Text

Improved Technical Specification Conversion License Amendment Request, Volume 7, (Revision 1), Section 3.2 - Power Distribution Limits
	ML081480467
Person / Time
Site:	Davis Besse
Issue date:	05/16/2008
From:	; FirstEnergy Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
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	Download: ML081480467 (134)
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DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 IMPROVED TECHNICAL SPECIFICATION CONVERSION LICENSE AMENDMENT REQUEST VOLUME 7 (Rev. 1)

SECTION 3.2 - POWER DISTRIBUTION LIMITS r 777-77-777 77777-1ý,I-1ý177,ý,

Attachment 1, Volume 7, Rev. 1, Page i of i Summary of Changes ITS Section 3.2 Change Description Affected Pages The changes described in the Davis-Besse Pages 87 and 90 response to question 200802211310 have been made, with the exception that typographical errors in the first sentence of the draft markup of JFD 6 provided in the response has been corrected ("ITS 3.2.4 (ISTS)" has been changed to "ISTS 3.2.4" and "to less than or equal to" has been changed to "of greater than or equal to").

This change deletes the phrase "from the ALLOWABLE THERMAL POWER" from ITS 3.2.4 Required Action A.1.2.2, consistent with similar wording in the Required Actions of ITS 3.2.5.

Added titles for UFSAR Appendix 3D references in Pages 31, 49, 71, and 102 the Bases (editorial change for consistency with the resolution to a question on a different section).

Page 1 of I Attachment 1, Volume 7, Rev. 1, Page i of i

Attachment 1, Volume 7, Rev. 1, Page 1 of 132

'ATTACHMENT 1 VOLUME 7 DAVIS-BESSE IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 1 0

Attachment 1, Volume 7, Rev. 1, Page 1 of 132

Attachment 1, Volume 7, Rev. 1, Page 2 of 132 LIST OF ATTACHMENTS

1. ITS 3.2.1

2. ITS 3.2.2

3. ITS 3.2.3

4. ITS 3.2.4

5. ITS 3.2.5 Attachment 1, Volume 7, Rev. 1, Page 2 of 132

Attachment 1, Volume 7, Rev. 1, Page 3 of 132 ATTACHMENT 1 ITS 3.2.1, REGULATING ROD INSERTION LIMITS Attachment 1, Volume 7, Rev. 1, Page 3 of 132

, Volume 7, Rev. 1, Page 4 of 132 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Attachment 1, Volume 7, Rev. 1, Page 4 of 132

Attachment 1, Volume 7, Rev. 1, Page 5 of 132 ITS 3.2.1 ITS REACTIVITY CONTROL SYSTEMS REGULATING ROD INSERTION LIMITS LIMITING CONDITION FOR OPERATION LCO 3.1.3.6 The regulating rod groups shall be positioned within the acceptable 3.2.1 operating limits for regulating rod position provided in the CORE OPERATING A02 LIMITS REPORT.

APPLICABILITY: MODES land 2.

ACTION:

ACTION A, With the regulating rod groups inserted beyond the operating limits (in a ACTION D region other than acceptable operationb,-or with any group sequence or overlap ACTION C}-.----

Dqutside the limits provided in the CORE OPERATING LIMITS REPORT except for _

LCO Note}---

surveillance testing -- pursuant to Specification 4.1.3.1.2, either: Actions AddproposedRequired A.1 and C.1 Required a. Restore the regulating groups to within hel provided in Actions A2, C.2, and the CORE OPERATING LIMITS REPORT within2 hours, or -

D.2.1 1br Reduce THERMAL POWER to less than or equal to that fraction of ACTION B, RATED THERMAL POWER which is allowed by the rod group position Required Action( limits provided in the CORE OPERATING LIMITS REPORT within T1 D.2.2 or ACTION E c. Be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

ACTION D NOTE: If in unacceptable region, also see Section 3/4.1.1.1.

A02

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Mot DAVIS-BESSE, UNIT 1 3/4 1-26 Amendment No. 00,0,.Z;,

, 144 Page 1 of 3 Attachment 1, Volume 7, Rev. 1, Page 5 of 132

Attachment 1, Volume 7, Rev. 1, Page 6 of 132 ITS 3.2.1 ITS REACTIVITY CONTROL SYSTEMS REGULATING ROD INSERTION LIMITS SIIRVFILLANCF 1EOUIRFMENTS SURVEILLANCE REOUIREMENTS SR 3.21.1, 4.1.3.6 The position of each regulating group shall be determined to be SR 3.2.1.2 within the limi tS r dd in the CORE OPERATING LIMITS REPORT at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ex ýpt when:

a. The rr/eg,lating rod insertion limit alarm is inoperable, the-n verify the groups to be within the insertion I mits at least/

once p r 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ;

b. The c ntrol rod drive sequence alarm is inope able, then verif the groups to be within the sequence nd overlap limi s at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

DAVIS-BESSE, UNIT I 3/4 1-27 Amendment No. 144 (next page is 3/4 1-30)

Page 2 of 3 Attachment 1, Volume 7, Rev. 1, Page 6 of 132

Attachment 1, Volume 7, Rev. 1, Page 7 of 132 ITS 3.2.1 ITS See ITS 3.1.1, ITS 3.1.8, and ITS 3.1.9_/

CITSSee3.1.1 Required Action D.1 within limits specified in the SURVEILLANCE REQUIREMENTS COLR L SR 3.2.1.3 4.1 .1.1.1 The SHUTDOWN MARGIN shall be determined to beL> B"Ak/kl See .

a Wi. . ol . . . . . . . . . ... ITS 3.1.411 a./ Within one hour after detection of an inoperable conIr~ol rod(s) and at least once.

I per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter while the rod(sl is inoperable If the inoperable control rod See is immovable or untrippable, the above required SHUTDOWN MARGIN shall be increased by an amount at least equal to the withdrawn worth of the immovable or] "

ITS 1.0 J-Suntrippable control rod s.L ( M01 '

SR 3.2.1,1, b. When in MODES I or at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,.by verifying that regulating SR 3.2.1.2 rod groups withdrawal is within the limits of Specification 3.1.3.6. L05 SR 3.2.1.3 c. lWhen in ýOD::E:2ý4 ýwithin 4 ýhours pýrior to achieving reactor criticalit by L0 verifying that t e predicted critical control rod positi n is within the limits of Specification .1.3.6.

d. Prior to initial operation above 5% RATED THERMAL POWER after each fuel See loading by consideration of the factors of e. below, with the regulating rod groups at the maximum insertion limit of Specification 3.1.3.6.

See ITS 3.1.1 1 See LCO 3.7.9, Steam Generator Level, for additional SHHUTDOWN MARGIN requirements.

rWith I/_> 1I0 J M01 1"with kýT< 1.0 DAVIS-BESSE, UNIT I 3/4 1-] Amendment No. 19tt&2, 276 Page 3 of 3 Attachment 1, Volume 7, Rev. 1, Page 7 of 132

Attachment 1, Volume 7, Rev. 1, Page 8 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The Applicability of CTS 3.1.3.6 is MODES 1 and 2 with footnote

stating "See Special Test Exception 3.10.1 and 3.10.2." The Applicability of CTS 3.1.1.1 includes MODE 1 and MODE 2, however MODE 2 footnote

states "See Special Test Exception 3.10.4." ITS 3.2.1 Applicability does not contain the footnote or a reference to any Special Test Exception.

The purpose of the footnote references is to alert the user that a Special Test Exception exists that may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.1.3.6 requires the regulating rod groups to be positioned within acceptable limits during operations in MODES 1 and MODE 2 with keff > 1.0. CTS 3.1.1.1 requires SHUTDOWN MARGIN to be met in MODES 1 and MODE 2 however CTS 4.1.1.1.1.b only requires a verification that SHUTDOWN MARGIN is within limits by verifying that regulating rod groups withdrawal is within limits in MODE 1 and MODE 2 with keff > 1.0. ITS 3.2.1 requires the regulating rod insertion limits to apply at all times in MODES 1 and 2 and ITS SR 3.2.1.1 and SR 3.2.1.2 require verification in these modes. This changes the CTS by expanding the applicability of the regulating rod groups and requires verification to include MODE 2 with keff < 1.0.

The purpose of the CTS 3.1.3.6 is to ensure the regulating rod groups are at the acceptable operating limits to help ensure SHUTDOWN MARGIN is met.

CTS 3.1.3.6 and CTS 3.1.1.1.1 help to ensure SHUTDOWN MARGIN is met in MODES 1 and 2; however, there is no specific requirement to verify SHUTDOWN MARGIN at a consistent frequency when in MODE 2 with keff < 1.0 except the requirement in CTS 4.1.1.1.1 .c (ITS SR 3.2.1.3). This change is acceptable because the ITS requires the regulating rod insertion limits to apply at all times in MODES 1 and 2 to help ensure SHUTDOWN MARGIN is maintained.

This change is designated as more restrictive because it expands the conditions for regulating rod groups and expands the conditions under which a Surveillance must be performed.

Davis-Besse Page 1 of 7 Attachment 1, Volume 7, Rev. 1, Page 8 of 132

Attachment 1, Volume 7, Rev. 1, Page 9 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of Cycle-Specific ParameterLimits from the Technical Specifications to the Core OperatingLimits Report) CTS 4.1.1.1 requires that the SDM be > 1% Ak/k. ITS 3.2.1.3 states that the SDM shall be within the limits of the COLR. This changes the CTS by relocating the SDM limit, which must be confirmed on a cycle-specific basis, to the COLR.

The removal of these cycle-specific parameter limits from the Technical Specifications to the COLR is acceptable because the cycle-specific limits are developed or utilized under NRC-approved methodologies which will ensure that the Safety Limits are met. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From 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 the SDM requirement. The methodologies used to develop the parameters in the COLR have obtained prior approval by the NRC in accordance with Generic Letter 88-16. 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 that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses 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.

LA02 (Type 3 - Removing ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.1.1.1.1 .c requires verification that SHUTDOWN MARGIN is within limit by verifying the "predicted critical control rod position is within the limits" of Specification 3.1.3.6. ITS SR 3.2.1.3 requires verification that SDM is within the limits. This changes the CTS by removing details of how to perform the SHUTDOWN MARGIN verification to the Bases.

The removal of these details for performing a Surveillance Requirement 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 verify SDM is within the limit. 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 change because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

Davis-Besse Page 2 of 7 Attachment 1, Volume 7, Rev. 1, Page9 of 132

Attachment 1, Volume 7, Rev. 1, Page 10 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) The CTS 3.1.3.6 Action requires entry with the regulating rod groups inserted beyond the operating limits (in a region other than acceptable operation) or with any group sequence or overlap outside the limits. CTS 3.1.3.6 provides three optional Required Actions.

CTS 3.1.3.6 Action a requires restoration of the regulating groups to within the limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . CTS 3.1.3.6 Action b requires the reduction in THERMAL POWER to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the rod group position limits. CTS 3.1.3.6 Action c requires the plant to be in Hot Standby (MODE 3) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . ITS 3.2.1 ACTION A requires entry when regulating rod groups are inserted in the restricted operational region. ITS 3.2.1 ACTION C requires entry when regulating rod groups sequence or overlap limits are not met. ITS 3.2.1 ACTION D requires entry when regulating rod groups are inserted in the unacceptable operational region. ITS 3.2.1 ACTION A requires the performance of ITS SR 3.2.5.1 once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when THERMAL POWER is > 20% RTP and the restoration of regulating rod groups to within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of failure to meet the LCO. ITS 3.2.1 ACTION B covers the conditions when the Required Actions and associated Completion Times of Condition A are not met when the plant is operating in the restricted operational region and it allows 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to reduce THERMAL POWER to less than or equal to THERMAL POWER allowed by regulating rod group insertion limits. ITS 3.2.1 ACTION C requires performance of ITS SR 3.2.5.1 within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when THERMAL POWER is

> 20% RTP and the restoration of regulating rod groups to within limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.2.1 ACTION D, in part, requires the restoration of the rod groups to within restricted operating region within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or a reduction of THERMAL POWER to less than or equal to the THERMAL POWER allowed by the regulating rod group insertion limits. This changes the CTS by extending the Completion Time to restore regulating rod groups to within limits from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when regulating rod groups are inserted in restricted operational region, and from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when regulating rod groups are not within the sequence or overlap limits. However it provides an additional requirement to verify F0 and F.Hare within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (for ITS 3.2.1 ACTION A) or within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (for ITS 3.2.1 ACTION C) during the extended Completion Times. This change also provides an additional allowance to operate in the restricted operational region for an additional 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (after the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period) to reduce THERMAL POWER to less than or equal to THERMAL POWER allowed by regulating rod group insertion limits.

The purpose of the CTS 3.1.3.6 Actions are to preclude long term depletion with abnormal group insertions or configurations, thereby limiting the potential for an adverse xenon redistribution. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. The CTS is changed in several ways. The Completion Time to restore regulating rod groups to within limits has been extended from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when regulating rod groups are inserted Davis-Besse Page 3 of 7 Attachment 1, Volume 7, Rev. 1, Page 10 of 132

Attachment 1, Volume 7, Rev. 1, Page 11 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS in restricted operational region and from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when regulating rod groups are not within the sequence or overlap limits. However during the time an additional requirement to verify FQ and FA H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (for ITS 3.2.1 ACTION A) and within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (for ITS 3.2.1 ACTION C) is required. This change also provides an additional allowance to operate in the restricted operational region for an additional 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months (after the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period) to reduce THERMAL POWER to less than or equal to THERMAL POWER allowed by regulating rod group insertion limits. Operation with the regulating rods in the restricted region or with any group sequence or overlap outside the limits potentially violates the LOCA LHR limits (FQ limits), or the loss of flow accident DNB peaking limits (FA H limits). Verification that FQ and FAH are within their limits ensures that operation with the regulating rods inserted into the restricted region does not violate the ECCS or DNB criteria. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is acceptable in that it allows the operator sufficient time for obtaining a power distribution map and for verifying the power peaking factors. Repeating SR 3.2.5.1 every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for ITS 3.2.1 ACTION A is acceptable because it ensures that continued verification of the power peaking factors is performed as core conditions (primarily regulating rod insertion and induced xenon redistribution) change. SR 3.2.5.1 is only required when THERMAL POWER is greater than 20% RTP. This establishes a Required Action that is consistent with the Applicability of LCO 3.2.5, "Power Peaking Factors." Indefinite operation with the regulating rods inserted in the restricted region, or in violation of the group sequence or overlap limits, is not prudent.

Even if power peaking monitoring is continued, reactivity limits may not be met and the abnormal regulating rod insertion or group configuration may cause an adverse xenon redistribution, may cause the limits on AXIAL POWER IMBALANCE to be exceeded, or may adversely affect the long term fuel depletion pattern. Therefore, power peaking monitoring is allowed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after discovery of failure to meet the LCO for ITS 3.2.1 ACTION A and only up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for ITS 3.2.1 ACTION C. This required Completion Time 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after discovery of failure to meet the LCO (for ITS 3.2.1 ACTION A) and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months (for ITS 3.2.1 ACTION C) is reasonable based on the low probability of an event occurring simultaneously with the limit out of specification in this relatively short time period. If the regulating rods cannot be restored within the insertion limits, then the insertion limits can be restored by reducing the THERMAL POWER to a value allowed by the regulating rod insertion limits. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is sufficient to allow the operator to complete the power reduction in an orderly manner and without challenging the plant systems. Operation for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months more in the restricted region is acceptable, based on the low probability of an event occurring simultaneously with the limit out of specification in this relatively short time period. In addition, it precludes long term depletion with abnormal group insertions or configurations and limits the potential for an adverse xenon redistribution. If the regulating rods cannot be restored to within the insertion limits as required by ITS 3.2.1 ACTIONS A and C, or if the power reduction cannot be completed within the required Completion Time as required by ITS 3.2.1 ACTION B, then the reactor is placed in MODE 3, in which this LCO does not apply. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

Davis-Besse Page 4 of 7 Attachment 1, Volume 7, Rev. 1, Page 11 of 132

Attachment 1, Volume 7, Rev. 1, Page 12 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS L02 (Category 7- Relaxation of Surveillance Frequency - Non-24 Month Type Change) CTS 4.1.3.6 requires the position of each regulating group to be determined to be within the limits provided in the COLR at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the regulating rod insertion limit alarm or the control rod drive sequence alarm is inoperable. With either of these alarms inoperable, CTS 4.1.3.6.a requires a verification that the rod groups are within the insertion limits at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and CTS 4.1.3.6.b requires a verification that the rod groups are within the sequence or overlap limits at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , respectively. ITS SR 3.2.1.1 requires verification that regulating rod groups are within the sequence and overlap limits of the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , and ITS SR 3.2.1.2 requires verification that the regulating rod groups meet the insertion limits specified in the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by eliminating the requirement to verify that each regulating group is within insertion limits at accelerated frequencies when the regulating rod insertion limit alarm or the control rod drive sequence alarm is inoperable.

The purpose of CTS 4.1.3.6 is to periodically verify that the regulating rods are within the limits specified in the LCO. This change is acceptable because increasing the Frequency of regulating rod insertion limit verification when the regulating rod insertion limit alarm or the control rod drive sequence alarm is inoperable is unnecessary. An inoperability of the alarm does not increase the probability that the regulating rod insertion limits are not met. The routine 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequencies (ITS SR 3.2.1.1 and SR 3.2.1.2) continue to ensure the regulating rod limits are met. Furthermore, the regulating rod insertion limit alarm and the control rod drive sequence alarm are for indication only. Their use is not credited in any safety analyses. Thus, any response determined necessary by plant personnel due to an inoperable alarm is more appropriately controlled by plant procedures, not Technical Specifications. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L03 (Category3 - Relaxation of Completion Time) CTS 3.1.3.6 Action Note requires entry into the Actions of CTS 3.1.1.1 if the plant is in the unacceptable region specified in the COLR. The CTS 3.1.1.1 Action states that when the SHUTDOWN MARGIN is less than the applicable limit, boration must be initiated immediately. Under the same conditions in the ITS, ITS 3.2.1 Required Action D.1 states that boration must be initiated within 15 minutes. This changes the CTS by relaxing the Completion Time from "immediately" to 15 minutes.

The purpose of CTS 3.1.1.1 Action is to restore the SDM to within its limit promptly. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering a reasonable time for restoration and the low probability of a DBA occurring during the allowed Completion Time. The ITS Completion Time of 15 minutes is adequate for an

-operator to correctly align and start the required systems and components. In addition, the ITS Bases for the ACTION state that boration must be initiated promptly. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

0 Davis-Besse Page 5 of 7 Attachment 1, Volume 7, Rev. 1, Page 12 of 132

Attachment 1, Volume 7, Rev. 1, Page 13 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS L04 (Category 4 - Relaxation of Required Action) CTS 3.1.1.1 Action states that when the SDM is not within the applicable limits, boration must be initiated and continued at ->25 gpm of a solution containing > 7875 ppm boron or its equivalent until the required SDM is restored. ITS 3.2.1 Required Action D.1 states that with the regulating rod groups inserted in the unacceptable operational region to initiate boration to restore SDM to within limits. This changes the CTS by eliminating the specific values of flow rate and boron concentration that must be used to restore compliance with the LCO.

The purpose of the CTS 3.1.1.1 Action is to restore the SDM to within its limits.

This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the operability status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. Removing the specific values of flow rate and boron concentration from the CTS Action provides flexibility in the restoration of the SDM and eliminates conflicts between the SDM value and the specific boration values in the CTS Action. As stated in the ITS 3.1.1 Bases for ACTION A, "In the determination of the required combination of boration flow rate and boron concentration, there is no unique requirement that must be satisfied. Since it is imperative to raise the boron concentration of the RCS as soon as possible, the boron concentration should be a highly concentrated solution, such as that normally found in the boric acid storage tank or the borated water storage tank. The operator should borate with the best source available for the plant conditions." Specifying a minimum flow rate and concentration in the ACTION may not accomplish the objective of raising the RCS boron concentration as soon as possible. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L05 (Category 7- Relaxation Of Surveillance Frequency - Non-24 Month Type Change) CTS 4.1.1.1.1 .c requires verification of SDM, when in MODE 2 with keff

< 1.0, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving reactor criticality. ITS SR 3.2.1.3 requires SDM to be verified within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving criticality. This changes the CTS by eliminating the explicit statement that the Surveillance is required to be performed in MODE 2.

The purpose of CTS 4.1.1.1.1 .c is to estimate the critical position-of the control rods 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to going critical. This change is acceptable because the proposed Surveillance Frequency of within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving criticality ensures that there is sufficient SDM capability with the control rods at the estimated critical position. CTS 4.1.1.1.1 .c requires verification of SDM, when in MODE 2 with keff < 1.0, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving reactor criticality. ITS SR 3.2.1.3 requires SDM to be within limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving criticality. This change eliminates the explicit statement that the Surveillance is required to be performed in MODE 2. The Surveillance may be performed in another MODE as long as it is performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of going critical. The Surveillance Frequency still requires the estimated critical position to be Davis-Besse Page 6 of 7 Attachment 1, Volume 7, Rev. 1, Page 13 of 132

Attachment 1, Volume 7, Rev. 1, Page 14 of 132 DISCUSSION OF CHANGES ITS 3.2.1, REGULATING ROD INSERTION LIMITS determined within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to criticality and is therefore acceptable because it provides sufficient time to establish the estimated critical position after the determination is performed. This change is designated as less restrictive because the Surveillance is not required to be performed in MODE 2.

Davis-Besse Page 7 of 7 Attachment 1, Volume 7, Rev. 1, Page 14 of 132

Attachment 1, Volume 7, Rev. 1, Page 15 of 132 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 15 of 132

Attachment 1, Volume 7, Rev. 1, Page 16 of 132

Regulating Rod Insertion Limits 3.2.1 CTS 0 3.2 3.2.1 POWER DISTRIBUTION LIMITS Regulating Rod Insertion Limits 3.1.3.6 LCO 3.2.1 Regulating rod groups shall be within the physical insertion, sequence,

.and overlap limits specified in the COLR.

NOTE -----------------------

3.1.3.6 Not required for any regulating rod repositioned to perform SR 3.1.4.2.

Action APPLICABILITY: MODES I and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.1.3.6 *A. Regulating rod groups A.1 ---------- NOTE-------

Action a inserted in restricted Only required when operation[] regio , or THERMAL POWER is, sequencýor overlap, or > 20% RTP.

