Text

Supplement to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A,
	ML22343A255
Person / Time
Site:	Vogtle, Farley
Issue date:	12/09/2022
From:	Gayheart C; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	NL-22-0897
	Download: ML22343A255 (1)
	v • d • e

Cheryl A. Gayheart 3535 Colonnade Parkway

>. Southern Nuclear Regulatory Affairs Director Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com

December 9, 2022

Docket Nos.: 50-348 50-424 52-025 NL-22-0897 50-364 50-425 52-026 10 CFR 50.90

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001

Joseph M. Farley Nuclear Plant - Units 1 &2 Vogtle Electric Generating Plant - Units 1 &2 Vogtle Electric Generating Plant-Units 3&4 Supplement to Non-Voluntary License Amendment Request:

Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fo Surveillance Technical Specifications

Ladies and Gentlemen:

On October 14, 2022, Southern Nuclear Operating Company requested a license amendment [ML22387A174] to Vogtle Electric Generating Plant (VEGP) Units 1 and 2 renewed facility operating licenses NPF-68 and NPF-81, respectively, Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2 renewed facility operating licenses NPF-2 and NPF-8, respectively, and VEGP Units 3 and 4 combined licenses NPF-91 and NPF-92, respectively.

By letter dated November 18, 2022, the Nuclear Regulatory Commission (NRC) identified that additional information was needed [ML22308A204] to justify the variation from the Notes associated with Technical Specification 3.2.1, Condition A and Condition B, as included in the applicable Appendix A and Appendix D of WCAP-17661-P-A, Revision 1.

Additional information addressing the subject Notes is included in the Enclosure.

The conclusions of the No Significant Hazards Consideration Determination Analysis and Environmental Consideration contained in the original application have been reviewed and are unaffected by this supplement.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia and State of Alabama of this license amendment request supplement by transmitting a copy of this letter and enclosures to the designated State Official. This letter contains no NRC commitments.

If you have any questions, please contact Amy C Chamberlain at 205.992.6361.

U.S. Nuclear Regulatory Commission NL-22-0897 Page2

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of December 2022.

Respectfully submitted,

SOUTHERN NUCLEAR OPERATING COMPANY

C. A. Gay e rt Director, ul tory Affairs Southern Nuclear Operating Company

CAG/EG/DW

Enclosure : Acceptance Review Revisions

cc: Regional Administrator, Region II NRR Project Manager - Vogtle 1 & 2 Senior Resident Inspector-Vogtle 1 & 2 NRR Project Manager-Farley 1 & 2 Senior Resident Inspector-Farley 1 & 2 NRR Project Manager-Vogtle 3 & 4 Senior Resident Inspector - Vogtle 3 & 4 State of Georgia Environmental Protection Division Director, State of Alabama Office of Radiation Protection RType: CFA04.054, CVC?000 Joseph M. Farley Nuclear Plant - Units 1 and 2; Vogtle Electric Generating Plant - Units 1 and 2; Vogtle Electric Generating Plant-Units 3 and 4

Enclosure to NL-22-0897 Supplement to NL-20-0170

Acceptance Review Revisions Supplemental Information Enclosure to NL-22-0897 Acceptance Review Revisions

Supplemental Information for NL-20-0170

In the License Amendment Request (LAR) provided by Southern Nuclear Operating Company (SNC) letter NL-20-0170 date October 14, 2022, SNC proposed variations from the changes identified in WCAP-17661-P-A, Appendices A and D, as applicable.

One such variation affected the addition to the Technical Specification (TS} 3.2.1 Condition A Note 1 and the Note to proposed Required Action B.2.1 which were modified to omit the phrase, "prior to increasing THERMAL POWER above the limit of Required Action A.1 [B.2.1]." This portion of the Note was not included because it is redundant to the completion time of the Required Action to which the Note refers and could cause misinterpretation of the entry condition for the Notes.

SNC has elected to include the subject phrase in the pertinent Notes to align with the approved TS changes in the WCAP-17661-P-A, Rev. 1 Safety Evaluation. Impacts to the LAR are identified and addressed below and replacement pages are provided with revision bars in the Attachment.

The Enclosure and Attachments to NL-20-0170 are revised as follows:

Replacement pages are provided for Enclosure pages E-4 and E-5.

Section 2.4, Description of Proposed Change, Item A for proposed changes to VEGP 1 &2 and FNP 1 &2 TS 3.2.1, Action A and Action B, is revised to show the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1 [B.2.1 ]" is included.

Replacement pages are provided for Enclosure pages E-6 and E-7.

Section 2.4, Description of Proposed Change, Item B for proposed changes to VEGP 3&4 TS 3.2. 1, Condition A and Condition B, is revised to show the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1 [B.2. 1]" is included.

Replacement pages are provided for Enclosure pages E-14 and E-15.

Section 3, Technical Evaluation, Item A for proposed changes to VEGP 1&2 and FNP 1 &2, Section 3.5, Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations, variation #5 is removed.

Replacement pages are provided for Enclosure pages E-21 and E-22.

Section 3, Technical Evaluation, Item A for proposed changes to VEGP 3&4, Section 3.5, Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations, variation #2 is removed.

A replacement page is provided for the second page of Attachment 1.

The VEGP 1 &2 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in Insert 3.2.1-1 for the Condition A Note 1.

A replacement page is provided for the fourth page of Attachment 1.

The VEGP 1 &2 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1" in Insert 3.2.1-2 for the Required Action B.2.1 Note.

SE-2 Enclosure to NL-22-0897 Acceptance Review Revisions

A replacement TS page 3.2.1-1 is provided for Attachment 2.

The clean VEGP 1 &2 Revised TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in the Condition A Note 1.

A replacement TS page 3.2.1-2 is provided for Attachment 2.

The clean VEGP 1 &2 Revised TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1" in the Required Action B.2.1 Note.

A replacement TS page 3.2. 1-3 is provided for Attachment 2.

The clean VEGP 1 &2 Revised TS Pages are revised to include a horizontal line between Required Action B.2.5 and Condition C. This is an editorial revision identified during the impact review.

A replacement page is provided for the second page of Attachment 3.

The FNP 1 &2 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in Insert 3.2.1-1 for the Condition A Note 1.

A replacement page is provided for the fourth page of Attachment 3.

The FNP 1 &2 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1 " in Insert 3.2.1-2 for the Required Action B.2.1 Note.

