ML23275A117
| ML23275A117 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 10/02/2023 |
| From: | Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML23275A109 | List: |
| References | |
| L-2023-126 | |
| Download: ML23275A117 (1) | |
Text
ENCLOSURE 2 VOLUME 7 ST. LUCIE PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 2 R2
LIST OF ATTACHMENTS
- 1. ITS 3.2.1, LINEAR HEAT RATE (LHR)
- 2. ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
- 3. ITS 3.2.3, AZIMUTHAL POWER TILT ()
- 4. ITS 3.2.4, AXIAL SHAPE INDEX (ASI)
- 5. ISTS NOT ADOPTED
ATTACHMENT 1 ITS 3.2.1, LINEAR HEAT RATE (LHR)
Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)
ITS ITS 3.2.1 A01 3/4.2 POWER DISTRIBUTION LIMITS LINEAR HEAT RATE (LHR)
LIMITING CONDITION FOR OPERATION LHR LCO 3.2.1 3.2.1 The linear heat rate shall not exceed the limits specified in the COLR.
Applicability APPLICABILITY: MODE 1.
LHR, as determined by the Excore Detector Monitoring system, exceeds the limits as indicated ACTION: LHR, as determined by the Incore Detector Monitoring system, s the specified in the COLR specified in the ASI ACTION A With the linear heat rate exceeding its limits, as indicated by four or more coincident incore channels or by the AXIAL SHAPE INDEX outside of the power dependent control limits of COLR Figure 3.2-2, within 15 minutes initiate corrective action to reduce the linear heat rate to L01 within the limits and either:
LHR Required Action a. Restore the linear heat rate to within its limits within one hour, or A.1 MODE 2 L02 Required Action b. Be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
B.1 SURVEILLANCE REQUIREMENTS 4.2.1.1 The provisions of Specification 4.0.4 are not applicable. M01 SR Note 4.2.1.2 The linear heat rate shall be determined to be within its limits by continuously monitoring the core power distribution with either the excore detector monitoring system or with the incore detector monitoring system. shall be used to determine LHR Only required to be met when SR 3.2.1.1 Note 4.2.1.3 Excore Detector Monitoring System - The excore detector monitoring system may be used for monitoring the linear heat rate by: to determine LHR.
is being
- a. Verifying in accordance with the Surveillance Frequency Control Program that See the full length CEAs are withdrawn to and maintained at or beyond the Long ITS 3.1.6 Term Steady State Insertion Limit of Specification 3.1.3.6.
SR 3.2.1.1 b. Verifying in accordance with the Surveillance Frequency Control Program that the AXIAL SHAPE INDEX alarm setpoints are adjusted to within the limits shown on COLR Figure 3.2-2.
specified in the ASI ST. LUCIE - UNIT 1 3/4 2-1 Amendment No. 32, 150, 223
ITS ITS 3.2.1 A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (continued)
- c. Verifying that the AXIAL SHAPE INDEX is maintained within the allowable limits of COLR Figure 3.2-2, where 100 percent of maximum allowable power represents the maximum THERMAL POWER allowed by the following expression:
MxN where: LA01
- 1. M is the maximum allowable THERMAL POWER level for the existing Reactor Coolant Pump combination.
- 2. N is the maximum allowable fraction of RATED THERMAL POWER as determined by the F Tr curve of COLR Figure 3.2-3.
SR 3.2.1.2 is being 1. Only required to be met when Note 1 and 2 SR 3.2.1.3 4.2.1.4 Incore Detector Monitoring System# - The incore detector monitoring system may Note 1 and 2 be used for monitoring the linear heat rate by verifying that the incore detector to determine LHR.
Verify incore detector Local Power Density alarms: 2. Not required to be performed below 20% RTP. L03 SR 3.2.1.2 a. Are adjusted to satisfy the requirements of the core power distribution map which shall be updated in accordance with the Surveillance Frequency Control Program in MODE 1.
Verify incore detector local power density s are SR 3.2.1.3 b. Have their alarm setpoint adjusted to less than or equal to the limits shown on COLR Figure 3.2-1.
specified in the in accordance with the Surveillance Frequency Control Program M02
- If the incore system become inoperable, reduce power to M x N within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and LA01 monitor linear heat rate in accordance with Specification 4.2.1.3.
ST. LUCIE - UNIT 1 3/4 2-2 Amendment No. 17, 27, 32, 63, 65, 70, 109, 134, 136, 150, 223
Pages 3/4 2-4 (Amendment 106), 3/4 2-5 (Amendment 63), and 3/4 2-6 through 3/4 2-8 (Amendment 109) have been deleted from the Technical Specifications. A01 The next page is 3/4 2-9.
ST. LUCIE - UNIT 1 3/4 2-3 Amendment No. 27, 32, 48, 70, 74, 84, 150
ITS ITS 3.2.1 A01 3/4.2 POWER DISTRIBUTION LIMITS 3/4 2.1 LINEAR HEAT RATE (LHR)
LIMITING CONDITION FOR OPERATION LHR LCO 3.2.1 3.2.1 The linear heat rate shall not exceed the limits specified in the COLR.
Applicability APPLICABILITY: MODE 1.
LHR, as determined by the Excore Detector Monitoring system, exceeds the limits as indicated ACTION: LHR, as determined by the Incore Detector Monitoring system, s the specified in the COLR specified in the ASI ACTION A With the linear heat rate exceeding its limits, as indicated by four or more coincident incore channels or by the AXIAL SHAPE INDEX outside of the power dependent control limits of COLR Figure 3.2-2, within 15 minutes initiate corrective action to reduce the linear heat rate to within the L01 limits and either:
LHR Required Action a. Restore the linear heat rate to within its limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, or A.1 MODE 2 L02 Required Action b. Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
B.1 SURVEILLANCE REQUIREMENTS 4.2.1.1 The provisions of Specification 4.0.4 are not applicable. M01 SR Note 4.2.1.2 The linear heat rate shall be determined to be within its limits by continuously monitoring the core power distribution with either the excore detector monitoring system or with the incore detector monitoring system. shall be used to determine LHR SR 3.2.1.1 Note 4.2.1.3 Excore Detector Monitoring System - The excore detector monitoring system may be used for monitoring the linear heat rate by: to determine LHR.
is being
- a. Verifying in accordance with the Surveillance Frequency Control Program that the See full-length CEAs are withdrawn to and maintained at or beyond the Long Term ITS 3.1.6 Steady State Insertion Limit of Specification 3.1.3.6.
SR 3.2.1.1 b. Verifying in accordance with the Surveillance Frequency Control Program that the AXIAL SHAPE INDEX alarm setpoints are adjusted to within the limits shown on COLR Figure 3.2-2.
specified in the ASI ST. LUCIE - UNIT 2 3/4 2-1 Amendment No. 92, 173
ITS ITS 3.2.1 A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
- c. Verifying that the AXIAL SHAPE INDEX is maintained within the allowable limits of COLR Figure 3.2-2, where 100% of maximum allowable power represents the maximum THERMAL POWER allowed by the following expression:
LA01 MxN where:
- 1. M is the maximum allowable THERMAL POWER level for the existing Reactor Coolant Pump combination.
- 2. N is the maximum allowable fraction of RATED THERMAL POWER as determined by the F T curve of COLR Figure 3.2-3.
r ST. LUCIE - UNIT 2 3/4 2-2 Amendment No. 17, 75, 92, 138, 182
ITS ITS 3.2.1 A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
SR 3.2.1.2 1. Only required to be met when Note 1 and 2 SR 3.2.1.3 4.2.1.4 Incore Detector Monitoring System# - The incore detector monitoring system may be Note 1 and 2 is being used for monitoring the linear rate by verifying that the incore detector Local Power to determine LHR. Density alarms: Verify incore detector
- 2. Not required to be performed below 20% RTP. L03 SR 3.2.1.2 a. Are adjusted to satisfy the requirements of the core power distribution map which shall be updated in accordance with the Surveillance Frequency Control Program in MODE 1.
Verify incore detector local power density s are SR 3.2.1.3 b. Have their alarm setpoint adjusted to less than or equal to the limits shown on COLR Figure 3.2-1.
specified in the in accordance with the Surveillance Frequency Control Program M02
- If incore system becomes inoperable, reduce power to M x N within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and monitor linear LA01 heat rate in accordance with Specification 4.2.1.3.
ST. LUCIE - UNIT 2 3/4 2-2a Amendment No. 138, 173
ITS ITS 3.2.1 A01 Pages 3/4 2-4 (Amendment 42), 3/4 2-5 (Amendment 8), and 3/4 2-6 (Amendment 17) have been A01 deleted from the Technical Specifications. The next page is 3/4 2-7.
ST. LUCIE - UNIT 2 3/4 2-3 Amendment No. 92
ITS ITS 3.2.1 A01 POWER DISTRIBUTION LIMITS A01 DELETED A01 ST. LUCIE - UNIT 2 3/4 2-7 Amendment No. 8, 92, 138
ITS ITS 3.2.1 R2 A01 POWER DISTRIBUTION LIMITS A01 DELETED A01 ST. LUCIE - UNIT 2 3/4 2-8 Amendment No. 138
DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE (LHR)
ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2, 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-1432, Rev. 5.0, "Standard Technical Specifications-Combustion Engineering 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 4.2.1.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. ITS 3.2.1 does not provide a Surveillance Note that states that the provisions of LCO 4.0.4 are not applicable.
LCO 4.0.4 states that entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCOs Surveillances have been met within their specified Frequency, except as provided by Surveillance Requirement 4.0.3. LCO 4.0.3 provides the provisions for a missed surveillance and does not apply to a surveillance known to not be met within its specified Frequency prior to entering the Mode of Applicability.
The purpose of CTS 4.2.2.1 is to provide an allowance for entering the MODE of applicability when any Surveillance is not met. This change is designated as more restrictive because the CTS 4.0.4 MODE change allowance is deleted and entry into MODE 1 shall only be made when the LCOs surveillances have been met within their specified Frequency. This changes CTS by allowing entry into the MODE of Applicability by only deferring the performance of the Surveillance Requirements instead of deferring compliance with the LCO.
ITS SR 3.2.1.2 and SR 3.2.1.3 each contain a note that states "Not required to be performed below 20% RTP." ITS SR 3.2.1.2 and SR 3.2.1.3 Surveillance Requirements Note will provide an allowance whereby, Surveillance performance is not required prior to entering MODE 1. This allows establishing the conditions at which the Surveillances can be performed. See DOC L03 discussion of change for ITS SR 3.2.1.2 Note and SR 3.2.1.3 Note.
M02 CTS 4.2.1.4.b does not explicitly state how often the incore detector low power density alarm setpoint is adjusted to less than or equal to the limits shown on COLR Figure 3.2.1. CTS 4.2.1.4.b is changed to include a Surveillance Frequency in accordance with the Surveillance Frequency Control Program (SFCP) consistent with the Frequency to update the core distribution map as specified in CTS 4.2.1.4.a. The Frequency of ITS 3.2.1.3 is in accordance with the Surveillance Frequency Control Program.
St. Lucie Unit 1 and Unit 2 Page 1 of 5
DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE (LHR)
PSL controls periodic Frequencies for Surveillances in accordance with the Surveillance Frequency Control Program (SFCP) per CTS 6.8.4.o (Unit 1) and CTS 6.8.4.q (Unit 2). Performance of SR 3.2.1.3 (CTS 4.2.1.4.b) verifies, in part, that the Incore Detector Monitoring System can accurately monitor LHR and is performed following the update of the core flux map, which is performed at a frequency specified in the SFCP. The change to the Frequency of CTS 4.2.1.4.a is discussed in FPL (PSL Unit 1 and Unit 2) "Application for Technical Specification Change Regarding Risk-Informed Justifications for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program" (ADAMS Accession No. ML14070A087). The NRC issued Amendment No. 223 to Renewed Facility Operating License No. DPR-67 and Amendment No. 173 to Renewed Facility Operating License No. NPF-16 for the St. Lucie Plant, Unit Nos. 1 and 2 (St. Lucie 1 and 2), respectively (ADAMS Accession No. ML15127A066). The initial frequency established in accordance with the SFCP will be 31 days consistent with the frequency established for ISTS SR 3.2.1.3 and considers the historical testing frequency of the reactor monitoring system.
This change is designated as more restrictive because a Surveillance Frequency has been added to ensure the incore detector local power density alarm setpoints are periodically verified to be within the limits of the COLR.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 4 - Removal of LCO, SR, or other TS Requirement to the TRM, UFSAR, ODCM, QAP, CLRT Program, IST Program, ISI Program, or Surveillance Frequency Control Program) CTS 4.2.1.4 footnote # states that if the incore detector monitoring system becomes inoperable, reduce power to M x N within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> and monitor linear heat rate in accordance with Specification 4.2.1.3.
CTS 4.2.1.3.c provides the determination of M x N and directs which figures in the COLR to use for LHR verifications using the excore detection system.
ITS 3.2.1 does not include this requirement. This changes the CTS by relocating the action to take when the incore detector monitoring system is inoperable to the Technical Requirements Manual (TRM).
The incore detector monitoring system monitors LHR. However, there are no requirements in CTS for this indication-only instrumentation system to be OPERABLE. Therefore, it is unnecessary to provide actions in the Technical Specifications that must be performed when this non-TS system is not functional.
The removal of action requirements for indication-only instrumentation and alarms 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 requirement to determine LHR and actions to perform when LHR is not within limits remains in the ITS. Either the incore detector monitoring system or the excore detector monitoring system is used to monitor LHR.
St. Lucie Unit 1 and Unit 2 Page 2 of 5
DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE (LHR)
Normally, LHR is verified using the incore detector local power density alarm.
The setpoint is maintained less than or equal to the COLR Figure 3.2-1 limits.
When the incore detector monitoring system is discovered to be non-functional, the ASI alarm associated with the excore detector monitoring system is used to determine LHR. The ASI alarm setpoint is maintained within the COLR Figure 3.2-2 limits. A power reduction may be required to adjust the ASI alarm setpoint to correspond to the COLR figure limits, however, a power reduction may not be necessary based on plant conditions. If a power reduction is necessary to adjust the ASI alarm setpoints to within COLR limits, the power reduction is accomplished using normal plant operating procedures.
This change is acceptable because inoperability of the incore detector monitoring system alone does not indicate that LHR has exceeded the limit and the removed information will be adequately controlled in the TRM. Changes to the TRM are lR1 l
made under 10 CFR 50.59, thereby ensuring changes are properly evaluated.
This change is designated as a less restrictive removal of detail change because action requirements for non-TS indication-only instrumentation and alarms is being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.1 Action states that within 15 minutes initiate corrective action to reduce the linear heat rate (LHR) to within limits. ITS 3.2.1 Required Action A.1 and associated Completion Time states that LHR be restored to within limits with a Completion Time of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
This changes the CTS by not requiring that within 15 minutes corrective action be taken to reduce the LHR to within limits, rather only requiring that the LHR be restored to within limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, consistent with the ITS 3.2.1 Completion Time. Requiring corrective action be taken within 15 minutes does not necessarily restore LHR within limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
The purpose of CTS 3.2.1 is to maintain LHR within the limits specified in the COLR. When the LCO is not met, both CTS 3.2.1 and ITS 3.2.1 require that the LHR be restored to within limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. With the LHR exceeding its limit, fuel damage could occur following an accident. In this Condition, prompt action must be taken to restore the LHR to within the specified limits. One hour to restore the LHR to within its specified limits is reasonable and ensures that the core does not continue to operate in this Condition. The 1-hour Completion Time also allows the operator sufficient time for evaluating core conditions and for initiating proper corrective actions. This change is acceptable because the CTS 3.2.1 Completion Time and ITS 3.2.1 Completion Time are both 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
This change is designated as less restrictive because the CTS requirement to within 15 minutes initiate corrective action to reduce the linear heat rate (LHR) to within limits is deleted.
St. Lucie Unit 1 and Unit 2 Page 3 of 5
DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE (LHR)
L02 (Category 4 - Relaxation of Required Action) CTS 3.2.1 Action b. states that with the linear heat rate (LHR) not within limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, to be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. ITS 3.2.1 Action B states that with the LHR not within limits within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, then be in MODE 2 with a Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This changes the CTS by only requiring entry into MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Once in MODE 2, LCO 3.0.2 allows the LCO to be exited since the Applicability is MODE 1, and completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
The purpose of CTS 3.2.1 Action b. and ITS 3.2.1 Action B is to reduce THERMAL POWER. Exiting the Mode of Applicability provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative 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, 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 repair period.
This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.2.1.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. ITS 3.2.1 does not provide a Surveillance Note that states that the provisions of LCO 4.0.4 are not applicable. See DOC M01.
ITS SR 3.2.1.2 and SR 3.2.1.3 each contain a note that states "Not required to be performed below 20% RTP." ITS SR 3.2.1.2 and SR 3.2.1.3 Surveillance Requirements Note will provide an allowance whereby, Surveillance performance is not required prior to entering MODE 1. This allows establishing the conditions at which the Surveillances can be performed. CTS 4.0.1. states that Surveillance Requirements shall be applicable during the OPERATIONAL MODES or other conditions specified for individual LCOs unless otherwise stated in an individual Surveillance Requirement. Similarly, ITS SR 3.0.1 states that SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. This changes the CTS by providing a Surveillance Note which states "Not required to be performed below 20% RTP."