0 0 any comb nation not o IMe Perform SR 3.2.5.1. Once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND A.2 Restore regulating rod 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from groups to within limits. discovery of failure to meet the LCO B. Required Action and B.1 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 3.1.3.6 Action b associated Completion POWER.to less than or Time of Condition A not equal to THERMAL met. POWER allowed by regulating rod group insertion limits.

I.

L--[ INSERT 1 0

BWOG STS 3.2.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 16 of 132

Attachment 1, Volume 7, Rev. 1, Page 17 of 132 3.2.1 CTS (DINSERT 1 3.1.3.6 C. Regulating rod groups C.1 --------- NOTE ------..--------

Action a sequence or overlap Only required when limits not met. THERMAL POWER is

> 20% RTP.

Perform SR 3.2.5.1. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND C.2 Restore regulating rod groups 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to within limits.

Insert Page 3.2.1-1 Attachment 1, Volume 7, Rev. 1, Page 17 of 132

Attachment 1, Volume 7, Rev. 1, Page 18 of 132 Regulating Rod Insertion Limits.

3.2.1 CTS ACTIONS (continued)

,CON DITION REQUIRED ACTION COMPLETION TIME I-.

3.1.3.6 Regulating rod groupsý 1 Initiate boration to festore6 15 minutes 0 Action Note, inserted in, unacceptpablp operatio0nW] region.

SDM to within the limit Is pocifieodi the ,COL 0

3.1.1.1 Action AND 1 2.1 Restore regulating rod 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0

groups. to within restricted operat9q region.

OR

[.2.2 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 0

POWER to less.than or the restricted operation region of} PWE Rql d

t pual to the THERMAL allowed byThE 0 regulating rod group insertion limits.

3.1.3.6 Required Action and [1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 0ttion te, 3.1.1.1 associated 'Completion.

Time ,of Condition C not 0 Action met. or 0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.1.3.6, SR 3.2.1.1 Verify regulating rod groups are within the sequence 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4.1.1.1.1 .b and overlap limits as specified in the COLR.

4.1.3.6, :SR 3.2.1.2 Verify regulating rod groups meet:the insertion limits 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 4.1.1.1.1.b as specified in the COLR.

4.1.1.1.1.c SR 3.2.1.3 Verify SDM is within the.limit specified in the COLR. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to achieving criticality 0 BWAOG STS 3.2.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume. 7, Rev. 1, Page 18 of 132

Attachment 1, Volume 7, Rev. 1, Page 19 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, REGULATING ROD INSERTION LIMITS

1. Ifthe regulating rod groups are not within the sequence or overlap limits, ISTS 3.2.1 ACTION A allows up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the regulating rod groups to within the limits. This is an excessive time to allow the unit to operate outside these limits.

Therefore, ITS ACTION C has been added to only allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore the regulating rod groups to within the sequence and overlap limits. This is consistent with the Arkansas Nuclear One (ANO) ITS amendment, as approved by the NRC on October 29, 2001. Furthermore, consistent with ISTS 3.2.1 Required Action A.1, performance of SR 3.2.5.1 is required within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . Further performance of the SR (i.e., every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ) is not required since the rods have to be restored within the limits by the time the next performance would be required. Due to this change, ISTS 3.2.1 Condition A has been modified to delete sequence and overlap references, and subsequent ACTIONS have been renumbered.

2. Changes are made to be consistent with the format of the ITS. The location of where a parameter's limits reside, whether in the COLR or an actual LCO statement, is not normally specified in the Required Action. The Required Action normally states that the parameter shall be "within limits."

3. Clarifying words have been added. Power only has to be reduced to exit the unacceptable operation region.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 19 of 132

Attachment 1, Volume 7, Rev. 1, Page 20 of 132 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 20 of 132

Attachment 1, Volume 7, Rev. 1, Page 21 of 132 Regulating Rod Insertion Limits B 3.2.1 B332 POWERDISTRIBUTION LIMITS B13.2.1 Regulating. Rod Insertion Limits BASES.

BACKGROUND The insetion limits of the regulating rods are initial condition assumptions used in all safety analyses that assume rodinsertion upont reactor trip.

The insertion limits directly affect the core power distributions, the worth of a potential ejected rod, the assumptions ofavailable SDM, and the initial reactivity insertion rate.

~The applicable criteria for these reactivity. and power distribution *design:

requirements are described in 10.CFR'50, Appendix.A,/GDC 10, "R~eacto 6._

Design,"' DC-26, "ReachtiviyControi SystemnRedunjelancy-an~d Capbi ty'"GDC 28, "React' ty Lirots /(aef. 1)y and in,10 CFR 50.46, "Acceptance Criteria for. Emergency Core Cooling Systems for Light Water Nuclear Power Plants" (Ref. 2).

[ are specified in the COLR Limits on regulating rod insertion [have bee'r-stablished, and all rod positions are monitored and controlled during power operation to ensureý Q

that the power distribution and reactivity limits defined by the design power peaking and SDM limits are not violated.

The regulating rod groups operate with a predetermined amount of position overlapp rto approximate a. linear relation between rod worth and rod position (integral rod worth). To achieve this approximately linear relationship, the regulating rod~groups are withdrawn and operated in a predetermined sequence. The automatic control system controls reactivity by moving the regulating rod groups in sequence within analyzed ranges. The group sequence and overlap limits are specified in the COLR.

The regulating rods are used for precise reactivity, control of the reactor.

The positions of the regulating rods are normally controlled automatically by the automatic control system but can also be controlled manually.

They are capable of adding reactivity quickly compared with borating or diluting the Reactor Coolant System (RCS).

The power density at any point in the core must be limited to maintain specified acceptable fuel design limits, including* limits that ensure that the

criteria specified in 10 CFR 50.46 (Ref. 2) are not violated. Together, .

LCO 3.2.1, "Regulating Rod Insertion Limits,' LCO 3.2.2, "AXIAL POWER

%SHAPINGROD (APSR) Insertion Limits,": LCO3.2.3, "AXIAL POWER BWOG STS B 3.2.1-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 21 of 132

Attachment 1, Volume 7, Rev. 1, Page 22 of 132 B 3.2.1 OINSERT 1 UFSAR, Appendices 3D.1.6, 3D.1.21, 3D.1.22, 3D.1.23, and 3D.1.24 Insert Page B 3.2.1-1 Attachment 1, Volume 7, Rev. 1, Page 22 of 132

Attachment 1, Volume 7, Rev. 1, Page 23 of 132

.Regulating Rod Insertion Limits B 3.2.1 BASES BACKGROUND :(continued)

IMBALANCE Operating Limits,. and LCO 3.2.4, QUADRANT POWER TILT (QPT)," proVide. limits on control cormponent operation and on mIrohitored process variables to0ensure that the core operates within the FQR)- and FX, limits in the COLR. Operation within the FcM limits given 0

inear heat rateERR in'the COLR prevents power peaks thatwould exceed the loss of coolant accident (LOCA) limits derived from the analysis of the Emergency Core 0 Cooling Systems (ECCS). Operation within the FNH limits given in the COLR prevents departure from nucleate boiling (DNB) during a loss of forced reactor coolant flow accident. In addition to the FQO-) and FHA 0

limits, certain reactivity limits are met by regulating rod insertion limits.

The regulating rod insertion limits also restrict the ejected CONTROL ROD worth to the values assumed. in the safety analysis and maintain the minimum required SDM i.n MODES 1 andi2.

This LCO is required to minimize fuel cladding failures that breach the primary fission product barrier and release fission products, into the reactor coolant in the event of a LOCA, loss of flow accident, ejected rod accident, or other postulated accidents requiring termination by a Reactor Protection System.trip function.

APPLICABLE The fuel cladding must not sustain damage as:a result of normal SAFETY operation (Condition 1) or anticipatedoperationa occurrences ANALYSES (Condition 2). The LCOs governing regulating ro.d insertion, APSR position, AXIAL POWER IMBALANCE, and QPT preclude core power distributions that violate the following fuel design criteria:

a. During aa exceed 2200°F (Ref. 2)g.

LOCA, the peak cladding temperature must not

[-

0

b. During a loss of forced reactor coolantflow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a DNB condition (Ref..

00

c. During an ejected rod accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref.

t!C3 a-n 00

d. TheCONTROL RODS must be capable of shutting down the reactor with a minimum required SDM with the:highest worth CONTROL ROD stuck fully withdrawn (Ref. 1).

BWOG STS B 3.2.1-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 23 of 132

Attachment 1, Volume 7, Rev. 1, Page 24 of 132

.Regulating Rod Insertion Limits B 3.32.1 BASES.

ApPLICABLE SAFETY ANALYS ES (continued)

Fuel cladding damage does not occur when the core is operated .outside the conditions of these LOs. during normal operation. However, fuel cladding, damage could result if an accident occurs with the simultaneous violation of one or more of the LCQs limiting the regulating rod position,

the APSR positionthe AXIAL POWER IMBALANCE,ýand thbeQPT.. This, potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and correspondingly increased local linear t rate lHRsf.

The SDM requirement is met bylimiting the regulating and safety rod insertion limits such that sufficient inserted reactivity is available in the

rods to shut down the reactor to hot zero power with a reactivity margin that assumes that the maximum worth rod remains fulIy withdrawn upon trip (Ref. 4). Operation at the SDM based regulating rod insertion limit may also indicate that the maximum ejected rod worth could be equal to the limiting value.

O Cio -t the regulating rod insertion limits may cause the localcore*

power to approach themaximum linear heat generation rate or peaking factor with the allowed QPT present.

The regulating rod and safetyrod insertion limits ensure that the safety analysis assumptions for SDM, ejected~rod worth, and power distribution peaking factors remain valid (Refs. 3,5,nd 3 and 5 The regulating rod insertion limits LCO satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

rod e imits oýnJCONT L RO sequence, including group overlap, and

insertion positions as defined in the COLR, must be maintained because they ensure that the resulting power distribution is withinthe range.of analyzed power distributions and that the SDM and ejected.rod worth are maintained.

The overlap between regulating groups, provides more uniform rates .of reactivity insertion and withdrawal and is imposed to maintain acceptable power peaking during regulating rod motion.

Errormakimum a'lwable s"apoifor regulating rod insertionElmis are provided in the COLR. Thes sre erived by an adjustment of the measurement system independent limits to allow for THERMAL POWER level uncertainty and rod position errors.

BWOG STS B 3.2.1-3 Rev. 3.0,.03/31/04 Attachment 1, Volume 7, Rev. 1, Page 24 of 132

Attachment 1, Volume 7, Rev. 1, Page 25 of 132 Regulating Rod Insertion Limits B 3.2.1 BASES.

LCO (6ontinued)

Actual larm setpoints impl mented in the unit may e more restrictive than the wnaximum allowable setpointvalues to provie additional

.conserva \sm between the a al alarm setpoint and t e measurement 0

.system in, pendent limit.

LCO 3.2,1 has been modified bya Note that suspends the LCO requirement for those regulating rods not within the limits of the COLR solely due to testing in accordance with SR 3.1.4.2, which verifies the freedom of the. rods to move. This SR may require the regulating rods to move below the LCO limit, which would otherwise violate the LCO.

APPLICABILITY The regulating rod sequence, overlap, and physical insertion limits shall be maintained with the reactor in MODES 1 and 2. These limits maintain the validity of the assumed power distribution, ejected rod worth, SDM,

,and reactivity insertion rate assumptions used in the safety analyses.

Applicability in MODES 3, 4, and 5 is not required, because neither the power distribution nor ejected rod worth assumptions are exceeded in these MODES. SDM.in MODES 3, 4, and 5 is governed by LCO 3.1.1, "SHUTDOWN MARGIN (SDM)."

ACTIONS The regulating rod insertion alarm stpoints provided in the COLR are 0 based on both the initial conditions assumed in the accident analyses-and

.on the SDM. Specifically, separate insertion limits are specified to determine whether the unit is operating in violation of the initial conditions (e.g.,.the range of power distributions) assumed in the accident analyses

.or whether the unit is in violation of the SDM or ejected rod worth limits.

Separate insertion limits are provided because different Required Actions and Completion Times apply, depending on which insertion limit has been violated. The area between the boundaries of acceptable operation and unacceptable operation, illustrated on the regulating rod insertionlimit figures in the COLR, is the restricted region. The actions required when operationoccurs in the restricted region are described under Condition A.

The actions required when operation occurs in the unacceptable region

ýare described under Conditionf 0 DThe actions required when operation occurs with the regulating rod group sequence or overlap limits A. 1 not met are described under Condition C.

Operation with the regulating rods in the restricted region shown on the regulating rod insertion figures specified inthe.COLR or lth any groupi Isequence or o erlap outside the limits specified in the CMhLR potentially 0 000 violates the LOCA LH R limits (FQo] limits), or the loss of flow accident DNB peaking limits F'AH limits). IThe design ca-cttions assume no0 BVWOG STS B 3.2.1-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 25 of 132

Attachment 1, Volume 7, Rev. 1, Page 26 of 132 Regulating Rod Insertion Limits 13.2.1 B

. BASES ACTIONS :,(continued) deviation in nomirIloverlap between regula ing rod groups. However, ddeviations.of 5%o 0the core height above or elow the. nominal overlap:

may be typical and o not cause significant di ferences in core reactivity, in power distribution, or in rod worth, relative t the design calculations; the groUp sequence ust be maintained beca se design calculations assume: the regulatin rods withdraw and insert n a predetermined .order; For verification that Fo(5- and F"H are within their limits, SR 3.2.5.1 is performed using theý Incore Detector System to obtain a three oeo dimensional power distribution map. Verification that FQa and FH are

within their limits ensures that operation with the regulating rods inserted Q

into the restricte egion does notiviolate the ECCS or DNB criteria (3 6 (Ref. RD. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is acceptable in that it allows the operator. sufficient time for obtaining a power distribution map and for verifyingthe power peaking factors. Repeating SR 3.2.5.1 every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is acceptable because it ensures that continued verification of the power peaking factors is performed as core conditions (primarily regulating-rod insertion and induced xenon redistribution) change.

Monitoringthe power peaking factors F 0* and F* does not provideA verification that the reactivity insertion rate on the rod trip, or the ejected rod worth limit is maintained, because worth is a reactivity parameter rather than a power peaking parameter. However, if the COLR figures do not show that a rod insertion limit is ejected rod worth limited, then the ejected rod worth is.no more limiting than the SDM based rod insertion limit in the core design (RefT. . Ejected rod worth limits are independently maintained by the Required Actions of Conditions A and Required Action A.1 is modified by a Note that requires the performance of SR 3.2.5.1 only when THERMAL POWER is greater than 20% RTP.

This establishes a Required.Action that is consistent with the Applicability of LCO 3.2.5, "Power Peaking Factors.".

A.2 Indefinite operation with the regulating rods inserted in the restricted region, or in violatio: fthe group sequoce or overlap limitsJ is not Q prudent. Even if power peaking monitoring per Required Action A.1 is

continued, reactivity limits may not be met and the abnormal regulating rod insertion.or group configuration may cause an adverse xenon redistribution, may cause the limits on; AXIAL POWER IMBALANCE to be exceeded, or may adversely affect the long term fuel depletion pattern.

O BWOG STS B 3.2.1-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 26 of 132

Attachment 1, Volume 7, Rev. 1, Page 27 of 132 Regulating Rod Insertion Limits B 3.2:1 BASES.

ACTIONS (continued) restoration of the regulating rod groups to within limits is required within Therefore, power peakhkg monitoring i allowed for up to 24.hours after discovery of failure to meet th.e requirements of'this LCO. This required

,Completion Time is reasonable :based on the low probability:of an event occurring simultaneously with the limit out of specification in this relatively short time period. In addition, it precludes, long, term depletion with abnormal group.:insertions or configurations, thereby limiting the potential for an adverse xenon redistribution.

B.1 operation region If the regulating rods cannot be restored within the 'acceptable o Ii its]shown on the figures in the COLR withinithe required Completion Time (i.e.,, Required Action A.2 not met), then the limitj can. be restored

by reducing the THERMAL POVVER.,to a value allowed by the regulating rod insertion limits in the COLR. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is sufficient, toallow the operator to. complete the power reduction in an orderly manner~and without challenging the plant systems. I Operation for up to2 hours more in the: restricted region shown in the COLR is acceptable, based onthe low probability of an event occurring Esimultaneously with theimit outof specification in this relatively short 4 time period. In addition, it precludes long term depletion with abnormal group insertions or configuraticons and limits the potential for.an adverse xenon redistribution.

Operation. in the unacceptableregion shown on the figures in the COLR corresponds to power operation with an SDM less than the minimum required value orwith theejected rod worth greater than the allowable value. The regulating rods may be inserted too far to provide sufficient negative reactivity insertion following a reactor trip and the ejected rod worth may exceed its initial condition limit. Therefore, the RCS boron concentration must be increased to restore the regulating rod insertion to

,a valuelthat preserves the SDM and.ejected rod worth limits. The RCS_ the Bases of boration must occur as described in ISectioh 3.1 .1. The required LCO3.1.1 K>

Completion Time of 15 minutes to initiate boration is reasonable, based

on limiting the potential xenon redistribution, the low probability of an BWOG STS B 3.2.1-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 27 of 132

Attachment 1, Volume 7, Rev. 1, Page 28 of 132 B 3.2.1 O INSERT 2 C.1 and C.2 Operation with the regulating rod groups out of sequence or with the group overlap limits exceeded may represent a condition beyond the assumptions used in the safety analyses, including SDM. The design calculations assume no deviation in nominal overlap between regulating rod groups. However, deviations as allowed by the COLR above or below the nominal overlap may be typical and would not cause significant differences in core reactivity, in power distribution, or in rod worth, relative to the design calculations. The group sequence must be maintained because design calculations assume the regulating rods withdraw and insert in a predetermined order.

For verification that FQ and F',Hare within their limits, SR 3.2.5.1 is performed using the Incore Detector System to obtain a three dimensional power distribution map. Verification that FQ and FA H are within their limits ensures that operation with the regulating rods sequence or overlap limits not met does not violate the ECCS or DNB criteria (Ref. 6). The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is acceptable in that it allows the operator sufficient time for obtaining a power distribution map and for verifying the power peaking factors. Required Action C.1 is modified by a Note that requires the performance of SR 3.2.5.1 only when THERMAL POWER is greater than 20% RTP. This establishes a Required Action that is consistent with the Applicability of LCO 3.2.5.

Indefinite operation with the regulating rods sequence or overlap limits not met is not prudent because of the potential severity associated with gross violations of group sequence or overlap requirements. Therefore, the regulating rod groups must be restored to within the sequence and overlap limits within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time is based on operating experience which supports the restoration time without unnecessarily challenging unit operation and the low probability of an event occurring simultaneously with the limit out of specification.

Insert Page B 3.2.1-6 Attachment 1, Volume 7, Rev. 1, Page 28 of 132

Attachment 1, Volume 7, Rev. 1, Page 29 of 132 Regulating Rod InSertion: Limits B 3.2i.1 BASES ACTIONS (continued) accident occurring in. this relatively short time period', andthe nu.mber of

.steps.requiredto complete thisAction. This, period allows the-,operator sufficient time for aligning the required valves and for starting.the boric acid pumps. Boration continues until the regulating rod groupýpositions are restored to at least within the restricted operational tegion,.which restores the minimum SDM capability and reduces the potential ejected rod worthlto within its limit.

FD.2 1 0

The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months from initial discovery of a r regulating rod group inthe unacceptable region until its restoration to' within the restricted operaq region shown on the figures in the C'OLR allows sufficient:time for borated water to enter the RCS from the chemical addition and makeup systems, thereby allowing the, regulating unacceptable rods to be.withdrawn to the restricted region. Operation in theI restNcted Q operation region for up to aA iddona 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable, .based on limitirig the potential for an adverse xenon redistribution, the.low probability of an accident occurring in this relatively short time, period, and the number of steps required to completethis Action.

0.2.2 0D The SDM and ejected rod worth limit can also be restored by reducing the THERMAL POWER to a value allowed by the regulating rod insertion limits in the COLR. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is sufficient to allow the operator to complete the power reductionin an orderly manner and without challenging the plantsystems. Operation for up to, unacceptable operation hoursonm-ree. in 2 ase owtheres cte ofregion probability shown an event in the COLR occurring. is acceptable, simultaneously with the 0 limit out of specification in this relatively short time period..In addition,, it precludes long term depletion with abnormal group insertionsor configurations and limits the potential for an adverse xenon redistribution.

BWOG STS B 3.2.1-7 Rev. 3.0,.03/31/04 Attachment 1, Volume 7, Rev. 1, Page 29 of 132

Attachment 1, Volume 7, Rev. 1, Page 30 of 132 Regulating Rod Insertion Limits B :3.2.1 BASES ACTIONS (conti any Required Action and associated Completion Time of Condition C or D is not met Ifhe re ulating rods cannot b restored to within the acceptable operati limits for the original THERMAL POWER,'or if the power freductin cannot be complet- within the requiredCompletionTimthen KJ the reactor is placed in MODE 3, in whichthis LCO does not~apply. This Action ensures that the reactor does not continue operating in violation of

.the peaking limits, the ejected rod worth, the reactivity insertion rate assumed as initial conditions in the accident analyses, or the required minimum SDM assumed in the accident analyses. The required

Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience regarding the amount of time required to reach MODE 3 fr6om RTP without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS This Surveillance ensures that the sequence and overlap limits are not violated. A Surveillance Frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is acceptable because:

little'rod motion occurs in 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months due to fuel burnup and Iof a deviation opcurring simultaneousy with an inoperaible,ýIequence pro a ility 0 Imonitor in this V/elatively~short time frs/mejis low/. Also, the Frequency takes into, account other information available in theacontrol room for monitoring the status of the regulating rods.

SR 3.2.1.2 JWith amOPERABLE r ulating rod insernioo limit alarm, **erification of the 0 regulating rod insertion limits as specified in the COLR .at a Frequency of 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months s~is sufficientEto ensu*e the OPER'ABILITY of the hequlating o(-

linslrtion hmit alarl andl to detect regulating rodb ke that mab g____

approaching the group insertion limits, because little rod motion due to fuel burnup occurs in 12.hours. Also, the Frequency takes -into account other information available in the control room for monitoring the status of the regulating rods.

BWOG STS B 3.2.1-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 30 of 132

Attachment 1, Volume 7, Rev. 1, Page 31 of 132 Regulating Rod Insertion Limits B 3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.3 w in4 hour---- rior.to achieving criticality, an estimated critical position forthe CONTROLIRODS is determined. Verification that SDM meets the 0

minimum requirements ensures that.sufficient SDM :capability exists with the CONTROL RODS at the estimated critical position if it is necessary to shut down or trip the reactor after criticality, The Frequencyof 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to criticalityprovidessufficient time to verify SDM capability and establish the estimated critical position.

