, plus an allowance for densification power spiking.

The LHGR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

BWR/4 STS B 3.2.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 55 of 73

Attachment 1, Volume 7, Rev. 0, Page 56 of 73 LHGR 0 nal B 3.2.3 0

BASES LCO The LHGR is a basic assumption in the fuel design analysis. The fuel has been designed to operate at rated core power with sufficient design margin to the LHGR calculated to cause a 1% fuel cladding plastic strain.

The operating limit to accomplish this objective is specified in the COLR.

APPLICABILITY The LHGR limits are derived from fuel design analysis that is limiting at high power level conditions. At core thermal power levels < 25% RTP, the reactor is operating with a substantial margin to the LHGR limits and, therefore, the Specification is only required when the reactor is operating at 2 25% RTP.

ACTIONS A.1 If any LHGR exceeds its required limit, an assumption regarding an initial condition of the fuel design analysis is not met. Therefore, prompt action should be taken to restore the LHGR(s) to within its required limits such that the plant is operating within analyzed conditions. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is normally sufficient to restore the LHGR(s) to within its limits and is acceptable based on the low probability of a transient or Design Basis Accident occurring simultaneously with the LHGR out of specification.

B.1 If the LHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER is reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER TO < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.3.1 REQUIREMENTS 3 lThY are The LHG F~reqirto be initially calculated within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter 8 THERMAL POWER is 2 25% RTP and then every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter. 0 E1compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slow changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 2 25% RTP is achieved is acceptable given the large inherent margin to operating limits at lower power levels.

BWR/4 STS B 3.2.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 56 of 73

Attachment 1, Volume 7, Rev. 0, Page 57 of 73 LHGR (Op* nal (

B 3.2.3 BASES REFERENCES 1. A,,S,[

I Chapter 14 0D SR Tn[ Chapter 3 )

0D

3. NUREG-0800, Section lI.A.2(g), Revision 2, July 1981.

BWR/4 STS B 3.2.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 57 of 73

Attachment 1, Volume 7, Rev. 0, Page 58 of 73 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, LINEAR HEAT GENERATION RATE (LHGR)

1. This reviewer's type of note has been deleted. This is not meant to be retained in the final version of the plant specific submittal.

2. The brackets are removed and the proper plant specific information/value is provided.

3. Changes are made (additions, deletions, and/or changes) to the ISTS Bases, which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

4. Change made to be consistent with the Specification.

5. Editorial change made for clarity.

6. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, NEI 01-03, Section 5.1.3.

Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 58 of 73

Attachment 1, Volume 7, Rev. 0, Page 59 of 73 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 0, Page 59 of 73

Attachment 1,Volume 7, Rev. 0, Page 60 of 73 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

There are no specific NSHC discussions for this Specification.

Monticello Page 1 of 1 Attachment 1,Volume 7, Rev. 0, Page 60 of 73

Attachment 1, Volume 7, Rev. 0, Page 61 of 73 ATTACHMENT 4 Improved Standard Technical Specifications (ISTS) not adopted in the Monticello ITS Attachment 1, Volume 7, Rev. 0, Page 61 of 73

Attachment 1, Volume 7, Rev. 0, Page 62 of 73 ISTS 3.2.4, Average Power Range Monitor (APRM) Gain and Setpoints Attachment 1, Volume 7, Rev. 0, Page 62 of 73

Attachment 1, Volume 7, Rev. 0, Page 63 of 73 ISTS 3.2.4 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 63 of 73

Attachment 1,Volume 7, Rev. 0, Page 64 of 73 APRM Gain a d Setpoints (Optional) 3.2.4 3.2 POWER ISTRIBUTION LIMITS 3.2.4 Av rage Power Range Monitor APRM) Gain and Setpoints ( ptional)

LCO 3.2.4 a. MFLPD shall b less than or equal to Fractio of RTP, or

b. Each required PRM setpoint specified in th COLR shall be made applicable, or

c. Each required PRM gain shall be adjusted uch that the APRM readings are 100% times MFLPD.

APPLICABI TY: THERMAL POWE 2 25% RTP.

ACTIONS C NDITION EQUIRED ACTION COMPLETION TIME

-o0 A. Requl ements of the A.1 Satisfy the requirements of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months LCO ot met.he LCO.