The purpose of CTS 4.2.1.1 is to provide a note that states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met.
ITS 3.2.1 does not provide a Surveillance Note that states that the provisions of LCO 4.0.4 are not applicable.
St. Lucie Unit 1 and Unit 2 Page 4 of 5
DISCUSSION OF CHANGES ITS 3.2.1, LINEAR HEAT RATE (LHR)
This change is acceptable because the note added to ITS SR 3.2.1.2 and SR 3.2.1.3 will provide an allowance whereby, Surveillance performance is not met prior to entering MODE 1. This allows establishing the conditions at which the Surveillances can be performed. This change is designated as less restrictive because Surveillances will be performed after entering MODE 1 rather than being performed prior to entry into MODE 1.
St. Lucie Unit 1 and Unit 2 Page 5 of 5
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
CTS LHR (Analog) 4 3.2.1 3.2 POWER DISTRIBUTION LIMITS (Analog) 4 LCO 3.2.1 3.2.1 Linear Heat Rate (LHR) (Analog)
LCO 3.2.1 LCO 3.2.1 LHR shall not exceed the limits specified in the COLR.
Applicability APPLICABILITY: MODE 1.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. LHR, as determined by A.1 Restore LHR to within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the Incore Detector limits.
Monitoring System, exceeds the limits specified in the COLR, as indicated by four or more coincident incore channels.
OR LHR, as determined by the Excore Detector Monitoring System, exceeds the limits as indicated by the ASI outside the power dependent control limits specified in the COLR.
ACTION B B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
Combustion Engineering STS 3.2.1-1 Rev. 5.0 1
St. Lucie - Unit 1 Amendment XXX R2
CTS LHR (Analog) 4 3.2.1 SURVEILLANCE REQUIREMENTS
NOTE-----------------------------------------------------------
SR 4.2.1.2 Either the Excore Detector Monitoring System or the Incore Detector Monitoring System shall be used to determine LHR.
SURVEILLANCE FREQUENCY SR 3.2.1.1 -------------------------------NOTE------------------------------
SR 4.2.1.3 Only required to be met when the Excore Detector Monitoring System is being used to determine LHR.
SR 4.2.1.3.b Verify ASI alarm setpoints are within the limits [ 31 days specified in the COLR.
OR 2 In accordance with the Surveillance Frequency Control Program ]
2 SR 4.2.1.4.a SR 3.2.1.2 ------------------------------NOTES-----------------------------
- 1. Only required to be met when the Incore Detector Monitoring System is being used to determine LHR.
- 2. Not required to be performed below 20% RTP.
Verify incore detector local power density alarms [ 31 days satisfy the requirements of the core power 2 distribution map, which shall be updated at least OR 3
once per 31 days of accumulated operation in MODE 1. In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.1-2 Rev. 5.0 1
St. Lucie - Unit 1 Amendment XXX R2
CTS LHR (Analog) 4 3.2.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 4.2.1.4.b SR 3.2.1.3 ------------------------------NOTES-----------------------------
- 1. Only required to be met when the Incore Detector Monitoring System is being used to determine LHR.
- 2. Not required to be performed below 20% RTP.
Verify incore detector local power density alarm [ 31 days 2
setpoints are less than or equal to the limits specified in the COLR. OR In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.1-3 Rev. 5.0 1
St. Lucie - Unit 1 Amendment XXX R2
CTS LHR (Analog) 4 3.2.1 3.2 POWER DISTRIBUTION LIMITS (Analog) 4 LCO 3.2.1 3.2.1 Linear Heat Rate (LHR) (Analog)
LCO 3.2.1 LCO 3.2.1 LHR shall not exceed the limits specified in the COLR.
Applicability APPLICABILITY: MODE 1.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A A. LHR, as determined by A.1 Restore LHR to within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> the Incore Detector limits.
Monitoring System, exceeds the limits specified in the COLR, as indicated by four or more coincident incore channels.
OR LHR, as determined by the Excore Detector Monitoring System, exceeds the limits as indicated by the ASI outside the power dependent control limits specified in the COLR.
ACTION B B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
Combustion Engineering STS 3.2.1-1 Rev. 5.0 1
St. Lucie - Unit 2 Amendment XXX R2
CTS LHR (Analog) 4 3.2.1 SURVEILLANCE REQUIREMENTS
NOTE-----------------------------------------------------------
SR 4.2.1.2 Either the Excore Detector Monitoring System or the Incore Detector Monitoring System shall be used to determine LHR.
SURVEILLANCE FREQUENCY SR 3.2.1.1 -------------------------------NOTE------------------------------
SR 4.2.1.3 Only required to be met when the Excore Detector Monitoring System is being used to determine LHR.
SR 4.2.1.3.b Verify ASI alarm setpoints are within the limits [ 31 days specified in the COLR.
OR 2 In accordance with the Surveillance Frequency Control Program ]
2 SR 4.2.1.4.a SR 3.2.1.2 ------------------------------NOTES-----------------------------
- 1. Only required to be met when the Incore Detector Monitoring System is being used to determine LHR.
- 2. Not required to be performed below 20% RTP.
Verify incore detector local power density alarms [ 31 days 2
satisfy the requirements of the core power distribution map, which shall be updated at least OR 3 once per 31 days of accumulated operation in MODE 1. In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.1-2 Rev. 5.0 1
St. Lucie - Unit 2 Amendment XXX R2
CTS LHR (Analog) 4 3.2.1 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 4.2.1.4.b SR 3.2.1.3 ------------------------------NOTES-----------------------------
- 1. Only required to be met when the Incore Detector Monitoring System is being used to determine LHR.
- 2. Not required to be performed below 20% RTP.
Verify incore detector local power density alarm [ 31 days 2
setpoints are less than or equal to the limits specified in the COLR. OR In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.1-3 Rev. 5.0 1
St. Lucie - Unit 2 Amendment XXX R2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, LINEAR HEAT RATE (LHR)
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3. The ISTS SR 3.2.1.2 statement which shall be updated at least once per 31 days of accumulated operation in MODE 1 is deleted. ITS SR 3.2.1.2, including update of the core power distribution map, is in accordance with the Surveillance Frequency Control Program (SFCP). The SFCP Frequency is at least once per 31 days.
- 4. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)
LHR (Analog) 5 B 3.2.1 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.1 Linear Heat Rate (LHR) (Analog)
BASES (Linear Heat Rate (LHR))
1 BACKGROUND The purpose of this LCO is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the does not result in violation of 1 power distribution satisfies this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.1-1 Rev. 5.0 1
St. Lucie - Unit 1 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES BACKGROUND (continued) AXIAL SHAPE INDEX (
AZIMUTHAL POWER TILT ( ) )
The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), Total 4 Integrated Radial Peaking Factor (F r), Tq, and ASI represent limits within T 1 which the LHR algorithms are valid. These limits are obtained directly from the core reload analysis.
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provides adequate monitoring of the core power distribution and is capable of verifying that the LHR is within its limits. The Excore Detector Monitoring System performs this function by continuously monitoring ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing ASI limits, the following assumptions are made:
1 conditions assumed
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4
- c. F Txy is within the limits of LCO 3.2.2. 4 FrT , the The Incore Detector Monitoring System continuously provides a more 1
direct measure of the peaking factors and alarms that have been established for the individual incore detector segments, ensuring that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for: described in Reference 3.
3
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.1-2 Rev. 5.0 1
St. Lucie - Unit 1 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) and AOOs (Condition 2) (Ref. 3, GDC 10). The 4 1 ANALYSES power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by accident analyses (Ref. 1), with due regard for the correlations between measured quantities, the power distribution, and uncertainties in determining the power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does 5
not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
and , and within the Tq limits 1 The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, FrT , and Tq limits specified in the COLR. The latter are process 4 variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.
Combustion Engineering STS B 3.2.1-3 Rev. 5.0 1
St. Lucie - Unit 1 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES APPLICABLE SAFETY ANALYSES (continued) reactor 1
Fuel cladding damage does not normally occur while the unit is operating at conditions outside the limits of these LCOs during normal operation.
Fuel cladding damage could result, however, if an accident or AOO occurs from initial conditions outside the limits of these LCOs. The This 1 potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and can correspondingly increase local LHR.
The LHR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNB ratio operating limits. The power distribution LCO limits, except Tq, are provided in the COLR. The limitation on the LHR ensures that, in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1, power distribution must be maintained within the limits assumed in the accident analysis to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because there is not sufficient THERMAL POWER to require a limit on 1 the core power distribution.
ACTIONS A.1 With the LHR exceeding its limit, excessive fuel damage could occur following an accident. In this Condition, prompt action must be taken to restore the LHR to within the specified limits. One hour to restore the LHR to within its specified limits is reasonable and ensures that the core does not continue to operate in this Condition. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time also allows the operator sufficient time for evaluating core conditions and for initiating proper corrective actions.
B.1 If the LHR cannot be returned to within its specified limits, THERMAL POWER must be reduced. The change to MODE 2 provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative condition. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 2 from full power MODE 1 conditions in an orderly manner and without challenging plant systems.
Combustion Engineering STS B 3.2.1-4 Rev. 5.0 1
St. Lucie - Unit 1 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES SURVEILLANCE A Note was added to the SRs to require LHR to be determined by REQUIREMENTS either the Excore Detector Monitoring System or the Incore Detector Monitoring System.
SR 3.2.1.1 Performance of this SR verifies that the Excore Detector Monitoring System can accurately monitor the LHR. Therefore, this SR is only applicable when the Excore Detector Monitoring System is being used to determine the LHR. [ The 31 day Frequency is appropriate for this SR because it is consistent with the requirements of SR 3.3.1.3 for calibration 2 of the excore detectors using the incore detectors.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance 2
Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The SR is modified by a Note that states that the SR is only required to be met when the Excore Detection Monitoring System is being used to determine LHR. The reason for the Note is that the excore detectors input neutron flux information into the ASI calculation.
SR 3.2.1.2 and SR 3.2.1.3 Continuous monitoring of the LHR is provided by the Incore Detector Monitoring System and the Excore Detector Monitoring System. Either of these two core power distribution monitoring systems provides adequate monitoring of the core power distribution and is capable of verifying that the LHR does not exceed its specified limits.
Performance of these SRs verifies that the Incore Detector Monitoring System can accurately monitor LHR. Therefore, they are only applicable when the Incore Detector Monitoring System is being used to determine the LHR.
Combustion Engineering STS B 3.2.1-5 Rev. 5.0 1
St. Lucie - Unit 1 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued)
[ A 31 day Frequency is consistent with the historical testing frequency of the reactor monitoring system.
2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2
description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The SRs are modified by two Notes. Note 1 allows the SRs to be met only when the Incore Detector Monitoring System is being used to determine LHR. Note 2 states that the SRs are not required to be performed when THERMAL POWER is < 20% RTP. The accuracy of the neutron flux information from the incore detectors is not reliable at 6 THERMAL POWER < 20% RTP.
REFERENCES 1. FSAR, Chapter [15].
U 2
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.46.
5 low power levels . Note 2 allows entry into and operation in MODE 1 prior to performing the SRs in order to establish a power level that provides more 6 accurate neutron flux information . Consistent with the requirements of SR 3.0.1 and SR 3.0.2, as specified in Example 1.4-5 of Section 1.4, Frequency, the Surveillances must be performed within the Frequency requirements of the Surveillance Frequency Control Program prior to exceeding 20% RTP.
Combustion Engineering STS B 3.2.1-6 Rev. 5.0 1
St. Lucie - Unit 1 Revision XXX R2
LHR (Analog) 5 B 3.2.1 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.1 Linear Heat Rate (LHR) (Analog)
BASES (Linear Heat Rate (LHR))
1 BACKGROUND The purpose of this LCO is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the does not result in violation of 1 power distribution satisfies this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.1-1 Rev. 5.0 1 St. Lucie - Unit 2 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES BACKGROUND (continued) AXIAL SHAPE INDEX (
AZIMUTHAL POWER TILT ( ) )
4 The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), Total Integrated Radial Peaking Factor (F r), Tq, and ASI represent limits within T 1 which the LHR algorithms are valid. These limits are obtained directly from the core reload analysis.
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provides adequate monitoring of the core power distribution and is capable of verifying that the LHR is within its limits. The Excore Detector Monitoring System performs this function by continuously monitoring ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing ASI limits, the following assumptions are made:
1 conditions assumed
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4
- c. F Txy is within the limits of LCO 3.2.2. 4 FrT , the The Incore Detector Monitoring System continuously provides a more 1
direct measure of the peaking factors and alarms that have been established for the individual incore detector segments, ensuring that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for: described in Reference 3.
3
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.1-2 Rev. 5.0 1 St. Lucie - Unit 2 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) and AOOs (Condition 2) (Ref. 3, GDC 10). The 4 1 ANALYSES power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by accident analyses (Ref. 1), with due regard for the correlations between measured quantities, the power distribution, and uncertainties in determining the power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does 5
not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
and , and within the Tq limits 1 The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, FrT , and Tq limits specified in the COLR. The latter are process 4 variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.
Combustion Engineering STS B 3.2.1-3 Rev. 5.0 1 St. Lucie - Unit 2 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES APPLICABLE SAFETY ANALYSES (continued) reactor 1
Fuel cladding damage does not normally occur while the unit is operating at conditions outside the limits of these LCOs during normal operation.
Fuel cladding damage could result, however, if an accident or AOO occurs from initial conditions outside the limits of these LCOs. The This 1 potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and can correspondingly increase local LHR.
The LHR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNB ratio operating limits. The power distribution LCO limits, except Tq, are provided in the COLR. The limitation on the LHR ensures that, in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1, power distribution must be maintained within the limits assumed in the accident analysis to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because there is not sufficient THERMAL POWER to require a limit on 1 the core power distribution.
ACTIONS A.1 With the LHR exceeding its limit, excessive fuel damage could occur following an accident. In this Condition, prompt action must be taken to restore the LHR to within the specified limits. One hour to restore the LHR to within its specified limits is reasonable and ensures that the core does not continue to operate in this Condition. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time also allows the operator sufficient time for evaluating core conditions and for initiating proper corrective actions.
B.1 If the LHR cannot be returned to within its specified limits, THERMAL POWER must be reduced. The change to MODE 2 provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative condition. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 2 from full power MODE 1 conditions in an orderly manner and without challenging plant systems.
Combustion Engineering STS B 3.2.1-4 Rev. 5.0 1 St. Lucie - Unit 2 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES SURVEILLANCE A Note was added to the SRs to require LHR to be determined by REQUIREMENTS either the Excore Detector Monitoring System or the Incore Detector Monitoring System.
SR 3.2.1.1 Performance of this SR verifies that the Excore Detector Monitoring System can accurately monitor the LHR. Therefore, this SR is only applicable when the Excore Detector Monitoring System is being used to determine the LHR. [ The 31 day Frequency is appropriate for this SR because it is consistent with the requirements of SR 3.3.1.3 for calibration 2 of the excore detectors using the incore detectors.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance 2
Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The SR is modified by a Note that states that the SR is only required to be met when the Excore Detection Monitoring System is being used to determine LHR. The reason for the Note is that the excore detectors input neutron flux information into the ASI calculation.
SR 3.2.1.2 and SR 3.2.1.3 Continuous monitoring of the LHR is provided by the Incore Detector Monitoring System and the Excore Detector Monitoring System. Either of these two core power distribution monitoring systems provides adequate monitoring of the core power distribution and is capable of verifying that the LHR does not exceed its specified limits.
Performance of these SRs verifies that the Incore Detector Monitoring System can accurately monitor LHR. Therefore, they are only applicable when the Incore Detector Monitoring System is being used to determine the LHR.
Combustion Engineering STS B 3.2.1-5 Rev. 5.0 1 St. Lucie - Unit 2 Revision XXX R2
LHR (Analog) 5 B 3.2.1 BASES SURVEILLANCE REQUIREMENTS (continued)
[ A 31 day Frequency is consistent with the historical testing frequency of the reactor monitoring system.
2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2
description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The SRs are modified by two Notes. Note 1 allows the SRs to be met only when the Incore Detector Monitoring System is being used to determine LHR. Note 2 states that the SRs are not required to be performed when THERMAL POWER is < 20% RTP. The accuracy of the neutron flux information from the incore detectors is not reliable at 6 THERMAL POWER < 20% RTP.
REFERENCES 1. FSAR, Chapter [15].
U 2
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.46.
5 low power levels . Note 2 allows entry into and operation in MODE 1 prior to performing the SRs in order to establish a power level that provides more 6 accurate neutron flux information . Consistent with the requirements of SR 3.0.1 and SR 3.0.2, as specified in Example 1.4-5 of Section 1.4, Frequency, the Surveillances must be performed within the Frequency requirements of the Surveillance Frequency Control Program prior to exceeding 20% RTP.
Combustion Engineering STS B 3.2.1-6 Rev. 5.0 1 St. Lucie - Unit 2 Revision XXX R2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, BASES, LINEAR HEAT RATE (LHR)
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3. The ISTS contains tolerances to be applied to the incore detector alarm setpoints.