REFERENCES 1. 10.CFR 50, Appendi"GDC 10 and GDC 26.

0

2. 10CFR5o.46. UFSAR Appendices 3D.1.6,

3. FSAR, Section 4 Criterion 10 - Reactor Design; 3D.1.21, Criterion 25 -

Protection System Requirements 0 0 4.qFsAR, Section F1U For Reactivity Control Malfunctions; 3D.1.22, Criterion 26 - Reactivity Control System 0 0 5.5FSAR, SectioniLg, Redundancy and Capability; 3D.1.23, Criterion 27 -

Combined Reactivity Control 0 0

6. jFS AR, !ecti [] .

Systems Capability; and 3D.1.24, Criterion 28 - Reactivity Limits 0 0

7. FýAR, Vectiol [ ]. 0 0 18.\ FSAI 0

SBAW-10179P-A, "Safety Criteria and Methodology for Acceptance Cycle Reload Analyses" (revision specified in Specification 5.6.3)

BAW-10122P-A, "Normal Operating Controls" (revision specified in Specification 5.6.3)

J1 BWOG STS B 3.2.1-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 31 of 132

Attachment 1, Volume 7, Rev. 1, Page 32 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, REGULATING ROD INSERTION LIMITS

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. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

3. Changes are made to reflect changes made to the Specification.

4. Changes are made to reflect the Specification.

5. The brackets have been removed and the proper plant specific information/value has been provided.

6. Davis-Besse was designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. The design of Davis-Besse meets the intent of 10 CFR 50, Appendix A published in the Federal Register on February 20, 1971, and as amended in Federal Register on July 7, 1971. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section of the UFSAR.

7. Editorial change corrected with no change in intent.

8. The ISTS 3.2.1 LCO Bases includes a discussion of "Actual Alarm Setpoints" for Regulating Rod insertion limits. This discussion is not included in the ITS LCO 3.2.1 Bases. The "Actual Alarm Setpoints" are not needed to satisfy the requirements of the LCO and therefore a discussion of the "Actual Alarm Setpoints" is not needed in the LCO Bases.

9. Changes are made to be consistent with other places in the Bases (i.e., LCO 3.2.5 Bases Background).

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 32 of 132

Attachment 1, Volume 7, Rev. 1, Page 33 of 132 Specific No Significant Hazards Considerations (NSHCs) 0 Attachment 1, Volume 7, Rev. 1, Page 33 of 132

Attachment 1, Volume 7, Rev. 1, Page 34 of 132 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, REGULATING ROD INSERTION LIMITS There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 34 of 132

Attachment 1, Volume 7, Rev. 1, Page 35 of 132 ATTACHMENT 2 ITS 3.2.2, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS Attachment 1, Volume 7, Rev. 1, Page 35 of 132

, Volume 7, Rev. 1, Page 36 of 132 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 1, Page 36 of 132

Attachment 1, Volume 7, Rev. 1, Page 37 of 132 ITS 3.2.2 ITS REACTIVITY CONTROL SYSTEMS AXIAL POWER SHAPING ROD INSERTION LIMITS LIMITING CONDITION FOR OPERATION LCO 3.1.3.9 The axial power shaping rod group shall be within the acceptable 3.2.2 Dperating limits for axial power shaping rod position specified in the CORE

)PERATING LIMITS REPORT.

MOl APPLICABILITY: MODES 1 and 2[t ACTION:

ACTION A With the axial power shaping rod group outside the'above'insertion limits, L01 either: proposed

a. Restore e axial power shaping rod group to within the limits RequiredActionA.

within 'hours, or 24

b. Red ce THERMAL POWER to ess than or equal to th t fraction of RATE THERMAL POWER whic is allowed by the rod g oup position using the acceptable oper ing limits provided in he CORE OPERATING A02 LIMITS REPORT within 2 hou , or ACTION B c. Be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

0 SUIRVEILLANI'E RUEOUIRVNFNTS SURVEILLANCE REQUIREME S SR 3.2.2.1 4.1.3.9 The position of the axial power shaping rod group shall be determined to be within the limits provided in the CORE OPERATING LIMITS REPORT at least onevery 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except when the-axial power shaping ro sertion limit 7 Falarm is inoper ble, then verify the group to be within the imit provided in/

the CORE OPER ING LIMITS REPORT at least once every 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . L I-Wih kf _.0 M01 DAVIS-BESSE. UNIT I 3/4 1-34 Amendment No. MR, VIAL, 00jl7144 (Next page is 3/4 2-1)

Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 37 of 132

Attachment 1, Volume 7, Rev. 1, Page 38 of 132

.DISCUSSION OF CHANGES ITS 3.2.2, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 In the event the APSRs are outside the operating limits specified in the CORE OPERATING LIMITS REPORT (COLR), CTS 3.1.3.9 Action b requires a reduction in THERMAL POWER to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the rod group position using the acceptable operating limits provided in the COLR within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , as one of three alternative actions. ITS 3.2.2 does not provide a comparable Required Action for this Condition. This change deletes the CTS Action to reduce THERMAL POWER to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the rod group position using the acceptable operating limits provided in the COLR within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , in the event that the APSRs are not within the limits provided in the COLR.

The COLR provides APSR insertion limits based on exposure. The APSR insertion limits are not based on THERMAL POWER. Therefore a reduction of the THERMAL POWER to less than or equal to that fraction of RATED THERMAL POWER which is allowed by the rod group position using the acceptable operating limits provided in the COLR is not an appropriate action.

This change is designated as administrative because it does not result in a technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 The Applicability of CTS 3.1.3.9 is MODE 1 and MODE 2 with the Applicability in MODE 2 modified by a footnote, designated as "#," stating "With keff > 1.0."

ITS 3.2.2 Applicability is MODE 1 and 2. The CTS is revised to delete the footnote.

The purpose of the footnote is to provide an allowance such that, when in MODE 2 with the reactor not critical, the APSR insertion limits are not applicable.

This change provides a more restrictive requirement, in that the APSR insertion limits are now applicable at all times in MODE 2. This change is acceptable because applying that requirement prior to bringing the reactor critical ensures the APSR are in the correct position when required so that the axial fuel burnup design conditions assumed in the reload safety analyses will be satisfied. This change is designated as more restrictive because the Applicability has been broadened to encompass all of MODE 2.

Davis-Besse Page 1 of 3 Attachment 1, Volume 7, Rev. 1, Page 38 of 132

Attachment 1, Volume 7, Rev. 1, Page 39 of 132 DISCUSSION OF CHANGES ITS 3.2.2, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS

. RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) In the event the APSRs are outside the operating limits specified in the COLR, CTS 3.1.3.9 Action a requires the APSRs to be restored to within the limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , as one of three alternative actions. ITS 3.2.2 ACTION A provides a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time to restore the APSRs to within limits and requires the performance of SR 3.2.5.1 (Verify FQ and FH are within limits by using the Incore Detector System to obtain a power distribution map) when THERMAL POWER is > 20% RTP once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by extending the Completion Time from "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months " to "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " and provides a requirement to verify FQ and F. H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The purpose of the CTS 3.1.3.9 Action a is to ensure that the APSRs are restored so that the axial burnup distribution that accumulates in the fuel will be consistent with the expected (as designed) distribution. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition. This change extends the Completion Time to restore APSRs to within insertion limits from "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months " to "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " and provides a requirement to verify FQ and FA H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Successful verification that F0 and FA H are within their limits ensures that operation with the APSRs inserted or withdrawn in violation of the times specified in the COLR do not violate either the ECCS or DNB criteria. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable to allow the operator to obtain a power distribution map and to verify the power peaking factors. Repeating SR 3.2.5.1 every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable to ensure that continued verification of the power peaking factors is obtained as core conditions (primarily the regulating rod insertion and induced xenon redistribution) change. Required Action A.1 is modified by a Note that requires the performance of SR 3.2.5.1 only when THERMAL POWER is greater than 20% RTP. This establishes a Required Action that is consistent with the Applicability of LCO 3.2.5, "Power Peaking Factors." Indefinite operation with the APSRs inserted or withdrawn in violation of the times specified in the COLR is not prudent. Even if power peaking monitoring is continued, the abnormal APSR insertion or withdrawal may cause an adverse xenon redistribution, may cause the limits on AXIAL POWER IMBALANCE to be exceeded, or may affect the long term fuel depletion pattern.

Therefore, power peaking monitoring is allowed for up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This required Completion Time is reasonable based on the low probability of an event occurring simultaneously with the APSR limit out of specification. In addition, it Davis-Besse Page 2 of 3 Attachment 1, Volume 7, Rev. 1, Page 39 of 132

Attachment 1, Volume 7, Rev. 1, Page 40 of 132 DISCUSSION OF CHANGES ITS 3.2.2, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS precludes long term depletion with the APSRs in positions that have not been analyzed, thereby limiting the potential for an adverse xenon redistribution. This time limit also ensures that the intended burnup distribution is maintained, and allows the operator sufficient time to reposition the APSRs to correct their positions. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L02 (Category7 - Relaxation of Surveillance Frequency - Non-24 Month Type Change) CTS 4.1.3.9 requires the position of the APSR group to be determined to be within the limits provided in the CORE OPERATING LIMITS REPORT (COLR) at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the APSR insertion limit alarm is inoperable.. With this alarm inoperable, CTS 4.1.3.9 requires the verification that the group is within the limit provided in the COLR at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS SR 3.2.2.1 requires verification that APSRs are within the acceptable limits specified in the COLR every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by eliminating the requirement to verify that the APSR group is within the limits provided in the COLR at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when the APSR insertion limit alarm is inoperable.

The purpose of CTS 4.1.3.9 is to periodically verify that the APSRs are within the limits specified in the LCO. This change is acceptable because increasing the Frequency of APSR insertion limit verification when the APSR insertion limit alarm is inoperable is unnecessary. An inoperability of the alarm does not increase the probability that the APSR insertion limits are not met. The routine 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency (ITS SR 3.2.2.1) continues to ensure the APSR insertion limits are met. Furthermore, the APSR insertion limit alarm is for indication only.

Its use is not credited in any safety analyses. Thus, any response determined necessary by plant personnel due to an inoperable alarm is more appropriately controlled by plant procedures, not Technical Specifications. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Davis-Besse Page 3 of 3 Attachment 1, Volume 7, Rev. 1, Page 40 of 132

Attachment 1, Volume 7, Rev. 1, Page 41 of 132 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 41 of 132

Attachment 1, Volume 7, Rev. 1, Page 42 of 132 APSR Insertion Limits

.2.2ý CTS 3.2 POWER DISTRIBUTION LIMITS 3.2.2 AXIAL POWER SHAPING ROD (APSR) Insertion Limits 3.1.3.9 LCO 3.2.12 APSRs shall be positioned within.the limits specified in the COLR.

APPLICABILITY: MODES 1 and.2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.1.3.9 *A. APSRs:not within limits. A.1 NOTE ------- --------------

Action a Only required when THERMAL POWER is

> 20% RTP.

Perform SR 3.2.5.1. Once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AND A.2 Restore APSRs to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months limits.

3.1.3.9 B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action c associated Completion Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.1.3.9 SR 3.2.2.1 Verify APSRs are within acceptable limits specified 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in the COLR..

BVW/OG STS 3.2.2-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 42 of 132

Attachment 1, Volume 7, Rev. 1, Page 43 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS None Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 43 of 132

Attachment 1, Volume 7, Rev. 1, Page 44 of 132 Improved Standard Technical Specifications (ISTS) Bases 40 Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 44 of 132

Attachment 1, Volume 7, Rev. 1, Page 45 of 132 APSR Insertion Limits, B 3.2 2 B 3.2 POWER DISTRIBUT-ION LIMITS B13.2.2 AXIAL POWER;SHAPING ROD (APSR) Insertion Limits BASES.

BACKGROUND The insertion limits of the APSRs are initial condition assumptions in all safety.analyses that are affected by core power distributions. The applicable criterion for these power distribution design requirements are 110 CFR 50, Appe-0, "Reactor Desi n' (Ref. 1),.and UFSAR, Appendices 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling [3D.1.6and3D.1.22 (U Systems for Light Water Nuclear Power Plants" (Ref. 2).

are specified in the COLR Limits on APSR insertion have ee stablishe , and all APSR positions are monitored and controlled during power operation to ensure that the power distribution defined by the design power peaking limits is maintained.

The powerdensity at any point in the core must be :limited to maintain

specifiedacceptable fuel design limits, including limits lthat meet the criteria specified in Reference 2. Together, LCO 3.2.1, "Regulating Rod Insertion Limits," LCO.3.2.2, 'AXIAL .POWER SHAPING ROD (APSR)

Insertion "Limits," LCO 3.2.3, "AXIAL. POWER. IMBALANCE Operating Limits," and LCO 3.24, "QUADRANT POWER TILT (QPT)," provide limits on control component operation and on monitored process variables to ensure that the core operates within the F0 I] and FA H limits in the COLR. Operation within the. FcD limits given in the COLR prevents 0 linear heat rate (LHR power peaks that. exceed the os--of coolant accident (LOCA)t limits 0 derived from the analysis of the Emergency Core Cooling Systems (ECCS). Operation within the FA H limits given in the .COLR prevents departure from nucleate boiling (DNB) duringa loss of forced reactor coolant flow accident. The APSRs are not required for reactivity insertion rate on trip or SDM and, therefore,. they do not trip upon:a reactor trip.

This LCO isrequired to minimize fuel 'cladding failures that would breach the primary fission product barrier and release fission products to the reactor coolant in the event of a LOCA, loss.of flow accident, ejected rod accident, or other postulated accident requiring termination by a Reactor

,Protection System trip function.

BWOG STS B 3.2.2-1 Rev. 3.0, 03/31/04 0

Attachment 1, Volume 7, Rev. 1, Page 45 of 132

Attachment 1, Volume 7, Rev. 1, Page 46 of 132 APSR Insertion Limits B 3.2.2 BASES.

APPLICABLE The fuel cladding' must not lsustain damage as a result of normal SAFETY operation:(Condition 1.) or anticipated operationalccurtrences ANALYSES (Condition 2). Acceptance criteria for the safety and regulating rod insertion, APSR position, AXIAL POWER IMBALANCE, 1arnd QPT LCOs' preclude core power distributions that Violate the followingfuel design criteria:

a. During aa LOCA, the peak cladding temperature must not' exceed 2200' F (Ref. 2 )4, 0

0

b. During a loss offorced reactor coolant: flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a DNB Li (Ref. 1) condition oO c, During an ejected rod accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref 3)Mpnd 0

d. CONTROL RODS must be capable of'shutting down the reactor with a minimum required SDM with the-highest worth CONTROL ROD stuck fully withdrawn GD 26,Ref. 0 Fuel cladding damage does not occur when the core is operated outside these LCOs during normal operation. However,.fuel cladding damage could result should an accident occur simultaneously with.violation of one-,

or more of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and corresponding increased 10calt 0

Operation at the APSR insertion limits may approach the~maximum allowable linear heat generation rate or peaking factor with the allowed QPT present.

The APSR insertion limits satisfy Criterion 2 of 10 CFR 50,36(c)(2)(ii).

BWOG STS B 3.2.2-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 46 of 132

Attachment 1, Volume 7, Rev. 1, Page 47 of 132 APSR Insertion Limits B133,2.:

BASES LCO The limits on APSR physical'insertion as defined in the COLR must be maintained because they serve:the function of controlling the power distribution within an acceptable, range, The fuel cycle design assumes APSR withdrawal at the effective full power days (EFPD)I burnupwindow specified in the COLR. Prior to this are maintained in accordance rod operationwith the Window, the APSRs cannoet-.be maintained-4illy withdrawn iJteady state to. After this window, the APSRs are not allowed to be reinserted 0 recommendations for the remainder of the fuel cycle.

Error adjusted na-um a wab e spoints for APSR insertion are 0 lI provided in the COLR. Thet sare derived, by adjustment of the measurement system independent limits to allow for THERMAL POWER level uncertainty and rod position errors.

Actual Alarm setpoints implenented in the unit may ke more restrictive than the ýhaximum allowable Xetpoint values to allow fr additional, conservatim between the act al alarm setpoints andt e measurement 0 svstem ind rendent limits. \ \

APPLICABILITY The APSR physical insertion limits shall be maintained with the reactor in MODES 1 and 2. These limits maintain the power distribution within the range assumed in the accident analysesý. In MOIW1, the limits on,AF S R Tfins!-tin spe-cified by t is LCO maintain the axial fdptl burnup design Icondyions assumed in tl reload safety evaluation ah~alysis. In MODE 2,/ 0

/applic~bility( is .required be' 'use kerr.--- 0.99./Applicability in MODES,3 4, and 5 is not required, because the power distribution assumptions inthe accident analyses would not be exceeded in these MODES.

ACTIONS For steady state power operation., a normal position for APSR insertioh is od operation ista opetin rodures The APSRs may be recommendations j positioneda.s necessary for transient AXIAL POWER IMBALANCE control Until the fuel cycle design requires them to be fully withdrawn.

(Not all fuel cycles may incorporate APSR withdrawal.) APSRIp n0 limits are not imposed for gray APSRs, with two exceptions. If the fuel

.cycle design incorporates an APSR withdrawal (usually near end of cycle

('ae s"* (EOC)),

osiioed the APSRs may pnotothefucyce not berma urup tained withdrawal.

for. the *PSR in the fullywit drawn position If tlisoccus the Iloperation th o APSRs must ýb.restored to their nortial inserted positioln/ Cn ersely; Srecommendations lafter the fuel cycle burnup for the APSR withdrawal occurs,.the APS:Rs

]before the withdrawal~cus1 may not be reinserted for the remainder of the fuel cycle. These restrictions apply to ensure the axial burnup distribution that accumulates in the fuel will be consistent with the expected (as designed) distribution.

BVVOG STS B 3.2.2-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 47 of 132

Attachment 1, Volume 7, Rev. 1, Page 48 of 132 APSR Insertion Limits B 3.2:2:

BASES ACTIONS .(continued)

A.1 For verification that the core parameters FQV) and N H arewithin their Iimits, SR 3.2.5.1 .is performed using the Incore Detector System to obtain a three dimensional power distribution map.. Successful verification that FQM'*and F'F,: are within their limits ensures.that operation with the APSRs inserted or withdrawn in violation of the times specified in the

(

COLR do not violate either the ECCSor DNB criteria (Ref.. A. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months isreasonable to allow the operator (D to obtain a power distribution map and to.verify the power peaking factors. Repeating.SR 3.2:5.1 every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable to ensure. that continued verification of the power peaking factors is obtained as core conditions (primarily the regulating rod insertion and induced xenon redistribution) change.

Required Action A.1 is modified by a Note.that requires the performance; of SR 3.2-.5.1 only when THERMAL POWER, is greater than 20% RTP.

This establishes a Required Action that is consistent with the Applicability of LCO 3.2.5, "Power Peaking Factors."

A.2 Indefinite operation with the APSRs inserted or withdrawn in Violation of the times specified in the COLR is not prudent. Even if power peaking monitoring per Required Action A.1 is continued, the abnormal APSR insertion or withdrawal may cause an adverse xenon redistribution, may cause the limits on AXIAL POWER IMBALANCE to be exceeded, or may affect the long term fuel depletion pattern. Therefore, power peaking monitoring is allowed for up to .24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This required Completion Time is reasonable based on the low probability of an event occurring simultaneously with the APSR limit out of specification. In .addition, it precludes long term depletion with the APSRs in positions that have not been analyzed, thereby limiting the potential for an adverse xenon redistribution. This time limit also ensuresthat the intended burnup distribution is maintained, and allows the operator sufficient time to reposition the APSRs to correct their positions.

Because the APSRs are not operated by the automatic control system, manual action by.the operator is required to restore the APSRs to the positions specified in the COLR.

BWVAOG STS B 3.2.2-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 48 of 132

Attachment 1, Volume 7, Rev. 1, Page 49 of 132 APSR Insertion Limits B 3.2.2 BASES ACTIONS (continued)

B.1 any Required Action and associated Completion Time is not met IJfthe \PSRs cannot be re tored~to. their intended:sitions withintheI requir d Completion Time cf 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ,the reactor must be placed in 0 MODE 3, in which this LCO does not apply. This action ensures that the fuel does not continue to be depleted in an unintended burnup distribution. The required Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience regarding the time required to reach MODE 3 from RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS Fuel cycle designs that allow APSR. withdrawal near EOC do not permit reinsertion of APSRS after the time of w~ithdrawal. Wen the plant acorruter is OPERABLE, the opb~ator wil receive .ac0 *puter alarm iftte lAPSI s insert after that time in corblife when ithe APS .R ithdra~wal-0 Ve~~rificto thateAPrr within their insertion limits at a 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency issufficient.to ensure that the APSR insertion limits are preservedland the, computer atarm remains aPERABLE[ The 0 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency required for performing this verification is sufficient because APSRs are, positioned by manual control and are normally moved infreque ntly* /The probab~t of a, deviation od-'urringý Isimultari~ously with an inoperable computer alarm is I1)w in this relatively 0 (D

Ishort tim6,frame. Also, *e Fre'q~ency~ta!kes.into Occount~other information available in the control roomrfor monitoring the axial power distribution in the reactor core.

REFERENCES 1.. 110CPR50, Appeni A, GDC.10 2 010CFR 46*--*--*FSAR, dGDC2.

Appendices 3D.1.6, Criterion 0

2. 10 CFR 50.46. .

10-Reactor Design and 3D.1.22, iCriterion 26 - Reactivity Control r-o-l

FSAR ¢*;E:T~ qSection 15.4.3 } System Redundancy and Capability, 3.- FSAR, j~a rer L* L "** ' 1 r F, AR, *haptr [ ].

[4. UFSAR, Appendix3-.1.23.

BAW-10179P-A, "Safety Criteria and Methodology for Acceptance Cycle Reload Analyses" (revision specified in Specification 5.6.3)

BWOG STS B 3.2.2-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 49 of 132

Attachment 1, Volume 7, Rev. 1, Page 50 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2 BASES, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS

1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which 0 reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

3. Changes are made to reflect the Specification.

4. The brackets have been removed and the proper plant specific information/value has been provided.

5. Davis-Besse was designed and under construction prior to the promulgation of 10 CFR 50, Appendix A. The design of Davis-Besse meets the intent of 10 CFR 50, Appendix A published in the Federal Register on February 20, 1971, and as amended in Federal Register on July 7, 1971. Bases references to the 10 CFR 50, Appendix A criteria have been replaced with references to the appropriate section of the UFSAR.