B. Requ red Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months asso iated Completion POWER to < 25% RTP.

Time not met.

BWRI4 STS 3.2.4-1 Rev. 3.0, 03/31/04 Attachment 1,Volume 7, Rev. 0, Page 64 of 73

, Volume 7, Rev. 0, Page 65 of 73 , Volume 7, Rev. 0, Page 65 of 73

Attachment 1, Volume 7, Rev. 0, Page 66 of 73 JUSTIFICATION FOR DEVIATIONS ISTS 3.2.4, AVERAGE POWER RANGE MONITOR (APRM) GAIN AND SETPOINTS

1. ISTS 3.2.4 has not been adopted since it is not applicable to Monticello. The requirements for Average Power Range Monitor (APRM) Gain and Setpoints have been previously deleted from the Monticello Technical Specifications as a result of License Amendment 29, dated November 16, 1984.

Monticello Page 1 of 1 Attachment 1, Volume 7, Rev. 0, Page 66 of 73

Attachment 1, Volume 7, Rev. 0, Page 67 of 73 ISTS 3.2.4 Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 0, Page 67 of 73

Attachment 1, Volume 7, Rev. 0, Page 68 of 73 APRM Gain a d Setpoints (Optional)

B 3.2.4 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.4 Avera e Power Range Monitor (A M) Gain and Setpoints (Opt onal)

BASES BACKGROU D The OPERABILITY f the APRMs and their setpoi ts is an initial condition of all safety analyse that assume rod insertion up n reactor scram.

Applicable GDCs ar GDC 10, "Reactor Design," DC 13, "Instrumentation an Control," GDC 20, "Protecti System Functions,"

and GDC 23, "Prote ion against Anticipated Ope ation Occurrences" (Ref. 1). This LCO provided to require the AP M gain or APRM flow biased scram setpo ts to be adjusted when ope ting under conditions of excessive power p king to maintain acceptable nargin to the fuel cladding integrity S fety Limit (SL) and the fuel cl dding 1% plastic strain limit.

The condition of e essive power peaking is det rmined by the ratio of the actual power peaking to the limiting power p aking at RTP. This ratio is equal to the rati of the core limiting MFLPD t the Fraction of RTP (FRTP), where FR P is the measured THERM POWER divided by the RTP. Excessive p wer peaking exists when:

MFLPD > 1l

-o0 FRTP indicating that MF PD is not decreasing propo ionately to the overall power reduction, r conversely, that power pea ing is increasing. To maintain margins similar to those at RTP condi ions, the excessive power peaking is comp nsated by a gain-adjustment n the APRMs or adjustment of th APRM setpoints. Either of t ese adjustments has effectively the sa e result as maintaining MF D less than or equal to FRTP and thus aintains RTP margins for AP HGR and MCPR.

The normally se cted APRM setpoints positi the scram above the upper bound of e normal power/flow operati g region that has been considered in t design of the fuel rods. Th setpoints are flow biased with a slope tha approximates the upper flow control line, such that an approximately nstant margin is maintained etween the flow biased trip level and the u per operating boundary for c re flows in excess of about 45% of rated c re flow; In the range of infre ent operations below 45%

of rated core fl , the margin to scram is red ced because of the nonlinear core w versus drive flow relation hip. The normally selected APRM setpoin are supported by the analy s presented in References 1 nd 2 that concentrate on eve ts initiated from rated conditions. De ign experience has shown t at minimum deviations occur within expecte margins to operating limits ( PLHGR and MCPR), at BWR/41STS I B 3.2.4-1 . I Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 68 of 73

Attachment 1, Volume 7, Rev. 0, Page 69 of 73 APRM Gain and petpoints (Optional)

BASES I BACKGROUI ND col tinued)

I I

/ B 3.2.4 rated conditions for no nnal power distributions. How ver, at other than rated conditions, contro rod patterns can be establis ed that significantly reduce the margin to th rmal limits. Therefore, the fl w biased APRM scram setpoints may b reduced during operation w en the combination of THERMAL POWER nd MFLPD indicates an exc ssive power peaking distribution.

