ML24213A335

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License Amendment Request to Revise Technical Specification 3.2.1, Heat Flux Hot Channel Factor (Fq(Z)) (Fq Methodology), to Implement the Methodology from WCAP-17661-P-A, Revision 1.
ML24213A335
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 07/31/2024
From: Boyce M
Wolf Creek
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
000269
Download: ML24213A335 (1)


Text

P.O. Box 411 l Burlington, KS 66839 l 620-364-8831

Michael T. Boyce Vice President Engineering July 31, 2024 000269 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

Subject:

Docket No. 50-482: License Amendment Request to Revise Technical Specification 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology), to Implement the Methodology from WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications Commissioners and Staff:

In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Wolf Creek Nuclear Operating Corporation (WCNOC) requests an amendment to Renewed Facility Operating License No. NPF-42 to revise the Technical Specifications (TS) for the Wolf Creek Generating Station (WCGS), Unit 1. The proposed amendment modifies the WCGS TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology), to implement the methodology in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications. Additionally, the proposed amendment modifies TS 5.6.5, CORE OPERATING LIMITS REPORT (COLR), to include WCAP-17661, Revision 1, in the list of the Nuclear Regulatory Commission (NRC) approved methodologies used to develop the COLR.

Westinghouse Nuclear Safety Advisory Letter (NSAL) 09-5, Relaxed Axial Offset Control FQ Technical Specification Actions, and NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance, recommended that conservative interim actions be administratively implemented in accordance with NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety. Administrative controls were implemented at WCGS to address the issues identified in NSAL-09-5 and NSAL-15-1. Therefore, in accordance with the guidance in NRC Administrative Letter 98-10, the proposed amendment addresses the non-conservatisms identified by the NSALs.

Attachment I provides the evaluation of the proposed change. Attachment II provides the existing TS pages marked up to show the proposed change. Attachment III provides revised (clean) TS pages. Attachment IV provides the proposed TS Bases changes for information only.

000269 Page 2 of 3

The changes in this LAR are not required to address an immediate safety concern. WCNOC requests approval of this proposed amendment within 12 months from the date of this submittal.

Once approved, the amendment will be implemented prior to MODE 4 entry from Refueling Outage 27 (Fall 2025).

It has been determined that this amendment application does not involve a significant hazard consideration per 10 CFR 50.92, Issuance of amendment. Pursuant to 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, Section (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The amendment application was reviewed by the Plant Safety Review Committee. In accordance with 10 CFR 50.91, Notice for public comment; State consultation, Section (b)(1), a copy of this amendment application, with Attachments, is being provided to the designated Kansas State official.

There are no regulatory commitments contained in this submittal. If you have any questions concerning this matter, please contact me at (620) 364-8831 x8687, or Dustin Hamman at (620) 364-4204.

Sincerely, Michael T. Boyce MTB/

Attachments: I Evaluation of the Proposed Change II Proposed Technical Specification Changes (Mark-up)

III Revised Technical Specification Pages IV Proposed TS Bases Changes (for information only) cc:

S. S. Lee (NRC), w/a J. Meinholdt (KDHE), w/a J. D. Monninger (NRC), w/a G. E. Werner (NRC), w/a Senior Resident Inspector (NRC), w/a Licensing Correspondence - ET 24-000269, w/a

Attachment I to 000269 Page 1 of 18 EVALUATION OF THE PROPOSED CHANGE

Subject:

License Amendment Request to Revise Technical Specification 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology), to Implement the Methodology from WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

2.1 Background

2.2 System Design and Operation 2.3 Current Technical Specification Requirements 2.4 Reason for the Proposed Changes 2.5 Description of the Proposed Changes

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

Attachment I to 000269 Page 2 of 18 1.0

SUMMARY

DESCRIPTION Wolf Creek Nuclear Operating Corporation (WCNOC) requests an amendment to Renewed Facility Operating License No. NPF-42 to revise the Technical Specifications (TS) for the Wolf Creek Generating Station (WCGS), Unit 1. The proposed amendment modifies the WCGS TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology), to implement the methodology in WCAP-17661-P-A, Revision 1 (Reference 6.1), Improved RAOC and CAOC FQ Surveillance Technical Specifications. Additionally, the proposed amendment modifies TS 5.6.5, CORE OPERATING LIMITS REPORT (COLR), to include WCAP-17661-P-A, Revision 1, in the list of the Nuclear Regulatory Commission (NRC) approved methodologies used to develop the COLR.