6. The ISTS LCO 3.2.2 Bases includes a discussion of "Actual Alarm Setpoints" for APSR insertion limits. This discussion is not included in the ITS LCO 3.2.2 Bases.

The "Actual Alarm Setpoints" are not needed to satisfy the requirements of the LCO and therefore a discussion of the "Actual Alarm Setpoints" is not needed in the LCO Bases.

7. Changes are made to be consistent with other places in the Bases (i.e., LCO 3.2.5 Bases Background).

8. Changes are made to reflect changes made to the Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 50 of 132

Attachment 1, Volume 7, Rev. 1, Page 51 of 132 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 1, Page 51 of 132

Attachment 1, Volume 7, Rev. 1, Page 52 of 132 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, AXIAL POWER SHAPING ROD (APSR) INSERTION LIMITS There are no specific NSHC discussions for this Specification.

0 Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 52 of 132

Attachment 1, Volume 7, Rev. 1, Page 53 of 132

ATTACHMENT 3 ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS Attachment 1, Volume 7, Rev. 1, Page 53 of 132

, Volume 7, Rev. 1, Page 54 of 132 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 1, Page 54 of 132

Attachment 1, Volume 7, Rev. 1, Page 55 of 132 ITS 3.2.3 ITS 3/4.2 POWER DISTRIBUTION LIMITS AXIAL POWER IMBALANCE LIMITING CONDITION FOR OPERATION LCO 3.2.1 AXIAL POWER IMBALANCE shall be maintained within the acceptable AXIAL I 3.2.3 POWER IMBALANCE operating limits provided in the CORE OPERATING LIMITS REPORT.

APPLICABILITY: MODE 1 above 40% of RATED THERMAL POWER.A ACTION:

ACTION A With AXIAL POWER IMBALANCE exceeding the limits, specified above, either: ReprActionAposed

a. Restore the AXIAL POWER IMBALANCE to wi h h limi s provided in the CORE OPERATING LIMITS REPORT within 15 m* ute , or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

_* * , hous L {L02 ACTION B b. WithinInnpnur reduce power until imbalance limits provided in the CORE OPERATING LIMITS REPORT are met or to 40% of RATED THERMAL POWER or less.

SURVEILLANCE REQUIREMENTS 4.2.1 The AXIAL POWER IMBALANCE shall be determined to be within the, limits provided in the CORE OPERATING LIMITS REPORT at least once every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months SR 3.2.3.1 when above 40% of RATED THERMAL POWER except/ when the AXIAL POWEý IMBALANCE alarm is inoperab Ke, then calculate the AXI POWER IMBALANCE a least once/ L03 per hour. / - 7

-See pecial t Exceptl 3.10.1. A02 DAVIS-BESSE, UNIT I 3/4 2-1 Amendment No. ,

(Next page is 3/4 2-5) .0,;23, 144 Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 55 of 132

Attachment 1, Volume 7, Rev. 1, Page 56 of 132 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The Applicability of CTS 3.2.1 is MODE 1 above 40% RATED THERMAL POWER with footnote

stating "See Special Test Exception 3.10.1 ." ITS 3.2.3 Applicability is MODE 1 above 40% RATED THERMAL POWER and does not contain the footnote or a reference to the Special Test Exception. This changes the CTS by deleting explicit reference to the Special Test Exception.

The purpose of the footnote reference is to alert the user that a Special Test Exception exists that may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative as it incorporates an ITS convention with no technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category3- Relaxation of Completion Time) CTS 3.2.1 Action a requires the restoration of AXIAL POWER IMBALANCE to be within limits within 15 minutes.

ITS 3.2.3 ACTION A requires the performance of ITS SR 3.2.5.1 (Verify F0 and FIH are within limits by using the Incore Detector System to obtain a power distribution map) once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and the restoration of the AXIAL POWER IMBALANCE to within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by extending the Completion Time from "15 minutes" to "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " and provides a requirement to verify FQ and FA H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

Davis-Besse Page 1 of 4 Attachment 1, Volume 7, Rev. 1, Page 56 of 132

Attachment 1, Volume 7, Rev. 1, Page 57 of 132 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS The purpose of CTS 3.2.1 Action a is to restore AXIAL POWER IMBALANCE to ensure that the axial burnup distribution that accumulates in the fuel will be consistent with the expected (as designed) distribution. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering a reasonable time for restoration and the low probability of a DBA occurring during the allowed Completion Time. This changes the CTS by extending the Completion Time to restore AXIAL POWER IMBALANCE operating limits from "15 minutes" to "24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " and provides a requirement to verify FQ and F' H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The AXIAL POWER IMBALANCE operating limits that maintain the validity of the assumptions regarding the power distributions in the accident analyses of the LOCA and the loss of flow accident are provided in the COLR. Operation within the AXIAL POWER IMBALANCE limits given in the COLR is the acceptable region of operation. Operation in violation of the AXIAL POWER IMBALANCE limits given in the COLR is the restricted region of operation. Operation with AXIAL POWER IMBALANCE in the restricted region shown on the AXIAL POWER IMBALANCE figures in the COLR potentially violates the LOCA LHR limits (FQ limits) or the loss of flow accident DNB peaking limits FA H limits) or both. For verification that FQ and FH. are within their specified limits, SR 3.2.5.1 is performed using the Incore Detector System to obtain a three dimensional power distribution map. Verification that F0 and FA H are within their specified limits ensures that operation with the AXIAL POWER IMBALANCE in the restricted region does not violate the ECCS or 95/95 DNB criteria. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months provides reasonable time for the operator to obtain a power distribution map and to determine and verify that the power peaking factors are within their specified limits. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Frequency provides reasonable time to ensure that continued verification of the power peaking factors is obtained as core conditions (primarily regulating rod insertion and induced xenon redistribution) change, because little rod motion occurs in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months due to fuel burnup, the potential for xenon redistribution is limited, and the probability of an event occurring in this short time frame is low. Indefinite operation with the AXIAL POWER IMBALANCE in the restricted region is not prudent. Even if power peaking monitoring per Required Action A.1 is continued, excessive AXIAL POWER IMBALANCE over an extended period of time may cause a potentially adverse xenon redistribution to occur. Therefore, power peaking monitoring is only allowed for a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This required Completion Time is reasonable based on the low probability of a limiting event occurring simultaneously with the AXIAL POWER IMBALANCE outside the limits of this LCO. In addition, this limited Completion Time precludes long term depletion of the reactor fuel with excessive AXIAL POWER IMBALANCE and gives the operator sufficient time to reposition the APSRs or regulating rods to reduce the AXIAL POWER IMBALANCE because adverse effects of xenon redistribution and fuel depletion are limited. This change is designated as less restrictive because additional time is allowed to restore AXIAL POWER IMBALANCE to within the LCO limits than was allowed in the CTS.

L02 (Category 3 - Relaxation of Completion Time) In the event the AXIAL POWER IMBALANCE exceeds the limits, CTS 3.2.1 Action b requires power to be reduced until the imbalance limits are met or to be < 40% RTP within one hour, as one of two alternative actions. ITS 3.2.3, Required Action B.1 requires Davis-Besse Page 2 of 4 Attachment 1, Volume 7, Rev. 1, Page 57 of 132

Attachment 1, Volume 7, Rev. 1, Page 58 of 132 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS THERMAL POWER to be reduced to _< 40% RTP within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if the Required Actions and Completion Times of Condition A (AXIAL POWER IMBALANCE not within limits) are not met. This change revises the CTS Action by extending the total time allowed to reduce THERMAL POWER to < 40% RTP from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months (the Required Actions of ITS 3.2.3 Condition A provides a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Times prior to Condition B being entered). The justification for the Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is discussed in Discussion of Change L01.

The purpose of the CTS 3.2.1 Action b is to ensure that the AXIAL POWER IMBALANCE is restored so that the assumptions regarding the power distributions in the accident analyses are valid or to be in a condition where the AXIAL POWER IMBALANCE limits are not applicable. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. This change revises the CTS Action by extending the total time allowed to reduce THERMAL POWER to _<40% RTP from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 26 hours3.009259e-4 days 0.00722 hours 4.298942e-5 weeks 9.893e-6 months (the Required Actions of ITS 3.2.3 Condition A provides a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Times prior to Condition B being entered). The acceptability of the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is justified in DOC L01. This change is concerned with the relaxation of the Completion Time to reach 40% RTP from "one hour" to "2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ." The revised Completion Time allows reactor power to be reduced in a controlled manner without challenging operators or plant systems. This change is designated as less restrictive because additional time is allowed to reduce power than was allowed in the CTS.

L03 (Category 7- Relaxation of Surveillance Frequency - Non-24 Month Type Change) CTS 4.2.1 requires the AXIAL POWER IMBALANCE to be determined to be within operating limits at least once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months except during time intervals when the AXIAL POWER IMBALANCE alarm is inoperable. With this alarm inoperable, CTS 4.2.1 requires the verification that AXIAL POWER IMBALANCE is within limits at least once per hour. ITS SR 3.2.3.1 requires verification that AXIAL POWER IMBALANCE is within limits every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This changes the CTS by eliminating the requirement to verify that AXIAL POWER IMBALANCE is within the limits at least once per hour when the AXIAL POWER IMBALANCE alarm is inoperable.

The purpose of CTS 4.2.1 is to periodically verify that the AXIAL POWER IMBALANCE is within the limits. This change is acceptable because increasing the Frequency of AXIAL POWER IMBALANCE operating limit verification when the AXIAL POWER IMBALANCE alarm is inoperable is unnecessary. An inoperability of the alarm does not increase the probability that the AXIAL POWER IMBALANCE limits are not met. The routine 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency (ITS SR 3.2.3.1) continues to ensure the AXIAL FLUX IMBALANCE limits are met.

Furthermore, the AXIAL POWER IMBALANCE limit alarm is for indication only.

Its use is not credited in any safety analyses. Thus, any response determined necessary by plant personnel due to an inoperable alarm is more appropriately controlled by plant procedures, not Technical Specifications. This change is Davis-Besse Page 3 of 4 Attachment 1, Volume 7, Rev. 1, Page 58 of 132

Attachment 1, Volume 7, Rev. 1, Page 59 of 132 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Davis-Besse Page 4 of 4 Attachment 1, Volume 7, Rev. 1, Page 59 of 132

Attachment 1, Volume 7, Rev. 1, Page 60 of 132 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 60 of 132

Attachment 1, Volume 7, Rev. 1, Page 61 of 132 AXIAL POWER, IMBALANCE Operating Limits 3.2.3 CTS 3.2 POWER DISTRIBUTION LIMITS 3;2.3 AXIAL POWER IMBALANCE Operating Limits 3.2.1 LCO 3.2.3 AXIAL POWER IMBALANCE shall be-maintained *within the limits specified in the COLR.

APPLICABILITY: MODE 1 with THERMAL POWER > 40% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.2.1 Action a A. AXIAL POWER A;1 Perform SR 3.2.5.1. Once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months IMBALANCE not within limits. AND A;2 Reduce AXIAL POWER 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months IMBALANCE within limits.

c2 .tilonb B. Required Action and B.1 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months associated Completion POWER to

40% RTP.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.2.1 SR 3.2.3.1 Verify AXIAL POWER IMBALANCE is within limits 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months as specified in the COLR.

BWOG STS 3.2.3-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 61 of 132

Attachment 1, Volume 7, Rev. 1, Page 62 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS None.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 62 of 132

Attachment 1, Volume 7, Rev. 1, Page 63 of 132 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 63 of 132

Attachment 1, Volume 7, Rev. 1, Page 64 of 132 AXIAL POWER IMBALANCE Operating Limnits B 3.2.3 B 32 POWER, bISTRIBUTION LIMITS B:3.2.3 AXIAL POWER IMBALANCE Operatling Limits BASES BACKGROUND, This LCO is required to limit the core power distributionbased on accident initial condition criteria.

The power density at any point in the core must be limited to maintain specified acceptable fuel design limits, including limitsthat satisfy the criteria specified in 10 CFR 50.46 (Ref. 1). This LCO provides limitson:

AXIAL POWER IMBALANCE to ensure that the core operates.within the FaM and FN H limits given in the COLR. Operation within the FC(]limits 0 given in the COLR prevents power peaks that exceed the loss of coolant linear heat rate (LH accident (LOCA)tlimits derived from the analysis of the Emergency Core Cooling Systems (ECCS), Operation within the FAH limits given in the COLR prevents departure from nucleate boiling (DNB) during a loss of forced reactor coolant flow accident.

This LCO is required to limit fuel cladding failures that breach the primary fission product barrier and release .fission products into the reactor coolant in the :event of a LOCA, loss oftforced reactorcoolant flow accident, or other postulated accident requiring termination by a Reactor.

Protection System trip function. *This LCO limits~the amount of damage to the fuel cladding during an accident by maintaining the. validity of the assumptions in the safety analyses related to the initial powerdistribution and reactivity.

Fuel cladding failure during a postulated LOCA is limited by restricting the maximum linear heat rate. (LHR) so that the peak cladding temperature does not exceed 2200'F (Ref. 2). Peak cladding temperatures > 22000 F cause severe cladding failure by oxidation due to a Zircaloy water reaction. Other criteria must also be met (e~g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling). However, peak claddingtemperature is usually most limiting.

Proximity to the DN B condition is expressed by the departure from nucleate boiling ratio (DNBR), defined as the ratio of the cladding surface heat flux required to cause. DNB to the actual cladding surface heat flux.

The minimum DNBR Value during both normal operation and anticipated transients is limited to the DNBR correlation limitfor the particular fuel design in use and is accepted as an appropriate margin to DNB. The DNB correlation limit ensures that there is at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the, core does.not experience DNB, BVAOG STS. B 3.2.3-1 Rev. 3.0, 03/31/04:

Attachment 1, Volume.7, Rev. 1, Page 64 of 132

Attachment 1, Volume 7, Rev. 1, Page 65 of 132 AXIAL POWER IMBALANCE Operating Limits.

B 3..2.3 BASES BAC KGROUND :(continued)

The measurement system independent limits on AXIAL POWER

IMBALANCE are determined directly by the reload safety evaluation analysis without adjustment for measurement system error and

,uncertainty. Operation .beyond these limits could invalidate'the

,assumptions used in the accident analyses regarding the core power distribution.

APPLICABLE The fuel cladding must not sustain damage as a result of, normal SAFETY operation (Condition 1) and anticipated operational occurrences ANALYSES (Condition 2). The LCOs based o~n powerdistribution, LCO 3.2.1, "Regulating Rod Insertion Limits," LCO 3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits," LCO 3.2.-3, "AXIAL POWER IMBALANCE

.Operating Limits,'.' and LCO 3.2.4, "QUADRANT POWER TILT (QPT),"

preclude core power distributions that would violate the. following fuel design criteria:

"a. During a rLOCA, peak cladding temperature must not 40 exceed 2200°F (Ref.

(D b.. During a lossof.forced reactor~coolant flow accident, there must be at least a 95% probability at the 95% confidence level (the 95/95 DN B criterion) that the, hot fuel rod in the core does not experience a DNB condition@._ _

"* [ INSERT 1] 0

The regulating rod positions, the APSR positions, the AXIAL POWER.

IMBALANCE, and the QPT are process variables that characterize and control the three dimensional power distribution of the reactor core.

.Fuel cladding damage does not occur when the core .is operated outside:

this, LCO during normal operation. However, fuel cladding damage could result should an accident occur with simultaneous violation of one or

.more of the. LCOsgoverning~the four process variables cited above. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and corresponding increased local LHRs.

BWOG STS B 3.2.3-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 65 of 132

Attachment 1, Volume 7, Rev. 1, Page 66 of 132 B 3.2.3 OINSERT I

c. During an ejected rod accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. 3); and

d. The CONTROL RODS must be capable of shutting down the reactor with a minimum required SDM with the highest worth CONTROL ROD stuck fully withdrawn (Ref. 4).

0 Insert Page B 3.2.3-2 Attachment 1, Volume 7, Rev. 1, Page 66 of 132

Attachment 1, Volume 7, Rev. 1, Page 67 of 132 AXIAL POYWER IMBALANCE Operating Limits B 3.2.*31 BASES APPLICABLE SAFETY ANALYS ES (continued).

The regulating rod insertion, the APSR positions, the AXIAL POWER IMBALANCE, and the QPT.are monitored and controlled during power operation to-ensure that the power distribution is Within the bounds set by the safety analyses. The axial power distribution is maintained, primarily bythe AXIAL POWER IMBALANCE~and the APSR p i mits;. and 2 the radial power distribution is maintained primarily by the QPT limits.,

The regulating rod insertion limits affect both the radialand axial power, distributions.

The dependence of the core power distribution on burnup, regulating rod insertion, APSR.position, and spatial xenon distribution is taken into account when the reload safety evaluation analysis is performed.

Operation at the AXIAL POWER IMBALANCEilimit must be interpretedcas operating the core at the maximum allowable FCM or FH peaking, factors assumed as initial conditions for the accident analyses with the allowed QPT present.

AXIAL POWER IMBALANCE satisfies Criterion 2o0f 10 CFR 50.36(c)(2)(ii).

LCO The power distribution LCO limits have been established based on correlations between power peaking and easily measured process variables: regulating rod position, APSR position, AXIAL POWER IMBALANCE, and QPT. The AXIAL POWER IMBALANCE envelopem (j contained in the COLR represents the setPintsor w ic t e core power distribution would either exceed the LOCA LHR limitsior cause a reduction in the DN BR below the Safety Limit during the loss of flow accident with the allowable QPT present and with the: APSR positions consistent with the limitations on APSR withdrawal determined by the fuel cycle design and specified by LCO 3.2.2.

Operat on beyond the pow r distribution based LC limits.for the corresp nding ALLOWABL THERMAL POWER a di.simultaneous occurren e~of either the LO or loss of forced reac rcoolant flow accident as an acceptably-lo probability. Therefor if the LCO limits are violatel, ashort time is all wed for corrective actio before a 0

significant ower reduction is r quired.

BVVOG STS B 3.2.3-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 67 of 132

Attachment 1, Volume 7, Rev. 1, Page 68 of 132 AXIAL POWER IMBALANCE Operating Limits; B 3.2.3 BASES L'OC (continued)

The AXIAL POWER IMBALANCE Ima mum aNwable s ints:

ý(measurement system dependent limits) applicable for the IfW Incore Detector Systemnthe Minimum Ihtore Detecto System, and the Excore Detector System are provided in the COLR.

Actual arm setpoints imple ented in the. unit may e more restrictive than the aximum allowable etpoint values to provi e additional conservat m between the act al alarm setpoints and' e measurement system indpendent limit.

0 APPLICABILITY In MODE 1, the limits on AXIAL POWER IMBALANCE must be maintained when THERMAL POWER is > 40% RTPto preventthe core..

power distribution from exceeding the LOCA and loss of flow assumptions used in the accident analyses. Applicability of these limits at < 40%1 RTP in MODE 1 is not required. This operation is acceptable because the

combination of AXIAL POWER IMBALANCE with the maximum allowable THERMAL POWER level will not result in LHRs sufficiently largeto:

violate the fuel design limits. In MODES 2, 3, 4, 5, and 6, this LCO is not applicable because the reactor is not generating sufficient THERMAL.

.POWER. to produce fuel damage.

in MODE 1, it may be necessary to suspend the AXIAL POWER

.IMBALANCE limits during PHYSICS TESTS per LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 1 ." Suspension of these limits is permissible because the reactor protection criteria are maintained by the remaining LCOs.governing the three dimensional power distribution and by the Surveillances required by LCO 3.1.8.

ACTIONS A.1 The AXIAL POWER IMBALANCE operating limits that maintain the validity of the assumptions regarding the power distributions in the accident analyses of the LOCA and the loss of flow accident are provided in the COLR. Operation within the AXIAL POWER IMBALANCE limits given in the COLR is the acceptable region of operation. Operation. in violation of the AXIAL POWER IMBALANCE limits given in the COLR is, the restricted region of operation.

Operation with AXIAL POWER IMBALANCE in the restricted region shown on the AXIAL POWER IMBALANCE figures in the COLR potentially violatesthe LOCA LHR limits (Fog)] limits) or the loss:of flow 0

accident DNB peaking limits F,, limits) or both. For verification that BVVOG STS B 3.2.3-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 68 of 132

Attachment 1, Volume 7, Rev. 1, Page 69 of 132 AXIAL POWER: IMBALANCE Operating Limits B 3.2.3

. BASES ACTIONS (continued)

FQ and ýF.* H are;within their Specified limits, SR 3.2.5.1 is performed Using the Incore Detecto.r System to obtain a three dimensional power distribution map. Verification that FQ*]and .FH are within their specified limits ensures that operation with the. AXIAL: POWER IMBALANCE in the restricted region does not violate the ECCSor 95/95 DNB criteria. The required'Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , provides reasonable time for the operator0to obtain a power distribution map and to determine and verify that the power peaking factors are within their specified limits. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Frequency provides reasonable time .to ensure that continued verification of the power peaking factors isobtained as core conditions (primarily

.regulating rod insertionand induced xenon redistribution) change, becausedlittle rod motion occurs.in 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months due to fuel burnup, the potential for'xenon redistribution is limited, and the probability of an event.

occurring in this short time frame is low.

A.2 Indefinite operation with the AXIAL POWER IMBALANCE in the restricted region is not prudent. Even if power peaking monitoring per Required Action A..1 is continued, excessive AXIAL POWER IMBALANCE over an extended period of time~may cause a potentially adverse xenon redistribution tooccur. Therefore, power peaking monitoring is only allowed for a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This required Completion Time is reasonable based on the low probability of a limiting event occurring simultaneously with the AXIAL POWER IMBALANCE outside the limits of this LCO. In addition, this limited Completion Time precludes long term depletion of the reactor fuel with excessive AXIAL POWER IMBALANCE and gives the operator.sufficient time to reposition the APSRs or regulating rods'to reduce the AXIAL POWER IMBALANCE because adverse effects.of xenon redistribution and fuel depletion are limited.

.B.1.

any If t e Required Actiorj and[Re associated Completion Time§ exc(ed isn tnot bmet,,.the AXIAL POWER IMBALANCE may. exceed its:specified limits and the reactor may be~operating with a global axial power distribution mismatch. Continued operation in this configuration may induce an.axial xenon oscillation and may result in an increased linear heat generation rate when the xenon redistributes. Reducing O BWOG STS B 3.2.3-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 69 of 132

Attachment 1, Volume 7, Rev. 1, Page 70 of 132 AXIAL POWER IMBALANCE Operating, Limits B 3.2.3

. BASES ACTIONS '(continued)

THERMAL POWER to_. 40% RTP reduces, the maximum LHRto a value that does not exceed the,Fc and FN H initial condition limits assumed in 0 the accident analyses, The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable based on limiting a potetially adverse xenon redistribution,

,the low: probability of an accident occurring in this relatively short time period, and the number of steps .required to complete this Action.