PSL Unit 1 UFSAR, Section 13.8, Licensee-Controlled Technical Specification Requirements, and PSL Unit 2 UFSAR, Section 13.7, Licensee-Controlled Technical Specification Requirements, each contain these tolerances to be applied to the incore detector alarm setpoints. Additionally, these tolerances will be provided in the Technical Requirements Manual. Therefore, the tolerances to be applied to the incore detector alarm setpoints are deleted.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively.
- 5. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
- 6. Changes made to clarify the SR Frequency and Note 2 consistent with the generic Surveillance requirements specified in ISTS Section 3.0, LCO and SR Applicability, as specified in ISTS Section 1.4, Frequency.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, LINEAR HEAT RATE (LHR)
There are no specific No Significant Hazards Considerations for this Specification.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
ATTACHMENT 2 ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)
ITS ITS 3.2.2 A01 POWER DISTRIBUTION LIMITS T
TOTAL INTEGRATED RADIAL PEAKING FACTOR - F r LIMITING CONDITION FOR OPERATION 2
T LCO 3.2.2 3.2.3 The calculated value of F r shall be within the limits specified in the COLR.
Applicability APPLICABILITY: MODE 1*. A03 ACTION:
ACTION A Note Required Actions shall be completed if this Condition is entered.
T LCO 3.1.6, Regulating Control ACTION A With F r not within limits, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> either: Element Assembly (CEA) Insertion L02 MODE 2 Limits, as specified in the COLR L01 Required Action B.1 a. Be in at least HOT STANDBY, or specified in the control element assemblies ( )
Required Action A.1 b. Reduce THERMAL POWER to bring the combination of THERMAL POWER and Required Action A.2 FTr to within the limits of COLR Figure 3.2-3 and withdraw the full length CEAs to or beyond the Long Term Steady State Insertion Limits of Specification 3.1.3.6. The THERMAL POWER limit determined from COLR Figure 3.2-3 shall then be used to LA01 Required Action A.3 as specified in the establish a revised upper THERMAL POWER level limit on COLR Figure 3.2-4 (truncate Figure 3.2-4 at the allowable fraction of RATED THERMAL POWER LA01 determined by COLR Figure 3.2-3) and subsequent operation shall be maintained within the reduced acceptable operation region of COLR Figure 3.2-4.
SURVEILLANCE REQUIREMENTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable. M01 FT T SR 3.2.2.1 Note 4.2.3.2 r shall be calculated by the expression F r = F r (1 + Tq ) when Fr is calculated with a non-full core power distribution analysis code and shall be calculated as F Tr = Fr when LA02 SR 3.2.2.1 calculations are performed with a full core power distribution analysis code. F Tr shall be determined to be within its limit at the following intervals. Verify the value of
> 70% RTP SR 3.2.2.1 a. Prior to operation above 70 percent of RATED THERMAL POWER after each fuel Frequency loading.
SR 3.2.2.1 b. In accordance with the Surveillance Frequency Control Program in MODE 1, and Frequency
- c. Within four hours if the AZIMUTHAL POWER TILT (Tq) is > 0.03. A02 SR 3.2.2.1 and SR 3.2.2.3 shall be completed each time SR 3.2.2.1 is required. FTr shall be determined using the incore detectors to obtain a power distribution map with all CEAs at or above the long term steady state insertion limit as specified in the COLR.
A03
- See Special Test Exception 3.10.2 ST. LUCIE - UNIT 1 3/4 2-9 Amendment No. 27, 32, 48, 65, 150, 152, 223
ITS ITS 3.2.2 A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
SR 3.2.2.2 Verify the value of SR 3.2.2.2 and SR 3.2.2.3 completed SR 3.2.2.1 SR 3.2.2.1 Note 4.2.3.3 Fr shall be determined each time a calculation of F Tr is required by using the incore detectors to obtain a power distribution map with all shall be full length CEAs at or above the Long Term Steady State Insertion Limit determined for the existing Reactor Coolant Pump combination. as specified in the COLR SR 3.2.2.3 Verify the value of SR 3.2.2.2 and SR 3.2.2.3 completed SR 3.2.2.1 required SR 3.2.2.1 Note 4.2.3.4 Tq shall be determined each time a calculation of F Tr is made using a non-full core power distribution analysis code. The value of Tq LA02 used to determine F Tr in this case shall be the measured value of Tq.
SR 3.2.2.2 Frequency In accordance with the Frequency requirements of SR 3.2.2.1.
SR 3.2.2.3 Frequency ST. LUCIE - UNIT 1 3/4 2-10 Amendment No. 27, 65
ITS ITS 3.2.2 A01 POWER DISTRIBUTION LIMITS TOTAL INTEGRATED RADIAL PEAKING FACTOR - F Tr LIMITING CONDITION FOR OPERATION 2
LCO 3.2.2 3.2.3 The calculated value of F Tr shall be within the limits specified in COLR.
Applicability APPLICABILITY: MODE 1*. A03 ACTION:
ACTION A Note Required Actions shall be completed if this Condition is entered.
LCO 3.1.6, Regulating Control ACTION A With F Tr not within limits, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> either: Element Assembly (CEA) Insertion L02 MODE 2 Limits, as specified in the COLR L01 Required Action B.1 a. Be in at least HOT STANDBY, or specified in the control element assemblies ( )
Required Action A.1 b. Reduce THERMAL POWER to bring the combination of THERMAL POWER and Required Action A.2 FTr to within the limits of COLR Figure 3.2-3 and withdraw the full-length CEAs to or beyond the Long Term Steady State Insertion Limits of Specification 3.1.3.6. The THERMAL POWER limit determined from COLR Figure 3.2-3 shall then be used to LA01 Required Action A.3 as specified in the establish a revised upper THERMAL POWER level limit on COLR Figure 3.2-4 (truncate COLR Figure 3.2-4 at the allowable fraction of RATED THERMAL LA01 POWER determined by COLR Figure 3.2-3) and subsequent operation shall be maintained within the reduced acceptable operation region of COLR Figure 3.2-4.
SURVEILLANCE REQUIREMENTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable. M01 4.2.3.2 FT F T = F r (1 + Tq ) when Fr is calculated with a r shall be calculated by the expression r SR 3.2.2.1 Note non-full core power distribution analysis code and shall be calculated as F Tr = Fr when LA02 SR 3.2.2.1 calculations are performed with a full core power distribution analysis code. F Tr shall be determined to be within its limit at the following intervals: Verify the value of
> 70% RTP SR 3.2.2.1 a. Prior to operation above 70% of RATED THERMAL POWER after each fuel Frequency loading, SR 3.2.2.1 b. In accordance with the Surveillance Frequency Control Program in MODE 1, and Frequency
- c. Within four hours if the AZIMUTHAL POWER TILT (Tq) is > 0.03. A02 SR 3.2.2.1 and SR 3.2.2.3 shall be completed each time SR 3.2.2.1 is required. FTr shall be determined using the incore detectors to obtain a power distribution map with all CEAs at or above the long term steady state insertion limit as specified in the COLR.
- See Special Test Exception 3.10.2 A03 ST. LUCIE - UNIT 2 3/4 2-9 Amendment No. 8, 60, 92, 173
ITS ITS 3.2.2 A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
SR 3.2.2.2 Verify the value of SR 3.2.2.2 and SR 3.2.2.3 completed SR 3.2.2.1 SR 3.2.2.1 Note 4.2.3.3 Fr shall be determined each time a calculation of F Tr is required by using the incore detectors to obtain a power distribution map with all full shall be length CEAs at or above the Long Term Steady State Insertion Limit for the determined existing reactor coolant pump combination. as specified in the COLR SR 3.2.2.3 Verify the value of SR 3.2.2.2 and SR 3.2.2.3 completed SR 3.2.2.1 required SR 3.2.2.1 Note 4.2.3.4 Tq shall be determined each time a calculation of F Tr is made using a non-full core power distribution analysis code. The value of Tq used to LA02 determine F T in this case shall be the measured value of Tq.
r SR 3.2.2.2 Frequency In accordance with the Frequency requirements of SR 3.2.2.1.
SR 3.2.2.3 Frequency ST. LUCIE - UNIT 2 3/4 2-10
ITS ITS 3.2.2 R2 A01 Pages 3/4 2-12 (Amendment 42) has been deleted from the Technical Specifications. The next A01 page is 3/4 2-13.
ST. LUCIE - UNIT 2 3/4 2-11 Amendment No. 8, 92
DISCUSSION OF CHANGES ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2, 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-1432, Rev. 5.0, "Standard Technical Specifications-Combustion Engineering Plants" (ISTS).
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 4.2.3.2.c states that CTS 4.2.3.2 be performed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if the Azimuthal Power Tilt (Tq) is > 0.03. CTS 3.2.4 Action a. states that with the Tq > 0.03 the FrT be verified within limits within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if the Tq is not restored.
CTS 4.2.3.2.c is redundant to CTS 3.2.4 Action a. and is deleted.
This change is designated as an administrative change and is acceptable because the change does not result in technical changes to the CTS.
A03 CTS 3.2.3 Applicability is MODE 1 with a footnote (footnote *) for MODE 1 stating "See Special Test Exception 3.10.2. ITS 3.2.2 does not contain the footnote or a reference to the Special Test Exceptions. This changes the CTS by not including footnote
- in the ITS.
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 4.2.3.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. ITS 3.2.2 does not provide a Surveillance Note that states that the provisions of LCO 4.0.4 are not applicable.
LCO 4.0.4 states that entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCOs Surveillances have been met within their specified Frequency, except as provided by Surveillance Requirement 4.0.3. LCO 4.0.3 provides the provisions for a missed surveillance and does not apply to a surveillance known to not be met within its specified Frequency prior to entering the Mode of Applicability.
The purpose of CTS 4.2.3.1 is to provide an allowance for entering the MODE of applicability when any Surveillance is not met.
St. Lucie Unit 1 and Unit 2 Page 1 of 4
DISCUSSION OF CHANGES ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
This change is designated as more restrictive because the CTS 4.0.4 MODE change allowance is deleted and entry into MODE 1 shall only be made when the LCOs surveillances have been met within their specified Frequency.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or R2 Reporting Requirements) CTS 3.2.3 Action b. states, in part, establish a revised upper THERMAL POWER level limit, and provides the COLR details used for this determination. ITS 3.2.2 Required Action A.3 states Establish a revised upper THERMAL POWER limit as specified in the COLR. This changes the CTS by relocating the details for making the revised upper THERMAL POWER limit determination to the COLR.
The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to establish a revised upper THERMAL POWER limit as specified in the COLR. Also, this change is acceptable because these types of procedural details will be adequately controlled in the COLR. Changes to the COLR are made under 10 CFR 50.59 which ensures changes are properly evaluated. 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.
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or R2 Reporting Requirements) CTS 4.2.3.2 and CTS 4.2.3.4 state details for calculating FrT with a non-full core power distribution analysis code and with a full core power distribution analysis code. ITS SR 3.2.2.1 and ITS SR 3.2.2.3 do not provide details for calculating FrT . This changes the CTS by relocating the details for calculating FrT to the ITS Bases. The ITS still retains the requirement to verify the value of Fr and to verify the value of Tq.
The removal of these details for performing actions from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases. 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.
St. Lucie Unit 1 and Unit 2 Page 2 of 4
DISCUSSION OF CHANGES ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
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.
LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.2.3 Action a. states that R1 with FrT not within limits, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> as an alternative to CTS Action b. ITS 3.2.2 Action B states that with the Required Actions and associated Completion Times (of Condition A) not met, then be in MODE 2 with a Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This changes the CTS by only requiring that MODE 2 be entered. Once in MODE 2, LCO 3.0.2 allows the LCO to be exited since the Applicability is MODE 1, and completing the Required Actions is not required when an LCO is met or is no longer applicable, unless otherwise stated in the individual Specifications.
R1 The purpose of CTS 3.2.3 Action a. and ITS 3.2.2 Action B is to reduce THERMAL POWER. Exiting the Mode of Applicability provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative 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, 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 repair period.
This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L02 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 Action a. states that R1 with FrT not within limits, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> be in at least HOT STANDBY as an alternative to CTS Action b. ITS 3.2.2 Action B states that with the Required Actions and associated Completion Times (of Condition A) not met, then be in MODE 2 with a Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The ITS 3.2.2 Completion Time for Required Action A.1, A.2, and A.3 is 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Therefore, up to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> may be allowed to be in MODE 2. This changes the CTS by allowing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to restore FrT to within limits before requiring that MODE 2 be entered within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. See DOC L01 for a discussion of change from MODE 3 (CTS) to MODE 2 (ITS).
The purpose of CTS 3.2.3 Action a. and ITS 3.2.2 Action B is to exit the Mode of R1 Applicability should the LCO not be restored or the Required Actions not be completed within the associated Completion Times. A Note modifying ITS 3.2.2 Condition A requires Required Actions A.1, A.2, and A.3 to be completed if the Condition is entered. This ensures that corrective action is taken prior to unrestricted operation. The limitations on FrT provided in the COLR ensure that the assumptions used in the analysis for establishing the ASI, LCO, and LSSS St. Lucie Unit 1 and Unit 2 Page 3 of 4
DISCUSSION OF CHANGES ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
remain valid during operation at the various allowable CEA group insertion limits.
If FrT exceeds its basic limitation, operation may continue under the additional restrictions imposed by the Required Actions (reducing THERMAL POWER, withdrawing CEAs to or beyond the long term steady state insertion limits of LCO 3.1.6, and establishing a revised upper THERMAL POWER limit) because these additional restrictions provide adequate provisions to ensure the assumptions used in establishing the LHR, LCO, and LSSS remain valid. 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 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 repair period.
This change is designated as less restrictive because the ITS allows up to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> longer to exit the Mode of Applicability should the LCO not be restored or the Required Actions not be completion within the associated Completion Times.
St. Lucie Unit 1 and Unit 2 Page 4 of 4
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
FrT (Analog) 5 CTS 3.2.3 4 2
3.2 POWER DISTRIBUTION LIMITS (Analog) 5 3.2.3 Total Integrated Radial Peaking Factor ( FrT ) (Analog) 4 2
3.2.3 LCO 3.2.3 The calculated value of FrT shall be within the limits specified in the 2 COLR.
Applicability APPLICABILITY: MODE 1.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A. ------------NOTE------------ A.1 Reduce THERMAL 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ACTION b. Required Actions shall POWER to bring the be completed if this combination of THERMAL Condition is entered. POWER and FrT to within
limits specified in the COLR.
FrT not within limit.
AND A.2 Withdraw the control 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> element assemblies (CEAs) to or beyond the long term steady state insertion limits of LCO 3.1.6, "Regulating Control Element Assembly (CEA) Insertion Limits," as specified in the COLR.
AND A.3 Establish a revised upper 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> THERMAL POWER limit as specified in the COLR.
ACTION a. B. Required Actions and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Times not met.
Combustion Engineering STS 3.2.3-1 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Amendment XXX R2
FrT (Analog) 5 CTS 3.2.3 4 2
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 2 2 2 SR 4.2.3.2 SR 3.2.3.1 -------------------------------NOTE------------------------------
SR 4.2.3.2.a SR 4.2.3.2.b 2 SR 3.2.3.2 and SR 3.2.3.3 shall be completed each 4 time SR 3.2.3.1 is required. FrT shall be determined by using the incore detectors to obtain a power distribution map with all full length CEAs at or above 3 the long term steady state insertion limit as specified in the COLR.
Verify the value of FrT . Prior to operation
> 70% RTP after each fuel loading AND
[ Each 31 days of accumulated operation in MODE 1 2 OR In accordance with the Surveillance Frequency Control Program ]
SR 4.2.3.3 SR 3.2.3.2 Verify the value of Fr. In accordance 4 2
with the Frequency requirements of SR 3.2.3.1 2
SR 4.2.3.4 SR 3.2.3.3 Verify the value of Tq. In accordance 4 2 with the Frequency requirements of SR 3.2.3.1 2
Combustion Engineering STS 3.2.3-2 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Amendment XXX R2
FrT (Analog) 5 CTS 3.2.3 4
2 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 3.2.3 Total Integrated Radial Peaking Factor ( FrT ) (Analog) 4 2
3.2.3 LCO 3.2.3 The calculated value of FrT shall be within the limits specified in the 2 COLR.
Applicability APPLICABILITY: MODE 1.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION A. ------------NOTE------------ A.1 Reduce THERMAL 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> ACTION b. Required Actions shall POWER to bring the be completed if this combination of THERMAL Condition is entered. POWER and FrT to within
limits specified in the COLR.
FrT not within limit.
AND A.2 Withdraw the control 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> element assemblies (CEAs) to or beyond the long term steady state insertion limits of LCO 3.1.6, "Regulating Control Element Assembly (CEA) Insertion Limits," as specified in the COLR.
AND A.3 Establish a revised upper 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> THERMAL POWER limit as specified in the COLR.
ACTION a. B. Required Actions and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Times not met.