2.0 DETAILED DESCRIPTION

2.1 Background

Westinghouse Electric Company LLC (Westinghouse) Nuclear Safety Advisory Letter (NSAL) 09-05, Revision 0, Relaxed Axial Offset Control FQ Technical Specification Actions, (Reference 6.2) notified Westinghouse customers of an issue associated with the Required Actions for Condition B of NUREG-1431 (Reference 6.3) TS 3.2.1B, Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology), for plants that have implemented the relaxed axial offset control (RAOC) methodology. In certain situations where transient FQ, FQW(Z), is not within its limit, the existing Required Actions may be insufficient to restore FQW(Z) to within the limit. NSAL-09-5, Revision 1 (Reference 6.4), provided clarification regarding the applicability of the recommended interim actions to address this issue. On August 7, 2009, administrative controls were established in association with Condition B of TS 3.2.1 to address NSAL-09-5.

Westinghouse NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance, (Reference 6.5), notified Westinghouse customers of an issue associated with TS Surveillance Requirement (SR) 3.2.1.2. Specifically, one aspect of the SR may not be sufficient to assure that the peaking factor assumed in the licensing basis analysis remains valid under all conditions between the instances of performance of SR 3.2.1.2. On May 14, 2015, administrative controls were implemented to address NSAL-15-1.

WCNOC participated in an industry Pressurized Water Reactor Owners Group (PWROG) project to correct the TSs. The PWROG submitted (Reference 6.6) the approved proprietary and non-proprietary version of WCAP-17661, Revision 1, to the Nuclear Regulatory Commission (NRC) with TS corrections and associated TS Bases. The NRC issued a verification letter of approval (Reference 6.7) for WCAP-17661-P-A, Revision 1, specifying acceptability for referencing in licensing applications with limitations.

2.2 System Design and Operation Heat Flux Hot Channel Factor (FQ(Z))

FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions. Therefore, FQ(Z) is a measure of the peak fuel pellet power within the reactor core.

Attachment I to 000269 Page 3 of 18 The purpose of the limits on the values of FQ(Z) is to limit the local (i.e., pellet) peak power density.

The value of FQ(Z) varies along the axial height (Z) of the core.

During power operation, the global power distribution is limited by limiting condition for operation (LCO) 3.2.3, AXIAL FLUX DIFFERENCE (AFD), and LCO 3.2.4, QUADRANT POWER TILT RATIO (QPTR), which are directly and continuously measured process variables. These LCOs, along with LCO 3.1.4, Rod Group Alignment Limits, LCO 3.1.5, Shutdown Bank Insertion Limits, and LCO 3.1.6, Control Bank Insertion Limits, maintain the core limits on power distributions on a continuous basis. FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution.

FQ(Z) is not directly measurable but is inferred from a power distribution measurement obtained with either the movable incore detector system or the Power Distribution Monitoring System (PDMS). The results of the three-dimensional power distribution measurement are analyzed to derive a measured value for FQ(Z). These measurements are generally taken with the core at or near equilibrium conditions. However, because this value represents an equilibrium condition, it does not include the variations in the value of FQ(Z) that are present during nonequilibrium situations, such as load following. To account for these possible variations, the steady state value of FQ(Z) is adjusted by an elevation dependent factor that accounts for the calculated worst case transient conditions.

The proposed changes to TS 3.2.1 involve a reformulation of these elevation dependent factors, designated as [T(Z)]COLR. The proposed TS 3.2.1 incorporates various RAOC operating spaces that define the corresponding elevation dependent factors, [T(Z)]COLR. Each RAOC operating space is composed of corresponding COLR limits associated with TS 3.2.3, AXIAL FLUX DIFFERENCE (AFD), and TS 3.1.6, Control Bank Insertion Limits, assumed in the calculation of each particular [T(Z)]COLR function.

AFD The purpose of TS 3.2.3 is to establish limits on the values of the AFD in order to limit the amount of axial power distribution skewing to either the top or bottom of the core. By limiting the amount of power distribution skewing, core peaking factors are consistent with the assumptions used in the safety analyses. Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in axial power distribution control.