SURVEILLANCE The AXIAL POWER IMBALANCE can be monitored by both the Incore REQUIREMENTS and Excore Detector Systems. The AXIAL POWER IMBALANCE limits maximum allowable"]etlýints are derived, from their corresponding measurement system independent:limits by adjusting for both the system observability errors and instrumentation errors; Although they may be based on the same measurement system independent limits, the setpoints for the different systems are not identical because of differences in the errors applicable for each of these systems. The uncertainty amaximum analysis that defines the required error adjustment to convert the allowable limits measurement system independent limits to a arm t oints assumes that incre 7-5% of-t e detectors in each quadrant are OPERABLE. Detectors located orl the cre major:axes pre assumned to contrbt one half of their/

0upuo ehqudrant; dete cc*s in the c Ienter asEmbt r assumed jto/

Indore DeeForý Sytm, contribute dne quarter measurem POWER IMB*ALANCE to each the of their ou9ututst.using quadrant. Fo IAL the Minimur Incore Detector. Syste* consists of OPERABLE7 *etectors .

. configured ýa follows- F a.. Ni detectors shall be rranged suchthat there re three detectors in e Ch of three strings a d there are three detect rs lying in the same axial plane,: with on plane: at the core midpl e and one plane in eac axial core half, bT i haxiai planes in eachcore halt shall be sym trica aou he Core idplarie, and.

c. T detector strin" shall not have ra al symmetry.

Figure 3.2.3-1 (Minimum I3coreDetectorSystemf AXIAL POWER IMBALA CE Measurement)ý epicts an example of thi configuration.

This arra gementis chosen t reduce the uncertainty i the measure ent of the AXIAL P .WER IMBALANCE by th Minimum Incore Detector S stem. For example, the requirement for pla cng one detector of each of t e three. strings at th core midplane puts thr detectors in BWOG STS B 3.2.3-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 70 of 132

Attachment 1, Volume 7, Rev. 1, Page 71 of 132 AXIAL POWER IMBALANCE Operating Limits B 32.3 BASES SURVEILLANCE REQUIREMENTS (continued) the ce ral region of the cor, where the neutron flux t nds: to be higher. It also hel s prevent measurin an AXIAL POWER IMB"LANCE that is

.excessi ly large-whenthe re ctor is operating at low HERMAL POWER vels. The third req 'rement for placement of etectors (i.e.,

0 radial asy metry) reduces-unc rtainty.by rreasuring the, 'eutronflux at core Iocati* ns that are not radia symmetric.

SR 3.2.3.1 Verification of the AXIAL POWER IMBALANCE 'indication every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ensures that the AXIAL POWER IMBALANCE-limits are not violated and takes into account other information ndarms available to.the operator in the control room. This Surveil ance.Frequency s acceptable because 0 the mechanisms.that can cause AXIAL POWER IMBALANCE, such as xenon redistribution or CONTROL ROD drive mechanism malfunctions that cause slow AXIAL POWER IMBALANCE in creases, can be:

discovered by the operator before the specified limits are violated.

REFERENCES 1. 10 CFR50.46.

2. [-SAR,lChap r [15]. Section 6.3 C(

(DG

3. UFSAR, Section 15.4.3.

4p UFSAR, Appendix 3D.1.23, Criterion 27 - Combined Reactivity Control Systems Capability.

Kj 'b BWOG STS B 3.2.3-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 71 of 132

0 , Volume 7, Rev. 1, Page 72 of 132

Attachment 1, Volume 7, Rev. 1, Page 73 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL POWER IMBALANCE OPERATING LIMITS

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. Changes are made to reflect other places in the Bases.

3. Changes are made to reflect changes made to the Specification.

4. 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.

5. The brackets have been removed and the proper plant specific information/value has been provided.

6. Changes are made to be consistent with other places in the Bases (i.e., LCO 3.2.5 Bases Background).

7. The ISTS LCO 3.2.3 Bases includes a discussion of "Actual Alarm Setpoints" for AXIAL POWER IMBALANCE operating limits. This discussion is not included in the ITS LCO 3.2.3 Bases. The "Actual Alarm Setpoints" are not needed to satisfy the requirements of the LCO and therefore a discussion of the "Actual Alarm Setpoints" is not needed in the LCO Bases.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 73 of 132

Attachment 1, Volume 7, Rev. 1, Page 74 of 132 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 1, Page 74 of 132

Attachment 1, Volume 7, Rev. 1, Page 75 of 132 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AXIAL POWER IMBALANCE OPERATING LIMITS There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 75 of 132

Attachment 1, Volume 7, Rev. 1, Page 76 of 132

ATTACHMENT 4 ITS 3.2.4, QUADRANT POWER TILT (QPT) 0 Attachment 1, Volume 7, Rev. 1, Page 76 of 132

, Volume 7, Rev. 1, Page 77 of 132 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 1, Page 77 of 132

Attachment 1, Volume 7, Rev. 1, Page 78 of 132 ITS 3.2.4 ITS POWER OISTRIBUTION LIMITS,

ýQUADRANT POWER TILT LIMITING CONDITION FOR OPERATION LCO 3.2.4 THE QUADRANT POWER TILT shall not exceed the Steady State. Limit for 3.2.4 QUADRANT POWER TILT provided in the CORE OPERATING LIMITS REPORT.

APPLICABILITY: MODE I above 1 of RATED THERMAL POWER ACTION:

a. With the QUADRANT POWER TILT determined to exceed the Steady State Limit but less. than or equal to the Transient Limit provided in the CORE OPERATING LIMITS REPORT: Add proposed t iter reduce the"NUADRANT POWR TI! o within its, stea;Mlv State Limit.\orA0 b) Reduce THERMAL POWER so as not to exceed THERMAL POWER, ACTION A - -- power includingpump level cutoff, allowable.for the reactor coolant combination less at least 2% for each 1% of QUADRANT POWEB TILT in excess of the Steadj State Limit L02 and withlnLj~jours. reduce the High Flux Trip Setpoint

and th Flux-b Flux-Flow Trip Setpoint at least 2% for each 1% of QUADRANT POWER TILT in excess of the Steady State Limit.

2. Verify that the QUADRANT POWER TILT is within its Steady State Limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after exceeding the Steady State Limit o reduce THERMAL POWER to less than 60% of THERMAL POWER allowable for the reactor coolant pump combination within the ACTION C next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the High Flux Trip Setpoint to < 65.5%

of THER14AL POWER allowable for the reactor coolant pump .

combination within the [e~hour.

SR 3.2.4.1 3. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION

'above 60% of THER4AL POWER allowable for the reactor coolant pump combination may proceed provided that the QUADRANT POWER TILT is verified within its Steady State Limit at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or until verified acceptable at 95% or greater RATED THERMAL POWER.

AdProposed ACTION DJ M01*

see ecial Te Exception .10.1.

DAVIS.BESSE, UNIT I 3/4 2-9 Amendment No. ;Z3,144 Page 1 of 3 Attachment 1, Volume 7, Rev. 1, Page 78 of 132

Attachment 1, Volume 7, Rev. 1, Page 79 of 132 ITS 3.2.4 ITS POWER DISTRIBUTION LIMITS LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

b. With the QUADRANT POWER TILT determined to exceed the Transient Limit but less than the Maximum Limit 'provided in the CORE OPERATING LIMITS ACTION B -

REPORT, due to misalignment of either a safety, regulating or axial power shaping rod:

I

1. Reduce THERMAL POWER at least 2% for each 1% of indicated QUADRANI T POWER TILT in excess of the Steady State Limit within 30 minutes.

.2. Verify that the QUADRANT POWER TILT is within its Transient Limit w 2hous afer exeedin the. Transient Limit or -reduce THERMAL POWER to less than 60% of THERMAL POWER allowable for the ACTION C 4 reactor coolant pump combination within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the.High Flux'Trip Setpoint .to< 65.5% of THERMAL POWER allowable for the reactor'coolant pump-combination within the ours.L03 SR 3.2.4.1 3. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 60%

of THERMAL POWER allowable for the reactor coolant pump combina.

tion may proceed provided that the QUADRANT POWER TILT is verified within its Steady State Limit at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or until verified acceptable at 95% or greater RATED THENMAL POWER

c. With the QUADRANT POWER TILT determined to exceed the Transient Limit ACTION C but less than the Maximum Limit provided in the CORE OPERATING LIMITS REPORT, due to causes other than the misalignment of either a safety, regulating or axial power'shaping rod: I

1. Reduce THERMAL POWER to less than 60% of THERMAL POWER allowable for the reactor coolant pump combination within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and reduce the High Flux Trip Setpoint to < 65.5% of THERMAL POWER allowable for the reactor coolant pump combination within the n hours. L03 TR 3.2.4.1 2. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 60%

of THERMAL POWER allowable for the reactor coolant pump combina-tion may proceed provided that -the QUADRANT POWER TILT is verified within its Steady State Limit at least once per hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months or until verified at 95% or greater RATED THERMAL POWER.

Add proposed ACTION D M0-DAVIS-BESSE, UNIT 1 3/4 2-10 Amendment No. ;Z3j.7 , 144 Page 2 of 3 Attachment 1, Volume 7, Rev. 1, Page 79 of 132

Attachment 1, Volume 7, Rev. 1, Page 80 of 132 ITS 3.2.4 ITS POWER DISTRIBUTION LIMITS

,LIMITING CONDITION FOR OPERATION (Continued)

ACTION: (Continued)

ACTION D d. With the QUADRANT POWER TILT determined, to exceed the Maximum Limait provid d in the CORE OPERATING LIMITS REPORT, reduce THERMAL POWER to RTDTHERMAL POWERwithin 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

SURVEILLANCE REQUIREMENTS SR 3.2.4.1 4.2.4 The QUADRANT POWER TILT shall be determined to be < the Steady State.

Limits provided in the CORE.OPERATING LIMITS REPORT at least once every i 7 days durinn operation above q of RATED THERMAL POWER excep w en. e- L01 TQUADRAIiT POWER TAT alarm is inopera e, then the QUADRANT POWE. TILT shall be cuated a least once per 12 urs.'

L04 DAVIS-BESSE, UNIT I 3/4 2-11 Amnendment No. )ZA,144 (Next page Is 3/4.2-13)

Page 3 of 3 Attachment 1, Volume 7, Rev. 1, Page 80 of 132

Attachment 1, Volume 7, Rev. 1, Page 81 of 132 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT (QPT)

ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

A02 The Applicability of CTS 3.2.4 is modified by footnote

stating "See Special Test Exception 3.10.1." ITS 3.2.4 Applicability does not contain the footnote or a reference to the Special Test Exception.

The purpose of the CTS 3.2.4 footnote

reference is to alert the user that a Special Test Exception exists which may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as an administrative change since it does not result in technical changes to the CTS.

A03 CTS 3.2.4 Action a.1 .a states that with QPT determined to exceed the Steady State Limit but less than or equal to the Transient Limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to reduce the QPT to within its Steady State Limit. ITS 3.2.4 does not contain a Required Action stating QPT must be reduced to within its limit.

This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action and it is the convention in the ITS to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as an administrative change since it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.2.4 Action a.2, Action b.2, and Action c.1 do not provide any default actions to exit the Applicability of the Specification if any of the Required Actions are not met. If those actions are not complete, CTS 3.0.3 would be entered requiring entry into Hot Standby (MODE 3) within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . However, since the Applicability of CTS 3.2.3 is MODE 1 with THERMAL POWER > 15% RTP, the power reduction would only be to 15% RTP. ITS 3.2.4 ACTION D requires a THERMAL POWER reduction to < 20% RTP within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This changes the CTS by requiring THERMAL POWER to be reduced to outside of the Applicability of the Specification from 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The change from 15% RTP to 20% RTP is discussed in DOC L01.

The purpose of requiring a reduction of THERMAL POWER is to place the plant in a condition where the requirements for QPT limits are not required. This change is acceptable because it provides an adequate period of time to correct the condition or be in a MODE in which the requirement does not apply. The Davis-Besse Page 1 of 5 Attachment 1, Volume 7, Rev. 1, Page 81 of 132

Attachment 1, Volume 7, Rev. 1, Page 82 of 132 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT (QPT)

Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable for reaching < 20 % RTP from full power in an orderly manner and without challenging unit systems. This change has been designated as more restrictive because it reduces the Completion Time to be outside of the Applicability of the Specification.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category2 - Relaxation of Applicability) CTS 3.2.4 is applicable in MODE 1 above 15% RTP. In addition, due to this Applicability, when the QPT is exceeding the Maximum Limit in the COLR, CTS 3.2.4 Action d requires a power reduction to < 15% RTP. Furthermore, CTS 4.2.4, the QPT Surveillance, is required when above 15% RTP. ITS 3.2.4 is applicable in MODE 1 when > 20%

RTP. Under similar conditions as in the CTS, ITS 3.2.4 ACTION D requires a reduction in power to < 20% RTP. Furthermore, ITS SR 3.2.4.1 is applicable when > 20% RTP. This changes the CTS by changing the Applicability of the QPT requirement from > 15% RTP to >20% RTP.

The purpose of the QPT limits is to assist in preventing the core power distribution from exceeding the design limits. This change is acceptable because the proposed 20% RTP Applicability limit will continue to ensure the core power distribution will not exceed the design limits. At power levels at or below 20%

RTP, tilt limitations are unnecessary. Since tilt is a measure of the increase in quadrant radial power relative to average quadrant power, large tilts can result from small deviations in core quadrant powers when the reactor is operating at low power. Requiring tilt monitoring at 20% RTP provides a conservatively low power limit for Applicability. Operation below 20% RTP with a QPT up to 20% is acceptable because the resulting maximum linear heat rate (LHR) is not high enough to cause violation of the loss of coolant LHR limit (Fa limit) or the initial condition departure from nucleate boiling allowable peaking factor (F.H limit) during accidents initiated from this power level. Furthermore, the proposed power level of 20% RTP is large enough to obtain more meaningful QPT indications using the Incore Detector System without compromising safety. This change is designated as less restrictive because the ITS LCO requirements are applicable in fewer operating conditions than in the CTS.

L02 (Category 3 - Relaxation of Completion Time) CTS 3.2.4 Action a.1 .b, which applies when QPT is determined to exceed the Steady State Limit but less than or equal to the Transient Limit, requires a reduction of THERMAL POWER within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and also requires a reduction of the High Flux trip setpoint and the Flux-Davis-Besse Page 2 of 5 Attachment 1, Volume 7, Rev. 1, Page 82 of 132

Attachment 1, Volume 7, Rev. 1, Page 83 of 132 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT (QPT)

AFlux-Flow trip setpoint at least 2% for each 1% of QPT in excess of the Steady State Limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 3.2.4 Action a.2 requires QPT to be within it Steady State limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Under the same conditions in the ITS, ITS 3.2.4 ACTION A requires the reduction in THERMAL POWER and the trip setpoints but the Completion Time for reducing the trip setpoints has been extended to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months or provides the option to perform ITS SR 3.2.5.1 (Verify FQ and F' Hare within limits by using the Incore Detector System to obtain a power distribution map) once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and requires restoration of QPT to within limits within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This changes the CTS by extending the Completion Time to reduce the trip setpoints from "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months " to "10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months " and providing an option to verify FQ and F' H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for the first 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months instead of reducing THERMAL POWER and the trip setpoints.

The purpose of CTS 3.2.4 Action a.1 .b is provide appropriate compensatory measures for QPT greater than that the Steady State Limit but less than or equal to the Transient Limit. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. This changes the CTS by extending the Completion Time to reduce the trip setpoints and provides an option to verify FQ and F, H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months instead of reducing THERMAL POWER and the trip setpoint. The steady state limit specified in the COLR provides an allowance for QPT that may occur during normal operation. A peaking increase to accommodate QPTs up to the steady state limit is allowed by the regulating rod insertion limits of LCO 3.2.1 and the AXIAL POWER IMBALANCE limits of LCO 3.2.3. Operation with QPT greater than the steady state limit specified in the COLR potentially violates the LOCA LHR limits (Fa limits), or loss of flow accident DNB peaking limits (F, H limits), or both. Verification that FQ and F' H are within their limits ensures that operation with QPT greater than the steady state limit does not violate the ECCS or 95/95 DNB criteria. The required Completion Time of once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is a reasonable amount of time to allow the operator to obtain a power distribution map and to verify the power peaking factors. Repeating SR 3.2.5.1 every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is a reasonable Frequency at which to ensure that continued verification of the power peaking factors is obtained as core conditions that influence QPT change. The safety analysis has shown that a conservative corrective action is to reduce THERMAL POWER by 2% RTP or more from the ALLOWABLE THERMAL POWER for each 1% of QPT in excess of the steady state limit. This action limits the local LHR to a value corresponding to steady state operation, thereby reducing it to a value within the assumed accident initial condition limits.

The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable, based on limiting the potential for xenon redistribution, the low probability of an accident occurring, and the steps required to complete the Required Action. If QPT can be reduced to less than or equal to the steady state limit in < 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , the reactor may return to normal operation without undergoing a power reduction. Significant radial xenon redistribution does not occur within this amount of time. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the last performance of SR 3.2.5.1 allows reduction of THERMAL POWER in the event the operators cannot or choose not to continue Davis-Besse Page 3 of 5 Attachment 1, Volume 7, Rev. 1, Page 83 of 132

Attachment 1, Volume 7, Rev. 1, Page 84 of 132 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT (QPT) to perform SR 3.2.5.1 as required by Required Action A.1.1. Power operation is allowed to continue if THERMAL POWER is reduced in accordance with Required Action A.1.2.1. The same reduction (i.e., 2% RTP or more) is also applicable to the High Flux trip setpoint and the Flux-AFlux-Flow trip setpoint, for each 1% of QPT in excess of the steady state limit. This reduction maintains both core protection and an OPERABILITY margin at the reduced THERMAL POWER level similar to that at RTP. The required Completion Time of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is reasonable based on the need to limit the potentially adverse xenon redistribution, the low probability of an accident occurring while operating out of specification, and the number of steps required to complete the Required Action.

Although the actions directed by Required Action A.1.2.1 restore margins, if the source of the QPT is not established and corrected, it is prudent to establish increased margins. A required Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to reduce QPT to less than the steady state limit is a reasonable time for investigation and corrective measures. This change is designated as less restrictive because additional time is allowed to reduce the trip setpoints and an option has been provided to verify FQ and F. H are within their limits once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

L03 (Category 3- Relaxation of Completion Time) CTS 3.2.4 Action a.1 and a.2 provide Actions for when QPT is determined to exceed the Steady State Limit but less than or equal to the Transient Limit. CTS 3.2.4 Action b.1 and b.2 provide Actions for when QPT is determined to exceed the Transient Limit but less than or equal to the Maximum Limit. CTS 3.2.4 Action b.1 and b.2 provide Actions for when QPT is determined to exceed the Transient Limit but less than or equal to the Maximum Limit due to misalignment of either a safety, regulating or axial power shaping rod. When these Actions are not met CTS 3.2.4 Action a.2 and CTS 3.2.4 Action b.2 both require a reduction to less than 60% of the ALLOWABLE THERMAL POWER within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and a reduction in the High Flux trip setpint to < 65.5% within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . CTS 3.2.4 Action c.1 provide Actions for when QPT is determined to exceed the Transient Limit but less than the Maximum Limit due to causes other than the misalignment of either a safety, regulating or axial power shaping rod. Under the same conditions, ITS 3.2.4 ACTION C specifies the same requirements however the Completion Time to reduce the High Flux trip setpoint has been extended to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . This changes the CTS by extending the Completion Time from "4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months " to "10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months ."

The purpose of CTS 3.2.4 Actions is to provide appropriate compensatory measures for QPT greater than the specified limits. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering a reasonable time for restoration and the low probability of a DBA occurring during the allowed Completion Time. This changes the CTS by extending the Completion Time to reduce the trip setpoints of the High Flux channels. Under the specified conditions a power reduction to

< 60% RTP provides conservative protection from increased peaking due to xenon redistribution. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable to allow the operator to reduce THERMAL POWER to < 60% of ALLOWABLE THERMAL POWER without challenging plant systems. Reduction of the High Flux trip setpoint to - 65.5% of ALLOWABLE THERMAL POWER after THERMAL POWER has been reduced to < 60% of ALLOWABLE THERMAL POWER maintains both core protection and OPERABILITY margin at reduced Davis-Besse Page 4 of 5 Attachment 1, Volume 7, Rev. 1, Page 84 of 132

Attachment 1, Volume 7, Rev. 1, Page 85 of 132 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT (QPT) power similar to that at full power. The required Completion Time of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months allows the operator sufficient time to reset the trip setpoint and is reasonable based on the number of steps required to complete the action. This change is designated as less restrictive because additional time is allowed to reduce the trip setpoints.

L04 (Category 7- Relaxation Of Surveillance Frequency - Non-24 Month Type Change) CTS 4.2.4 requires the QPT to be verified to be within limit every 7 days when the QPT alarm is OPERABLE and requires the verification every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months when the QPT alarm is inoperable. ITS SR 3.2.4.1 requires verification that QPT is within limit every 7 days. This changes the CTS by eliminating the requirement to verify QPT more frequently when the QPT alarm is inoperable.

The purpose of CTS 4.2.4 is to periodically verify that QPT is within limit. This change is acceptable because increasing the frequency of QPT verification when the QPT alarm is inoperable is unnecessary. The inoperability of the alarm does not increase the probability that QPT is outside its limit. The routine 7 day Frequency (ITS SR 3.2.4.1) continues to ensure QPT is within the limit.

Furthermore, the QPT alarm is for indication only. Its use is not credited in any of the safety analyses. Thus, any response determined necessary by plant personnel due to an inoperable alarm is more appropriately controlled by plant procedures, not Technical Specifications. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

0 Davis-Besse Page 5 of 5 Attachment 1, Volume 7, Rev. 1, Page 85 of 132

Attachment 1, Volume 7, Rev. 1, Page 86 of 132 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 86 of 132

Attachment 1, Volume 7, Rev. 1, Page 87 of 132 CTS QPT 3.2.4 3.2 POWER DISTRIBUTION LIMITS 3.2.41 ,QUADRANT POWER TILT :(QPT) 3.2.4 LCO 3.2.4 QPT shall be maintained less than orequal to the steady state limits

specified in the COLR.