A replacement TS page 3.2.1-1 is provided for Attachment 4.

The clean FNP 1 &2 Revised TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in the Condition A Note 1.

Replacement TS pages 3.2. 1-2 and 3.2.1-3 are provided for Attachment 4.

The clean FNP 1 &2 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1 " in the Required Action B.2.1 Note.

A replacement page is provided for the second page of Attachment 5.

The VEGP 3&4 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in Insert 3.2.1-1 for the Condition A Note 1.

A replacement page is provided for the fourth page of Attachment 5.

The VEGP 3&4 Marked-up TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1 " in Insert 3.2.1-2 for the Required Action B.2.1 Note.

A replacement TS page 3.2.1-1 is provided for Attachment 6.

The clean VEGP 3&4 Revised TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in the Condition A Note 1. The page is also revised to include "(continued)" below the final line.

SE-3 Enclosure to NL-22-0897 Acceptance Review Revisions

A replacement TS page 3.2.1-3 is provided for Attachment 6.

The clean VEGP 3&4 Revised TS Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1" in the Required Action B.2.1 Note.

A replacement page is provided for the Insert B 3.2.1-8 page of Attachment 7.

The VEGP 1 &2 Marked-up TS Bases Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in Insert B 3.2.1-8 for the Condition A Note 1.

Three replacement pages are provided for the Insert B 3.2.1-9 pages of Attachment 7.

The VEGP 1 &2 Marked-up TS Bases Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1" in the second page of Insert 3.2.1-9 for the Required Action B.2.1 Note.

A replacement page is provided for the Insert B 3.2.1-8 page of Attachment 8.

The FNP 1 &2 Marked-up TS Bases Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in Insert B 3.2.1-8 for the Condition A Note 1.

Three replacement pages are provided for the Insert B 3.2.1-9 pages of Attachment 8.

The FNP 1 &2 Marked-up TS Bases Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1" in the second page of Insert 3.2.1-9 for the Required Action B.2.1 Note.

A replacement page B 3.2.1-5 markup is provided for Attachment 9.

The VEGP 3&4 Marked-up TS Bases Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action A.1" in the Bases for Required Action A.3 addressing the Condition A Note 1.

Two replacement pages are provided for the Insert B 3.2.1-4 pages of Attachment 9.

The VEGP 3&4 Marked-up TS Bases Pages are revised to include the phrase "prior to increasing THERMAL POWER above the limit of Required Action B.2.1 " in the second page of Insert 3.2.1-4 for the Required Action B.2.1 Note.

The thirty-two (32) replacement pages are provided in the Attachment.

SE-4 Joseph M. Farley Nuclear Plant - Units 1 and 2; Vogtle Electric Generating Plant - Units 1 and 2; Vogtle Electric Generating Plant-Units 3 and 4

Attachment to NL-22-0897 Supplement to NL-20-0170

Acceptance Review Revisions Replacement Pages Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

Action A

Two notes are added. Note 1 states: "Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1." Note 2 states: "SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after refueling."

Required Actions A.2 and A.3 are revised replacing, "1 % for each 1 % Fa(Z) exceeds steady state limit" with "1% for each 1% that THERMAL POWER is limited below RTP by Required Action A.1."

Revising the completion times of Required Actions A.1, A.2, and A.3 to include;

"... after each Fi(Z) determination."

Required Action A.4 is being revised to state (addition in italics text):

"Perform SR 3.2.1.1 and SR 3.2.1.2."

Action B

Required Action B. 1 and associated completion time is deleted and replaced with the following actions:

Required Action B.1.1 states "Restore F '; (Z) to within limits specified in the COLR," with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and Required Action B.1.2 states "Perform SR 3.2.1.1 and SR 3.2.1.2," with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

A Note modifies Required Action B.1.1 stating "Required Action B.1.2 shall be completed if control rod motion is required to comply the new operating space implemented by Required Action B.1.1."

An alternative to Required Actions B.1.1 and B.1.2 is provided as:

Required Action B.2.1 states "Limit THERMAL POWER to less than RTP by amount specified in the COLR," with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each F';(Z) determination, Required Action B.2.2 states "Reduce AFD limits by amount specified in the COLR," with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each F';(Z) determination, Required Action B.2.3 states "Reduce Power Range Neutron Flux - High trip setpoints ~ 1 % for each 1 % THERMAL POWER is limited below RTP by Required Action B.2.1," with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each F';(Z) determination, Required Action B.2.4 states "Reduce Overpower b. T trip setpoints ~ 1 % for each 1 % that THERMAL POWER is limited below RTP by Required Action B.2.1," with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each F';(Z) determination, and Required Action B.2.5 states "Perform SR 3.2.1.1 and SR 3.2.1.2," with a completion time of "Prior to increasing THERMAL POWER above the limit of Required Action B.2.1."

E-4 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

A note modifies Required Action B.2.1 stating "Required Action B.2.5 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1."

Surveillance Requirements

FNP Only - The note to the SRs; allowing, during power escalation at the beginning of each cycle, thermal power to be increased until an equilibrium power level has been achieved at which a power distribution map is obtained; is deleted.

VEGP Only - Revising the first frequency of SR 3.2.1.1 from "Once after each refueling after achieving equilibrium conditions at any power level exceeding 50% RTP," to "Once after each refueling prior to THERMAL POWER exceeding 75% RTP."

Revising the second frequency of SR 3.2.1.1 to include a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months delay after achieving equilibrium conditions, from "Once after achieving equilibrium conditions after exceeding, by~ 20% RTP, the THERMAL POWER at which Fa(Z) was last verified," to "Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by~ 10% RTP, the THERMAL POWER at which Faw(Z) was last verified."

Note to SR 3.2.1.2, describing additional requirements if Fa(Z) measurements indicate an increase in the maximum over Z expression, is deleted.

Revising the first frequency of SR 3.2.1.2 from "Once after each refueling after achieving equilibrium conditions at any power level exceeding 50% RTP," for VEGP and "Once after each refueling prior to THERMAL POWER exceeding 75% RTP," for FNP to "Once after each refueling within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after THERMAL POWER exceeds 75% RTP."

Revising the second frequency of SR 3.2.1.2 from "Once after achieving equilibrium conditions after exceeding, by~ 20% RTP, the THERMAL POWER at which Fa(Z) was last verified," to "Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by~ 10% RTP, the THERMAL POWER at which Faw(z) was last verified."