The APRM neutron flu signal is also adjusted to m re closely follow the fuel cladding heat flux uring power transients. The APRM neutron flux signal is a measure of e core thermal power dunn steady state operation. During poer transients, the APRM sign i leads the actual core thermal power re ponse because of the fuel t rmal time constant.

Therefore, on power i crease transients, the APR signal provides a conservatively high nasure of core thermal powe By passing the APRM signal through an electronic filter with a tim constant less than, but approximately eqal to, that of the fuel thermal me constant, an APRM transient resp nse that more closely follow actual fuel cladding heat flux is obtained, while a conservative margin i maintained. The delayed response of he filtered APRM signal allos the flow biased APRM scram levels o be positioned closer to the pper bound of the

-o0 normal power and fl w range, without unnecessar y causing reactor scrams during short uration neutron flux spikes. hese spikes can be caused by insignifi nt transients such as perfo ance of main steam line valve surveillances r momentary flow increases f only several percent.

APPLICABL The acceptance crite Ha for the APRM gain or set oint adjustments are SAFETY that acceptable margins (to.APLHGR and MCPR be maintained to the ANALYSES fuel cladding integri y SL and the fuel cladding 1 plastic strain limit.

FSAR safety analy es (Refs. 2 and 3) concentra e on the rated power condition for which he minimum expected margi to the operating limits (APLHGR and MC R) occurs. LCO 3.2.1, "AV RAGE PLANAR LINEAR HEAT GENERATI N RATE (APLHGR)," and L 3.2.2, "MINIMUM CRITICAL POWE RATIO (MCPR)," limit the in tial margins to these operating limits at ated conditions so that speci ied acceptable fuel design limits are et during transients initiated om rated conditions. At initial power level less than rated levels, the m rgin degradation of either the APLHGR or t e MCPR during a transient n be greater than at the rated condition ev nt. This greater margin deg adation during the transient is prima ly offset by the larger initial nfargin to limits at the lower than rated power evels. However, power distri utions can be I

3WR/4 S I B 3.2.4-2 II Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 69 of 73

Attachment 1, Volume 7, Rev. 0, Page 70 of 73 l APRM Gain an Setpoints (Optional)

B 3.2.4 BASES APPLICABLE S FETY ANALYSES (contin d) hypothesized that wou d result in reduced margins t the pre-transient operating limit. When ombined with the increased everity of certain transients at other tharated conditions, the SLs co Id be approached.

At substantially redu dpower levels, highly peake power distributions could be obtained tha could reduce thermal margi to the minimum levels required for tra sient events. To prevent or itigate such situations, either the PRM gain is adjusted upwarv by the ratio of the core limiting MFLPD the FRTP, or the flow biase APRM scram level is required to be reduc I by the ratio of FRTP to the ore limiting MFLPD.

Either of these adjus ents effectively counters th, increased severity of some events at othe than rated conditions by pro ortionally increasing the APRM gain or pr portionally lowering the flow iased APRM scram l setpoints, dependen! on the increased peaking th t may be encountered.

l The APRM gain and setpoints satisfy Criteria 2 an 3 of 10 CFR 50.36(c)(2)(l LCO l Meeting any one of he following conditi ons ensur s acceptable operating margins for events escribed above:

a. Limiting exces power peaking,

b. Reducing the' PRM flow biased neutron flu upscale scram setpoints by m Itiplying the APRM setpoints by the ratio of FRTP and the core limiti value of MFLPD, or

c. Increasing AP M gains to cause the APR to read greater than 100 times MF PD (in %). This condition is o account for the reduction in argin to the fuel cladding inte rity SL and the fuel cladding 1% lastic strain limit.

MFLPD is the rati of the limiting LHGR to the HGR limit for the specific bundle type. As ower is reduced, if the desig power distribution is maintained, MFL D is reduced in proportion to the reduction in power.

However, if powe peaking increases above th design value, the MFLPD Is not reduced in Proportion to the reduction in ower. Under these conditions, the APRM gain is adjusted upward r the APRM flow biased scram setpoints Are reduced accordingly. Wh n the reactor is operating with peaking les than the design value, it is n t necessary to modify the APRM flow bias d scram setpoints. Adjusting APRM gain or setpoints is equivalent to M LPD less than or equal to FR P, as stated in the LCO.