APPLICABILITY: MODE 1 with THERMAL.POWER >((0r/o RTP. 0 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.2.4 Action a.1 A. QPT greater than the A.11.1 Perform SR 3.2.5.1. :Once per 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months steady state limit and less than or equal to the OR transient limit.

A.1.2.1 Reduce THERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months POWER. Ž2% RTP from the ALLOWABLE OR THERMAL POWER for each 1% of QPT greater 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after last than the steady state limit, performance of SR3 0

,AND 0

High Flux A.11.22. Reduce Inuclear-verp 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months triopsetPoint andjlnuclea" overpowyf based .one__

Reactorteortant f.stwan AXIALt yshm ER.

0 IMBAANNCDtrip.setpoint

_>2% RTP fromtl e IALLO*WABLE T ERMALI 0 I OVRfor each 1%O/ of QPT greater than the steady state. limit.

AND BWOG STS 3.2.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 87 of 132

Attachment 1, Volume 7, Rev. 1, Page 88 of 132 QPT 3.214 CTS ACTIONS (continued)

CON DITION REQUIRED ACTION COMPLETION TIME 3.2.4 Action a.2 -A;2 Restore:QPT to less than or 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months slfrom equal to the steady: state discovery of failure to limit. meet the LCO, 3.2.4 Action b.1, B. QPT greater than the B.1 Reduce THERMAL 30 minutes 3.2.4 Action b.2 transient limit and less POWER Ž 2% RTP from than or equal to-the ALLOWABLE THERMAL maximum limit due. to POWER for each 16/o of misalignment of a QPT greater than the CONTROL ROD or an steady statei limit.

APSR.

AND.

B.2 Restore QPT to less.than or 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months equal to the transient limit.

3.2.4 Action a.2, C. Required Action and C.1 Reduce THERMAL 2, hours 3.2.4 Action b.2 associated Completion POWER to < 60% of the Time of Condition A or B ALLOWABLE THERMAL not met. POWER.

AND:

-0 Reduce Inuclea owe 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months trip-setpoint to

65.5% of N. "1High Flux OR the ALLOWABLE THERMAL POWER.

0 3.2.4 Action c.1 QPT greater than the D.1 Reduce T ERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months transient limitand less POWER t < 60% of the than or equal to the ALLOWABE THERMAL maximum limit due to POWER.

causes other than the 3 misalignment of either AND, CONTROL ROD or APSR. D.2 Reduce nucear overpower 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months trip setpoint o ý.65.5% of the ALLOW BLE THERMAL P WER.

BWOG STS 3.2.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 88 of 132

Attachment 1, Volume 7, Rev. 1, Page 89 of 132 QPT 3.2.4 0

CTS ACfFIONS (continued)

CONDITION REQUI RED ACTION COMPLETION TIME Required Action and DOG M01 associated Completion Reduce THERMAL POWER to < I20,/o RTP.

.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months o03 01 Timefor Condition C I p

FoKD not met.

OR 3.2.4 Action d [ QPT greater than the F. Reduce T ERMAL 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months maximum limit. POWER to [20]% RTP. 0 SURVEILLANCE REQUIREMENTS SURVEILLANCEE.FREQUENCY 4.2.4, SFR 3.2.4.1 Verify QPT is within limits as specified in the COLR. 7 days 3.2.4 Action a.3 3.2.4 Action b.3 AND Only required to be performed if both Condition C was entered and THERMAL When QPT has 0

POWER is > 60% of ALLOWABLE THERMAL POWER been restored to-less than or equal once every hour for 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to the steady state limit, 1hourror l2r hou__/ or until 0

verified acceptable at

> 95% RTP BWOG STS 3.2.4-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 89 of 132

Attachment 1, Volume 7, Rev. 1, Page 90 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT (QPT)

1. The brackets have been removed and the proper plant specific information/value has been provided.

2. Editorial changes made with no change in intent.

3. The Required Actions and associated Completion Times in ISTS 3.2.4 ACTION C and ACTION D are equivalent. Therefore, the Condition of ISTS 3.2.4 ACTION D has been merged with the Condition of ISTS 3.2.4 ACTION C. The Required Actions and associated Completion Times in ISTS 3.2.4 ACTION E and ACTION F are equivalent. Therefore, the Condition of ISTS 3.2.4 ACTION E (ITS 3.2.4 ACTION D) has been merged with the Condition of ISTS 3.2.4 ACTION F. This change is consistent with the Writer's Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, Section 4.1.6. Subsequent Conditions and Required Actions have been renumbered, as applicable.

4. A Note has been added to the second Frequency of ISTS SR 3.2.4.1. The Note states that "Only required to be performed if both Condition C was entered and THERMAL POWER is 60% of ALLOWABLE THERMAL POWER. This allowance is consistent with CTS 3.2.4 Action a.3 and CTS 3.2.4 Action b.3 and the description of the SR in the Bases.

5. Changes are made which reflect the plant specific nomenclature.

6. ISTS 3.2.4 Required Action A.1.2.2 has been changed to require a reduction in the High Flux trip setpoint and Flux-AFlux-Flow trip setpoint of greater than or equal to 2% for each 1% of QPT in excess of the Steady State Limit. This change is consistent with the current licensing basis, consistent with the Bases wording for Required Action A.1.2.2, and consistent with similar Required Actions in ITS 3.2.5.

Additionally, without this change, Operators must know that they have to reduce power even further after completing Required Action A.1.2.1. Otherwise, when they comply with Required Action A.1.2.2, they will end up lowering the trip setpoints to the same power level stipulated by Required Action A.1.2.1 and cause a reactor trip.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 90 of 132

Attachment 1, Volume 7, Rev. 1, Page 91 of 132 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 91.of 132

Attachment 1, Volume 7, Rev. 1, Page 92 of 132 QPT B 3.2.4 BR3.2 POWER DISTRIBUTION LIMITS B 3.2.4 QUADRANT POWER TILT.(QPT)ý BASES BACKGROUND This LCO is required 'to limit the core ppwer distribution based on accident initial condition criteria.

The power density at any point in the core must be limited to maintain specified acceptable fuel design limits, including limits that preserve the criteria specified in 10 CFR:50.46 (Ref. 1). Together, .LCO 3.2.1, "Regulating Rod Insertion Limits," LCO.3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits," LCO 3.2.3, "AXIAL POWER. IMBALANCE Operating Limits," and LCO 32.4, "QUADRANT POWER TILT (QPT),"

provide limits on control component operation and on monitored process variables to ensure that the core operates within the FckM.and F:A H limits given in the COLR. Operation within the FCM limits given in the COLR prevents power peaks that exceed the loss of coolant accident (LOCA) inear heatrateLHR limits derived by Emergency Core Cooling Systems (ECCS) analysis.

Operation within the FAH limits given' in the COLR prevents departure from nucleate boiling (D.NB) during a loss of'forced reactor coolant flow accident.

This LCO is. required to limit fuel cladding failuresthat breach the primary fission product barrier and release fission .products to the reactor coolant in the event of a LOCA, loss.offorced reactor coolant flow, or other accident requiring termination by a Reactor Protection System trip function. This LCO limits the amount0ofdamage.to.the fuel cladding during an accident by maintainingthe:validity of the assumptions used in the safety analysis related to the initial power .distribution and reactivity.

Fuel cladding failure during a postulated LOCA is limited by restricting the maximum linear heat rate (LHR) so that the. peak; cladding temperature does not exceed 2200°F (Ref. 2). Peak cladding temperatures > 2200°F cause severe cladding failure by oxidation due to a Zircaloy water

.reaction. Other criteria must also be met (e.g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling). However, peak cladding temperature is usually most limiting.

BVWOG STS B 3.2.4-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 92 of 132

Attachment 1, Volume 7, Rev. 1, Page 93 of 132

QPT B 3.'24

BASES, BACKG.R.OUN D .(continued)

Proximity to the DNB condition-is expressed by the departure from nucleate boiling ratio (DNBR), defined as the ratio of the cladding surface heat flux required to cause DNB to the actual cladding sufface heat flux.

The minimum DNBR.-value during both normal operationand anticipated transients is limited to the DNBR correlation limit for the particular fuel design in use, and is accepted as an appropriate margin to DNB. Thet DNBR. correlation limit ensures that there is at least 95% probability at.the 95% confidence level (the 95/95 DNB criterion) thatthe hot fuel rod in the core does not experience DNB.

The measurement system independent limits on QPT are determined directly by the reload safety evaluation analysis without adjustment for measurement system error and uncertainty. Operation beyond these.

limits could invalidate core power distribution assumptions used in the limits accident analysis. The error adjusted maximum allowable--n s

in the COLR.

(measurement system dependent limits) for QPT are specified Q APPLICABLE The fuel cladding must not sustain damage~as a result of normal SAFETY operation (Condition 1) and anticipated operational occurrences ANALYSES (Condition 2). The LCOs based on power distribution (LCO 3.2.1, LCO 3.2.2, LCO 3.2.3, and LCO 3.2.4) precludecore power :distributions that violate the following fuel design criteria: 2

a. During a jlarg rea LOCA, the peak cladding temperature must not exceed 2200'F (Ref. z 4_- 2 0

b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the.95/95 DNB criterion) that the hot fuel. rod in the core does not.experience, a DNB conditionz----

c diin( INSERT11 QPT is one of the process variables that:characterize and control the three dimensional power distribution of the reactor core.

Fuel cladding damage does not occur when the core is operated outside this LCO during normal operation. However, fuel cladding damage could result if an accident occurs with simultaneous violation ofone. or more of the LCOs governing the core power distribution. Changes in the power distribution can cause increased power peaking and correspondingly increased local LHRs.

BWOG STS B 3.2.4-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 93 of 132

Attachment 1, Volume 7, Rev. 1, Page 94 of 132 B 3.2.4 OINSERT 1 0 c. During an ejected rod accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. 3); and

d. The CONTROL RODS must be capable of shutting down the reactor with a minimum required SDM with the highest worth CONTROL ROD stuck fully withdrawn (Ref. 4).

0 Insert Page B 3.2.4-2 Attachment 1, Volume 7, Rev. 1, Page 94 of 132

Attachment 1, Volume 7, Rev. 1, Page 95 of 132 QPT B 3.2.4

. BASES APPLI(CABLE SAFETYANALYSES (continued)

The dependence of th#e core power distribution on burnup,. regulating rod insertion, APSR position:,= and spatial xenon distribution is taken into

.account during the reload safety evaluation analysis. An allowance for QPT is accommodated in the analysis and resultant LCO limits. The increas'e in peaking taken for QPTis developed from a. database of full core power distbution calculations (Ref. Ly) The calculations consist of simulations of many power, distributions with tilt causing mechanisms (e.g.., dropped or misalig~ned CONTROL RODS, broken APSR fingers fully inserted, misloaded assemblies, and burnup gradients). An increase:

of < 2% peak power'per 1%QPT iS:supported by the analysis, therefore a valueof 2% peak power increase per 1% QPT is used to bound peak power .increases due to QPT.

Operation at the AXIAL POWER IMBALANCE or rod insertion limits must be interpreted as operating the. core at the maximum allowable F 0*,or F&H peaking factors.for accident initial conditions with the allowed QPT present.

QPT satisfies Criterion 2 of 1,0 CFR 50.36(c)(2)(ii).

LCO The power distribution LCO limits have been established based on correlations between power'p.eaking and easily measured process variables: regulating rod position, APSR position, AXIAL POWER.

IMBALANCE, and QPT. The regulating rod insertion limits :and the AXIAL POWER IMBALANCE boundaries contained in the COLR. represent the measurement system independent limits at which the core power distribution either exceeds. the LOCA LH R limits or causes a reduction in DNBR below.the safety limit during a loss of flow accident with the allowable QPT present andwith an APSR position consistent with the limitations on APSR withdrawal determined by the fuel cycle design and specified by LCO 3.2.2.

Operat on beyond the powe distribution based. LCO I*its for the corresp nding allowable TH RMAL POWER and sim Itaneous occurren e of one of a LOCA,\loss of forced reactor co lant flow accident, or ejecte rod accident has an cceptably low probabilit. Therefore, if these LC limits are violated, a\short time is allowed for orrective action before :a\si nificant power reduc on is required.

O BWOG STS B 3.2.4-3 Rey. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 95 of 132

Attachment 1, Volume 7, Rev. 1, Page 96 of 132 QPT B 3.2.4 BASESt LCO (o ntinued) limitsalowa I

The Imaximum maximum setpoints forlsteady for QPTdapplicable state, transient, for the full:sy and etrical Incore lmits Detector System nimum-core ljetector. jystem, and I-Xeore Detector[/

S.are providedl;the setpommtare giveri lin the COLR. The setintsl Incore Detector System for thtreesstem ar: deiedI by adjuotmentof the measurement system independent QPT limits'ybiven'i COLIto allow for system observability and instrumentation.errors.

.Actual a arm setpoints imple ented in the plant may b more restrictive than the aximum allowable s tpointvalues to allow fo additional conservatim between the actu I alarm setpoint and the easurement 0

system ind endent limit.

It is de irable foran operato *toretain the ability to:op rate the reactor when a PT exists:. In certai instances, operation of he reactor with a QPT ma be helpful or neces ary to~discover the caus of the OPT. The combinat on of power level res riciion with QPT in each . equired Action 0

statemen restricts the local LH to a safe level, allowin: movement through th specified applicabili conditions in theexcep ion to Specificati , 3:0.3.

APPLICABILITY In MODE 1, the limits on QPT must be maintained when THERMAL POWER is > 20% RTP to preventthe core power distribution from exceeding the design limits'.. The minimum power level of 20P% RTP is large enough to obtain, meaningful QPT indications without compromising safety. Operation~at or below 20% RTP with QPT up to 20% is acceptable because-the resulting.maximum LHR is not high enough to cause violation of the LOCA LHR limit .(FQK- limit) orthe initial condition DNB allowable peaking limit (FA"H limit) during accidents initiated from this 0

power level.

In MODE 2, the combination of QPT with maximum ALLOWABLE THERMAL POWER level does not result in LHRs sufficiently. large to violate the fuel design limits, and therefore, applicability in this MODE is not required. Althoughonot specifically addressed in the LCO, QPTs

> 20% in MODE 1 with THERMAL POWER: < 20% RTP are allowed for the same reason.

BWOG STS B 3.2.4-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 96 of 132

Attachment 1, Volume 7, Rev. 1, Page 97 of 132 OPT B 3.2.4:

. BASES APPLICABILITY (continued).

In MODES 3, 4, 51, and 6, this LC'O: is not applicable,ý because the reactor is not generating THERMAL POWER and .QPT is, indeterminate.

'In MODE 1, it may be. necessary to suspend the OPT limits'during PHYSICS TESTS per:LCO,3.1.8, "PHYSICS TESTS Exceptions -

MODE 1." Suspension of these limits is permissible because the reactor protection criteria are maintained by the. remaining. LCOs governing the three dimensional power distribution~and by the Surveillances required by

.LCO 3.1 .8.

ACTIONS A.1.1 The steady state limit specified in the COLR provides an allowance for OPT that may occur during normal operation. A peaking increase. to accommodate QPTs up to the steady state limit is allowed by the regulating rod insertion limits of LCO3.2.1 and.the AXIAL POWER IMBALANCE limits of LCO 3.2.3.

Operation with QPT greater than the steady state limit specified in the COLR potentially violates the LOCA LH R, limits (FOM] limits), or loss of flow accident DNB peaking limits (FA H limits), or both. For verification that FQ*-)I and EFi are within their.specified limits', SR 12s performed using the. Incore Detector System to, obtain a three dimensional power distribution map. Verification that FM and FA H are 0 within their limits ensures that operation with QPT greater than the steady

state limit does not violate the ECCS or.95/95 DNB criteria. The required Completion Time of once per.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is a reasonable amountof time to allow the operator to obtain a power distr ibution map and to verify the power peaking factors. Repeating SR 3.2.5.1 every 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is.a reasonable Frequency at which to ensure-that continued verification of the power peaking factors is obta ined as core conditions that influence QPT change.

A.1.2.1 The safety, analysis has shown'that a conservative corrective action is to reduce THERMAL POWER by 2% RTP or more from the ALLOWABLE THERMAL POWER for each 1% of QPT in excess of the steady state limit. This action limits the local LHRto a value corresponding to steady state operation, thereby reducing it to a value within the assumed 1

B3WOG STS B 3.2.4-5 Rev. 3.0, 03131/04 Attachment 1, Volume 7, Rev. 1, Page 97 of 132

Attachment 1, Volume 7, Rev. 1, Page 98 of 132 QPT B 3.2.4

BASES, ACTIONS (continued) accident initial condition limits.- The required..Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable, based on limiting the potential for xenon redistribution, the, low probability of an accident.occurring, and the steps required to complete the Required Action.

If QPT can be reduced to less than.or equallto0the steady state limitin

<2 hours, the reactor may return to normal operation without undergoing a power reduction. Significant radial xenon redistribution does not occur within this amount of time.

3.2.5.1 SThe requiredallows Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after the last performance of reduction of THERMAL POWER in the event the operators cannot or choose not to continue to perform as required by Required Action A.1.1-A.1.2.2

.Power operationis allowed to continue if THERMAL.POWER is. reduced High Flux in accordance with Required Action A.l..2.1. The same reduction(i.e.,

2% RTP or more) is also applicable to thed huclear-over owerltrip setpoint.

anduthear rpower b~sed on Reactor Cioolant Sse RCy.w

[75X-~lux-lo a nd _XIAL POWVER IM BALANCEitrip setpoint, for each 1% of QPT in L~~Flx-ux-FloZJ)excess of the steady state limit. This reduction maintains both core protection and an OPERABILITY margin at the reducedTHERMAL POWER level similar to that at RTP. The required Completion Time:of

10 hours is reasonable based on the need to limit the potentially adverse xenon redistribution, the low probability of an accident occurring while operating out of specification, and the number of steps requiredto complete the Required Action.

from discovery of A.2 rfailure to meet the LCO Although the actions directed by Required Action A.1.2.1 restore margins, ifthe source of the QPT is not established and corrected, it is prudent to establishincreased margins. A required Completion Time of 24.hourto reduce QPT to less than the steady state limit is~a reasonable-time for 0

investigation and corrective measures.

BWOG STS B 3.2.4-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 98 of 132

Attachment 1, Volume 7, Rev. 1, Page 99 of 132 QPT B 32.4 BASES, ACTIONS '(continue.d)

B.A If QPT exceeds the transient limit but is equal to or less thanthe maximum limit due to a misaligned CONTROL ROD or APSR,.theen p*ower:

operation is allowed .tocorntinue if the THERMAL POWER is reduced 2% RTP ormore from the ALLOWABLE THERMAL POWER for each 1%

of QPT inexcess of thesteady state limit. Thus, thetrarlent imitisthe maximum upper bound within which the 2% for 1% power reduction rule :may be applied, but only for QPTs caused by CONTROL ROD or APSR misalignment. The required Completion Time of 30 minutes ensures that theý operator completes the THERMAL POWER reduction before significant xenon redistribution occurs.

.B.2 When a misaligned CONTROL ROD or APSR occurs,,a local xenon redistribution r'ay occur. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

allows the operator sufficient time to relatch orrealign a CONTROL ROD or APSR,.but is.short enough to limit xenon redistribution sothat large

.increases in the local LHR do not occur due-to.,xenon redistribution resulting from the QPT. --

or if OPT is greater than the transient limit and less than or equal to the maximum limit due to misalignment of a CONTROL ROD CA1 or an APSR Eany i Ift e Required Actionand associated Completion Time of ConditionA ALPower reduction to 60

(ýo-aor of the W

B ae not met, a further power reduction is required. Power reduction to 60% RTP provides conservative protection from increased peaking isa conservative method of due to xenon redistributon. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is limiting the maximum core LHR reasonableito-allow. te operator to reduce THERMAL POWER to <60%

for QPTs up to the maximum limit.

Although the power reduction is of ALLOWABLE THERMAL POWER without challenging plant systems.

based on the correlation used in Required Actions A. 1.2.1 and B. 1, the database for a power peaking increase as a function of QPT is C.2 less extensive for tilt mechanisms High Flux other than misaligned CONTROL RODS and APSRs. Because Reduction of the nucleaý ver owe trip .setpoint to _ .65.5% of greater uncertainty in the potential ALLOWABLETHERMAL POWER after THERMAL POWER hasbeen power peaking increase exists with the less extensive database, reduced to <60%of ALLOWABLE THERMAL POWER maintains both a more conservative action is core protection and OPERABILITY margin at reduced powersimilarto taken when the tilt is caused by a .... .

mechanism other thana that at full power. The required Completion Time of 10 hour1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months sallows the misaligned CONTROL ROD or operator sufficient time to reset the trip setpoint and is .reasonable based AP9sR. .1/on loperatin "xperienc BWOG STS B 3.2.4-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 99 of 132

Attachment 1, Volume 7, Rev. 1, Page 100 of 132 QPT B 3.2.4 BASES ACTIONS (continued)

D.1 Powe reduction to 60% of he ALLOWABLE THER AL POWER is a conse ative method of limi ing the maximumn core L R for QPTs up.to

ý20% Ithough the power r duction is based on the orrelation used in Requir d Actions A.1-2.1 an B.1, the database for a ower peaking increas 'as a function of QP is less extensive for tilt echanisms other than mi aligned 'CONTROL ODS and APSRs. Becal se greater 0 uncertai ty in the potential po er peaking increase exi ts with the less extensiv database, a more c nservative action is tak when the tilt is caused ba mechan~is~m othe, than a misaligned CON ROL ROD or APSR. e required Completi in Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months allo 'the operator.to reduce T. ERMAL POWER to ,60% of the ALLOWVAB E THERMAL POWER ithout challenging p1nt systems.

D.2 Reduc ion of the nuclear ov rpower trip setpoint to P 15.5%

ALLO ABLE'THERMAL P WER after THERMAL WER of hasthebeen 0 reduce to <60% of the ALL WABLE THERMAL P0 R maintains both cor protection and an o erating margin at reduce power similar to that at fu I power. The require 'Completion Time of 10 ours allows the operator ufficient time to rese the trip setpoint and is r sonable based on operat g experience.