TS 5.6.5 Change

Westinghouse topical report WCAP-17661-P-A, Revision 1, "Improved RAOC and CAOC Fa Surveillance Technical Specifications," February 2019 is added to the list of documents describing the analytical methods used to determine the core operating limits specified in Specification 5.6.5.b of the VEGP Units 1 and 2 TS and FNP Units 1 and 2 TS with applicability to TS 3.1.6, TS 3.2.1, and TS 3.2.3.

VEGP only - Changes are made in the list of documents describing the analytical methods for WCAP-10216-P-A, Revision 1A, WCAP-10266-P-A, Revision 2, WCAP-12610-P-A, and WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, to remove the parenthetical phrase "(W(Z) surveillance requirements for Fa Methodology)" from each.

E-5 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

FNP only - Specification 5.6.5.a listing of Specifications for which core operating limits must be established is revised for items 5, 6 and 8 from:

5. Control Bank Insertion Limit for LCO 3.1.6,

6. Heat Flux Hot Channel Factor FaRTP limits, K(Z) figure, W(Z) values, and Fa(Z) Penalty Factors for LCO 3.2.1,

8. Axial Flux Limits for LCO 3.2.3, to:

5. Control Bank Insertion Limit and RAOC Operating Spaces for LCO 3.1.6,

6. Heat Flux Hot Channel Factor FaRTP limit, K(Z) figure, T(Zf 0 LR values, and RAOC Operating Spaces for LCO 3.2.1,

8. Axial Flux Limits and RAOC Operating Spaces for LCO 3.2.3.

B. The proposed change would modify the following for VEGP 3&4:

TS 3.2. 1 Changes

Condition A

The existing entry Condition Note is revised to read : ""Required Action A.3 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1. "

A second note is added to the entry Condition. Note 2 states: "SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after refueling."

Required Action A.2 is revised replacing, "F;(Z) exceeds limit" with "that THERMAL POWER is limited below RTP by Required Action A.1."

Condition B

The Condition B Note of "Required Action B.3 shall be completed whenever this Condition is entered" is omitted.

The Condition B Required Actions and associated Completion Times are deleted and replaced with the following:

Required Action B.1.1 states "Restore F'/;(Z) to within limits specified in the COLR," with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

A note modifies Required Action B.1.1 stating "Required Action B.1.2 shall be completed if control rod motion is required to comply with the new operating space implemented by Required Action B.1.1."

E-6 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

Required Action B.1.2 states " Perform SR 3.2.1.1 and SR 3.2.1.2," with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

An alternative to Required Actions B. 1.1 and B.1.2 is provided as:

Required Action B.2.1 states "Limit THERMAL POWER to less than RTP by amount specified in the COLR," with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each F';(Z) determination.

A note modifies Required Action B.2. 1 stating "Required Action B.2.3 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1."

Required Action B.2.2 states "Reduce Overpower ~T trip setpoints ~ 1% for each 1 % that THERMAL POWER is limited below RTP by Required Action B.2.1," with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each F '; (Z) determination.

Required Action B.2.3 states "Perform SR 3.2.1.1 and SR 3.2.1.2," with a completion time of "Prior to increasing THERMAL POWER above the limit of Required Action B.2.1."

Surveillance Requirements

The frequency of SR 3.2.1.2 is revised from "Once after each refueling prior to THERMAL POWER exceeding 75% RTP," to "Once after each refueling within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after THERMAL POWER exceeds 75% RTP."

The first frequency of SR 3.2.1.3 from "Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by~ 10% RTP, the THERMAL POWER at which F ;(Z) was last verified," to "Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by~ 10% RTP, the THERMAL POWER at which F;(Z) was last verified."

The Note 2 to SR 3.2.1.4, describing additional requirements if F '; (Z) measurements indicate an increase in the maximum over Z expression, is deleted. The number "1." for the first Note is removed as is the S on NOTES.

The first frequency of SR 3.2.1.4 from "Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by~ 10% RTP, the THERMAL POWER at which F';(Z) was last verified," to "Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by~ 10% RTP, the THERMAL POWER at which F';(Z) was last verified."

E-7 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

1. System {RTS) Instrumentation (Without Setpoint Control Program), STS 3.3.1 B, Reactor Trip System {RTS) Instrumentation (With Setpoint Control Program), STS 3.6.4A, Containment Pressure (Atmospheric, Dual, and Ice Condenser), STS 3.6.4B, Containment Pressure (Subatmospheric),

STS 3.6.6.C, Containment Spray System (Ice Condenser), and Quench Spray (QS) System (Subatmospheric)).

This variation is a presentation preference, is administrative in nature, and does not alter the intent of the requirements specified in Appendix A of WCAP-17661-P-A.

2. Uses of RATED THERMAL POWER in the TS markup of WCAP-17661-P-A Appendix A are changed to RTP. The abbreviation "RTP" is defined in the definition of RA TED THERMAL POWER in Section 1.1 of the TS. Section 3.2.2.g of the ISTS Writer's Guide (Ref. 5) states, for abbreviations already defined for terms of Section 1.1 of TS, the abbreviation should not be redefined on first time use (e.g., AFD, QPTR, COLR). This is also consistent with other uses of the abbreviation "RTP" throughout the STS and the VEGP and FNP TS. This variation is administrative in nature and continues to meet the intent of the requirements specified in Appendix A of WCAP-17661-P-A

3. Required Actions B.1.1 and B.1.2 and the associated Note are revised and re-arranged. The end result of Required Action B. 1.1 as presented by the WCAP is restoration of the parameter to within limits specified in the COLR.

The method of restoration, in this case "Implement a RAOC operating space specified in the COLR" is moved to the Bases to provide a Required Action that is as brief as possible, consistent with Section 4.1.6.d of the ISTS Writer's Guide (Ref. 5). Further since the end result of Required Action B.1.1 is restored compliance of the parameter to "within the limits specified in the COLR," and thus, compliance with the LCO requirements. Restored compliance with the LCO allows for exiting the Condition. Thus, the intent of Required Action B.1.2 would no longer be required. To ensure that Required Action B.1.2 is performed when "control rod motion is required to comply with the new operating space implemented by Required Action B.1. 1," a Note that requires performance of Required Action B.1.2 is included, such that Required Action B.1.2 must be performed if the conditions of the Note are met, even if Condition Bis exited due to restoration of compliance with the LCO, i.e., the parameter restored to within the limits specified in the COLR. This variation is a presentation preference, considered administrative, and is consistent with the intent of the affected requirements.