Combustion Engineering STS 3.2.3-1 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Amendment XXX R2
FrT (Analog) 5 CTS 3.2.3 4
2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 2 2 2 SR 4.2.3.2 SR 3.2.3.1 -------------------------------NOTE------------------------------
SR 4.2.3.2.a SR 4.2.3.2.b 2 SR 3.2.3.2 and SR 3.2.3.3 shall be completed each 4 time SR 3.2.3.1 is required. FrT shall be determined by using the incore detectors to obtain a power distribution map with all full length CEAs at or above 3 the long term steady state insertion limit as specified in the COLR.
Verify the value of FrT . Prior to operation
> 70% RTP after each fuel loading AND
[ Each 31 days of accumulated operation in MODE 1 2 OR In accordance with the Surveillance Frequency Control Program ]
SR 4.2.3.3 SR 3.2.3.2 Verify the value of Fr. In accordance 4 2
with the Frequency requirements of SR 3.2.3.1 2
SR 4.2.3.4 SR 3.2.3.3 Verify the value of Tq. In accordance 4 2 with the Frequency requirements of SR 3.2.3.1 2
Combustion Engineering STS 3.2.3-2 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Amendment XXX R2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR ( )
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3. ISTS SR 3.2.2.1 Note, deletes the term full length as related to control element assemblies (CEAs). Part length CEAs are not used at PSL Unit 1 and PSL Unit 2.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively.
- 5. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)
FTXY (Analog) 5 FrT B 3.2.3 4
2 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.3 Total Integrated Radial Peaking Factor (FTXY) (Analog) 2 4 FrT BASES BACKGROUND The purpose of this LCO (Total Integrated Radial Peaking Factor (FTr)) is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. The use of CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings (LSSS) and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on the linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.3-1 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Revision XXX
FTXY (Analog) 5 FrT B 3.2.3 4
2 BASES BACKGROUND (continued)
LINEAR HEAT RATE ( ) AZIMUTHAL POWER TILT ( )
AXIAL SHAPE INDEX (
The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), FrT , Tq, and 4 ASI represent limits within which the LHR algorithms are valid. These 1
limits are obtained directly from the core reload analysis.
)
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provide adequate monitoring of the core power distribution and are is capable of verifying that the LHR does not exceed its limits. The Excore 1 Detector Monitoring System performs this function by continuously monitoring the ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following conditions are assumed:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4
- c. FTxy does not exceed the limits of LCO 3.2.2.
FrT The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms established for the individual incore detector segments ensure that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for:
described in Reference 3.
3
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.3-2 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Revision XXX
FTXY (Analog) 5 FrT B 3.2.3 4
2 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) and AOOs (Condition 2) (Ref. 3, GDC 10). The 4 1 ANALYSES power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1), with due regard for the correlations between measured quantities, the power distribution, and uncertainties in the determination of power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 5
assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, and FrT limits specified in the COLR, and within the Tq limits. The 4
latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the range used in the accident analysis.
Combustion Engineering STS B 3.2.3-3 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Revision XXX
FTXY (Analog) 5 FrT B 3.2.3 4
2 BASES APPLICABLE SAFETY ANALYSES (continued) the reactor is operating 1
Fuel cladding damage does not normally occur while at conditions outside the limits of these LCOs during normal operation. Fuel cladding damage could result, however, if an accident or AOO occurs from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution cause increased power peaking and correspondingly increased local LHR.
FTr satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
certain LCO The LCO limits for power distribution are based on correlations between 1 power peaking and measured variables used as inputs to LHR and DNB ratio operating limits. The LCO limits for power distribution, except Tq, are provided in the COLR. The limitation on the LHR ensures that, in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1, power distribution must be maintained within the limits assumed in the accident analysis to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because there is not sufficient THERMAL POWER to require a limit on 1
the core power distribution.
ACTIONS A.1, A.2, and A.3 A Note modifying Condition A requires Required Actions A.1, A.2, and A.3 to be completed if the Condition is entered. This ensures that corrective action is taken prior to unrestricted operation.
The limitations on FrT provided in the COLR ensure that the assumptions used in the analysis for establishing the ASI, LCO, and LSSS remain valid during operation at the various allowable CEA group insertion limits. If FrT exceeds its basic limitation, operation may continue under the additional restrictions imposed by the Required Actions (reducing THERMAL POWER, withdrawing CEAs to or beyond the long term steady state insertion limits of LCO 3.1.6, and establishing a revised upper THERMAL POWER limit) because these additional restrictions provide adequate provisions to ensure that the assumptions used in establishing the LHR, LCO, and LSSS remain valid. Six hours to return FrT to within its limits by adjusting the ASI limits based on maximum power allowed for 4
FrT FXY T
is reasonable and ensures that all CEAs meet the long term steady state insertion limits of LCO 3.1.6.
Combustion Engineering STS B 3.2.3-4 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Revision XXX
FTXY (Analog) 5 FrT B 3.2.3 4
2 BASES ACTIONS (continued)
B.1 If FrT cannot be returned to within its limit, THERMAL POWER must be reduced. A change to MODE 2 provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative condition. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.2. 3.1 5 REQUIREMENTS 2 The periodic Surveillance to determine the calculated FrT ensures that FrT remains within the range assumed in the analysis throughout the fuel cycle. Determining the measured FrT once after each fuel loading prior to exceeding 70% RTP ensures that the core is properly loaded.
[ Performance of the Surveillance every 31 days of accumulated operation in MODE 1 provides reasonable assurance that unacceptable changes in the FTr are promptly detected. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The power distribution map can only be obtained after THERMAL POWER exceeds 20% RTP because the incore detectors are not reliable below 20% RTP.
The SR is modified by a Note that requires SR 3.2.3.2 and SR 3.2.3.3 be completed each time SR 3.2.3.1 is completed. This procedure is required because the values computed by these SRs are required to perform this SR.
FrT is calculated by the expression FrT = Fr (1 + Tq) when Fr is calculated with a non-full core power distribution analysis code and is calculated by the expression FrT = Fr when calculations are 6 performed with a full core power distribution analysis code.
Combustion Engineering STS B 3.2.3-5 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Revision XXX
FTXY (Analog) 5 FrT B 3.2.3 4
2 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.2.3.2 and SR 3.2.3.3 5 2 2 Measuring the values of FrT and Tq each time a value of FrT is calculated ensures that the calculated value of FrT accurately reflects the condition of the core.
The Frequency for these Surveillances is in accordance with the 5 requirements of SR 3.2.3.1 because these SRs provide information to complete SR 3.2.2.1. 2 REFERENCES 1. FSAR, Chapter [15].
U 2
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.46.
5 Combustion Engineering STS B 3.2.3-6 Rev. 5.0 1 4 St. Lucie - Unit 1 2 Revision XXX
5 FTXY (Analog)
FrT B 3.2.3 4 2
B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.3 Total Integrated Radial Peaking Factor (FTXY) (Analog) 4 2
FrT BASES BACKGROUND The purpose of this LCO (Total Integrated Radial Peaking Factor (FTr)) is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. The use of CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings (LSSS) and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on the linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.3-1 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Revision XXX
5 FTXY (Analog)
FrT B 3.2.3 4 2
BASES BACKGROUND (continued)
LINEAR HEAT RATE ( ) AZIMUTHAL POWER TILT ( )
AXIAL SHAPE INDEX (
The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), FrT , Tq, and 4 ASI represent limits within which the LHR algorithms are valid. These 1
limits are obtained directly from the core reload analysis.
)
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provide adequate monitoring of the core power distribution and are is capable of verifying that the LHR does not exceed its limits. The Excore 1 Detector Monitoring System performs this function by continuously monitoring the ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following conditions are assumed:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4
- c. FTxy does not exceed the limits of LCO 3.2.2.
FrT The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms established for the individual incore detector segments ensure that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for:
described in Reference 3.
3
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.3-2 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Revision XXX
5 FTXY (Analog)
FrT B 3.2.3 4 2
BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) and AOOs (Condition 2) (Ref. 3, GDC 10). The 4 1 ANALYSES power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1), with due regard for the correlations between measured quantities, the power distribution, and uncertainties in the determination of power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 5
assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, and FrT limits specified in the COLR, and within the Tq limits. The 4
latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the range used in the accident analysis.
Combustion Engineering STS B 3.2.3-3 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Revision XXX
5 FTXY (Analog)
FrT B 3.2.3 4 2
BASES APPLICABLE SAFETY ANALYSES (continued) the reactor is operating 1
Fuel cladding damage does not normally occur while at conditions outside the limits of these LCOs during normal operation. Fuel cladding damage could result, however, if an accident or AOO occurs from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution cause increased power peaking and correspondingly increased local LHR.
FTr satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
certain LCO The LCO limits for power distribution are based on correlations between 1 power peaking and measured variables used as inputs to LHR and DNB ratio operating limits. The LCO limits for power distribution, except Tq, are provided in the COLR. The limitation on the LHR ensures that, in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1, power distribution must be maintained within the limits assumed in the accident analysis to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because there is not sufficient THERMAL POWER to require a limit on 1
the core power distribution.
ACTIONS A.1, A.2, and A.3 A Note modifying Condition A requires Required Actions A.1, A.2, and A.3 to be completed if the Condition is entered. This ensures that corrective action is taken prior to unrestricted operation.
The limitations on FrT provided in the COLR ensure that the assumptions used in the analysis for establishing the ASI, LCO, and LSSS remain valid during operation at the various allowable CEA group insertion limits. If FrT exceeds its basic limitation, operation may continue under the additional restrictions imposed by the Required Actions (reducing THERMAL POWER, withdrawing CEAs to or beyond the long term steady state insertion limits of LCO 3.1.6, and establishing a revised upper THERMAL POWER limit) because these additional restrictions provide adequate provisions to ensure that the assumptions used in establishing the LHR, LCO, and LSSS remain valid. Six hours to return FrT to within its limits by adjusting the ASI limits based on maximum power allowed for FrT FXY T
is reasonable and ensures that all CEAs meet the long term steady 4 state insertion limits of LCO 3.1.6.
Combustion Engineering STS B 3.2.3-4 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Revision XXX
5 FTXY (Analog)
FrT B 3.2.3 4 2
BASES ACTIONS (continued)
B.1 If FrT cannot be returned to within its limit, THERMAL POWER must be reduced. A change to MODE 2 provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative condition. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.2. 3.1 5 REQUIREMENTS 2 The periodic Surveillance to determine the calculated FrT ensures that FrT remains within the range assumed in the analysis throughout the fuel cycle. Determining the measured FrT once after each fuel loading prior to exceeding 70% RTP ensures that the core is properly loaded.
[ Performance of the Surveillance every 31 days of accumulated operation in MODE 1 provides reasonable assurance that unacceptable changes in the FTr are promptly detected. 2 OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The power distribution map can only be obtained after THERMAL POWER exceeds 20% RTP because the incore detectors are not reliable below 20% RTP.
The SR is modified by a Note that requires SR 3.2.3.2 and SR 3.2.3.3 be completed each time SR 3.2.3.1 is completed. This procedure is required because the values computed by these SRs are required to perform this SR.
FrT is calculated by the expression FrT = Fr (1 + Tq) when Fr is calculated with a non-full core power distribution analysis code and is calculated by the expression FrT = Fr when calculations are 6 performed with a full core power distribution analysis code.
Combustion Engineering STS B 3.2.3-5 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Revision XXX
5 FTXY (Analog)
FrT B 3.2.3 4 2
BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.2.3.2 and SR 3.2.3.3 5 2 2 Measuring the values of FrT and Tq each time a value of FrT is calculated ensures that the calculated value of FrT accurately reflects the condition of the core.
The Frequency for these Surveillances is in accordance with the requirements of SR 3.2.3.1 because these SRs provide information to 5 complete SR 3.2.2.1. 2 REFERENCES 1. FSAR, Chapter [15].
U 2
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.46.
5 Combustion Engineering STS B 3.2.3-6 Rev. 5.0 1 4 St. Lucie - Unit 2 2 Revision XXX R2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, BASES, TOTAL INTEGRATED RADIAL PEAKING FACTOR ( )
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3. The ISTS contains tolerances to be applied to the incore detector alarm setpoints.
PSL Unit 1 UFSAR, Section 13.8, Licensee-Controlled Technical Specification Requirements, and PSL Unit 2 UFSAR, Section 13.7, Licensee-Controlled Technical Specification Requirements, each contain these tolerances to be applied to the incore detector alarm setpoints. Additionally, these tolerances will be provided in the Technical Requirements Manual. Therefore, the tolerances to be applied to the incore detector alarm setpoints are deleted.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively.
- 5. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
- 6. CTS 4.2.3.2 and CTS 4.2.3.4 state details for calculating FrT with a non-full core power distribution analysis code and with a full core power distribution analysis code.
ITS SR 3.2.2.1 and ITS SR 3.2.2.3 do not provide details for calculating FrT . This changes the CTS by relocating the details for calculating FrT to the ITS Bases. This change is acceptable since procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications and relocating these details to the ITS Bases.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, TOTAL INTEGRATED RADIAL PEAKING FACTOR -
There are no specific No Significant Hazards Considerations for this Specification.
St. Lucie Unit 1 and 2 Page 1 of 1
ATTACHMENT 3 ITS 3.2.3, AZIMUTHAL POWER TILT (Tq)
Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)
ITS ITS 3.2.3 A01 POWER DISTRIBUTION LIMITS AZIMUTHAL POWER TILT - Tq LIMITING CONDITION FOR OPERATION 3 be LCO 3.2.3 3.2.4 The AZIMUTHAL POWER TILT (Tq) shall not exceed 0.03.
A02 Applicability APPLICABILITY: MODE 1*.
with THERMAL POWER > 50% RTP. L01 ACTION:
and Tq Restore Tq to 0.03 ACTION A Required Action A.1 a. With the indicated AZIMUTHAL POWER TILT determined to be
> .030 but < 0.10, either correct the power tilt within two hours or determine within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once M02 thereafter Required Action A.2 per subsequent 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, that the TOTAL INTEGRATED RADIAL LCO 3.2.2, Total Integrated Verify PEAKING FACTOR ( F Tr ) is within the limits of Specification Radial Peaking Factor (FTr).
3.2.3. Insert proposed ACTION B Insert proposed Required Action C NOTE M03
- b. With the indicated AZIMUTHAL POWER TILT determined to be > 0.10, M04 ACTION C Tq operation may proceed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided that the TOTAL 2 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> INTEGRATED RADIAL PEAKING FACTOR ( F T ) is within the limits of Verify Required Action C.1 r LCO Specification 3.2.3. Subsequent operation for the purpose of measurement and to identify the cause of the tilt is allowable L02 R2 Restore Tq to 50% within Required Actions 0.10 OR provided the THERMAL POWER level is restricted to < 20% of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> C.2.1 and C.2.2 Reduce the maximum allowable THERMAL POWER level for the existing Reactor Coolant Pump combination. AND M04 Required Actions Correct cause of out of limit condition C.3 and C.4 AND Verify Tq 0.03.
SURVEILLANCE REQUIREMENT 4.2.4.1 The provisions of Specification 4.0.4 are not applicable. M01 Verify Tq is s SR 3.2.3.1 4.2.4.2 The AZIMUTHAL POWER TILT shall be determined to be within the limit by:
- a. Calculating the tilt in accordance with the Surveillance Frequency Control Program when the Subchannel Deviation Alarm is OPERABLE, Prior to increasing THERMAL POWER above 50% RTP AND M04 R2 Once per hour thereafter for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified 75% RTP.
A02
- See Special Test Exception 3.10.2.
ST. LUCIE - UNIT 1 3/4 2-11 Amendment No. 9, 27, 32, 109, 223
ITS ITS 3.2.3 A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
SR 3.2.3.1 b. Calculating the tilt at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when the Frequency Subchannel Deviation Alarm is inoperable, and SR 3.2.3.1 c. Using the incore detectors to determine the AZIMUTHAL POWER Frequency TILT at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one excore channel is inoperable and THERMAL POWER is > 75% of RATED THERMAL POWER.
RTP ST. LUCIE - UNIT 1 3/4 2-12 Amendment No. 27
ITS ITS 3.2.3 A01 POWER DISTRIBUTION LIMITS 3/4.2.4 AZIMUTHAL POWER TILT - Tq LIMITING CONDITION FOR OPERATION 3 be LCO 3.2.3 3.2.4 The AZIMUTHAL POWER TILT (Tq) shall not exceed 0.03.
Applicability APPLICABILITY: MODE 1*. A02 with THERMAL POWER > 50% RTP.
ACTION: L01 Tq ACTION A a. With the indicated AZIMUTHAL POWER TILT determined to be > .030 Required Action A.1 and but < 0.10, either correct the power tilt within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or determine Restore Tq to 0.03 Required Action A.2 within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once per subsequent 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, thereafter M02 Verify that the TOTAL INTEGRATED RADIAL PEAKING FACTOR ( F Tr ) is within the limits of Specification 3.2.3. LCO 3.2.2, Total Integrated Radial Peaking Factor (FTr). M03 Insert proposed ACTION B Insert proposed Required Action C NOTE ACTION C
- b. Tq With the indicated AZIMUTHAL POWER TILT determined to be > 0.10, M04 operation may proceed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided that the TOTAL T Verify Required Action 2 within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> INTEGRATED RADIAL PEAKING FACTOR ( F r ) is within the limits of C1 LCO Specification 3.2.3. Subsequent operation for the purpose of measurement Required Actions Restore Tq to and to identify the cause of the tilt is allowable provided the THERMAL POWER L02 R2 C.2.1 and C.2.2 0.10 OR level is restricted to < 20% of the maximum allowable THERMAL POWER level Reduce for the existing Reactor Coolant Pump combination. 50% within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Required Actions C.3 and C.4 AND M04 Correct cause of out of limit condition SURVEILLANCE REQUIREMENTS AND Verify Tq 0.03.