The AFD is a measure of the axial power distribution skewing to either the top or bottom half of the core. The AFD is sensitive to many core related parameters such as control bank positions, core power level, axial burnup, axial xenon distribution, and, to a lesser extent, reactor coolant temperature and boron concentration.

The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements. The limits on the AFD ensure that the FQ(Z) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition II, III, or IV events.

RAOC as described in WCAP-10216-P-A, Revision 1A, Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification, (Reference 6.8), is a calculational procedure

Attachment I to 000269 Page 4 of 18 that defines the allowed operational space of the AFD versus THERMAL POWER. The AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of the AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidates the conclusions of the accident and transient analyses with regard to fuel cladding integrity.

The RAOC methodology establishes a xenon distribution library with tentatively wide AFD limits.

Axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requirements.

Control Bank Insertion Limits The insertion limits of the shutdown and control rods are initial assumptions in all safety analyses that assume rod insertion upon reactor trip. The insertion limits directly affect core power, fuel burnup distributions, assumptions of available shutdown margin (SDM), and initial reactivity insertion rate. Limits on rod insertion have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.

The rod cluster control assemblies (RCCAs) are divided among four control banks and five shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that are electrically paralleled to step simultaneously. Groups within a bank are moved in a staggered fashion, but always within one step of each other. Three shutdown banks (C, D, and E) consist of a single group.

The control bank insertion limits are specified in Section 2.4 of the COLR. The COLR also indicates how the control banks are moved in an overlap pattern. Overlap is the distance traveled together by two control banks. The control banks are used for precise reactivity control of the reactor. The positions of the control banks can be controlled manually, or automatically by the Rod Control System. They are capable of adding reactivity very quickly (compared to borating or diluting). The control banks must be maintained above design insertion limits and are typically near the fully withdrawn position during normal full power operation.

The power density at any point in the core must be limited, so that the fuel design criteria are maintained. Together, LCO 3.1.4, Rod Group Alignment Limits, LCO 3.1.5, Shutdown Bank Insertion Limits, LCO 3.1.6, Control Bank Insertion Limits, LCO 3.2.3, AXIAL FLUX DIFFERENCE (AFD), and LCO 3.2.4, QUADRANT POWER TILT RATIO (QPTR), provide limits on control component operation and on monitored process variables, which ensure that the core operates within the fuel design criteria. The shutdown and control bank insertion and alignment limits, AFD, and QPTR are process variables that together characterize and control the three dimensional power distribution of the reactor core.

2.3 Current Technical Specification Requirements LCO 3.2.1 specifies that FQ(Z), as approximated by FQC(Z) and FQW(Z), shall be within the limits specified in the COLR when the plant is in MODE 1.

Attachment I to 000269 Page 5 of 18 TS 3.2.1 Condition A specifies that when FQC(Z) is not within limit, the Required Actions and associated Completion Times are (in order):

Reduce THERMAL POWER by a certain amount within 15 minutes after each FQC(Z) determination, and Reduce both the Power Range Neutron Flux - High and the Overpower T trip setpoints by a certain amount within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQC(Z) determination, and Perform SR 3.2.1.1 prior to increasing THERMAL POWER above the limit in Required Action A.1.

TS 3.2.1 Condition B specifies that when FQW(Z) is not within limit, the Required Action/Completion Time is to reduce AFD limits by a certain amount within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

TS 3.2.1 Condition C specifies that when the Required Action and associated Completion Time is not met, place the plant in at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SR 3.2.1.1 and SR 3.2.1.2 verify that FQC(Z) and FQW(Z), respectively, are within limit:

Once after each refueling prior to THERMAL POWER exceeding 75% RTP, and Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions after exceeding by 10%

RTP, the THERMAL POWER at which FQC(Z) and FQW(Z) were last verified, and In accordance with the Surveillance Frequency Control Program.

The Surveillances are preceded by a Note stating that during power escalation at the beginning of each cycle, thermal power may be increased until an equilibrium power level has been achieved, at which a power distribution measurement is obtained. SR 3.2.1.2 has another Note directing additional action if the maximum over Z of FQC(Z) divided by K(Z), where K(Z) is the normalized FQ(Z) as a function of core height and provided in the COLR, has increased since the previous FQC(Z) evaluation.