4. VEGP only - The Note to the Surveillance Requirements is not included in VEGP TS 3.2. 1. Therefore, it is not annotated for deletion.

5. Not used.

E-14 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

6. The second sentence of the addition to Condition A note is separated into a separate note (Note 2) to Condition A, and revised appropriately to address this change in format. This change is made for clarity of the user. Changed

" NOTE " to "NOTES" and numbered the two notes. TS bases are revised to reflect two notes to Condition A. Section 2.1.4 of the ISTS Writer's Guide (Ref. 5) states that when more than one issue is addressed in a note, separate the items as an ordered list. In addition, Section 3.3.1.a of the ISTS Writer's Guide states that the use of compound sentences that combine related actions or thoughts should be minimized and do not combine unrelated actions or

E-15 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

definition of RATED THERMAL POWER in Section 1.1 of the TS. Section 3.2.2.g of the ISTS Writer's Guide (Ref. 5) states, for abbreviations already defined for terms of Section 1.1 of TS, the abbreviation should not be redefined on first time use (e.g., AFD, QPTR, COLR). This is also consistent with other uses of the abbreviation "RTP" throughout the STS and the VEGP and FNP TS. This variation is administrative in nature and continues to meet the intent of the requirements specified in Appendix A of WCAP-17661-P-A.

2. Not used.

E-21 Attachment to NL-22-0897 Acceptance Review Revisions - Replacement Page

3. The second sentence of the addition to Condition A note is separated into a separate note (Note 2) to Condition A and revised appropriately to address this change in format. This change is made for clarity of the user. Changed "NOTE" to "NOTES" and numbered the two notes. Section 2.1.4 of the ISTS Writer's Guide (Ref. 5) states that when more than one issue is addressed in a note, separate the items as an ordered list. In addition, Section 3.3.1.a of the ISTS Writer's Guide states that the use of compound sentences that combine related actions or thoughts should be minimized and do not combine unrelated actions or thoughts into a compound sentence. Separating the requirement to complete a required action when the Condition is entered and the allowance to not perform a surveillance under certain conditions into two separate notes disconnects these two unrelated thoughts.

This variation is a presentation preference, considered administrative, and continues to meet the intent of the requirement specified in Appendix A of WCAP-17661-P-A.

4. Deleted unnecessary use of the article "the" and "a" in several instances of the TS markups in accordance with Sections 3. 1.1.e and 4.1.6.d of the ISTS Writer's Guide (Ref. 5). Consistent with the concept conveyed in Sections 3. 1.1.e and 4.1.6.d of the ISTS Writer's Guide, additional descriptors (i.e., "its" and "that") are deleted in the TS actions since these words are not required to understand the requirement. This variation is a presentation preference, considered administrative, and does not alter the intent of the affected requirements.

5. Required Actions B.1.1 and B.1.2 and the associated Note are revised and re-arranged. The end result of Required Action B. 1.1 as presented by the WCAP is restoration of the parameter to within limits specified in the COLR.

The method of restoration, in this case "Implement a RAOC operating space specified in the COLR" is moved to the Bases to provide a Required Action that is as brief as possible, consistent with Section 4.1.6.d of the ISTS Writer's Guide (Ref. 5). Further since the end result of Required Action B.1.1 is restored compliance of the parameter to "within the limits specified in the COLR," and thus, compliance with the LCO requirements. Restored compliance with the LCO allows for exiting the Condition. Thus, the intent of Required Action B.1.2 would no longer be required. To ensure that Required Action B.1.2 is performed when "control rod motion is required to comply with the new operating space implemented by Required Action B. 1.1," a Note that requires performance of Required Action B.1.2 is included, such that Required Action B.1.2 must be performed if the conditions of the Note are met, even if Condition Bis exited due to restoration of compliance with the LCO, i.e., the parameter restored to within the limits specified in the COLR. This variation is a presentation preference, considered administrative, and is consistent with the intent of the affected requirements.

E-22 VEGP 1&2 TS Insert 3.2.1-1 (TSTF-290-A, Insert NOTE A )

(WCAP-17661-P-A, Appendix A )

---NOTE § ---

.1. Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1.

L SR 3.2. 1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling.

VEGP 1&2 TS Insert 3.2.1-2 (TSTF-290-A, Insert 1)

(TSTF-241-A based Completion Times)

(WCAP-17661-P-A, Appendix A )

B. F;(z) not within limits. B.1.1 -----------NOTE---

Required Action B.1.2 shall be completed if control rod motion is required to comply with the new operating space implemented by Required Action B.1.1.

Implement a RP,OC 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months operating space specified in the COLR tAat-fR estores F; (Z) to within its limits specified in the COLR.

B. 1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2. 1.2 if control rod motion is required to comply with the nei.v operating space.

OR

B.2.1 -----------NOTE---

Required Action B.2.4§ shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each POWER to less than F; (Z) determination R.l\\TED THERMAL POVVER RTP by TSTF-241-A amount and reduce Based CT AFD limits as specified in the COLR.

Fa(Z) 3.2.1

3.2 POWER DISTRIBUTION LIMITS

3.2.1 Heat Flux Hot Channel Factor (Fa(Z))

LCO 3.2.1 Fa(Z), as approximated by Fac(z) and Faw(z), shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. NOTES

1. Required Action A.4 A.1 Reduce THERMAL 15 minutes after each shall be completed POWER ~ 1 % RTP for Fac(z) determination whenever this each 1 % Fac(z) exceeds Condition is entered limit.

prior to increasing THERMAL POWER AND above the limit of Required Action A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each A.1. Neutron Flux - High trip Fac(z) determination setpoints ~ 1 % for each

2. SR 3.2.1.2 is not 1% that THERMAL required to be POWER is limited below performed if this RTP by Required Action Condition is entered A.1.

prior to THERMAL POWER exceeding AND 75% RTP after refueling. A.3 Reduce Overpower.1. T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each trip setpoints ~ 1 % for Fac(z) determination Fac(z) not within limit. each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

AND

A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1 (continued)

Vogtle Units 1 and 2 3.2.1-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Fa(Z) 3.2.1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

B. Faw(z) not within limits. B.1.1 ---NOTE-- 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Required Action B.1.2 shall be completed if control rod motion is required to comply with the new operating space implemented by Required Action B. 1.1.