4.2.4.1 The provisions of Specification 4.0.4 are not applicable. M01 Verify Tq is s SR 3.2.3.1 4.2.4.2 The AZIMUTHAL POWER TILT shall be determined to be within the limit by:
- a. Calculating the tilt in accordance with the Surveillance Frequency Control Program.
- b. Using the incore detectors to determine the AZIMUTHAL POWER TILT at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one excore channel is inoperable and THERMAL POWER is > 75% of RATED THERMAL POWER.
RTP Prior to increasing THERMAL POWER above 50% RTP AND M04 R2 Once per hour thereafter for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified 75% RTP.
A02
- See Special Test Exception 3.10.2.
ST. LUCIE - UNIT 2 3/4 2-13 Amendment No. 138, 173
DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT ()
ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2, 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-1432, Rev. 5.0, "Standard Technical Specifications - Combustion Engineering Plants" (ISTS).
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.4 Applicability is MODE 1 with a footnote (footnote *) for MODE 1 stating "See Special Test Exception 3.10.2. ITS 3.2.3 does not contain the footnote or a reference to the Special Test Exceptions. This changes the CTS by not including footnote
- in the ITS.
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 4.2.4.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. ITS 3.2.3 does not provide a Surveillance Note that states that the provisions of LCO 4.0.4 are not applicable. LCO 4.0.4 states that entry into a MODE or other specified condition in the Applicability of a Limiting Condition for Operation (LCO) shall only be made when the LCOs Surveillances have been met within their specified Frequency, except as provided by Surveillance Requirement 4.0.3. LCO 4.0.3 provides the provisions for a missed surveillance and does not apply to a surveillance known to not be met within its specified Frequency prior to entering the Mode of Applicability.
The purpose of CTS 4.2.4.1 is to provide an allowance for entering the MODE of applicability when any Surveillance is not met. The ITS MODE change is changed from MODE 1 to MODE 1 with THERMAL POWER > 50% RTP. See DOC L01 for a discussion of change regarding the MODE change from MODE 1, to MODE 1 with THERMAL POWER > 50% RTP. This change allows the performance of ITS 3.2.3.1 after entry into MODE 1 and up to 50% RTP. The ITS MODE change to MODE 1 with THERMAL POWER > 50% is less restrictive; however, the deletion of CTS 4.0.4 is solely a more restrictive change.
This change is designated as more restrictive because the CTS 4.0.4 MODE change allowance is deleted and entry into MODE 1 shall only be made when the LCOs surveillances have been met within their specified Frequency.
St. Lucie Unit 1 and Unit 2 Page 1 of 5
DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT ()
M02 CTS 3.2.4.a states that Tq be corrected within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or FrT be verified within limits within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once per subsequent 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. ITS 3.2.3 Condition A states that Tq be restored to 0.03 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or FrT be verified within the limits of LCO 3.2.2 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. CTS requires the first verification that FrT is within limits be completed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
ITS requires the first verification that FrT is within limits be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
The purpose of CTS/ITS is to provide reasonable assurance that the core is operating within its thermal limits during power operation beyond 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> by verifying that FrT is within limits if Tq is not corrected. The change requires that for operation to continue beyond 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> with Tq > 0.03 and 0.10, FrT must be verified within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Two hours is sufficient time to allow the operator to reposition CEAs, and significant radial xenon redistribution cannot occur within this time. This change is consistent with the ISTS Required Action A.2 Completion Time.
This change is designated as more restrictive as it requires that with Tq > 0.03 and 0.10, the first verification that FrT is within limits be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
M03 CTS 3.2.4 ACTION a. states, With the indicated AZIMUTHAL POWER TILT R2 determined to be > .03 but 0.10, either correct the power tilt within two hours or determine within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and at least once per subsequent 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, that the TOTAL INTEGRATED RADIAL PEAKING FACTOR (FrT) is within the limits of Specification 3.2.3. Similarly, ITS 3.2.3 ACTION A requires restoration of Tq to 0.03 or verification of FrT within limits with the same Completion Times. CTS 3.2.4 does not provide specific Required Actions if the Required Action and associated Completion Time of Action a. cannot be met. ITS 3.2.3 ACTION B requires a reduction in THERMAL POWER to 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> if the Required Action and associated Completion Time of Condition A is not met.
Inability to meet CTS Action a. Required Action and associate Completion time requires entry into CTS 3.0.3, which requires within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate action to place the unit in a MODE in which specification does not apply by placing it.. in MODE 3 within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This changes CTS by requiring a reduction in THERMAL POWER to 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> versus allowing 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate action and an additional 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to place the unit in a MODE in which the specification does not apply. (See L01 for the discussion of the change in Applicability.)
This change is designated as more restrictive because it adds a new requirement to the CTS and in addition, the ITS Required Action Completion Time is less than is currently allowed by CTS when relying on the provisions of CTS 3.0.3.
M04 CTS 3.2.4 Action b. states, in part, with the indicated Azimuthal Power Tilt determined to be > 0.10, operation may proceed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided that the TOTAL INTEGRATED RADIAL PEAKING FACTOR (FrT) is within the limits of Specification 3.2.3. Subsequent operation for the purpose of measurement and to identify the cause of the tilt is allowable provided the THERMAL POWER level is restricted to 20% of the maximum allowable THERMAL POWER level for the existing Reactor Coolant Pump combination. ITS 3.2.3 Condition C Required Actions are modified by a NOTE that states, All subsequent Required Actions St. Lucie Unit 1 and Unit 2 Page 2 of 5
DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT ()
R2 must be completed if power reduction commences prior to restoring Tq 0.10. ITS Required Actions C.3 and C.4 require correction of the cause for the out of limit condition and verification of Tq 0.03 prior to increasing THERMAL POWER. ITS 3.2.3 Required Action C.4 also requires verification that Tq is 0.03 at least once per hour thereafter for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified 75% RTP. The Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a historical value that allows an acceptable exit from the ACTIONS after the Tq value is verified acceptable. This changes CTS by adding additional requirements that require Condition C Required Actions be completed if power reduction is commenced prior to restoring Tq to 0.10, correction of the cause of the out of limit condition and restoration of Tq to 0.03 prior to increasing THERMAL POWER and monitoring Tq every hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until the unit reaches 75% RTP.
These changes are acceptable because ITS 3.2.3 Required Actions C.3 and C.4 in conjunction with the NOTE requiring completion of the Required Actions if power reduction commences prior to Tq restoration 0.10 ensures that corrective action is taken before unrestricted power operation resumes and power is not increased until Tq is within limits.
This change is designated as more restrictive because it adds new requirements to the CTS.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.2.4 states that the Applicability is MODE 1. ITS 3.2.3 states that the Applicability is MODE 1 with THERMAL POWER > 50% RTP. This changes the CTS by relaxing the Applicability to MODE 1 with THERMAL POWER > 50% RTP.
The purpose of CTS 3.2.4 Applicability is to state the MODE in which Tq must be maintained within the limits assumed in accident analysis to ensure that fuel damage does not result following an AOO. ITS 3.2.3 relaxes the Applicability to MODE 1 with THERMAL POWER > 50% RTP. CTS 4.2.4.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability with surveillances not met. ITS 3.2.3 Applicability of MODE 1 with THERMAL POWER > 50% RTP allows entry into MODE 1 with surveillances not met. See DOC M01 for the discussion of change for the MODE change.
This change limits the applicability of Tq to power operations with THERMAL POWER > 50% RTP. This change clarifies the applicability of the Tq, Azimuthal St. Lucie Unit 1 and Unit 2 Page 3 of 5
DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT ()
Power Tilt, consistent with the industry Standard Technical Specification (STS),
approved by the NRC for generic use as NUREG-1432, Rev. 5.0, "Standard Technical Specifications - Combustion Engineering Plants" (ISTS). This change is acceptable because the LCO requirements applied in ITS MODE 1 continue to ensure process variables, structures, systems, and components are maintained in the conditions assumed in the safety analyses and licensing basis, and the proposed TS has been generically approved for industry usage.
In MODE 1 with THERMAL POWER > 50% RTP, Tq must be maintained within the limits assumed in accident analysis to ensure that fuel damage does not result following an anticipated operational occurrence (AOO). In other MODES, this LCO does not apply because THERMAL POWER is not sufficient to require a limit on Tq, and xenon transients generated within the lower power level range are not severe. In addition, significant margin to thermal limits exists at lower power levels and therefore thermal limits are not significantly challenged.
The power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the fuel design criteria. The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of the power distribution LCOs, including ITS 3.2.3, Tq. This is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analysis.
PSL controls the AXIAL SHAPE INDEX (ASI) during startup, steady-state, and transients such as a dropped CEA. ASI COLR bands are applicable above 40%
RTP while fuel conditioning ASI bands are applicable above 50% RTP. Axial shape control establishes and maintains axial shape within the fuel conditioning control bands prior to exceeding 50% RTP. The intent of the fuel preconditioning guidelines is to minimize fuel pellet / clad interaction and maximize fuel rod integrity. When THERMAL POWER is 50 RTP, boration or dilution is the primary means to compensate for changes in power level and transient xenon. Using boration/dilution to compensate for power changes subjects the fuel rods to uniform and smooth power transients. Regulating Group CEAs are used to respond deviations of ASI from its target equilibrium shape index.
This change is designated as less restrictive because the LCO requirements will not be applied under plant conditions in which they would be applied under the CTS.
L02 (Category 4 - Relaxation of Required Action) CTS 3.2.4 Action b. states, in part, R2 with the indicated Azimuthal Power Tilt determined to be > 0.10, operation may proceed for up to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provided that the TOTAL INTEGRATED RADIAL PEAKING FACTOR (FrT) is within the limits of Specification 3.2.3. Subsequent operation for the purpose of measurement and to identify the cause of the tilt is allowable provided the THERMAL POWER level is restricted to 20% of the maximum allowable THERMAL POWER level for the existing Reactor Coolant Pump combination. PSL only operates in the four reactor coolant pump combination; therefore, subsequent operation is only allowed for measurement and St. Lucie Unit 1 and Unit 2 Page 4 of 5
DISCUSSION OF CHANGES ITS 3.2.3, AZIMUTHAL POWER TILT ()
R2 cause determination, provided the THERMAL POWER is reduced to 20% RTP.
CTS 3.2.4 does not state a specific time for FrT verification. ITS Required Action C.1 allows 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> for the FrT verification to be completed. ITS Required Actions C.2.1 and C.2.2 require restoration of Tq to 0.10 or power reduced to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This changes CTS by relaxing the completion time for FrT verification and specifying a power reduction to 50% THERMAL POWER instead of a power limit ( 20%) defined by the reactor coolant pump combination. (See Discussion of Changes M01 for discussion of Applicability change to > 50% RTP.)
Tq > 0.10 is not expected and the purpose of the limit and Required Actions is to ensure that acceptable flux peaking factors are maintained and to minimize the effect of Tq > 0.10. The ITS 3.2.3 Required Actions result in minimizing the effect of Tq being outside the limit. ITS 3.2.3 Required Actions C.2.1 and C.2.2 require restoration or Tq to 0.10 or a reduction in power to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and once power is reduced, ITS 3.2.3 Required Actions C.3 an C.4 ensure that the cause of the out of limit condition is corrected and power is not increased until Tq is verified to be within limits. These changes are acceptable because reducing THERMAL POWER to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provides an acceptable level of protection from increased power peaking due to potential xenon redistribution while maintaining a power level sufficiently high enough to allow the tilt to be analyzed and after power has been reduced to 50% RTP the rate and magnitude of changes in the core flux are greatly reduced.
These changes are designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
St. Lucie Unit 1 and Unit 2 Page 5 of 5
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
CTS Tq (Analog) 6 R2 3.2.4 3
3 3.2 POWER DISTRIBUTION LIMITS (Analog) 6 R2 3.2.4 3.2.4 AZIMUTHAL POWER TILT (Tq) (Analog) 3 3
LCO 3.2.4 LCO 3.2.4 Tq shall be [0.03]. 3 2 3
Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 50% RTP. R2 L01 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Indicated Tq > [0.03] and A.1 Restore Tq to [0.03]. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ACTION a. 0.10. 2 OR is T
A.2 Verify Fxy and FrT are 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> R2 M02 within the limits of LCO 3.2.2, "Total Planar AND T
Radial Peaking Factor ( Fxy 3
)," and LCO 3.2.3, "Total Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Integrated Radial Peaking thereafter Factor ( FrT ),"
B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> R2 M03 associated Completion POWER to 50% RTP.
Time of Condition A not met.
Combustion Engineering STS 3.2.4-1 Rev. 5.0 1 3 St. Lucie - Unit 1 3 Amendment XXX R2
CTS CCH017 Tq (Analog) 6 R2 3.2.4 3
3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME R2 ACTION b. C. Indicated Tq > 0.10. -------------------NOTE--------------------
M04 All subsequent Required Actions must be completed if power reduction commences prior to restoring Tq 0.10.
is T
C.1 Verify Fxy and FrT are 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> within the limits of 3 LCO 3.2.2 and LCO 3.2.3, R2 respectively.
L02 C.2.1 Restore Tq to 0.10. AND 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> OR C.2 Reduce THERMAL 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 4 POWER to < 50% RTP.
.2 7
AND C.3. Correct cause of out of limit condition.
C.3 Restore Tq to [0.03]. Correct the cause of 2 M04 the out of limit AND 4 Verify P
condition prior to increasing THERMAL POWER.
Subsequent power operation above 5
> 50% RTP may AND proceed provided that the measured Tq is verified [0.03] at least once per hour O for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified at 95% RTP 7
thereafter Combustion Engineering STS 3.2.4-2 Rev. 5.0 1 3 St. Lucie - Unit 1 3 Amendment XXX R2
CTS Tq (Analog) 6 R2 3.2.4 3
3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 4.2.4.2.a SR 3.2.4.1 Verify Tq is within limits. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when 3 3 the subchannel deviation alarm is inoperable AND 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when one excore detector is inoperable and
> 75% RTP AND
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance 2 with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.4-3 Rev. 5.0 1 3 St. Lucie - Unit 1 3 Amendment XXX R2
CTS Tq (Analog) 6 R2 3.2.4 3
3 3.2 POWER DISTRIBUTION LIMITS (Analog) 6 R2 3
3.2.4 3.2.4 AZIMUTHAL POWER TILT (Tq) (Analog) 3 LCO 3.2.4 LCO 3.2.4 Tq shall be [0.03]. 3 2 3
Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 50% RTP. R2 L01 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION a. A. Indicated Tq > [0.03] and A.1 Restore Tq to [0.03]. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 2 0.10.
OR is T R2 M02 A.2 Verify Fxy and FrT are 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> within the limits of LCO 3.2.2, "Total Planar AND 3 T
Radial Peaking Factor ( Fxy
)," and LCO 3.2.3, "Total Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Integrated Radial Peaking thereafter Factor ( FrT ),"
R2 M03 B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> associated Completion POWER to 50% RTP.
Time of Condition A not met.
Combustion Engineering STS 3.2.4-1 Rev. 5.0 1 3 St. Lucie - Unit 2 3 Amendment XXX R2
CTS Tq (Analog) 6 R2 3.2.4 3
3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME ACTION b. C. Indicated Tq > 0.10. -------------------NOTE-------------------- R2 All subsequent Required Actions M04 must be completed if power reduction commences prior to restoring Tq 0.10.
is T
C.1 Verify Fxy and FrT are 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> within the limits of 3 LCO 3.2.2 and LCO 3.2.3, R2 respectively.
L02 C.2.1 Restore Tq to 0.10. AND 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> OR C.2 Reduce THERMAL 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />
.2 POWER to < 50% RTP. 4 AND 7 C.3. Correct cause of out of limit condition.
C.3 Restore Tq to [0.03]. Correct the cause of M04 2 AND 4 Verify the out of limit P
condition prior to increasing THERMAL POWER.
Subsequent power operation above 50% RTP may 5 AND proceed provided that the measured Tq is verified [0.03] at least once per hour O for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified at 95% RTP 7
thereafter Combustion Engineering STS 3.2.4-2 Rev. 5.0 1 3 St. Lucie - Unit 2 3 Amendment XXX R2
CTS Tq (Analog) 6 R2 3.2.4 3
3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 4.2.4.2.a SR 3.2.4.1 Verify Tq is within limits. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when 3 3 one excore detector is inoperable and 2
> 75% RTP AND
[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 2
OR In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.4-3 Rev. 5.0 1 3 St. Lucie - Unit 2 3 Amendment XXX R2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AZIMUTHAL POWER TILT (Tq)
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively. The need to restrict operation based on Total Planar Radial Peaking T
Factor (Fxy ) was removed (ADAMS Accession Nos ML17223B164 (U1) and R2 ML050120363 (U2)) when a new reload methodology was adopted covering the full range of MODE 1 operation.