2.4 Reason for the Proposed Changes As described above in Section 2.1, the NRC staff has approved WCAP-17661-P-A/NP-A, Revision 1 for use with limitations to address the issues associated with TS 3.2.1 described in Westinghouse NSAL-09-5 and NSAL-15-1. WCNOC is proposing to change WCGS TS 3.2.1 to be consistent with the revised TS 3.2.1B provided in Appendix A of WCAP-17661-P-A, Revision

1. The WCGS TS Bases for TS 3.2.1 will be revised to address the proposed changes to TS 3.2.1 consistent with the TS Bases markups provided in Appendix B of WCAP-17661-P-A, Revision 1. Implementing the changes to TS 3.2.1 consistent with the NRC staff-approved WCAP will provide a series of more restrictive core operating spaces if the LCO is not met and a more clearly defined set of Surveillance Requirements and Required Actions.

Attachment I to 000269 Page 6 of 18 2.5 Description of the Proposed Changes The proposed changes to TS 3.2.1 correct the issues described in Section 2.1. The changes proposed below are consistent with the TS 3.2.1 changes reviewed and approved by the NRC staff in Appendix A of WCAP-17661-P-A, Revision 1.

An administrative change to the corresponding list of approved analytical methods for determining the core operating limits in TS 5.6.5b. is also made to add WCAP-17661-P-A.

The specific proposed changes to TS 3.2.1 and 5.6.5b. are as follows:

TS 3.2.1 Title and Header

1.

Administrative changes to the title and header would reflect the different methodology. The title of TS 3.2.1 would be changed from:

Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)

To:

Heat Flux Hot Channel Factor (FQ(Z)) (RAOC - T(Z) Methodology)

Similarly, the header for TS 3.2.1 would change from:

FQ(Z) (FQ Methodology)

To:

FQ(Z) (RAOC - T(Z) Methodology)

TS 3.2.1 Condition A

2.

A new Note is added to Condition A:

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1. SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling.

3.

Required Action A.2 would be changed from:

Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% FQC(Z) exceeds limit.

To:

Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

Attachment I to 000269 Page 7 of 18

4.

Similarly, Required Action A.3 would be changed from:

Reduce Overpower T trip setpoints 1% for each 1% FQC(Z) exceeds limit.

To:

Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

5.

Required Action A.4 would be change from:

Perform SR 3.2.1.1.

To:

Perform SR 3.2.1.1 and SR 3.2.1.2.

These changes are evaluated in Section 4.2 of the NRC Final Safety Evaluation included in Reference 6.1.

TS 3.2.1 Condition B

6.

Existing Required Action B.1 would be deleted and new Required Actions B.1.1, B.1.2, B.2.2, B.2.3, and B.2.4 would be added as follows:

REQUIRED ACTION COMPLETION TIME B.1.1 Implement a RAOC operating space specified in the COLR that restores FQW(Z) to within its limits.

AND B.1.2 Perform SR 3.2.1.1 and SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

OR B.2.1


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

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

Limit THERMAL POWER to less than RTP and reduce AFD limits as specified in the COLR.

AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after each FQW(Z) determination

Attachment I to 000269 Page 8 of 18 REQUIRED ACTION COMPLETION TIME B.2.2 Reduce Power Range Neutron Flux - High trip setpoints 1%

for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND B.2.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQW(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQW(Z) determination Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 These changes are evaluated in Section 4.3 of the NRC Final Safety Evaluation included in Reference 6.1.

Deviation from Appendix A WCAP-17661-P-A TS Markups The Completion Times for Required Actions B.2.1, B.2.2, and B.2.3 contain a deviation from those contained in Appendix A of WCAP-17661-P-A. The Completion Time for these Required Actions include the phrase after each FQW(Z) determination. This additional phrase has been included to these Completion Times since the THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of FQW(Z) that are not within limit when Required Action B.2.4 is performed and could require additional power reductions within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the subsequent FQW(Z) determination, if necessary, to comply with the decreased THERMAL POWER limit. The addition of the phrase after each FQW(Z) determination to the Completion Times for Required Action B.2.1, B.2.2, and B.2.3 ensures they apply after each subsequent determination FQW(Z) during performance of Required Action B.2.4, similar to the phrase after each FQC(Z) determination that is contained in the Completion Times for Required Actions A.1, A.2, and A.3 associated with FQC(Z). The TS Bases for Required Actions B.2.1, B.2.2, and B.2.3 have been updated to include the reason for the inclusion of the phrase after each FQW(Z) determination.