Restore F0 W(Z) to within limits specified in the COLR.

AND

B.1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2.

OR

B.2.1 NOTE Required Action B.2.5 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each POWER to less than Faw(z) determination RTP by amount specified in the COLR.

AND

B.2.2 Reduce AFD limits by 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each amount specified in the Faw(z) determination COLR. ( continued)

Vogtle Units 1 and 2 3.2.1-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Fa(Z) 3.2.1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

B. (continued) AND

B.2.3 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each Neutron Flux - High trip Faw(z) determination setpoints ~ 1 % for each 1 % THERMAL POWER is limited below RTP by Required Action B.2.1.

AND

B.2.4 Reduce Overpower ~ T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each trip setpoints for ~1 % for Faw(z) determination each 1% THERMAL POWER is limited below RTP by Required Action B.2.1.

AND

B.2.5 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action B.2.1

C. Required Action and C. 1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

Vogtle Units 1 and 2 3.2.1-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

FNP 1&2 TS Insert 3.2.1-1 (TSTF-290-A, Insert NOTE A )

(WCAP-17661-P-A, Appendix A )

---NOTE § ---

.1. Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1.

L SR 3.2. 1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling.

FNP 1&2 TS Insert 3.2.1-2 (TSTF-290-A, Insert 1)

(TSTF-241-A based Completion Times)

(WCAP-17661-P-A, Appendix A )

B. F;(z) not within limits. B.1.1 -----------NOTE---

Required Action B.1.2 shall be completed if control rod motion is required to comply with the new operating space implemented by Required Action B.1.1.

Implement a RP,OC 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months operating space specified in the COLR tAat-fR estores F; (Z) to within its limits specified in the COLR.

B. 1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2. 1.2 if control rod motion is required to comply with the nei.v operating space.

OR

B.2.1 -----------NOTE---

Required Action B.2.4§ shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each POWER to less than F; (Z) determination R.l\\TED THERMAL POVVER RTP by TSTF-241-A amount and reduce Based CT AFD limits as specified in the COLR.

Fa(Z) 3.2.1

3.2 POWER DISTRIBUTION LIMITS

3.2.1 Heat Flux Hot Channel Factor (Fa(Z))

LCO 3.2.1 Fa(Z), as approximated by Fac(z) and Faw(z), shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. NOTES A.1 Reduce THERMAL 15 minutes after each

1. Required Action A.4 POWER ~ 1 % RTP for Fac(z) determination shall be completed each 1 % Fac(z) whenever this exceeds limit.

Condition is entered prior to increasing AND THERMAL POWER above the limit of A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each Required Action A.1. Neutron Flux-High trip Fac(z) determination

2. SR 3.2.1.2 is not setpoints ~ 1 % for each required to be 1% that THERMAL performed if this POWER is limited below Condition is entered RTP by Required Action prior to THERMAL A.1.

POWER exceeding AND 75% RTP after refueling. A.3 Reduce Overpower lff 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each

Fac(z) not within limit. trip setpoints ~ 1 % for Fac(z) determination each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

AND (continued)

Farley Units 1 and 2 3.2.1-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Fa(Z) 3.2.1

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. (continued) A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1

B. Faw(z) not within limits. B. 1. 1 NOTE Required Action B.1.2 shall be completed if control rod motion is required to comply with the new operating space implemented by Required Action B. 1. 1.

Restore Faw(z) to within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits specified in the COLR.

AND

B.1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2.

OR

B.2.1 NOTE Required Action B.2.5 shall be completed whenever Required Action B.2. 1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each POWER to less than Faw(z) determination RTP by amount specified in the COLR.

AND

( continued)

Farley Units 1 and 2 3.2.1-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Fa(Z) 3.2.1

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

B. (continued) B.2.2 Reduce AFD limits by 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each amount specified in the Faw(z) determination COLR.

AND

B.2.3 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each Neutron Flux - High trip Faw(z) determination setpoints ~ 1 % for each 1% THERMAL POWER is limited below RTP by Required Action B.2.1.

AND

B.2.4 Reduce Overpower ti T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each trip setpoints ~ 1 % for Faw(z) determination each 1% THERMAL POWER is limited below RTP by Required Action B.2.1.

AND

B.2.5 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2 THERMAL POWER above the limit of Required Action B.2. 1

C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

Farley Units 1 and 2 3.2.1-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

VEGP 3&4 TS Insert 3.2.1-1 (WCAP-17661-P-A, Appendix D)

- NOTE~ -

.L Required Action A. 4~

shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1.

L SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling.

VEGP 3&4 TS Insert 3.2.1-2 (WCAP-17661-P-A, Appendix D )

B. F;(Z) not within limits. B.1.1 -----------NOTE Reguired Action B.1.2 shall be com12leted if control rod motion is reguired to com12ly with the new 012erating s12ace im12lemented by Reguired Action B.1.1.

lmplemeRt a GAGG 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months eperatiRg spase spesified iR the GOLR tJ::lat--fR estores F; (Z) to within its limits s12ecified in the COLR.

AND

B.1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2 if 69Rtrel red metieR is FeEj1:1iFed te Gemply with the Re 1 '1 eperatiRg spase.

OR

B.2.1

- NOTE-Required Action B.2. 4~

shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each POWER to less than F; (Z) determination RATED THERMAL POWER RTP by TSTF-241-A amount aRd rad1:1se Based CT AFD limits as specified in the COLR.

AND Technical Specifications Fa(Z) (CAOC W(Z) Methodology) 3.2.1

3.2 POWER DISTRIBUTION LIMITS

3.2.1 Heat Flux Hot Channel Factor (Fa(Z)) (Constant Axial Offset Control (CAOC) W(Z)

Methodology)

LCO 3.2.1 Fa(Z), as approximated by Fg (Z) and Fcf (Z), shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1 with THERMAL POWER~ 25% RTP and with On-Line Power Distribution Monitoring System (OPDMS) not monitoring parameters.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. A.1 Reduce THERMAL 15 minutes after each

- NOTES - POWER ~ 1 % RTP for Fg (Z) determination

1. Required Action A.3 each 1 % Fg (Z) exceeds shall be completed limit.

whenever this Condition is entered AND prior to increasing THERMAL POWER A.2 Reduce Overpower~ T trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each above the limit of setpoints ~ 1 % for each Fg (Z) determination Required Action A.1. 1% that THERMAL

2. SR 3.2.1.2 is not POWER is limited below required to be RTP by Required performed if this Action A.1.

Condition is entered AND prior to THERMAL POWER exceeding A.3 Perform SR 3.2.1.1 and Prior to increasing 75% RTP after SR 3.2.1.2. THERMAL POWER refueling. above the limit of Required Action A.1 Fg (Z) not within limit.