- 4. Required Action C.2.1 is added to ITS Condition C and subsequent Required Actions R2 are renumbered accordingly. Although restoration to within stated limits (Tq to 0.10) is implied and always acceptable; given the complexity of the unique ISTS Required Actions and modifying Notes, the Required Action to restore Tq to 0.10 has been included.
- 5. ISTS Required Action and Completion Time is modified to move the action to R2 Correct cause of out of limit condition to the Required Action column and revise ISTS 3.2.4 Required Action C.3 (ITS 3.2.3 Required Action C.4) to verify measured Tq is 0.03 combining ISTS Required Action C.3 with the action requirement in the Completion Time to periodically verify measured Tq is 0.03. Conforming changes are made to numbering of the Required Actions to support the change. The text specified in the Completion Time of ISTS 3.2.4 Required Action C.3 addresses actions and does not specify a Completion Time. These actions are more appropriately addressed as Required Actions. The Completion Time of Prior to increasing THERMAL POWER is retained for both ITS Required Actions C.3 and C.4. The additional Completion Time of Once per hour thereafter for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified 75% RTP, retains the ISTS 3.2.4 Required Action C.3 Completion Time. The power level at which the verification may be discontinued is changed from 95% to 75% RTP consistent with the power level specified in CTS 4.2.4.2.
- 6. The type of plant (Analog) is deleted since it is unnecessary. This information is R2 provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
- 7. ISTS Required Action C.2 (ITS Required Action C.2.2) is changed fromPOWER < R2 50% RTP to POWER 50% RTP for consistency with the APPLICABILITY of ISTS LCO 3.2.4 (ITS LCO 3.2.3), MODE 1 with THERMAL POWER > 50% RTP.
St. Lucie Units 1 and Unit 2 Page 1 of 2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AZIMUTHAL POWER TILT (Tq)
This change removes the ambiguity that exists at 50% RTP, which would be outside the APPLICABILITY but would not meet the Required Action C.2 condition. The R2 change is also consistent with Required Action B.1.
St. Lucie Units 1 and Unit 2 Page 2 of 2
Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)
Tq (Analog) 5 B 3.2.4 3 4 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.4 AZIMUTHAL POWER TILT (Tq) (Analog) 3 4 BASES BACKGROUND The purpose of this LCO (AZIMUTHAL POWER TILT (Tq)) is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not 1 R2 exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits for linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.4-1 Rev. 5.0 1 4 St. Lucie - Unit 1 3 Revision XXX
Tq (Analog) 5 B 3.2.4 3 4 BASES BACKGROUND (continued)
LINEAR HEAT RATE ( ) AXIAL SHAPE INDEX ( 4 The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), Total 1
Integrated Radial Peaking Factor ( Fr ), Tq, and ASI represent limits within T
which the LHR algorithms are valid. These limits are obtained directly from the core reload analysis. )
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provides adequate monitoring of the core power distribution and is capable of verifying that the LCO limits are not exceeded. The Excore Detector Monitoring System performs this function by continuously monitoring ASI with OPERABLE quadrant symmetric excore neutron detectors and by verifying ASI is maintained within the limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following assumptions are made:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4 4
- c. FTxy does not exceed the limits of LCO 3.2.2.
FrT The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms that have been 1 established for the individual incore detector segments ensure that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for: described in Reference 3. 3
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.4-2 Rev. 5.0 1 4 St. Lucie - Unit 1 3 Revision XXX
Tq (Analog) 5 B 3.2.4 3 4 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) or AOOs (Condition 2) (Ref. 3, GDC 10). The 4 1 ANALYSES power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This process is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analysis (Ref. 1) with due regard for the correlations between measured quantities, the power distribution, and uncertainties in determining the power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum 1
linear heat generation rate (LHGR) so that the peak cladding temperature 5
does not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, and FrT limits specified in the COLR, and within the Tq limits. The 4 latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the range used in the accident analyses.
Combustion Engineering STS B 3.2.4-3 Rev. 5.0 1 4 St. Lucie - Unit 1 3 Revision XXX
Tq (Analog) 5 B 3.2.4 3 4 BASES APPLICABLE SAFETY ANALYSES (continued)
Fuel cladding damage does not normally occur while the reactor is operating at conditions outside these LCOs during otherwise normal 1 This potential for fuel cladding operation. Fuel cladding damage could result, however, if an accident or damage exists because AOO occurs from initial conditions outside the limits of these LCOs. 1 Changes in the power distribution cause increased power peaking and correspondingly increased local LHRs.
The Tq satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
certain LCO The power distribution LCO limits are based on correlations between power peaking and the measured variables used as inputs to the LHR 1 and DNB operating limits. The power distribution LCO limits, except Tq, are provided in the COLR. The limits on LHR ensure that in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1 with THERMAL POWER > 50% RTP, Tq must be maintained within the limits assumed in accident analysis to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because THERMAL POWER is not sufficient to require a limit on Tq.
ACTIONS A.1 and A.2 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> If the measured Tq is > [0.03] and < 0.10, the calculation of Tq may be nonconservative. Tq must be restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or FXY T and FrT must be determined to be within the limits of LCO 3.2.2 and LCO 3.2.3, and 4
determined to be within these limits every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, as long as Tq is out of limits. Two hours is sufficient time to allow the operator to reposition CEAs, and significant radial xenon redistribution cannot occur within this time. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time ensures changes in FXY T and 4 Fr can be identified before the limits of LCO 3.2.2 and LCO 3.2.3, T
respectively, are exceeded.
B.1 R2 If Required Actions and associated Completion Times of Condition A are R2 not met, THERMAL POWER must be reduced to 50% RTP. This requirement provides reasonable assurance that the core is operating R2 within its thermal limits and places the core in a conservative condition.
Four hours is a reasonable time to reach 50% RTP in an orderly manner and without challenging plant systems.
Combustion Engineering STS B 3.2.4-4 Rev. 5.0 1 4 St. Lucie - Unit 1 3 Revision XXX
Tq (Analog) 5 B 3.2.4 3 4 BASES ACTIONS (continued)
.1, C.2.2, C.3 4 C.1, C.2, and C.3 6 R2 its With Tq > 0.10, FXY T and FrT must be within their specified limits to ensure that acceptable flux peaking factors are maintained. Based on operating 4 experience, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is sufficient time for the operator to evaluate these factors. If FXY T and FrT are within limits, operation may proceed for a total is of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the Condition is entered while attempts are made to restore Tq to within its limit.
If Tq 0.10 cannot be achieved, power must be reduced to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If the tilt is generated due to a CEA misalignment, R2 operating at 50% RTP allows for the recovery of the CEA. Except as a result of CEA misalignment, Tq > 0.10 is not expected; if it occurs, continued operation of the reactor may be necessary to discover the cause of the tilt. If this procedure is followed, operation is restricted to only those conditions required to identify the cause of the tilt. It is necessary to account explicitly for power asymmetries because the radial power peaking factors used in core power distribution calculations are based on an untilted power distribution.
If Tq is not restored to within its limits, the reactor continues to operate R2 with an axial power distribution mismatch. Continued operation in this configuration may induce an axial xenon oscillation that causes increased LHRs when the xenon redistributes. If Tq cannot be restored to within its R2 limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, reactor power must be reduced. Reducing THERMAL POWER to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provides conservative protection from increased peaking due to potential xenon redistribution.
The Required Actions are modified by a Note that requires all subsequent R2 actions to be performed once power reduction commences after entering the Condition if Tq is not restored to < 0.10. This procedure ensures corrective action is taken before unrestricted power operation resumes.
Following THERMAL POWER reduction to 50% RTP, Tq must be restored to [0.03] before THERMAL POWER is increased (Required 2 4
Action C.3). This Required Action prevents the operator from increasing 6 THERMAL POWER above the conservative limit when the Condition, Tq outside its limits, has existed but allows the unit to continue operation for T
diagnostic purposes. The Completion Time of Required Action C.3 is and measured Tq verified 0.03 modified with a Note to indicate that the cause of the out of limit condition 6
O must be corrected prior to increasing THERMAL POWER. This Note also indicates that subsequent power operation above 50% RTP may proceed provided that the measured Tq is verified [0.03] at least once per hour 2 for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified at 95% RTP. This ensures that the power 7
distribution is responding as predicted. The Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a historical value that allows an acceptable exit from the LCO after the 1 Tq value is verified acceptable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until 95% RTP is reached.
THERMAL POWER is at or above 7 ACTIONS Combustion Engineering STS B 3.2.4-5 Rev. 5.0 1 4 St. Lucie - Unit 1 3 Revision XXX
Tq (Analog) 5 B 3.2.4 3 4 BASES SURVEILLANCE SR 3.2.4.1 4 REQUIREMENTS 3
[ Tq must be calculated at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency prevents significant xenon redistribution between Surveillances.
Tq must be determined at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals when the subchannel Tq is also verified OR deviation alarm is inoperable, and at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals when one routinely and the excore detector is inoperable and > 75% RTP. R2 periodic The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
2 R2
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. FSAR, Chapter [15]. 2 U
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B 1 R2
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.
5 Combustion Engineering STS B 3.2.4-6 Rev. 5.0 1 4 St. Lucie - Unit 1 3 Revision XXX
Tq (Analog) 5 B 3.2.4 4
3 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.4 AZIMUTHAL POWER TILT (Tq) (Analog) 4 3
BASES BACKGROUND The purpose of this LCO (AZIMUTHAL POWER TILT (Tq)) is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not 1 R2 exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits for linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.4-1 Rev. 5.0 1 4 St. Lucie - Unit 2 3 Revision XXX
Tq (Analog) 5 B 3.2.4 4
3 BASES BACKGROUND (continued)
LINEAR HEAT RATE ( ) AXIAL SHAPE INDEX ( 4 The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), Total 1
Integrated Radial Peaking Factor ( Fr ), Tq, and ASI represent limits within T
which the LHR algorithms are valid. These limits are obtained directly from the core reload analysis. )
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provides adequate monitoring of the core power distribution and is capable of verifying that the LCO limits are not exceeded. The Excore Detector Monitoring System performs this function by continuously monitoring ASI with OPERABLE quadrant symmetric excore neutron detectors and by verifying ASI is maintained within the limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following assumptions are made:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4 4
- c. FTxy does not exceed the limits of LCO 3.2.2.
FrT The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms that have been 1 established for the individual incore detector segments ensure that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for: 3 described in Reference 3.
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.4-2 Rev. 5.0 1 4 St. Lucie - Unit 2 3 Revision XXX
Tq (Analog) 5 B 3.2.4 4
3 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) or AOOs (Condition 2) (Ref. 3, GDC 10). The 4 1 ANALYSES power distribution and CEA insertion and alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This process is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analysis (Ref. 1) with due regard for the correlations between measured quantities, the power distribution, and uncertainties in determining the power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate (LHGR) so that the peak cladding temperature 1 5
does not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, and FrT limits specified in the COLR, and within the Tq limits. The 4 latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the range used in the accident analyses.
Combustion Engineering STS B 3.2.4-3 Rev. 5.0 1 4 St. Lucie - Unit 2 3 Revision XXX
Tq (Analog) 5 B 3.2.4 4
3 BASES APPLICABLE SAFETY ANALYSES (continued)
Fuel cladding damage does not normally occur while the reactor is operating at conditions outside these LCOs during otherwise normal 1 This potential for fuel cladding operation. Fuel cladding damage could result, however, if an accident or damage exists because AOO occurs from initial conditions outside the limits of these LCOs. 1 Changes in the power distribution cause increased power peaking and correspondingly increased local LHRs.
The Tq satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
certain LCO The power distribution LCO limits are based on correlations between power peaking and the measured variables used as inputs to the LHR 1 and DNB operating limits. The power distribution LCO limits, except Tq, are provided in the COLR. The limits on LHR ensure that in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1 with THERMAL POWER > 50% RTP, Tq must be maintained within the limits assumed in accident analysis to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because THERMAL POWER is not sufficient to require a limit on Tq.
ACTIONS A.1 and A.2 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> If the measured Tq is > [0.03] and < 0.10, the calculation of Tq may be nonconservative. Tq must be restored within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or FXY T and FrT must be determined to be within the limits of LCO 3.2.2 and LCO 3.2.3, and determined to be within these limits every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, as long as 4 Tq is out of limits. Two hours is sufficient time to allow the operator to reposition CEAs, and significant radial xenon redistribution cannot occur within this time. The 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Completion Time ensures changes in FXY T and 4 Fr can be identified before the limits of LCO 3.2.2 and LCO 3.2.3, T
respectively, are exceeded.
B.1 R2 If Required Actions and associated Completion Times of Condition A are R2 not met, THERMAL POWER must be reduced to 50% RTP. This requirement provides reasonable assurance that the core is operating R2 within its thermal limits and places the core in a conservative condition.
Four hours is a reasonable time to reach 50% RTP in an orderly manner and without challenging plant systems.
Combustion Engineering STS B 3.2.4-4 Rev. 5.0 1 4 St. Lucie - Unit 2 3 Revision XXX
Tq (Analog) 5 B 3.2.4 4
3 BASES ACTIONS (continued) 4
.1, C.2.2, C.3 C.1, C.2, and C.3 6 R2 its With Tq > 0.10, FXY T and FrT must be within their specified limits to ensure that acceptable flux peaking factors are maintained. Based on operating 4
experience, 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is sufficient time for the operator to evaluate these factors. If FXY T and FrT are within limits, operation may proceed for a total is of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the Condition is entered while attempts are made to restore Tq to within its limit.
If Tq 0.10 cannot be achieved, power must be reduced to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. If the tilt is generated due to a CEA misalignment, R2 operating at 50% RTP allows for the recovery of the CEA. Except as a result of CEA misalignment, Tq > 0.10 is not expected; if it occurs, continued operation of the reactor may be necessary to discover the cause of the tilt. If this procedure is followed, operation is restricted to only those conditions required to identify the cause of the tilt. It is necessary to account explicitly for power asymmetries because the radial power peaking factors used in core power distribution calculations are based on an untilted power distribution.
If Tq is not restored to within its limits, the reactor continues to operate R2 with an axial power distribution mismatch. Continued operation in this configuration may induce an axial xenon oscillation that causes increased LHRs when the xenon redistributes. If Tq cannot be restored to within its R2 limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, reactor power must be reduced. Reducing THERMAL POWER to 50% RTP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> provides conservative protection from increased peaking due to potential xenon redistribution.
The Required Actions are modified by a Note that requires all subsequent R2 actions to be performed once power reduction commences after entering the Condition if Tq is not restored to < 0.10. This procedure ensures corrective action is taken before unrestricted power operation resumes.
Following THERMAL POWER reduction to 50% RTP, Tq must be restored to [0.03] before THERMAL POWER is increased (Required 2 4 Action C.3). This Required Action prevents the operator from increasing 6 THERMAL POWER above the conservative limit when the Condition, Tq outside its limits, has existed but allows the unit to continue operation for diagnostic purposes. The Completion Time of Required Action C.3 is and measured T Tq verified modified with a Note to indicate that the cause of the out of limit condition must be corrected prior to increasing THERMAL POWER. This Note also 6 0.03 O
indicates that subsequent power operation above 50% RTP may proceed provided that the measured Tq is verified [0.03] at least once per hour 2 7
for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, or until verified at 95% RTP. This ensures that the power distribution is responding as predicted. The Completion Time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is a historical value that allows an acceptable exit from the LCO after the 1 Tq value is verified acceptable for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until 95% RTP is reached.
ACTIONS THERMAL POWER is at or above 7 Combustion Engineering STS B 3.2.4-5 Rev. 5.0 1 4 St. Lucie - Unit 2 3 Revision XXX
Tq (Analog) 5 B 3.2.4 4
3 BASES SURVEILLANCE SR 3.2.4.1 4 REQUIREMENTS 3
[ Tq must be calculated at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals. The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency prevents significant xenon redistribution between Surveillances. 2 Tq must be determined at 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> intervals when one excore Tq is also verified OR detector is inoperable and > 75% RTP.
R2 routinely and the periodic The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. 2 R2
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. FSAR, Chapter [15].
U 2
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B 1 R2
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.
5 Combustion Engineering STS B 3.2.4-6 Rev. 5.0 1 4 St. Lucie - Unit 2 3 Revision XXX
JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, BASES, AZIMUTHAL POWER TILT (Tq)
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3. The ISTS contains tolerances to be applied to the incore detector alarm setpoints.
PSL Unit 1 UFSAR, Section 13.8, Licensee-Controlled Technical Specification Requirements, and PSL Unit 2 UFSAR, Section 13.7, Licensee-Controlled Technical Specification Requirements, each contain these tolerances to be applied to the incore detector alarm setpoints. Additionally, these tolerances will be provided in the Technical Requirements Manual. Therefore, the tolerances to be applied to the incore detector alarm setpoints are deleted.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively.