Attachment I to 000269 Page 9 of 18 TS 3.2.1 Surveillance Requirements

7.

The following Note to the Surveillance Requirements would be deleted in its entirety:


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

During power escalation following shutdown, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution measurement is obtained.

This change is evaluated in Section 4.4 of the NRC Final Safety Evaluation included in Reference 6.1.

8.

The following Note to SR 3.2.1.2 would be deleted in its entirety:


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

If FQC(Z) measurements indicate maximum over z

K(Z)

(Z)

F C

Q has increased since the previous evaluation of FQC(Z):

a.

Increase FQW(Z) by the appropriate factor specified in the COLR and reverify FQW(Z) is within limits; or

b.

Repeat SR 3.2.1.2 once per 7 EFPD until two successive power distribution measurements indicate maximum over z

K(Z)

(Z)

F C

Q has not increased.

This change is evaluated in Section 4.4 and Section 4.6 of the NRC Final Safety Evaluation included in Reference 6.1.

9.

The first SR 3.2.1.2 Frequency would be changed from:

Once after each refueling prior to THERMAL POWER exceeding 75% RTP To:

Once after each refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER exceeds 75% RTP

Attachment I to 000269 Page 10 of 18 This change is evaluated in Section 4.7 of the NRC Final Safety Evaluation included in Reference 6.1.

TS 5.6.5b.

10. An administrative change would add the NRC staff-approved core operating limits analytical method as follows:

WCAP-17661-P-A, Improved RAOC and COAC FQ Surveillance Technical Specification

3.0 TECHNICAL EVALUATION

The proposed changes to TS 3.2.1 address the issues described in Section 2.1 by reformulating the transient FQ surveillance and defining new Required Actions that ensure adequate margin recovery. As part of this reformulation, the FQ surveillance W(Z) factors are redefined to mitigate the sensitivity to differences between the measured and predicted steady-state power shapes.

The new factors, called T(Z) factors, primarily characterize the maximum transient P(Z), that is, the maximum expected values of the normalized core average axial power shape resulting from nonequilibrium operation. With the proposed changes, the radial FXY(Z) peaking factors would be measured and multiplied by the T(Z) factors to obtain the measured FQW(Z), which is the transient FQ(Z). The measured steady-state axial power shape would not be used in the surveillance, nor would the predicted surveillance axial power shape. This proposed change will also improve the accuracy of part-power surveillances since the surveillance axial power shape is not used to determine the measured transient FQ(Z). Use of the surveillance axial power shape in the part-power transient FQ(Z) measurement is a major source of the over-measurement that can lead to anomalous reductions in transient FQ margin for part-power surveillances.

To address the non-conservatism in the current Required Action B.1, the proposed changes would permit multiple RAOC operating spaces to be defined in the COLR. The COLR will include T(Z) functions for each RAOC operating space, which is defined as a unique combination of AFD limits and bank insertion limits. If there is a measured transient FQ violation, then a more restrictive RAOC operating space can be selected from the COLR that provides the required margin for future non-equilibrium operation. This retains the feature of using an AFD reduction to gain margin but in a manner that ensures that appropriate margin is recovered. If none of the RAOC operating spaces included in the COLR provides the required margin, then limits on thermal power and AFD must be implemented. These limits are specified in the COLR. The analysis methods used to determine the T(Z) values and the limits on thermal power and AFD are described in WCAP-17661-P-A, Revision 1.

The existing SR 3.2.1.1 and SR 3.2.1.2 are modified by a Note that could create confusion:

During power escalation following shutdown, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution measurement is obtained.

The proposed Amendment would delete the Note in its entirety. The proposed Surveillance Frequency of FQC(Z) and FQW(Z) are unambiguous. It is sufficient to confirm FQC(Z) once prior to exceeding 75% RTP following a refueling. It is sufficient to confirm FQW(Z) once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

Attachment I to 000269 Page 11 of 18 exceeding 75% RTP following a refueling. When the criterion for a higher power level achieved, another verification of FQC(Z) and FQW(Z) is required. Thus, the Surveillances will continue to be confirmed at high power levels where margin will be at its minimum.