(continued)

VEGP Units 3 and 4 3.2.1 - 1 Amendment No. (Unit 3)

Amendment No. (Unit 4)

Technical Specifications Fa(Z) (CAOC W(Z) Methodology) 3.2.1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

B. (continued) B.2.1 ------------------------------------

- NOTE -

Required Action B.2.3 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each to less than RTP by Fcf (Z) determination amount specified in the COLR.

AND

B.2.2 Reduce Overpower b. T trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each setpoints ~ 1 % for each Fcf (Z) determination 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND

B.2.3 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action B.2.1

C. Required Action and C.1 Reduce THERMAL 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion POWER < 25% RTP.

Time not met.

VEGP Units 3 and 4 3.2.1 - 3 Amendment No. (Unit 3)

Amendment No. (Unit 4)

VEGP 1&2 TS Bases

Insert B 3.2.1-7 (TSTF-241-A, Insert B3 )

The maximum allowable Overpower Lff trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of Fg(Z) and would require Overpower b.T trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F g(Z) determination, if necessary to comply with the decreased maximum allowable Overpower b.T trip setpoints. Decreases in Fg(Z) would allow increasing the maximum Overpower b. T trip setpoints.

Insert B 3.2.1-8 (TSTF-290-A, Insert Note A Bases )

(WCAP-17661, Appendix B )

Condition A is modified by a Note that two Notes. Note 1 requires Required Action A.4 to be performed whenever the Condition is entered prior to increasing THERMAL POWER above the I limit of Required Action A.1. The Note also states that Conducting the Surveillance for F '(: (Z) below 75% RTP is not reliable. Therefore, as stated in Note 2, performance of SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling. This ensures that SR 3.2.1.1 and SR 3.2.1.2 (if required) will be performed prior to increasing THERMAL POWER above the limit of Required Action A.1, even when Condition A is exited prior to performing Required Action A.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure Fa(Z) is properly evaluated prior to increasing THERMAL POWER.

VEGP 1&2 TS Bases

Insert B 3.2.1-9 (NUREG-1431, Rev. 4, B 3.2.1 B)

(TSTF-290-A, Inserts 3 and Note B Bases )

(WCAP-17661, Appendix B)

If it is found that the maximum calculated value of Fa(Z) that can occur during normal maneuvers, F;(z), exceeds its specified limits, there exists a potential for F;(Z) to become excessively high if a normal operational transient occurs. Implementing a more restrictive RAOC operating space, as specified in the COLR within the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months will restrict the AFD such that peaking factor limits will not be exceeded during non equilibrium normal operation. Several RAOC operating spaces, representing successively smaller AFD envelopes and, optionally, shallower control bank insertion limits, may be specified in the COLR. The corresponding T(Z) functions for these operating spaces can be used to determine which RAOC operating space will result in acceptable non-equilibrium operation within the F;(z) limit, and thus, restore F;(z) to within limits.

Required Action B.1.1 is modified by a Note that states Required Action B.1.2 shall be completed whenever Required Action B. 1.1 is performed and control rod motion is required to comply with the new operating space implemented by Required Action B.1. 1. Required Action B.1.2 requires the performance of SR 3.2.1.1 and SR 3.2.1.2 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Note ensures that the SRs will be performed even though Required Action B.1.1 restores F;(Z) to within limits and Condition Bis exited.

B. 1.2

If it is found that the maximum calculated value of Fa(Z) that can occur during normal maneuvers, F;(Z), exceeds its specified limits, there exists a potential for F;(Z) to become excessively high if a normal operational transient occurs. As discussed above, Required Action B.1.1 requires that a new RAOC operating space be implemented to restore F;(Z) to within its limits. Required Action B.1.2 requires that SR 3.2.1.1 and SR 3.2.1.2 be performed if control rod motion occurs as a result of implementing the new RAOC operating space in accordance with Required Action B.1.1. The performance of SR 3.2. 1. 1 and SR 3.2.1.2 is necessary to assure Fa(Z) is properly evaluated after any rod motion resulting from the implementation of a new RAOC operating space in accordance with Required Action B.1.1.

B.2.1 and B.2.2

When F;(Z) exceeds its limit, Required Action B.2.1 may be implemented instead of Required Action B.1 j_. Required Action B.2.1 limits THERMAL POWER to less than RATED THERMAL POWER RTP by the amount specified in the COLR. #----aIBe Required Action B.2.2 requires reductions in the AFD limits by the amount specified in the COLR. If the RAOC operating spaces specified in the COLR are insufficient to ensure margin to the F;(z) limit, then Required Action §. B.2.1 and B.2.2 must be entered are performed and THERMAL POWER must be limited to less than or equal to ~ 50% RTP and AFD limits must be reduced by the amounts specified in the COLR. This maintains an acceptable absolute power density relative to the maximum power density value assumed in the safety analyses.

If the required F; (Z) margin improvement exceeds the margin improvement available from the pre-analyzed THERMAL POWER and AFD reductions provided in the COLR, then THERMAL POWER must be further reduced to less than or equal to ~ 50% RTP. In this case, reducing VEGP 1&2 TS Bases

THERMAL POWER to less than or equal to ~ 50% RTP will provide additional margin in the transient Fa by the required change in THERMAL POWER and the increase in the Fa limit. This will ensure that the Fa limit is met during transient operation that may occur at or below 50% RTP.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to reduce the THERMAL POWER and AFD limits in an orderly manner to preclude entering an unacceptable condition during future non-equilibrium operation. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F '/; (Z) and would require power reductions within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the F'/;(Z) determination, if necessary to comply with the decreased THERMAL POWER limit. Decreases in F'/;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

Required Action B.2.1 is modified by a Note that states Required Action B.2.4§ shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER I above the limit of Required Action B.2.1. Required Action B.2.4§ requires the performance of SR 3.2. 1. 1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the limit established by Required Action B.2.1. The Note ensures that the SRs will be performed even if Condition B may be exited prior to performing Required Action B.2.4§. The performance of SR 3.2.1.1 and SR 3.2. 1.2 is necessary to assure Fa(Z) is properly evaluated prior to increasing THERMAL POWER.