. andassociated Completion Time of ior if QPT is greater than the th e re c o r m st b IrIe cliNir Required e d Cq ,m pleActionýjý t ioR Time Condition C or D c not be met itl*n t e lte n t e r at o r will c o n ti nu ýp o~we r the~~~

brought to a MODE or reato operation with must beOoain ignificant QPT. E her the power , vel has not been other specified condition in reduced to 6o ply with . the Requ red Action or thA nuclear overpower trip lwhich thachedvoes not setpoint has ot been reduced, ithin the requir d Completion Time. To status, THERMAL preclude ris of fuel damage in ny of theseco ditions, THERMAL POWER*urs./) be utrthinced POWER is t educed Ishutdown MODE3.& further.

HoweS er, ecification 3.0. normally requires a Operation at 20% RTP allows the operator to investigate the cause of the QPT and to correct it. Local LHRs with a large QPT do not violate the fuel design limits at or below 20% RTP. ,The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is acceptable based on limiting the potential increase in local LHRs that could occur due to xenon redistribution with the QPT out of specification.

The maximum limit specified in the COLR is set as the upper bound within which power reduction to 60% of ALLOWABLE THERMAL POWER or power reduction of 2% from ALLOWABLE THERMAL POWER for each 1% of QPT (for misaligned CONTROL RODS only) applies (Ref. 5). The maximum limit specified in the COLR is consistent with allowing power operation up to 60% of ALLOWABLE THERMAL POWER when OPT setpoints are exceeded. OPT in excess of the maximum limit can be an indication of a severe power distribution anomaly, and a power reduction to at most 20% RTP ensures local LHRs do not exceed allowable limits while the cause is being determined and corrected.

BWOG STS B 3.2.4-8 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 100 of 132

Attachment 1, Volume 7, Rev. 1, Page 101 of 132 QPT B 3.2.4 BASES ACTIONS, (continued)

F.1 The ma imum limit of 20%W T is set as the upper b und within which power r cduCtion to 60% of A LOWABLE THERMAL WER or power reductio of02% for 1% (for m saligned CONTROL RO S only) applies (Ref. 4).

The maxi urn limit of 20% Q is consistent with allo ing power operation up to 60% of ALLO-ABLE THERMAL POW R when QPT setpoints re exceeded. QPT i excess of the maximu limit can be an 0

indication f a severe power di&tribution anomaly, and'a power reduction to at most 0% RTP ensures lo alLHRs do not exceed ilowable limits while the c use is being determ hed andcorrected.

The require Completion Time o 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is reasonable t allowthe operator to educe THERMAL WER to 5 20% RTP wit out challenging plant syste s.

SURVEILLANCE QPT can be monitored by]5-hJthe/ncore land bxcor tetector.;ystemmn.

REQUIREMENTS The QPT e in are denvedfromthe~r correspond easurement limits s em independent limits, by adjustment for system observability errors Incore Detector and instrumentation errors. Althoug they may be base on the same Syte Imeasureme t system independent li it, the setpoints for e different systems are ot identical because of di ferences in the erro :applicable for these sySte s. For QPT measurements using the Incore Detector System, the inimum Incore Detectorstem consists o OPERABLE detecto rs Jco nfig u red.as follows:1 Sconsists of 75% of the F detectors per quadrant. a. Tw sets of four detecto shall lie in each core If. Each set of detecors shall liein the sme axial plane. The tw sets in the same core h f may lie in the sam axialplane.

Ib. Det*'edors in the same pf*ine shall have quarter corejadial symmetrv.1 Figure 0 3.2.4-2 (Minimum I core Detector System r QPT Measure~nent) depicts an ex mple of this configuratio . The symmetric incore sytem for QPT uses tl e Incore. Detector Systeb. as described above andis configured such t at at least 75% of the d tectors in each core quadrant are:OPERABLE.

J 0 BVVOG STS B 3.2.4-9 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 101 of 132

Attachment 1, Volume 7, Rev. 1, Page 102 of 132 QPT B 3.2.4 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.4.1 Checkingthe QPT indication every 7.days ensures thatthe operator can determine whether the plant computer software and Incore- Detector System inputs for monitoring QPT are functioning properly and takes into account other information available to the.operator in the

control room. This procedure allows the QPT mechanisms, such as 0) xenon redistribution, burnup gradients, and CONTROL ROD drive mechanism malfunctions,which can cause slow development of a QPT, to be detected. Operating experience has, confirmed the acceptability of a Surveillance Frequency of 7 days.

Following restoration of the.QPT to within the steady state limit, operation, at _>95% RTP may proceed provided the OPT is determined to: remain

[- within the steady state limitat the increased THERMAL POWER level. In

case QPT exceeds the steady :state limit for ore than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or exceeds the transient limit (Condition AUA or[I, the potential for xenon nredistribution is greater. Therefore, the QPT is monitored[qfr 0 h12 consecu ouve-h5orly interval to determine whether the period of any oscillation due to xenon redistribution causes the QPT to exceed the steady state limit again.

REFERENCES 1. 10CFR50.46.

2. FSAR, SectionF i - 00

3. ANSI N18.2-1973, A National Standards Institute, August 6, 1973.

0)

BAW10122A, Rev. 1, May 1984.

0

3. UFSAR, Section 15.4.3.

4. UFSAR, Appendix 3D.1.23, Criterion 27 - Combined Reactivity Control Systems Capability.

BWOG STS B 3.2.4-10 Rev. 3.0, 03/31/04 0

Attachment 1, Volume 7, Rev. 1, Page 102 of 132

0 , Volume 7, Rev. 1, Page 103 of 132

Attachment 1, Volume 7, Rev. 1, Page 104 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT (QPT)

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. 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.

3. The ISTS 3.2.4 Bases, LCO section provides a discussion that it is sometimes desirable to continue to operate the reactor when the QPT limit is not met, and describes why this is acceptable. This discussion has not been maintained in the Davis-Besse ITS Bases. The discussion is basically describing what is allowed for all LCO statements - that the LCO can be not met under certain circumstances as long as the associated ACTIONS are followed. The ISTS ACTIONS Bases provides the details concerning what to do if the LCO statement is not met, consistent with the format of the ISTS Bases. Furthermore, the ISTS Bases describes that the Required Actions restricts the local LHR to a safe level, "allowing movement through the specified applicability conditions in the exception to Specification 3.0.3."

ISTS LCO 3.0.3 provides action to take if no actions are provided in the individual Specifications. Thus, the ACTIONS provided in ISTS 3.2.4 are not an "exception to Specification 3.0.3." Therefore, this paragraph has been deleted.

4. Changes are made to reflect the Specification.

5. Changes are made to reflect changes made to the Specification.

6. The brackets have been removed and the proper plant specific information/value has been provided.

7. The ISTS LCO 3.2.4 Bases includes a discussion of "Actual Alarm Setpoints" for QPT. This discussion is not included in the ITS LCO 3.2.4 Bases. The "Actual Alarm Setpoints" are not needed to satisfy the requirements of the LCO and therefore a discussion of the "Actual Alarm Setpoints" is not needed in the LCO Bases.

8. Changes are made to be consistent with other places in the Bases (i.e., LCO 3.2.5 Bases Background).

9. Change made to be consistent with the Bases of LCO 3.2.4 Required Action A.1.2.2.

10. Changes made to be consistent with other places in the Bases.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 104 of 132

Attachment 1, Volume 7, Rev. 1, Page 105 of 132 Specific No Significant Hazards Considerations (NSHCs) 0 Attachment 1, Volume 7, Rev. 1, Page 105 of 132

Attachment 1, Volume 7, Rev. 1, Page 106 of 132 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, QUADRANT POWER TILT (QPT)

There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 106 of 132

Attachment 1, Volume 7, Rev. 1, Page 107 of 132 ATTACHMENT 5 ITS 3.2.5, POWER PEAKING FACTORS 0

Attachment 1, Volume 7, Rev. 1, Page 107 of 132

, Volume 7, Rev. 1, Page 108 of 132 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 1, Page 108 of 132

Attachment 1, Volume 7, Rev. 1, Page 109 of 132 ITS 3.2.5 ITS POWER DISTRIBUTION LIMITS NUCLEAR HEAT FLUX HOT CHANNEL FACTOR - F.

I TI4TTTNCS CONDTTTAN FAR OPFRATTAtI FOR OPFRATTAN ITMTTING CONDITTAN LCO 3.2.5 3.2.2 F shall be within the limits specified in the CORE OPERATING LIMITS RAPORT.

APPLICABILITY: MODE 1 with THERMAL POWER >20% RTP ACTION:

within ACTION A a. Reduce THERMAL POWER at least 1% for each 1% F, exceeds the limit 15 minutes and similarly reduce the high flux trip setpoint and flux-A flux-flow trip setpoint within ours.

ACTION A b. Demonstrate through incore mapping that Fa is within its limit within 24 L01 A=rs after exceeding the limit or *reduce THERMAL POWER to less than of --

ACTION C , T'ED THERMAL POWER within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. Iden ify and correct the c use of the out of limit *ondltion prior to incre sing THERMAL POWER a ve the reduced limit req ired by a or b, above; subsequent POWER OPE TION may proceed providd that F0 is demons rated through incore apping to be within its imit at a nominal L03E 50% of TED THERMAL POWER p ior to exceeding this THE$.MAL POWER, at a nominal 5% of RATED THERMAL OWER prior to exceeding his THERMAL POWER and with 'n 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after attaining 95% or greater RATE THERMAL POWER.

UIIRVIFTII ANmr IFrnIITInAM:T'Z SR 3.2.5.1 4.2.2.1_1 F, shall be determined to be within its limit by using the incore detectors to obtain a power distribution map: Add proposed Note to SR 3.2.5.1 ý L04 DAVIS-BESSE, UNIT I 3/4 2-5 Amendment No. 49,189 Page 1 of 4 Attachment 1, Volume 7, Rev. 1, Page 109 of 132

Attachment 1, Volume 7, Rev. 1, Page 110 of 132 ITS 3.2.5 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

SR 3.2.5.1 a.\ Prior after POWER to initial each 4eration aboveand75 perce t of RATED THERMAL fel loading, Asspecifiedby theapplicableL Effective Full Power 0 s. ýLCO(s)

b. t least once per 3

c. T e provisions of Spe ification 4.0.4 are not applicable.

4.2.2.2C The measured F of 2.2.1 above, shall be ncreased by 1.4%

to~accountfor manufactiring lerances and further I creased by 7.5%

to account or measurement unce tainty.

LA02 DAVIS-BESSE, UNIT 1 3/4 2-6 Page 2 of 4 Attachment 1, Volume 7, Rev. 1, Page 110 of 132

Attachment 1, Volume 7, Rev. 1, Page 111 of 132 ITS 3.2.5 ITS POWER DISTRIBUTION LIMITS NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - F*,.

LITTTINIG COnlTTOnU PAO OPERATION 3.2.3 FW. shall be within the limits specified in the CORE OPERATING LCO 3.2.5 L ITS REPORT.

APPLICABILITY: MODE 1. withTHERMALPOWER>20%RTP With F"AH exceeding its limit: RH%)RTP ACTION B a. Reduce THERMAL POWER at least [] for each 1% that Fll exceeds the limit within 15 minutes and similarly reduce the HigV Fl ux Trip Setpoint and Flux - AFlux - Flow Trip Setpoint within rhours.

ACTION B b. Demonstrate through in-core mapping that Foam is within its limit within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after exceeding the limit oreduce THERMAL POWER to 20 L01 ACTION C les than ýof RATED THERMAL POWER within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

c. *dentiy and correct t e cause of the out of limi condition prior o increasing THERMAL WCER above the reduced limi required by a or b above; subsequent POR OPERATION may proceed p vided that F" i demonstrated through n-core mapping to be withi its limit at a no inal 50% of RATED THEPL POWER prior to exceedin this THERMAL PO R, at a nominal 75% o RATED THERMAL POWER prior to exceeding thi THERMAL POWER and wit in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after attainin 95% or grea er RATED THERMAL POWER DAVIS-BESSE, UNIT I 3/4 2-7 Amendment No.189 Page 3 of 4 Attachment 1, Volume 7, Rev. 1, Page 111 of 132

Attachment 1, Volume 7, Rev. 1, Page 112 of 132 ITS 3.2.5 ITS POVJER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS

< i Add proposed Note to SR 325,51 SR 3.2.5.1 4.2.3.1 FNt4 shall be determined to be vithin its limit by using the Incore detectors to obtain a pover distribution maps As specified by the applicable LCO(s)

a. Pr or to .operation abov 75 percent of RATED POJEM after each fue loading, and

b. At 1*at once per 31 Effe tive Full Pover Days.

Th~visions of Specift-~o 4. r not appli ~le.

LA01 2.3.2m easuredent a n3.1 of 4 above, shall be incaed by 5X for measurement ncertainty.

= LA02 DAVIS-BESSE, UNIT 1 3/4 2-8 Amendment No. 135 Page 4 of 4 Attachment 1, Volume 7, Rev. 1, Page 112 of 132

Attachment 1, Volume 7, Rev. 1, Page 113 of 132 DISCUSSION OF CHANGES ITS 3.2.5, POWER PEAKING FACTORS ADMINISTRATIVE CHANGES A01 In the conversion of the Davis-Besse 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-1430, Rev. 3.1, "Standard Technical Specifications-Babcock and Wilcox Plants" (ISTS).

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

MORE RESTRICTIVE CHANGES M01 CTS 3.2.3 Action a requires a reduction of THERMAL POWER at least 1% for each 1% F' H exceeds the limit and a similar reduction in the High Flux and Flux-AFlux-Flow Trip Setpoints. ITS 3.2.5 Required Actions B.1 and B.2 require a reduction of THERMAL POWER and a reduction of the High Flux and Flux-AFlux-Flow Trip Setpoints of > RH (%) RTP for each 1% that F. H exceeds the limit. This changes the CTS by requiring THERMAL POWER and the High Flux and Flux-AFlux-Flow Trip Setpoints be reduced by RH (%) RTP for each 1% that H exceeds the limit instead of by 1% for each 1% that FA H exceeds the limit.

The purpose of CTS 3.2.3 Action a is to reduce the maximum linear heat rate in the core so that protection from departure from nucleate boiling (DNB) during a limiting loss of flow transient is maintained. The proposed RH value will be specified in the COLR, and is currently 3.3%. Thus, the proposed value of THERMAL POWER and Trip Setpoint reduction is greater than the current value provided in CTS 3.2.3 Action a.. The proposed value (RH) is based on an analysis of the DNB ratio during the limiting loss of forced reactor coolant flow transient from various initial THERMAL POWER levels. Therefore, the change is considered acceptable. This change is designated as more restrictive because a greater THERMAL POWER and Trip Setpoint reduction is required in the ITS than is required in the CTS.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removal of ProceduralDetails for Meeting TS Requirements or Reporting Requirements) CTS 4.2.2.2 requires that the measured FQ of CTS 4.2.2.1 to be increased by 1.4% to account for manufacturing tolerances and further increased by 7.5% to account for measurement uncertainty.

CTS 4.2.3.2 requires that the measured FAH of CTS 4.2.3.1 to be increased by 5% for measurement uncertainty. ITS SR 3.2.5.1 does not require these additional factors to be incorporated. This changes the CTS by relocating the Davis-Besse Page 1 of 5 Attachment 1, Volume 7, Rev. 1, Page 113 of 132

Attachment 1, Volume 7, Rev. 1, Page 114 of 132 DISCUSSION OF CHANGES ITS 3.2.5, POWER PEAKING FACTORS procedural detail to include manufacturing tolerances and measurement uncertainty, as appropriate, in the measurement of FQ and FA H to the Bases.

The relocation of the specific values of the manufacturing tolerances and measurement uncertainties corrections are justified in Discussion of Change LA02.

The purpose of CTS 4.2.2.2 and CTS 4.2.3.2 is to ensure that values of FQ and HAHdetermined through incore mapping conservatively include allowances for manufacturing tolerances and measurement uncertainty, as appropriate. The removal of these details for performing 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 still retains requirements to perform appropriate verifications of FQ and FA H. 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 Specifications 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 procedural details for meeting Technical Specifications requirements are being removed from the Technical Specifications.

LA02 (Type 5 - Removal of Cycle-Specific ParameterLimits from the Technical Specifications to the Core OperatingLimits Report) CTS 4.2.2.2 requires that the measured FQ of CTS 4.2.2.1 to be increased by 1.4% to account for manufacturing tolerances and further increased by 7.5% to account for measurement uncertainty. CTS 4.2.3.2 requires that the measured F. H of CTS 4.2.3.1 to be increased by 5% for measurement uncertainty. ITS SR 3.2.5.1 does not require these additional factors to be incorporated. This changes the CTS by relocating the specific values of the manufacturing tolerances and measurement uncertainties corrections, which must be confirmed on a cycle-specific basis, to the COLR. The relocation of the procedural details to make the corrections to the measured FQ and FA H is justified in Discussion of Change LA01.

The removal of these cycle-specific parameter limits from the Technical Specifications to the COLR is acceptable because the cycle-specific limits are developed or utilized under NRC-approved methodologies which will ensure that the Safety Limits are met. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits From 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 the'requirement to verify that the absolute position indicator channels and the relative position indicator channels agree within the limit. The methodologies used to develop the parameters in the COLR have obtained prior approval by the NRC in accordance with Generic Letter 88-16. 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 that the applicable limits (e.g., fuel thermal Davis-Besse Page 2 of 5 Attachment 1, Volume 7, Rev. 1, Page 114 of 132

Attachment 1, Volume 7, Rev. 1, Page 115 of 132 DISCUSSION OF CHANGES ITS 3.2.5, POWER PEAKING FACTORS mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analyses 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.

LESS RESTRICTIVE CHANGES L01 (Category 2- Relaxation of Applicability) CTS 3.2.2 and CTS 3.2.3 are both applicable in MODE 1. ITS 3.2.5 is applicable in MODE 1 with THERMAL POWER > 20% RTP. This changes the CTS by reducing the applicable MODES in which the Nuclear Heat Flux Hot Channel Factor (FQ) and Nuclear Enthalpy Rise Hot Channel Factor (F*. ) requirements must be met.

The purpose of CTS 3.2.2 and CTS 3.2.3 is to establish limits that constrain the core power distribution within design limits during normal operation and during anticipated operational occurrences such that accident initial condition protection criteria are preserved. This change is acceptable because the requirements continue to ensure that the core power distributions are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. This change revises the Applicabilities of CTS 3.2.2 and CTS 3.2.3 from "MODE 1" to "MODE 1 with THERMAL POWER > 20% RTP."

With THERMAL POWER less than or equal to 20% RTP, the reactor has insufficient stored energy in the fuel or energy being transferred to the coolant to require a limit on the distribution of core power. Along with this change the THERMAL POWER of 5% RTP in the default action (CTS 3.2.2 Action b and CTS 3.2.3 Action c) have been changed to 20% RTP. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L02 (Category3 - Relaxation of Completion Time) CTS 3.2.2 Action a states the High Flux and Flux-AFlux-Flow trip setpoints must be reduced 1% for each 1%

FQ exceeds its limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The CTS 3.2.3 Action a states the High Flux and Flux-AFlux-Flow trip setpoints must be reduced 1% for each 1% Fa H exceeds its limit within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.2.5 Required Actions A.2 and B.2 requires the trip setpoints to be reduced similarly within 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . This changes the CTS by extending the Completion Time from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months .

The purpose of CTS 3.2.2 Action a and the CTS 3.2.3 Action a is to reduce the High Flux and Flux-AFlux-Flow trip setpoints when FQ or F',H exceeds its limit in order to maintain both core protection and OPERABILITY margin at the reduced THERMAL POWER. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the allowed Completion Time. The power reduction required by CTS 3.2.2 Action a, CTS 3.2.3 Action a, and ITS 3.2.5 Required Actions A.1 Davis-Besse Page 3 of 5 Attachment 1, Volume 7, Rev. 1, Page 115 of 132

Attachment 1, Volume 7, Rev. 1, Page 116 of 132 DISCUSSION OF CHANGES ITS 3.2.5, POWER PEAKING FACTORS and B.1, limit the linear heat rate in the core to within an acceptable value. The reduction of the trip setpoints is considered to be a backup that is intended to maintain an OPERABILITY margin comparable to that at RTP, and to provide core protection. The revised Completion Time of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months is considered reasonable based upon the number of steps required to complete the action and the low probability of an accident occurring during the Completion Time that would require the associated trips to function. This change is designated as less restrictive because additional time is allowed to reduce the trip setpoints than was allowed in the CTS.

L03 (Category4 - Relaxation of Required Action) CTS 3.2.2 Action c and CTS 3.2.3 Action c require that, in the event FQ and FAH (the power peaking factors),

respectively, are not within limits, the cause of the out of limit condition be identified and corrected prior to increasing THERMAL POWER above the reduced limit required by Actions a or b. In addition, these Actions state that subsequent POWER OPERATION may proceed provided that FQ and FAH, respectively, are demonstrated through in-core mapping to be within their limits at a nominal 50% of RATED THERMAL POWER (RTP) prior to exceeding this THERMAL POWER, at a nominal 75% of RTP prior to exceeding this THERMAL POWER and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after attaining 95% or greater RTP. ITS 3.2.5 does not contain these actions. This changes the CTS by deleting the requirement to confirm the peaking factors are within limit at 50% RTP, 75% RTP, and 95%

RTP.

The purpose of the CTS 3.2.2 Action c and CTS 3.2.3 Action c is to require confirmation that the core power distributions are within limits during the power increase following an out of limit condition. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while providing time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, because only a short time period of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to operate with the power peaking factors outside of limits. This time period limits the potential for inducing an adverse perturbation in the axial xenon distribution.

Operating the unit in accordance with the requirements of ITS LCO 3.1.4, "CONTROL ROD Group Alignment Limits," LCO 3.2.1, "Regulating Rod Insertion Limits," LCO 3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits,"

LCO 3.2.3, "AXIAL POWER IMBALANCE Operating Limits," and LCO 3.2.4, "QUADRANT POWER TILT," provides assurance that the power peaking factors will be maintained within limits. These LCOs provide the Required Actions for correcting the cause of those conditions that could result in power peaking factors exceeding limits. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 7- Relaxation of Surveillance Frequency - Non-24 Month Type Change) CTS 4.2.2.1 and CTS 4.2.3.1 require, in part, that FQ and FNH, respectively, are determined to be within limits by using the incore detectors to obtain a power distribution map. The Frequencies of the Surveillance Requirements are prior to operation above 75% RTP after each fuel loading, at Davis-Besse Page 4 of 5 Attachment 1, Volume 7, Rev. 1, Page 116 of 132

Attachment 1, Volume 7, Rev. 1, Page 117 of 132 DISCUSSION OF CHANGES ITS 3.2.5, POWER PEAKING FACTORS least once per 31 Effective Full Power Days. The Surveillance Frequency also states that the provisions of Specification 4.0.4 are not applicable. ITS SR 3.2.5.1 requires that FQ and FAH, be verified to be within limits by using the Incore Detector System to obtain a power distribution map as specified by the applicable LCO(s). ITS SR 3.2.5.1 is modified by a note that states that the verification is only required to be performed when specified in LCO 3.1.8, "PHYSICS TESTS Exceptions - MODE 1," or when complying with Required Actions of LCO 3.1.4, "CONTROL ROD Group Alignment Limits," LCO 3.2.1, "Regulating Rod Insertion Limits," LCO 3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits," LCO 3.2.3, "AXIAL POWER IMBALANCE Operating Limits," and LCO 3.2.4, "QUADRANT POWER TILT." This changes the CTS by deleting the requirement to perform the power peaking factor determinations at the specified Frequencies.