The intent of SR 3.2.1.2 is to confirm that the FQ limit will be met during future nonequilibrium operation within the allowed operating space between the time of the current Surveillance and the next required Surveillance. There are two areas for improvement in SR 3.2.1.2. The first area for improvement concerns the Surveillance Frequency.

The first Frequency for SR 3.2.1.2 would be changed to state that FQW(Z) must be verified to be within its limit following each refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after thermal power exceeds 75% RTP.

This change is justified since core power distribution measurements taken at low powers (less than 50% RTP to confirm that the core is loaded properly) will provide ample indication that the core is operating consistent with expectations. The proposed Frequency will ensure that verification of FQW(Z) is performed within a reasonable time period and prior to extended operation at power levels where the maximum permitted peak linear heat rate could potentially be challenged. Power levels of 75% RTP are non-limiting for minimum transient FQW(Z) margin.

Furthermore, Surveillances at low power levels can be challenging with respect to obtaining an accurate transient FQ margin assessment. Performing this initial verification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 75% power ensures that the Surveillance will be performed with appropriate steady state peaking factors measured at or near the power level where future nonequilibrium operation could be limiting. If the Surveillance indicates that future nonequilibrium operation could challenge the limit, the proposed Required Actions will provide appropriate compensatory measures to ensure that the LCO will be met during such operation.

The second area for improvement of SR 3.2.1.2 concerns the existing Note to the SR. The intent of this Note is to account for potential increases in FQW(Z) between Surveillances. It requires application of a factor specified in the COLR whenever measurements indicate that the maximum value of FQC(Z) / K(Z) has increased. Alternatively, SR 3.2.1.2 must be repeated once per 7 EFPD until two successive power distribution measurements indicate that FQC(Z) / K(Z) has not increased.

This proposed change will eliminate this Note, but application of a penalty factor will continue to be required whenever the minimum margin to the FQW(Z) limit is predicted to decrease. The required penalty factors, referred to as Rj factors, will be included in the COLR and will become part of the FQW(Z) formulation. The penalty factors will be tied to a predicted decrease in the actual transient FQ margin in the upcoming time period rather than a measured increase in the value of FQC(Z) / K(Z) over the previous time period. When margin is predicted to increase, the COLR will indicate an Rj factor of 1.0 (no penalty). When margin is predicted to decrease, the COLR will indicate an appropriate Rj factor based on predicted margin trends.

This is more appropriate and rigorous than the current method since decreases in margin in the upcoming time period are the relevant concern. The basis for the current Surveillance Requirement is that past measurement trends of FQC(Z) / K(Z) can be used to determine whether or not the transient FQ margin will decrease in the future and, therefore, whether or not a penalty factor is needed. Past measurement trends of FQC(Z) / K(Z), however, may or may not be indicative of future margin trends. Though unlikely, it is possible for the maximum value of FQC(Z) / K(Z) to be decreasing while margin is also decreasing since margin depends not only on the maximum value of FQC(Z) / K(Z), which characterizes steady state peaking factors, but also on the range of possible nonequilibrium axial power shapes, characterized analytically by W(Z)

Attachment I to 000269 Page 12 of 18 and T(Z). Furthermore, the Rj penalty factors tend to be largest at beginning of life when the burnable absorbers are depleting relatively quickly with consequent changes in the power distribution. Current core models predict burnable absorber depletion and the resulting power distribution changes well. Thus, consistency between the measured and predicted trends in steady state peaking factors is expected. Consequently, basing the application and magnitude of the penalty factor on predicted margin trends is a reasonable approach.

Another difficulty with the current Surveillance Requirement is that a minimum penalty of 2% is applied regardless of how small the increase in FQC(Z) / K(Z) was measured to be. Even a small increase in FQC(Z) / K(Z) of 0.1% would require a 2% penalty to be applied. The proposed Surveillance Requirement eliminates this problem since the magnitude of the penalty factor is based on the predicted margin trends. No minimum penalty is specified.

Finally, the proposed Surveillance Requirement avoids any lag in the application of the penalty factor caused by the current requirement for two successive measurements, which could be a month apart, to indicate a potential decrease in margin. These measurements characterize the margin trend in the time period that just ended. Therefore, the proposed Surveillance Requirement will better capture the expected trend of the margin based on predictions. By eliminating the Note, however, the option to perform more frequent Surveillances in lieu of applying the penalty factor is also eliminated. It will be necessary to demonstrate that the LCO is met with the COLR Rj factor applied. If the LCO is not met, then the Required Actions must be implemented to restore margin.