If an Fa surveillance is performed at 100% RTP conditions, and both Fg(Z) and F'/;(Z) exceed their limits, the option to reduce the THERMAL POWER limit in accordance with proposed Required Action B.2.1 instead of implementing a new operating space in accordance with proposed Required Action B. 1j_, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In the event the evaluated THERMAL POWER reduction in the COLR for proposed Required Action B.2.1 did not result in a further power reduction (for example, if both Condition A and Condition B were entered at less than 100% RTP conditions), then the THERMAL POWER level established as a result of completing Required Action A.1 will take precedence, and will establish the effective operating power level limit for the unit until both Conditions A and B are exited.

A reduction of the Power Range Neutron Flux-High trip setpoints by ~ 1 % for each 1 % by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Action §. B.2.1 and B.2.2. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F '; (Z) and would require power reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F:(Z) determination, if necess~ry to comply with the decreased THERMAL POWER limit. Decre~ses in F'(;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

VEGP 1&2 TS Bases

B.2. J4

Reduction in the Overpower Lff trip setpoints value of i<4 by.:: 1 % for each 1 % by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Action §. B.2.1 and B.2.2. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F--;(Z) and would require power reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F --;(Z) determination, if necess~ry to comply with the decreased THERMAL POWER limit. Decre~ses in F;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

B.2. 4 5

Verification that F;(Z) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.2.1 ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.

FNP 1&2 TS Bases

Insert B 3.2. 1-8 (TSTF-290-A, Insert Note A Bases )

(WCAP-17661, Appendix B)

Condition A is modified by a Note that two Notes. Note 1 requires Required Action A.4 to be performed whenever the Condition is entered prior to increasing THERMAL POWER above the I limit of Required Action A.1. The Note also states that Conducting the Surveillance for F '(: (Z) below 75% RTP is not reliable. Therefore, as stated in Note 2, performance of SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling. This ensures that SR 3.2.1.1 and SR 3.2.1.2 (if required) will be performed prior to increasing THERMAL POWER above the limit of Required Action A.1, even when Condition A is exited prior to performing Required Action A.4. Performance of SR 3.2.1.1 and SR 3.2. 1.2 are necessary to assure Fa(Z) is properly evaluated prior to increasing THERMAL POWER FNP 1&2 TS Bases

Insert B 3.2.1-9 (NUREG-1431, Rev. 4, B 3.2.1 B)

(TSTF-290-A, Inserts 3 and Note B Bases )

(WCAP-17661, Appendix B)

If it is found that the maximum calculated value of Fa(Z) that can occur during normal maneuvers, F;(z), exceeds its specified limits, there exists a potential for F;(Z) to become excessively high if a normal operational transient occurs. Implementing a more restrictive RAOC operating space, as specified in the COLR within the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months will restrict the AFD such that peaking factor limits will not be exceeded during non equilibrium normal operation. Several RAOC operating spaces, representing successively smaller AFD envelopes and, optionally, shallower control bank insertion limits, may be specified in the COLR. The corresponding T(Z) functions for these operating spaces can be used to determine which RAOC operating space will result in acceptable non-equilibrium operation within the F;(z) limit, and thus, restore F;(z) to within limits.

Required Action B.1.1 is modified by a Note that states Required Action B.1.2 shall be completed whenever Required Action B. 1.1 is performed and control rod motion is required to comply with the new operating space implemented by Required Action B.1.1. Required Action B.1.2 requires the performance of SR 3.2.1.1 and SR 3.2. 1.2 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Note ensures that the SRs will be performed even though Required Action B.1.1 restores F;(Z) to within limits and Condition Bis exited.

B. 1.2

If it is found that the maximum calculated value of Fa(Z) that can occur during normal maneuvers, F;(Z), exceeds its specified limits, there exists a potential for F;(Z) to become excessively high if a normal operational transient occurs. As discussed above, Required Action B.1.1 requires that a new RAOC operating space be implemented to restore F; (Z) to within its limits. Required Action B.1.2 requires that SR 3.2.1.1 and SR 3.2.1.2 be performed if control rod motion occurs as a result of implementing the new RAOC operating space in accordance with Required Action B.1.1. The performance of SR 3.2. 1. 1 and SR 3.2.1.2 is necessary to assure Fa(Z) is properly evaluated after any rod motion resulting from the implementation of a new RAOC operating space in accordance with Required Action B.1.1.

B.2.1 and B.2.2

When F;(Z) exceeds its limit, Required Action B.2.1 may be implemented instead of Required Action B.1 j_. Required Action B.2.1 limits THERMAL POWER to less than RATED THERMAL POWER RTP by the amount specified in the COLR. #----aIBe Required Action B.2.2 requires reductions in the AFD limits by the amount specified in the COLR. If the RAOC operating spaces specified in the COLR are insufficient to ensure margin to the F;(z) limit, then Required Action §. B.2.1 and B.2.2 must be entered are performed and THERMAL POWER must be limited to less than or equal to ~ 50% RTP and AFD limits must be reduced by the amounts specified in the COLR. This maintains an acceptable absolute power density relative to the maximum power density value assumed in the safety analyses.

If the required F; (Z) margin improvement exceeds the margin improvement available from the pre-analyzed THERMAL POWER and AFD reductions provided in the COLR, then THERMAL POWER must be further reduced to less than or equal to ~ 50% RTP. In this case, reducing FNP 1&2 TS Bases

THERMAL POWER to less than or equal to ~ 50% RTP will provide additional margin in the transient Fa by the required change in THERMAL POWER and the increase in the Fa limit. This will ensure that the Fa limit is met during transient operation that may occur at or below 50% RTP.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to reduce the THERMAL POWER and AFD limits in an orderly manner to preclude entering an unacceptable condition during future non-equilibrium operation. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F; (Z) and would require power reductions within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the F;(Z) determination, if necessary to comply with the decreased THERMAL POWER limit. Decreases in F;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

Required Action B.2.1 is modified by a Note that states Required Action B.2.4§ shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER I above the limit of Required Action B.2.1. Required Action B.2.4§ requires the performance of SR 3.2. 1. 1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the limit established by Required Action B.2.1. The Note ensures that the SRs will be performed even if Condition B may be exited prior to performing Required Action B.2. 4§. The performance of SR 3.2.1.1 and SR 3.2. 1.2 is necessary to assure Fa(Z) is properly evaluated prior to increasing THERMAL POWER.