- 5. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
- 6. Changes are made to be consistent with changes made to the Specification. R2 St. Lucie Unit 1 and Unit 2 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AZIMUTHAL POWER TILT ()
There are no specific No Significant Hazards Considerations for this Specification.
St. Lucie Unit 1 and 2 Page 1 of 1
ATTACHMENT 4 ITS 3.2.4, AXIAL SHAPE INDEX (ASI)
Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)
ITS ITS 3.2.4 A01 POWER DISTRIBUTION LIMITS DNB PARAMETERS AXIAL SHAPE INDEX (ASI)
LIMITING CONDITION FOR OPERATION 4
3.2.5 The following DNB related parameters shall be maintained within the limits: See ITS 3.4.1
- a. Cold Leg Temperature as shown on Table 3.2-1 of the COLR,
- b. Pressurizer Pressure* as shown on Table 3.2-1 of the COLR,
- c. Reactor Coolant System Total Flow Rate - greater than or equal to 375,000 gpm, and LCO 3.2.4 d. AXIAL SHAPE INDEX as shown on Figure 3.2-4 of the COLR.
The ASI shall be maintained within the limits specified in Applicability APPLICABILITY: MODE 1.
with THERMAL POWER 40% RTP L01 ACTION:
ASI not within limits ASI s Required Action A.1 With any of the above parameters exceeding its limit, restore the parameter to within its limit Required Action B.1within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or reduce THERMAL POWER to < 5% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. RTP
< 40 L01 SURVEILLANCE REQUIREMENTS SR 3.2.4.1 (ASI) Verify ASI is specified in the COLR 4.2.5.1 Each of the DNB related parameters shall be verified to be within their limits by See ITS 3.4.1 instrument readout in accordance with the Surveillance Frequency Control Program.
4.2.5.2 The Reactor Coolant System total flow rate shall be determined to be within its limit by measurement** in accordance with the Surveillance Frequency Control See Program. ITS 3.4.1
- Limit not applicable during either a THERMAL POWER ramp increase in excess of 5% per minute of RATED THERMAL POWER or a THERMAL POWER step increase of greater than 10% of RATED THERMAL POWER.
- Not required to be performed until THERMAL POWER is > 90% of RATED THERMAL POWER.
ST. LUCIE - UNIT 1 3/4 2-13 Amendment No. 27, 150, 213, 223
ITS ITS 3.2.4 A01 Relocated to the COLR ST. LUCIE - UNIT 1 3/4 2-14 Amendment No. 27, 48, 130, 145, 150, 163, 213
ITS ITS 3.2.4 A01 POWER DISTRIBUTION LIMITS DNB PARAMETERS AXIAL SHAPE INDEX (ASI)
LIMITING CONDITION FOR OPERATION 4
3.2.5 The following DNB-related parameters shall be maintained within the limits: See ITS 3.4.1
- a. Cold Leg Temperature as shown on Table 3.2-2 of the COLR,
- b. Pressurizer Pressure* as shown on Table 3.2-2 of the COLR,
- c. Reactor Coolant System Total Flow Rate - greater than or equal to 375,000 gpm, and LCO 3.2.4 d. AXIAL SHAPE INDEX as shown on Figure 3.2-4 of the COLR.
The ASI shall be maintained within the limits specified in Applicability APPLICABILITY: MODE 1.
with THERMAL POWER 40% RTP L01 ACTION:
ASI not within limits ASI s Required Action A.1 With any of the above parameters exceeding its limit, restore the parameter to within its limit within Required Action B.1 2 hours or reduce THERMAL POWER to < 5% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. RTP
< 40 L01 SR 3.2.4.1 (ASI) SURVEILLANCE REQUIREMENTS Verify ASI is specified in the COLR 4.2.5.1 Each of the DNB-related parameters shall be verified to be within their limits by See ITS 3.4.1 instrument readout in accordance with the Surveillance Frequency Control Program.
4.2.5.2 The Reactor Coolant System total flow rate shall be determined to be within its limit by measurement** in accordance with the Surveillance Frequency Control Program.
See ITS 3.4.1
- Limit not applicable during either a THERMAL POWER ramp increase in excess of 5% per minute of RATED THERMAL POWER or a THERMAL POWER step increase of greater than 10% of RATED THERMAL POWER.
- Not required to be performed until THERMAL POWER is > 90% of RATED THERMAL POWER.
ST. LUCIE - UNIT 2 3/4 2-14 Amendment No. 89, 145, 163, 173
ITS 3.2.4 A01 DELETED ST. LUCIE - UNIT 2 3/4 2-15 Amendment No. 8, 92, 131, 138, 145, 163
DISCUSSION OF CHANGES ITS 3.2.4, AXIAL SHAPE INDEX (ASI)
ADMINISTRATIVE CHANGES A01 In the conversion of the St. Lucie Plant (PSL) Unit 1 and Unit 2, 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-1432, Rev. 5.0, "Standard Technical Specifications-Combustion Engineering 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 None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 (Category 2 - Relaxation of Applicability) CTS 3.2.5 states that the Applicability is MODE 1 and when the LCO is not met, the actions require restoring the parameter within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or reducing THERMAL POWER to 5% of RATED THERMAL POWER (i.e, MODE 2) within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.4 states that the Applicability is MODE 1 with THERMAL POWER 40% RTP and the Required Actions are consistent with CTS except THERMAL is reduced to < 40%
RTP, which results placing the unit in a condition where ASI no longer applies.
This changes the CTS by relaxing the Applicability to MODE 1 with THERMAL POWER 40% RTP and corresponding change to only require THERMAL POWER to be reduced < 40% RTP consistent with the revised Applicability.
The purpose of CTS 3.2.5 Applicability and ITS 3.2.4 Applicability is to establish the plant conditions where ASI is assumed in the safety analysis. PSL Unit 1 and Unit 2 safety analysis apply ASI at 40% RTP. The ASI limits curve specified in the COLR also explicitly state that the limits do not apply below 40% RTP.
Therefore, below 40% RTP, the ASI power distribution limit is not applicable.
Other limits assumed in the accident analysis ensure fuel damage does not occur below 40% RTP (e.g., linear heat rate (LHR) limit, power dependent rod insertion limits, CEA alignment, sequence, and overlap limits, and reactor coolant conditions; pressure, temperature, flow). The power distribution limits are based St. Lucie Unit 1 and Unit 2 Page 1 of 2
DISCUSSION OF CHANGES ITS 3.2.4, AXIAL SHAPE INDEX (ASI) on correlations between power peaking and certain measured variables used as inputs to the LHR and DNB operating limits. The limitation on ASI, along with the limitations of LCO 3.3.1, "Reactor Protection System Instrumentation,"
represents a conservative envelope of operating conditions consistent with the assumptions that have been analytically demonstrated adequate for maintaining an acceptable minimum DNBR throughout all AOOs.
This change is acceptable because the LCO requirements applied in the ITS Applicability continues to ensure process variables, structures, systems, and components are maintained in the conditions assumed in the safety analyses and licensing basis. In MODE 1 with THERMAL POWER 40% RTP, ASI must be maintained within the power distribution limits assumed in the accident analyses to ensure that fuel damage does not result following an AOO. In MODE 1 with THERMAL POWER < 40% RTP, THERMAL POWER is not sufficient to require a limit on ASI power distribution.
This change is designated as less restrictive because the LCO requirements will not be applied under plant conditions in which they would be applied under the CTS.
St. Lucie Unit 1 and Unit 2 Page 2 of 2
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
ASI (Analog) 4 CTS 3.2.5 3
4 3.2 POWER DISTRIBUTION LIMITS (Analog) 4 3.2.5 AXIAL SHAPE INDEX (ASI) (Analog) 4 3 LCO 3.2.5 LCO 3.2.5 The ASI shall be maintained within the limits specified in the COLR.
4 Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP. 5 DOC L01 40 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action A. ASI not within limits. A.1 Restore ASI to within limits. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Action B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> DOC L01 associated Completion POWER to 20% RTP.
Time not met. 5
< 40 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3
4.2.5.1 SR 3.2.5.1 Verify ASI is within limits specified in the COLR. [ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 4
OR 2 In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.5-1 Rev. 5.0 1 3 St. Lucie - Unit 1 4 Amendment XXX
ASI (Analog) 4 CTS 3.2.5 3
4 3.2 POWER DISTRIBUTION LIMITS (Analog) 4 3.2.5 AXIAL SHAPE INDEX (ASI) (Analog) 3 4
LCO 3.2.5 LCO 3.2.5 The ASI shall be maintained within the limits specified in the COLR.
4 Applicability APPLICABILITY: MODE 1 with THERMAL POWER > 20% RTP. 5 DOC L01 40 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Action A. ASI not within limits. A.1 Restore ASI to within limits. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Action B. Required Action and B.1 Reduce THERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> DOC L01 associated Completion POWER to 20% RTP. 5 Time not met.
< 40 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 3
4.2.5.1 SR 3.2.5.1 Verify ASI is within limits specified in the COLR. [ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 4
OR 2 In accordance with the Surveillance Frequency Control Program ]
Combustion Engineering STS 3.2.5-1 Rev. 5.0 1 3 St. Lucie - Unit 2 4 Amendment XXX
JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, AXIAL SHAPE INDEX (ASI)
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively.
- 4. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
- 5. ISTS 3.2.5 (renumbered as ITS 3.2.4) Applicability and Required Action B.1 are changed to reflect relaxing the CTS Applicability. ITS 3.2.4 Applicability is MODE 1 with THERMAL POWER 40% RTP. This changes the CTS by relaxing the Applicability from MODE 1, to MODE 1 with THERMAL POWER 40% RTP. See DOC L01 for a discussion of changes for relaxing the CTS Applicability.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)
ASI (Analog) 5 B 3.2.5 4
4 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.5 AXIAL SHAPE INDEX (ASI) (Analog) 4 4
BASES BACKGROUND The purpose of this LCO (AXIAL SHAPE INDEX (ASI)) is to limit the core power distribution to the initial values assumed in the accident analysis.
Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not 1 exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.5-1 Rev. 5.0 1 4 St. Lucie - Unit 1 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES BACKGROUND (continued) AZIMUTHAL POWER TILT (
LINEAR HEAT RATE ( ) )
The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), Total 4 Integrated Radial Peaking Factor ( Fr ), Tq, and ASI represent limits within T
1 which the LHR algorithms are valid. These limits are obtained directly from the core reload analysis.
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System and the Incore Detector Monitoring System, provide adequate monitoring of the core power distribution and are is capable of verifying that the LHR does not exceed its limits. The Excore 1 Detector Monitoring System performs this function by continuously monitoring the ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following conditions are assumed:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4
- c. FTxy does not exceed the limits of LCO 3.2.2.
FrT The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms that have been 1 established for the individual incore detector segments ensure that the peak LHR is maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, as follows: described in Reference 3. 3
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.5-2 Rev. 5.0 1 4 St. Lucie - Unit 1 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) or AOOs (Condition 2) (Ref. 3, GDC 10). The 4 ANALYSES power distribution and CEA insertion and alignment LCOs prevent core 1
power distributions from reaching levels that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2 2 3
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This limitation is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1) with due regard for the correlations between among measured quantities, the power distribution, and uncertainties in 1 the determination of power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 5
assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, and FrT limits specified in the COLR, and within the Tq limits. The 4 latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.
Combustion Engineering STS B 3.2.5-3 Rev. 5.0 1 4 St. Lucie - Unit 1 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES APPLICABLE SAFETY ANALYSES (continued)
Fuel cladding damage does not normally occur while the reactor is operating at conditions outside these LCOs during normal operation.
Fuel cladding damage results, however, when an accident or AOO occurs from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and correspondingly increased local LHRs.
The ASI satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNB operating limits. These power distribution LCO limits, except Tq, are provided in the COLR. The limitation on LHR ensures that in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
ve The limitation on ASI, along with the limitations of LCO 3.3.1, "Reactor Protection System Instrumentation," represents a conservative envelope R2 of operating conditions consistent with the assumptions that have been analytically demonstrated adequate for maintaining an acceptable minimum DNBR throughout all AOOs. Of these, the loss of flow transient is the most limiting. Operation of the core with conditions within the specified limits ensures that an acceptable minimum margin from DNB conditions is maintained in the event of any AOO, including a loss of flow transient.
40 APPLICABILITY In MODE 1 with THERMAL POWER > 20% RTP, power distribution must be maintained within the limits assumed in the accident analyses to ensure that fuel damage does not result following an AOO. In other 6 MODES, this LCO does not apply because THERMAL POWER is not sufficient to require a limit on the core power distribution. Below 20% RTP the incore detector accuracy is not reliable.
ACTIONS A.1 Operating the core within ASI limits specified in the COLR and within the limits of LCO 3.3.1 ensures an acceptable margin for DNB and for maintaining local power density in the event of an AOO. Maintaining ASI within limits also ensures that the limits of 10 CFR 50.46 are not exceeded during accidents. The Required Actions to restore ASI must be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to limit the duration the plant is operated outside the initial conditions assumed in the accident analyses. In addition, this Completion Time is sufficiently short that the xenon distribution in the core cannot change significantly.
Combustion Engineering STS B 3.2.5-4 Rev. 5.0 1 4 St. Lucie - Unit 1 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES ACTIONS (continued)
B.1 If the ASI cannot be restored to within its specified limits, or ASI cannot be determined because of Excore Detector Monitoring System inoperability, core power must be reduced. Reducing THERMAL 6
< 40 POWER to 20% RTP provides reasonable assurance that the core is operating farther from thermal limits and places the core in a conservative condition. Four hours is a reasonable amount of time, based on operating experience, to reduce THERMAL POWER to 20% RTP in an orderly manner and without challenging plant systems. < 40 SURVEILLANCE SR 3.2.5.1 4 REQUIREMENTS 4 Verifying that the ASI is within the specified limits provides reasonable assurance that the core is not approaching DNB conditions. [ A Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is adequate for the operator to identify trends in conditions that result in an approach to the ASI limits, because the mechanisms that affect the ASI, such as xenon redistribution or CEA drive mechanism malfunctions, cause the ASI to change slowly and 2 should be discovered before the limits are exceeded.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. FSAR, Chapter [15].
2 U
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.46.
5 Combustion Engineering STS B 3.2.5-5 Rev. 5.0 1 4 St. Lucie - Unit 1 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 B 3.2 POWER DISTRIBUTION LIMITS (Analog) 5 B 3.2.5 AXIAL SHAPE INDEX (ASI) (Analog) 4 4
BASES BACKGROUND The purpose of this LCO (AXIAL SHAPE INDEX (ASI)) is to limit the core power distribution to the initial values assumed in the accident analysis.
Operation within the limits imposed by this LCO either limits or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) 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 ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings and this LCO are based on the accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not 1 exceeded as a result of anticipated operational occurrences (AOOs), and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameter rs, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.5-1 Rev. 5.0 1 4 St. Lucie - Unit 2 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES BACKGROUND (continued) AZIMUTHAL POWER TILT (
LINEAR HEAT RATE ( ) )
The limits on LHR, Total Planar Radial Peaking Factor ( FXY T
), Total 4 Integrated Radial Peaking Factor ( Fr ), Tq, and ASI represent limits within T
1 which the LHR algorithms are valid. These limits are obtained directly from the core reload analysis.
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System and the Incore Detector Monitoring System, provide adequate monitoring of the core power distribution and are is capable of verifying that the LHR does not exceed its limits. The Excore 1 Detector Monitoring System performs this function by continuously monitoring the ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following conditions are assumed:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied, 3
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and 4
- c. FTxy does not exceed the limits of LCO 3.2.2.
FrT The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms that have been 1 established for the individual incore detector segments ensure that the peak LHR is maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, as follows: 3 described in Reference 3.
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.5-2 Rev. 5.0 1 4 St. Lucie - Unit 2 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) or AOOs (Condition 2) (Ref. 3, GDC 10). The 4 ANALYSES power distribution and CEA insertion and alignment LCOs prevent core 1
power distributions from reaching levels that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F 1 (Ref. 4),
5
- b. During a loss of flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel 1
rod in the core does not experience a DNB condition (Ref. 3, GDC 10), 4
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), and 2
3 2
- 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 1
withdrawn (Ref. 3, GDC 26).
4 The power density at any point in the core must be limited to maintain the 1
5 fuel design criteria (Ref. 4). This limitation is accomplished by maintaining the power distribution and reactor coolant conditions so that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1) with due regard for the correlations between among measured quantities, the power distribution, and uncertainties in 1 the determination of power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 4). High peak cladding temperatures are 1 5
assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, and FrT limits specified in the COLR, and within the Tq limits. The 4 latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.
Combustion Engineering STS B 3.2.5-3 Rev. 5.0 1 4 St. Lucie - Unit 2 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES APPLICABLE SAFETY ANALYSES (continued)
Fuel cladding damage does not normally occur while the reactor is operating at conditions outside these LCOs during normal operation.
Fuel cladding damage results, however, when an accident or AOO occurs from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and correspondingly increased local LHRs.
The ASI satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNB operating limits. These power distribution LCO limits, except Tq, are provided in the COLR. The limitation on LHR ensures that in the event of a LOCA, the peak temperature of the fuel cladding does not exceed 2200°F.