The purpose of CTS 4.2.2.1 .b and CTS 4.2.3.1 .b is to demonstrate that Fa and FNH are within the limits specified in the respective LCOs. This change is acceptable because operating the unit in accordance with the requirements of ITS LCO 3.1.4, "CONTROL ROD Group Alignment Limits," LCO 3.2.1, "Regulating Rod Insertion Limits," LCO 3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits," LCO 3.2.3, "AXIAL POWER IMBALANCE Operating Limits," and LCO 3.2.4, "QUADRANT POWER TILT," provides assurance that the power peaking factors will be maintained within limits. CTS 4.2.2.1 .b and CTS 4.2.3.1.b provide a confirmation of already known conditions, assuming that the unit is being operated within the requirements of LCO 3.1.4, LCO 3.2.1, LCO 3.2.2, LCO 3.2.3, and LCO 3.2.4. However, when required to be verified because of a failure to meet one or more of the referenced LCOs, the power peaking factors will be verified to ensure the continued compliance with the core power distribution assumptions of the accident analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Davis-Besse Page 5 of 5 Attachment 1, Volume 7, Rev. 1, Page 117 of 132

Attachment 1, Volume 7, Rev. 1, Page 118 of 132 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 118 of 132

Attachment 1, Volume 7, Rev. 1, Page 119 of 132 Power Peaking Factors 3.2.5 CTS 3.,2 POWER DISTRIBUTION LIMITS 3.2.5 Power Peaking Factors 3.2.2, 3.2.3 LCO 3.2.5 F 0v] and FR shall be within the limits specified in the COLR. 0 APPLICABILITY: MODE 1 with THERMAL POVWER > 20% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3.2.2 Action a, 3.2.2 Action b A. Fq0-- ] not within limit. A.1 Reduce THERMAL POWER 1% RTP for 15 minutes 0 each 1% that FQR-*

exceeds limit. 0 AND F Hig-h Flux }I 10 2 A.2 Reduce Inucleareyerpowe trip setpoint and nucear/

thours 0o overpow ased on_

Reactor/Coolant Sys m (RCS) ow and AXI L PO R IMBALAN E trip AFlux-AFW-owI 0

setpoint _>1% RTP for each 1% that FA exceeds limit.

0 AND A.3 Restore FQ*to within limit.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months -0 3.2.3 Action a, B. FNH not within limit. B.1 Reduce THERMAL 15 minutes 3.2.3 Action b POWER > RH(%) RTP (specified in the COLR) for each 1% that F,'H exceeds limit.

AND

______________________________ I____________________________________________________________

0 BWOG STS 3.2.5-1 Rev. 3.0, 03131/04 Attachment 1, Volume 7, Rev. 1, Page 119 of 132

Attachment 1, Volume 7, Rev. 1, Page 120 of 132 Power Peakingi Factors 3.2.5

. CTS ACTIONS (cpqntinued)

CONDITION REQUIRED ACTION :COMPLETION ýTIME 2 10 B.2 Reduce leaoverpower trip setpoint and nucle rý hours 0 overpow r asedon C, flow an AXIAL PO ER IMBA NCE trip setpoint

~AFIux-FIow 0

>_ RH(%) RTP (specified in the COLR) for each 1% that FNH exceeds limit.

AND B.3 Restore FN towithin limit. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3.2.2 Action b,C. Required Action and C. 1 Be MODE ith .2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 3.2.3 Action b associated Completion THERMAL POWER *20%

Time not met. RTP.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 4.2.2.1, 4.2.3.1

'SR 3.2.5.1 NOTE - --------

Only required to be performed when specified in LCO 3.1.8, "PHYSICS TESTS Exceptions -

MODE 1," or when complying with Required Actions of LCO 3.1.4, "CONTROL ROD Group Alignment Limits," LCO3.2.1, "Regulating Rod Insertion Limits," LCO.3.2.2, "AXIAL POWER SHAPING ROD (APSR) Insertion Limits," LCO 3.2.3, "AXIAL POWER IMBALANCE Operating Limits," LCO 3.2.4, "QUADRANT POWER TILT (QPT).'-" or 0

Verify Fcpg and FNH are within limits by using the As specified by 0 Incore Detector System to obtain a power the applicable distribution map. LCO(s)

BWOG STS 3.2.5-2 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 120 of 132

Attachment 1, Volume 7, Rev. 1, Page 121 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.5, POWER PEAKING FACTORS

1. Changes are made which reflect the plant specific nomenclature.

2. The Completion Times of ITS Required Action A.2 and B.2 have been changed from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . The proposed Completion Times are consistent with the Completion Times for similar actions in ISTS 3.2.4 Required Actions A.1.2.2 and C.2 and in ISTS 3.2.4 Required Action A.2.3.

3. Editorial change made to be consistent with other Specifications (i.e., ITS 3.2.3).

4. Typographical/grammatical error corrected.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 121 of 132

Attachment 1, Volume 7, Rev. 1, Page 122 of 132 Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

Attachment 1, Volume 7, Rev. 1, Page 122 of 132

Attachment 1, Volume 7, Rev. 1, Page 123 of 132 Power Peaking Factors B 3.2:5 B3.2 POWER DISTRIBUTION LIMITS B 3.2.5 Power Peaking Factors BASES BACKGROUND The purpose of this LCO is to establish limits that constrain the 'core power distribution'wthin design limits during normal operation (Condition 1) and during anticipated operational occurrences (Condition 2) such that accident initial condition protection criteria are preserved. The accident ihitial condition~criteria are preserved by bounding operation at THERMAL POWER within specifiedacceptable.

fuel design limits. -1 F cj 0 is a specified acceptable fuel design limit that preserves the initial 0

conditions for the Emergency Core Cooling Systems (ECCS) analysis.

FQf] is defined as the maximum local fuel:rod linear power density 0 divided by the average fuel rod linear power density, assuming nominal fuel pellet and rod dimensions. Because'FcM is a ratio of local power 0 densities, it is related to the maximum local (pellet) power density in a fuel rod. Operation within the F 0M limits given in the COLR prevents power 0 peaking that would exceed the loss of coolant accident (LOCA) linear heat rate (LHR) limits derived from.the analysis of the ECCS.

The FA H limit is a specified acceptable fuel design limit that preserves the initial conditions for the limiting loss of flow transient. F',' is defined as:

the ratio of the integral of linear power along therfuel rod on which the minimum departure from nucleate boiling ratio (DN BR) occurs to the average integrated rod power. Because FH is a ratio of integrated powers, it is related to the maximum total power produced in a fuel rod.

Operation within the F. limits given in the COLR prevents departure from nucleate boiling (DNB) during a postulated loss of forced reactor coolant flow accident, Measurement of the core power peaking factors usingthe Incore Detector System to obtain a three dimensional power distribution map provides direct confirmation that FF H are within their limits, and may be used to verify that the power peaking factors remain bounded when one 0

or more normal operating parameters exceed their limits.

BWOG STS B 3.2.5-1 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 123 of 132

Attachment 1, Volume 7, Rev. 1, Page 124 of 132 Power Peaking. Factors B 3.2.5 BASES.

APPLICABLE SAFETY The limits on .F4)]are determined by the ECCS analysis in Qrder toj imiti peak cladding temperatures to 2200°F during a LOCA. The:maximum 0

ANALYSES acceptable cladding tempera~ture is specified by 10CFR 50,.46 (Ref. 1);..

Higher cladding temperatures could cause severe. cladding failure by, oxidation due to aZircaloy Water reaction. Other criteria must also be met (e'g., maximum cladding oxidation, maximum hydrogen ,geneTration,;

coolable geometry, and Iong term cooling). However, peak cladding temperature is usually most limiting.

The limits on F'AH .provide protection from DNB during a limiting loss of flow transient. Proximity to the DNB condition is expressed by the DNBR, defined as the ratio of the cladding surface heat flux required to cause DNB to the actual cladding surface heat flux, The minimum DNBR value during both normal operation and anticipated transients is limited to the DNBR correlation limit for the particular fuel design in use, and is accepted as an appropriate margin to DNB. The DNBR correlation limit

ensures that there is at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that:the hot fuel rod in the core does not experience DNB.

This LCO precludes core power distributions that violate the following-fuel design criteria:

a. During aa LOCA, peak cladding temperature must not, 03 exceed 2200'F (Ref. 1)1;f*

0

b. During a loss of forced reactor coolant flow accident,.there must be at least 95% probabilityat the 950% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the.core does not experience a DNB condition.

The reload safety evaluation analysis determines limits on global core parameters that characterize the, core power distribution. The primary.

parameters used to monitorand control the core power distribution are the regulating rod position,.the APSR positionthe AXIAL POWER IMBALANCE, and the QPT. These parameters are normally used to monitor and control the core power distribution because their measurements are continuously observable. Limits:are placed on these parameters to ensure that the core power peaking factors remain BWOG STS B 3.2.5-2 Rev. 3.0,'03/31/,04 Attachment 1, Volume 7, Rev. 1, Page 124 of 132

Attachment 1, Volume 7, Rev. 1, Page 125 of 132 Power Peaking Factors B 3.2.5 BASES APPLICABLE SAFETY'AN ALYSES (continued).

bounded during operation in MODE: 1 with THERMAL POWER.greater than 20% RTP.,. Nuclear design model calculational uncertainty, manufacturing tolerances (e.g., the.engineeringihot channel factor),

effects of fuel densification and rod bow, and modeling simplifications (such as treatmehnt of the spacer grid effects) are accommodated through use of peaking augmentation factors in the. reload safety evaluation analysis.

Fomand F'. satisfy Criterion.2 of 10 CFR 50.36(c)(2)(ii).

LCO This LCO~for the power peaking factors FQ-) 0 ]andFN H ensures that the core operates within the bounds assumed for the ECCS and thermal hydraulic analyses. Verification that FZ] and F.Hare within the limits of (II this LCO'as specified in'the COLR allows continued operation at THERMAL POWER when the Required Actions of LCO 31.4, "CONTROL ROD Group Alignment Limits," LCO 3.2.1, "Regulating Rod Insertion Limits," LCO 3.2.2, "AXIAL POWER SHAPING ROD Insertion Limits," LCO 3.2.3, "AXIAL POWER IMBALANCE Operating Limits ".and LCO 3.2.4, "QUADRANT POWER TILT," are entered. Conservative THERMAL POWER reductions are required if the limits on FQM and FNH are exceeded. Verification that FR])and F'H are within limits is alSO 0 required during MODE 1 PHYSICS TESTS per LCO 3.1.8, "PHYSICS TESTS Exceptions. - MODE 1."

Measurement uncertainties are applied when F.Q and F'H are determined using the Incore Detector System. The measurement uncertainties applied to the measured values of FaQj and FjH account

for uncertainties in observability and instrument string signal processing.

APPLICABILITY in MODE 1 with THERMAL POWER greater than 20% RTP, the limits on FQO] and FNH must be maintained in order to prevent.the core power 0 distribution from exceeding the limits assumed in the~analyses of the LOCA and loss of flow accidents. In MODE 1 with THERMAL POWER less than or equal to 20% RTP and in MODES 2, 3, 4, 5, and 6, this LCO is not applicable because the reactor has insufficient stored energy, in the fuel or energy being transferred to the coolant to require a limit on the distribUtion of core power.

BWOG STS B 3.2.5-3 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 125 of 132

Attachment 1, Volume 7, Rev. 1, Page 126 of 132 Power Peaking Factors B 3.25:

BASES APPLICABILITY (continued)

The minimum THERMAL POWER level of 20% RTP was chosenbased on'the ability of the Incore Detector System to satisfactorily obtain meaningful power distribution data.

ACTIONS The operator must takeO care in interpreting the relationship of the:power peaking factors Fo*Mand F'H to their limits. Limit values of Fo]and I H in'the COLR may be expressed in either LHR or in peaking units.

Because FdM and F'H are power peaking factors, constant LHR-is maintained as THERMAL POWER is reduced, thereby allowing power peaking to be increased in inverse proportion to THERMAL POWER.

Therefore, the FaQ51and FA H limits increase as THERMAL POWER decreases (assuming FQa]and F', are expressed in peaking units) so that a constant LHR limit is maintained.

0 A.A When FQ*-'isdetermined not to be within its specified limit as determined by a three dimensional power.distribution map, a THERMAL POWER reduction is taken to reduce the maximum LHR in the core.

Design calculations have verified that a conservative THERMAL POWER reduction is 1% RTP or more for each 1% by which F 0- exceeds its limit 2 (The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time.

A.2 Power operationis allowed to continue by Required Action A. 1 if THERMAL POWER is reduced by 1% RTP or more from the.

Flux ALLOWABLE THERMAL POWERfor each 1% by which FoQv exceeds its limit. The same reduct ion ir nuc learýerpower trip setpoint and nuclear 4-the overpo AXIAL POWER/er based IMBALA(NCE Reactor on/he =tri-p Coolot setpoint is required (RCS)

Systemfor 1%and eachflow by Flux-AFlux-Flow j Which Fcf is in excess of its limit. These reductions maintain both core protection and OPERABILITY margin at the reduced THERMAL.POWER.

The required Completion Time ifhours s reasonable based on the low

~probabilityof an accident occurring in this short time period and the number of steps required to complete the Required Action.

BVVOG STS B 3.2.5-4 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 126 of 132

Attachment 1, Volume 7, Rev. 1, Page 127 of 132 Power Peaking Factors B 3.2.5 BASES ACTIONS (continued)

A.3 Continued operation with FQ-) exceeding its limit:is not permitted,.

because the initial conditions~assumed in. the accident~analyses, are no longervalid. The required Completion Time of 24-ho urs to restore Fcm ()

within its limits at the reduced THERMAL POWER level is reasonable based on .the low probability of a limiting event occurring simultaneously with FcM exceeding its limit. In addition, it precludes long term depletion with local LHRs higher than the limiting values, and limits the potential~for inducing an adverse perturbation in the axial.xenon distribution.

B.1 When FAH is determined not to be within its acceptable limit as determined by a three dimensional power distribution map,:a THERMAL.

POWER reduction is taken to reduce the maximum LHR in'the core. The parameter RH by which THERMAL POWER is decreased per 1%

increase in FNH above the limit has been verified to beconservative by design calculations, and is defined in the COLR.. The parameter RH is the inverse of the increase in F.H :allowed as:THERMAL POWER decreases by 1% RTP,.and is based on an analysis of the DNBR during the limiting loss of forced reactor coolant flow transient.from various initial THERMAL POWER levels. The, required Completion Time. of 15 minutes is reasonable for the 'operator to take the actions necessary to reduce the unit power.

B.2 Flux-A.Flux-Flow When a decrease in THERMAL POWER is required because FNA a exceeded its limit, Required Action B.2 requires reduction of the"igh ux trip s e tpo in t a n dl t e n c e r o e p w r b* e d o C l wa d A I L POWER IMBALANCEtrip setpoint. The amount of reductionofthese trip setpoints is governed by the same.factor .(RH(%) for each .1%that F"H

.exceeds its limit) that determines the THERMAL POWER reduction. This process maintains core protection by providing margin to the trip setpoints at the reduced THERMAL POWER similar to that at RTP. The parameter RH is specified in the COLR. The required Completion Time of hours is reasonable based on the low probability of an~accident occurring inthisr.-DE.

short time period and the number of steps required.to complete this Action.

BWOG STS B 3.2.5-5 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 127 of 132

Attachment 1, Volume 7, Rev. 1, Page 128 of 132 Power Peaking Factors B 3.2.5 BASES ACTIONS (continued)

B.3 Continued operation with. F1h exceeding its limit is not permitted, because the initial conditions assumed in the accident analyses are no

.longer valid. The required Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore FH within its limit at the reduced THERMAL POWER level is reasonable based on the low probability of a limiting event occurring simultaneously with F, H exceeding its limit. In addition, this Completion Time precludes long term depletion with an unacceptably high local power and limits the potential for inducing an adverse perturbation in the radial xenon distribution.

C.1 If a THERMAL POWER reduction is not sufficient to restore FOR) or FAH D within its limit (i.e., the Required Actions and associated Completion Times for Condition A or B are not met), then THERMAL POWER operation should be significantly reduced. The reactor is placed in MODE 1 with THERMAL POWER less than or equal to 20% RTP in which this LCO does not apply. The required Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months is a reasonable amount of time for the operator to reduce THERMAL POWER in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.5.1 REQUIREMENTS Core monitoring is performed using the Incore Detector System to obtain a three dimensional power distribution map. Maximum values of FoR-and F'Ah obtained from this map may then be compared with the FM and limits in the COLR to verifythat the limits have not been exceeded.

Measurement of the, core power peaking factors in this. manner may., be used to verify that the measured values of FA and F0 remain with'n their specified limits when one or more of the limits specified by LCO 3.1.4, LCO 3.2.1, LCO 3.2.2, LCO 3.2.3, or LCO 3.2.4 is exceeded, or when LCO 3.1.8 is applicable. If FQA]and FN H remain within their limits when one or more of these parameters exceed their limits, operation at THERMAL POWER may continue because the true initial conditions (the power peaking factors) remain within their specified limits.

BWOG STS B 3.2.5-6 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 128 of 132

Attachment 1, Volume 7, Rev. 1, Page 129 of 132 Power Peaking Factors B 3.2.5 BASES' SU.RVEILLANCE REQUIREMENNTS (continued)

Because the limits.:on FQ*51and FNH are preserved when the parameters specified by LCO 3.1.4, LCO 3.2.1, LCO3.2.2, LCO 3.2:3, and LCO 3.2.4 02 are within their limits, a Note is provided in the SR to indicate that monitoring of the power peaking factors is required only when complying wwith the Required Actions of these LCOs and when LCO 3.1.8 is

,applicable.

Frequencies for monitoring of the, power peaking factors are specified in the Action statements of the individual LCOs. These Frequencies are reasonable based on the low probability of a limiting event occurring simultaneously with either FcM or F' H exceeding its limit, and they provide sufficient time for the operator to obtain a power distribution map 0) from the Incore Detector System. Indefinite THERMAL POWER

-operation in a Required Action of LCO 3.1.4, LCO 3.2.1, LCO 3.2.2, LCO 3.2,3, or LCO 3.2.4 is not permitted, in order tolimit the potential for exceeding both the power peaking factors assumed in the accident analyses due to operation with unanalyzed core power distributions and spatial xenon distributions beyond their analyzed ranges. 0 REFERENCES 1. 10CFR50.46.

'The measured values are required to be adjusted to account for manufacturing tolerances and measurement uncertainties before being compared to the acceptance]

criteria specified in the COLR. These adjustments are included in the COLR.

BWOG STS B 3.2.5-7 Rev. 3.0, 03/31/04 Attachment 1, Volume 7, Rev. 1, Page 129 of 132

Attachment 1, Volume 7, Rev. 1, Page 130 of 132 JUSTIFICATION FOR DEVIATIONS ITS 3.2.5 BASES, POWER PEAKING FACTORS

1. These punctuation corrections have been made consistent with the Writer's Guide for the Improved Standard Technical Specifications, TSTF-GG-05-01, Section 5.1.3.

2. Changes are made to reflect changes made to the Specification.

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. This parenthetical Reference has been deleted. The ISTS Bases does not provide a specific reference in the References Section, and other similar Actions Bases (A.2, B.1, and B.2) do not specify a Reference.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 130 of 132

Attachment 1, Volume 7, Rev. 1, Page 131 of 132 Specific No Significant Hazards Considerations (NSHCs)

Attachment 1, Volume 7, Rev. 1, Page 131 of 132

Attachment 1, Volume 7, Rev. 1, Page 132 of 132 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.5, POWER PEAKING FACTORS There are no specific NSHC discussions for this Specification.

Davis-Besse Page 1 of 1 Attachment 1, Volume 7, Rev. 1, Page 132 of 132

v t e Letter Sequence Request
TAC:MD6398, Increase Flexibility in Mode Restraints, Addition of LCO 3.0.8, Inoperability of Snubbers, Deletion of E BAR Definition and Revision to RCS Specific Activity Tech Spec, Changes to Reflect Revision of 10 CFR 50.55A, Limit Inservice Testing Program SR 3.0.2 Application to Frequencies of 2 Years or Less, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO, Correct Example 1.4-1, Containment Structural Integrity, TSTF-28, Correct LCO 3.0.6 Bases, Add Restriction for Lowest LOOP Tave During Mode 2 Physics Testing (Approved, Closed) TAC:MD6319, DC Electrical Rewrite - Update to TSTF-360, Eliminate Use of Term Core Alterations in Actions and Notes, Provide Actions for One Steam Supply to Turbine Driven Afw/Efw Pump Inoperable, DC Electrical Rewrite, Clarification of Required Features in 3.8.1 Actions (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement Administration Meeting, Meeting, Meeting Questions 18 June 2008 20 June 2008 Answers 23 July 2008 3 September 2008 Results Approval Other: L-08-161, Copy of Applicable Portions of the NRC and Davis-Besse Improved Technical Specifications Conversion Website - Sections 3.0, 3.1, 3.2, 3.4, and 3.6 and Chapter 4.0, L-08-241, Attachment 1, Applicable Portions of the U.S. Nuclear Regulatory Commission (NRC) and Davis-Besse Nuclear Power Station (DBNPS) Improved. Technical Specification (ITS) Conversion Website, Section 3.5 RAIs, L-08-338, Copy of Improved Technical Specifications (ITS), L-08-378, Implementation of Improved Technical Specification Amendment No. 279, ML073531253, ML081350505, ML082000451, ML082270661, ML082270662, ML082270663, ML082270664, ML082270665, ML082270666, ML082270667, ML082270669, ML082270670, ML082600577, ML082840099, ML082900630, ML082900882, ML082910125
MONTHYEAR2008-02-04 [Table View]

ML081480467

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