If an Fa surveillance is performed at 100% RTP conditions, and both Fg(Z) and F;(Z) exceed their limits, the option to reduce the THERMAL POWER limit in accordance with proposed Required Action B.2.1 instead of implementing a new operating space in accordance with proposed Required Action B. 1j_, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In the event the evaluated THERMAL POWER reduction in the COLR for proposed Required Action B.2.1 did not result in a further power reduction (for example, if both Condition A and Condition B were entered at less than 100% RTP conditions), then the THERMAL POWER level established as a result of completing Required Action A.1 will take precedence, and will establish the effective operating power level limit for the unit until both Conditions A and B are exited.

A reduction of the Power Range Neutron Flux-High trip setpoints by ~ 1 % for each 1 % by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Action §. B.2.1 and B.2.2. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F '; (Z) and would require power reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F:(Z) determination, if necess~ry to comply with the decreased THERMAL POWER limit. Decre~ses in F'(;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

FNP 1&2 TS Bases

B.2. J4

Reduction in the Overpower Lff trip setpoints value of i<4 by.:: 1 % for each 1 % by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Action §. B.2.1 and B.2.2. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F--;(Z) and would require power reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F --;(Z) determination, if necess~ry to comply with the decreased THERMAL POWER limit. Decre~ses in F;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

B.2. 4 5

Verification that F;(Z) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.2.1 ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.

VEGP 3&4 TS Bases

Insert B 3.2.1-4 (WCAP-17661, Appendix E)

Implementing a more restrictive CAOC operating space, specified in the COLR, within the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months will restrict the AFD such that core peaking factor limits will not be exceeded during non-equilibrium normal operation. Several CAOC operating spaces, representing successively smaller AFD bands and, optionally, shallower Control Bank Insertion Limits, may be specified in the COLR. The corresponding [W(Z)]C0 LR functions for these operating spaces can be used to determine which CAOC operating space would result in acceptable non-equilibrium operation within the F;(z) limit, and thus, restore F;(z) to within limits.

Required Action B. 1.1 is modified by a Note that states Required Action B.1.2 shall be completed whenever Required Action B.1.1 is performed and control rod motion is required to comply with the new operating space implemented by Required Action B.1.1. Required Action B.1.2 requires the performance of SR 3.2. 1.1 and SR 3.2.1.2 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Note ensures that the SRs will be performed even though Required Action B.1.1 restores F;(z) to within limits and Condition B is exited.

B.1.2

If it is found that the maximum calculated value of Fa(Z) that can occur during normal maneuvers, F;(z), exceeds its specified limits, there exists a potential for Fi(Z) to become excessively high if a normal operational transient occurs. As discussed above, Required Action B.1.1 requires that a new CAOC operating space be implemented to restore F; (Z) to within its limits. The performance of SR 3.2.1.1 and SR 3.2. 1.2 is necessary to assure Fa(Z) is properly evaluated after any rod motion resulting from the implementation of a new CAOC operating space in accordance with Required Action B.1.1. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt implementation of the required CAOC operating space in accordance with Required Action B.1.1.

When F;(z) exceeds its limits, Required Action B.2. 1 may be implemented instead of Required Action B.1.1. Required Action B.2.1 limits THERMAL POWER to less than RTP by the amount specified in the COLR. This maintains an acceptable absolute power density relative to the maximum power density value assumed in the safety analyses.

If the required F; (Z) margin improvement exceeds the margin improvement available from the pre-analyzed THERMAL POWER reductions provided in the COLR, then THERMAL POWER must be further reduced to less than or equal to 50% RTP. In this case, reducing THERMAL POWER to less than or equal to 50% RTP will provide additional margin in the transient Fa by the required change in THERMAL POWER and the increase in the Fa limit. This will ensure that the Fa limit is met during transient operation that may occur at or below 50% RTP.

VEGP 3&4 TS Bases

Insert B 3.2.1-4

( continued)

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to reduce power in an orderly manner to preclude entering an unacceptable condition during future non-equilibrium operation.

The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of F;(Z) and would require power reductions within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the F'/;(Z) determination, if necessary to comply with the decreased THERMAL POWER limit.

Decreases in F;(Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

Required Action B.2.1 is modified by a Note that states Required Action B.2.3 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL I POWER above the limit of Required Action. Required Action B.2.3 requires the performance of SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the limit established by Required Action B.2.1. The Note ensures that the SRs will be performed even if Condition B may be exited prior to performing Required Action B.2.3. The performance of SR 3.2.1.1 and SR 3.2. 1.2 is necessary to assure Fa(Z) is properly evaluated prior to increasing THERMAL POWER.

If an Fa, surveillance is performed at 100% RTP conditions, and both Fg(Z) and F'/;(Z) exceed their limits, the option to reduce the THERMAL POWER limit in accordance with Required Action B.2.1 instead of implementing a new operating space in accordance with Required Action B.1.1, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In the event the evaluated THERMAL POWER reduction in the COLR for proposed Required Action B.2.1 did not result in a further power reduction (for example, if both Condition A and Condition B were entered at less than 100% RTP conditions), then the THERMAL POWER level established as a result of completing Required Action A.1, which is more restrictive limit than the THERMAL POWER level established by Required Action B.2.1,

will establish the effective operating power level limit for the unit until both Conditions A and B are exited.

Insert B 3.2.1-5 (WCAP-17661, Appendix E)

in the THERMAL POWER limit in accordance with Required Action B.2.1. The maximum allowable Overpower I),,. T trip setpoints initially determined by Required Action B.2.2 may be affected by subsequent determinations of F;(Z) and would require Overpower f),,.T trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the F'/;(Z) determination, if necessary to comply with the decreased maximum allowable Overpower I),,. T trip setpoints. Decreases in F '/; (Z) would allow increasing the maximum allowable Overpower I),,. T trip setpoints.

v t e Letter Sequence Supplement
EPID:L-2022-LLA-0148, TSTF-95, TSTF-241, TSTF-290, TSTF-99 (Open)
Initiation Request Acceptance, Acceptance Supplement Administration Questions Answers Results Approval... Other:
MONTHYEAR2022-11-18 [Table View]

NL-22-0897, Supplement to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A,

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NL-22-0897, Supplement to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A,

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