BWR/4 qTS B 3.2.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 70 of 73

/B Attachment 1, Volume 7, Rev. 0, Page 71 of 73 I I APRM Gain and Setpoints (Optional) 3.2.4 BASES LCO (continue )

For compliance with L 0 Item b (APRM setpoint ad ustment) or Item c (APRM gain adjustme t), only APRMs required to b OPERABLE per LCO 3.3.1.1, "Reacto Protection System (RPS) Ins rumentation," are required to be adjuste. In addition, each APRM m y be allowed to have its gain or setpoints a usted independently of othe APRMs that are having their gain or s tpoints adjusted.

APPLICABILI The MFLPD limit, AP M gain adjustment, and AP M flow biased scram and associated setd ns are provided to ensure t at the fuel cladding integrity SL and the feel cladding 1% plastic strain imit are not violated during design basis t ansients. As discussed in th Bases for LCO 3.2.1 and LCO 3.2.2, suffi ient margin to these limits ex ts below 25% RTP and, therefore, thes requirements are only nece ary when the reactor is operating at 2 250 RTP.

ACTIONS Al1 If the APRM gain o setpoints are not within limits while the MFLPD has exceeded FRTP, th margin to the fuel cladding i tegrity SL and the fuel {-D cladding 1% plastic strain limit may be reduced. herefore, prompt action should be taken to estore the MFLPD to within i required limit or make acceptable APRM djustments such that the pla t is operating within the assumed margin o the safety analyses.

The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Compl tion Time is normally sufficie t to restore either the MFLPD to within niits or the APRM gain or set oints to within limits and is acceptable bas d on the low probability of a t ansient or Design Basis Accident occurrin simultaneously with the LC not met.

B.1 If MFLPD cannot e restored to within its requi ed limits within the associated Con etion Time, the plant must b brought to a MODE or other specified c ndition in which the LCO doep not apply. To achieve this status, THE MAL POWER is reduced to 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The allowed Co pletion Time is reasonable, sed on operating experience, to r uce THERMAL POWER to 25% RTP in an orderly manner and wit ut challenging plant system BWR/4 $TS l B 3.2.4-4 Rev. 3.0, 03/31/04 I

Attachment 1, Volume 7, Rev. 0, Page 71 of 73

Attachment 1, Volume 7, Rev. 0, Page 72 of 73 I I /

APRM Gain anc Setpoints (Optional)

B 3.2.4 BASES SURVEILLANC SR 3.2.4.1 and SR 3. .4.2 REQUIREMEN S The MFLPD is require to be calculated and compa ed to FRTP or APRM gain or setpoints to e ure that the reactor is opera ng within the assumptions of the s ety analysis. These SRs ar only required to determine the MFLP and, assuming MFLPD is gr ater than FRTP, the appropriate gain or s point, and is not intended to e a CHANNEL FUNCTIONAL TEST or the APRM gain or flow biaed neutron flux scram circuitry. The 24 hou Frequency of SR 3.2.4.1 is osen to coincide with the determination of ther thermal limits, specificall those for the APLHGR (LCO 3.2.1 . The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is ased on both engineering judgme and recognition of the slown ss of changes in power distribution du ing normal operation. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months allowance after THERMAL POWER 25% RTP is achieved is ac eptable given the large inherent margin to o erating limits at low power le els.

The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Freque cy of SR 3.2.4.2 requires a r ore frequent verification than if M LPD is less than or equal to raction of rated power (FRP). When MFL D is greater than FRP, more apid changes in power distribution are typi ally expected.

1. 10 CFR 50, Ap endix A, GDC 10, GDC 13, tDC 20, and GDC 23.

-o0

2. FSAR, Sectio [ ] .

3. FSAR, Sectio [ ] .

r BWR/4 $TS I B 3.2.4-5 I Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 0, Page 72 of 73

Attachment 1, Volume 7, Rev. 0, Page 73 of 73 JUSTIFICATION FOR DEVIATIONS ISTS 3.2.4 BASES, AVERAGE POWER RANGE MONITOR (APRM) GAIN AND SETPOINTS

1. Changes are made to be consistent with changes made to the Specification.

Monticello Page lof 1 Attachment 1, Volume 7, Rev. 0, Page 73 of 73

ML051990461

Text

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