The limitation on ASI, along with the limitations of LCO 3.3.1, "Reactor ve Protection System Instrumentation," represents a conservative envelope R2 of operating conditions consistent with the assumptions that have been analytically demonstrated adequate for maintaining an acceptable minimum DNBR throughout all AOOs. Of these, the loss of flow transient is the most limiting. Operation of the core with conditions within the specified limits ensures that an acceptable minimum margin from DNB conditions is maintained in the event of any AOO, including a loss of flow transient.
40 APPLICABILITY In MODE 1 with THERMAL POWER > 20% RTP, power distribution must be maintained within the limits assumed in the accident analyses to ensure that fuel damage does not result following an AOO. In other 6 MODES, this LCO does not apply because THERMAL POWER is not sufficient to require a limit on the core power distribution. Below 20% RTP the incore detector accuracy is not reliable.
ACTIONS A.1 Operating the core within ASI limits specified in the COLR and within the limits of LCO 3.3.1 ensures an acceptable margin for DNB and for maintaining local power density in the event of an AOO. Maintaining ASI within limits also ensures that the limits of 10 CFR 50.46 are not exceeded during accidents. The Required Actions to restore ASI must be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to limit the duration the plant is operated outside the initial conditions assumed in the accident analyses. In addition, this Completion Time is sufficiently short that the xenon distribution in the core cannot change significantly.
Combustion Engineering STS B 3.2.5-4 Rev. 5.0 1 4 St. Lucie - Unit 2 4 Revision XXX
ASI (Analog) 5 B 3.2.5 4
4 BASES ACTIONS (continued)
B.1 If the ASI cannot be restored to within its specified limits, or ASI cannot be determined because of Excore Detector Monitoring System inoperability, core power must be reduced. Reducing THERMAL
< 40 POWER to 20% RTP provides reasonable assurance that the core is 6 operating farther from thermal limits and places the core in a conservative condition. Four hours is a reasonable amount of time, based on operating experience, to reduce THERMAL POWER to 20% RTP in an orderly manner and without challenging plant systems. < 40 SURVEILLANCE SR 3.2.5.1 4 REQUIREMENTS 4 Verifying that the ASI is within the specified limits provides reasonable assurance that the core is not approaching DNB conditions. [ A Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is adequate for the operator to identify trends in conditions that result in an approach to the ASI limits, because the mechanisms that affect the ASI, such as xenon redistribution or CEA drive mechanism malfunctions, cause the ASI to change slowly and 2 should be discovered before the limits are exceeded.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 2 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
REFERENCES 1. FSAR, Chapter [15].
2 U
- 2. FSAR, Chapter [6]. NUREG 0800, Section 4.2, Appendix B
- 3. Technical Requirements Manual
4
- 4. 10 CFR 50.46.
5 Combustion Engineering STS B 3.2.5-5 Rev. 5.0 1 4 St. Lucie - Unit 2 4 Revision XXX
JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, BASES, AXIAL SHAPE INDEX (ASI)
- 1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to all Combustion Engineering vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
- 3. The ISTS contains tolerances to be applied to the incore detector alarm setpoints.
PSL Unit 1 UFSAR, Section 13.8, Licensee-Controlled Technical Specification Requirements, and PSL Unit 2 UFSAR, Section 13.7, Licensee-Controlled Technical Specification Requirements, each contain these tolerances to be applied to the incore detector alarm setpoints. Additionally, these tolerances will be provided in the Technical Requirements Manual. Therefore, the tolerances to be applied to the incore detector alarm setpoints are deleted.
Radial Peaking Factor (Fxy ), ISTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ),
ISTS 3.2.4, Azimuthal Power Tilt (Tq), and ISTS 3.2.5, Axial Shape Index (ASI). CTS do not include a Specification for ISTS 3.2.2, Total Planar Radial Peaking T
Factor (Fxy ). The CTS and ISTS are renumbered. CTS 3.2.3, Total Integrated Radial Peaking Factor (FrT ), CTS 3.2.4, Azimuthal Power Tilt (Tq), and CTS 3.2.5, Axial Shape Index (ASI), are renumbered as ITS 3.2.2, ITS 3.2.3, and ITS 3.2.4, respectively.
- 5. The type of plant (Analog) is deleted since it is unnecessary. This information is provided in NUREG-1432, Rev. 5.0, to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion but serves no purpose in a plant specific implementation.
- 6. ISTS 3.2.5 Bases (renumbered as ITS 3.2.4) Applicability discussion and Action B.1 discussion are changed to reflect relaxing the CTS Applicability. ITS 3.2.4 Applicability is MODE 1 with THERMAL POWER 40% RTP. This changes the CTS by relaxing the Applicability from MODE 1, to MODE 1 with THERMAL POWER 40% RTP. See DOC L01 for a discussion of changes for relaxing the CTS Applicability. Additionally, in the Applicability discussion, the statement below 20%
RTP the incore detector accuracy is not reliable is deleted because the state of the incore detector accuracy at 20% RTP it is not relevant to the condition that below 40% RTP the ASI LCO no longer applies. In the Action B.1 discussion, the statement or ASI cannot be determined because of Excore Detector Monitoring System inoperability is deleted because the operability of the Excore Detector Monitoring System is not relevant to the Action B.1 action that when ASI is not restored to within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, then THERMAL POWER must be reduced to below 40% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, AXIAL SHAPE INDEX (ASI)
There are no specific No Significant Hazards Considerations for this Specification.
St. Lucie Unit 1 and Unit 2 Page 1 of 1
ATTACHMENT 5 ISTS Not Adopted
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
T A01 Fxy (Analog) 3.2.2 3.2 POWER DISTRIBUTION LIMITS (Analog)
T 3.2.2 Total Planar Radial Peaking Factor ( Fxy ) (Analog)
T LCO 3.2.2 The calculated value of Fxy shall not exceed the limits specified in the COLR.
APPLICABILITY: MODE 1.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NOTE------------ A.1 Reduce THERMAL 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Required Actions shall POWER to bring the be completed if this combination of THERMAL T
Condition is entered. POWER and Fxy to within
the limits specified in the COLR.
T Fxy not within limits.
AND A.2 Withdraw the control 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> element assemblies (CEAs) to or beyond the long term steady state insertion limits of LCO 3.1.6, "Regulating CEAs," as specified in the COLR.
B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
Combustion Engineering STS 3.2.2-1 Rev. 5.0
T A01 Fxy (Analog) 3.2.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 -------------------------------NOTE------------------------------
SR 3.2.2.2 and SR 3.2.2.3 shall be completed each T
time SR 3.2.2.1 is required. Fxy shall be determined by using the incore detectors to obtain a power distribution map with all full length CEAs at or above the long term steady state insertion limit, as specified in the COLR.
T Verify the value of Fxy Once prior to operation above 70% RTP after each fuel loading AND
[ Each 31 days of accumulated operation in MODE 1 OR In accordance with the Surveillance Frequency Control Program ]
SR 3.2.2.2 Verify the value of Fxy. In accordance with the Frequency requirements of SR 3.2.2.1 Combustion Engineering STS 3.2.2-2 Rev. 5.0
T A01 Fxy (Analog) 3.2.2 SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.2.2.3 Verify the value of Tq. In accordance with the Frequency requirements of SR 3.2.2.1 Combustion Engineering STS 3.2.2-3 Rev. 5.0
JUSTIFICATION FOR DEVIATIONS ISTS 3.2.2, TOTAL PLANAR RADIAL PEAKING FACTOR ( ) (ANALOG)
T
- 1. ISTS 3.2.2, Total Planar Radial Peaking Factor (Fxy ) (Analog) Specification is not included in the St. Lucie Plant (PSL) Unit 1 and Unit 2 ITS because the PSL CTS do T
not include a Specification for Total Planar Radial Peaking Factor (Fxy ) (Analog).
St. Lucie Unit 1 and Unit 2 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)
A01 FTXY (Analog)
B 3.2.2 B 3.2 POWER DISTRIBUTION LIMITS (Analog)
B 3.2.2 Total Planar Radial Peaking Factor (FTXY) (Analog)
BASES BACKGROUND The purpose of this LCO (Total Planar Radial Peaking Factor ( FXY T
)) is to limit the core power distribution to the initial values assumed in the accident analyses. Operation within the limits imposed by this LCO decreases or prevents potential fuel cladding failures that could breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow accident, ejected control element assembly (CEA) accident, or other postulated accident requiring termination by a Reactor Protection System trip function. This LCO limits damage to the fuel cladding during an accident by ensuring that the plant is operating within acceptable bounding conditions at the onset of a transient.
Methods of controlling the power distribution include:
- a. Using CEAs to alter the axial power distribution,
- b. Decreasing CEA insertion by boration, thereby improving the radial power distribution, and
- c. Correcting off optimum conditions (e.g., a CEA drop or misoperation of the unit) that cause margin degradations.
The core power distribution is controlled so that, in conjunction with other core operating parameters (e.g., CEA insertion and alignment limits), the power distribution does not result in violation of this LCO. The limiting safety system settings (LSSS) and this LCO are based on accident analyses (Refs. 1 and 2), so that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences (AOOs) and the limits of acceptable consequences are not exceeded for other postulated accidents.
Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in controlling the axial power distribution.
Power distribution is a product of multiple parameters, various combinations of which may produce acceptable power distributions.
Operation within the design limits of power distribution is accomplished by generating operating limits on the linear heat rate (LHR) and departure from nucleate boiling (DNB).
Combustion Engineering STS B 3.2.2-1 Rev. 5.0
A01 FTXY (Analog)
B 3.2.2 BASES BACKGROUND (continued)
The limits on LHR, FXY T
, Total Integrated Radial Peaking Factor ( FrT ), Tq, and ASI represent limits within which the LHR algorithms are valid.
These limits are obtained directly from the core reload analysis.
Either of the two core power distribution monitoring systems, the Excore Detector Monitoring System or the Incore Detector Monitoring System, provides adequate monitoring of the core power distribution and is capable of verifying that the LHR does not exceed its limits. The Excore Detector Monitoring System performs this function by continuously monitoring the ASI with the OPERABLE quadrant symmetric excore neutron flux detectors and verifying that the ASI is maintained within the allowable limits specified in the COLR.
In conjunction with the use of the Excore Detector Monitoring System and in establishing the ASI limits, the following assumptions are made:
- a. The CEA insertion limits of LCO 3.1.5, "Shutdown CEA Insertion Limits," and LCO 3.1.6, "Regulating CEA Insertion Limits," are satisfied,
- b. The Tq restrictions of LCO 3.2.4 are satisfied, and
- c. FTXY does not exceed the limits of this LCO.
The Incore Detector Monitoring System continuously provides a more direct measure of the peaking factors, and the alarms that have been established for the individual incore detector segments ensure that the peak LHRs are maintained within the limits specified in the COLR. The setpoints for these alarms include tolerances, set in conservative directions, for:
- a. A measurement calculational uncertainty factor of 1.062,
- b. An engineering uncertainty factor of 1.03,
- c. An allowance of 1.002 for axial fuel densification and thermal expansion, and
- d. A THERMAL POWER measurement uncertainty factor of 1.02.
Combustion Engineering STS B 3.2.2-2 Rev. 5.0
A01 FTXY (Analog)
B 3.2.2 BASES APPLICABLE The fuel cladding must not sustain damage as a result of normal SAFETY operation (Condition 1) or AOOs (Condition 2) (Ref. 3, GDC 10). The ANALYSES Power Distribution and CEA Insertion and Alignment LCOs preclude core power distributions that violate the following fuel design criteria:
- a. During a LOCA, peak cladding temperature must not exceed 2200°F (Ref. 4),
- b. During a loss of 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 condition (Ref. 3, GDC 10),
- c. During an ejected CEA accident, the fission energy input to the fuel must not exceed 280 cal/gm (Ref. [ ]), 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. 3, GDC 26).
The power density at any point in the core must be limited to maintain the fuel design criteria (Ref. 4). This limiting is accomplished by maintaining the power distribution and reactor coolant conditions such that the peak LHR and DNB parameters are within operating limits supported by the accident analyses (Ref. 1) with due regard for the correlations between measured quantities, the power distribution, and the uncertainties in the determination of power distribution.
Fuel cladding failure during a LOCA is limited by restricting the maximum linear heat generation rate so that the peak cladding temperature does not exceed 2200°F (Ref. 4). High peak cladding temperatures are assumed to cause severe cladding failure by oxidation due to a Zircaloy water reaction.
The LCOs governing LHR, ASI, and the Reactor Coolant System ensure that these criteria are met as long as the core is operated within the ASI, FXY T
, FrT , and Tq limits specified in the COLR. The latter are process variables that characterize the three dimensional power distribution of the reactor core. Operation within the limits for these variables ensures that their actual values are within the ranges used in the accident analyses.
Combustion Engineering STS B 3.2.2-3 Rev. 5.0
A01 FTXY (Analog)
B 3.2.2 BASES APPLICABLE SAFETY ANALYSES (continued)
Fuel cladding damage does not normally occur while at conditions outside the limits of these LCOs during normal operation. Fuel cladding damage could result, however, should an accident or AOO occur from initial conditions outside the limits of these LCOs. This potential for fuel cladding damage exists because changes in the power distribution can cause increased power peaking and correspondingly increased local LHR.
FTXY satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The power distribution LCO limits are based on correlations between power peaking and certain measured variables used as inputs to the LHR and DNB ratio operating limits. The power distribution LCO limits, except Tq, are provided in the COLR. The limitation on LHR ensures that in the event of a LOCA the peak temperature of the fuel cladding does not exceed 2200°F.
APPLICABILITY In MODE 1, power distribution must be maintained within the limits assumed in the accident analyses to ensure that fuel damage does not result following an AOO. In other MODES, this LCO does not apply because there is not sufficient THERMAL POWER to require a limit on the core power distribution.
ACTIONS A.1 and A.2 A Note modifies Condition A to require Required Actions A.1 and A.2 to be completed if the Condition is entered. This ensures that corrective action is taken prior to unrestricted operation.
The limitations on FTXY provided in the COLR ensure that the assumptions used in the analysis for establishing the LHR, LCO, and LSSS remain valid during operation at the various allowable CEA group insertion limits.
If FXY T
exceeds its basic limitation, operation may continue under the additional restrictions imposed by these Required Actions (reducing THERMAL POWER and withdrawing CEAs to or beyond the long term steady state insertion limits of LCO 3.1.6), because these additional restrictions adequately ensure that the assumptions used in establishing the LHR, LCO, and LSSS remain valid (Ref. 3). Six hours to return FTXY to within its limit is reasonable and ensures that all CEAs meet the long term steady state insertion limits of LCO 3.1.6.
Combustion Engineering STS B 3.2.2-4 Rev. 5.0
A01 FTXY (Analog)
B 3.2.2 BASES ACTIONS (continued)
B.1 If FrT cannot be returned to within its limit, THERMAL POWER must be reduced. A change to MODE 2 provides reasonable assurance that the core is operating within its thermal limits and places the core in a conservative condition. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience, to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The periodic Surveillance to determine the calculated FTXY ensures that FXY T
remains within the range assumed in the analysis throughout the fuel cycle. Determining the measured FXY T after each fuel loading prior to the reactor exceeding 70% RTP ensures that the core is properly loaded.
[ Performance of the Surveillance every 31 days of accumulated operation in MODE 1 provides reasonable assurance that unacceptable changes in the FTXY are promptly detected.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REVIEWERS NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
]
The power distribution map can only be obtained after THERMAL POWER exceeds 20% RTP because the incore detectors are not reliable below 20% RTP.
The SR is modified by a Note that requires that SR 3.2.2.2 and SR 3.2.2.3 be completed each time SR 3.2.1.1 is completed. (Values computed by these SRs are required to perform SR 3.2.2.1.) The Note also requires that the incore detectors be used to determine FXY T by using them to obtain a power distribution map with all full length CEAs above the long term steady state insertion limits, as specified in the COLR.
Combustion Engineering STS B 3.2.2-5 Rev. 5.0
A01 FTXY (Analog)
B 3.2.2 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.2.2.2 and SR 3.2.2.3 Measuring the value of FXY and Tq each time a calculated value of FXY T is required ensures that the calculated value of FXY accurately reflects the T
condition of the core.
The Frequency for these Surveillances is in accordance with the Frequency requirements of SR 3.2.2.1, because these SRs provide information to complete SR 3.2.2.1.
REFERENCES 1. FSAR, Chapter [15].
- 2. FSAR, Chapter [6].
- 4. 10 CFR 50.46.
Combustion Engineering STS B 3.2.2-6 Rev. 5.0
JUSTIFICATION FOR DEVIATIONS ISTS 3.2.2, BASES, TOTAL PLANAR RADIAL PEAKING FACTOR ( ) (ANALOG)
T
- 1. ISTS 3.2.2, Total Planar Radial Peaking Factor (Fxy ) (Analog) Specification is not included in the St. Lucie Plant (PSL) Unit 1 and Unit 2 ITS because the PSL CTS do T
not include a Specification for Total Planar Radial Peaking Factor (Fxy ) (Analog).
St. Lucie Unit 1 and Unit 2 Page 1 of 1