WCAP-17661-P-A, Revision 1, Approval Limitations In the NRC final safety evaluation included in WCAP-17661-P-A, Revision 1, the NRC staff stipulated two limitations for the implementation of the proposed Technical Specifications.

Limitation 1: Use of AXY and AQ The use of Methods 1 and 2 are acceptable for calculating AXY and AQ when performing RAOC and COAC W(Z) Surveillances, subject to the following limitations:

1.

The NRC-approved methods provided in the response to RAI 15.b must be used to perform the surveillance-specific AXY or AQ calculations. Newer methods with similar capabilities may be considered acceptable provided the NRC staff specifically approves them for calculating AXY and AQ factors.

2.

The depletion calculation used to determine the numerator and denominator of the AXY or AQ factor must be performed similarly to the original design calculation, as described in the response to RAI 15.c.

3.

The use of Method 1 for calculating AQ is only acceptable subject to the constraints discussed in the response to RAI 15.a. The surveillance Axial Offset must be within 1.5-percent of the target AO, and there must be assurance that the limiting FQW(Z) location does not lie within a rodded elevation at the time of surveillance. Note that the use of Method 1 remains acceptable when surveillance-specific W(Z) functions are used.

Attachment I to 000269 Page 13 of 18 WCNOC Response The TS Bases were revised to limit the methods to calculate AXY to Methods 1 and 2. Method 1 sets AXY(Z) to 1.0. Method 2 calculates AXY(Z) for the conditions existing at the time of the Surveillance. The NRC approved methods provided in the response to Request for Additional Information 15.b are ANC and BEACON, which uses the same neutronic methodology as the design ANC model that was used as the base model for calculating the FQ Surveillance factors.

There are no plans at this time to add an additional method to calculate the AXY(Z) values but doing so would require a revision to the TS, which would require NRC approval.

When BEACON is used to calculate Surveillance condition specific AXY(Z) values, the calculation will be performed without using nodal calibration factors and the core depletion assumptions will be the same as used in the original core model to generate the T(Z) factors.

When ANC is used to calculate the surveillance condition specific AXY(Z) values, the calculation will use the same nuclear model and depletion basis that was used to generate the original T(Z) factors.

Item 3 of the limitation is not applicable because AQ is applicable to the CAOC methodology, whereas WCNOC uses the RAOC methodology.

Limitation 2: Power Level Reduction to 50% RTP The use of 50% as the final power level reduction in the event of failed FQ surveillance is not included in the TS, but rather in the BASES and in the COLR. As such, this final power level, 50%, must be implemented on a plant-specific basis and included in COLR input generated, using this methodology, in order to use this TR.

WCNOC Response The TS Bases were revised to use 50% as the final power level reduction in the event of a failed FQ Surveillance. Appendix C of WCAP-17661-P-A, Revision 1, provides sample COLR input for a RAOC plant, which specifies 50% RTP as the final power level reduction in the event of a failed FQ Surveillance. The COLR input for WCGS fuel cycles will also specify 50% RTP as the final power level reduction in the event of a failed FQ Surveillance as part of implementation of the WCAP-17661-P-A, Revision 1, methodology.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements The proposed change has been evaluated to determine whether the applicable regulations and requirements, noted below, continue to be met.

10 CFR 50.36, Technical Specifications Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The TSs ensures the operational capability of SSCs that are required to protect the health and safety of the public. The NRC's requirements related

Attachment I to 000269 Page 14 of 18 to the content of the TSs are contained in Section 50.36 of Title 10 of the Code of Federal Regulations (10 CFR 50.36) which requires that the TSs include items in the following specific categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements per 10 CFR 50.36(c)(3); (4) design features; and (5) administrative controls. The proposed change does not affect WCGSs compliance with the intent of 10 CFR 50.36.

NRC Generic Letter (GL) 88-16, Removal of Cycle-Specific Parameter Limits From Technical Specifications, (Accession No. ML031200485), established the NRC position that licensees could remove cycle-specific values of certain operating limits from the technical specifications and maintain them in a COLR, provided that the following requirements were met.

1.

Use NRC-approved methodology to determine the operating limits,

2.

Include a list, in the technical specification administrative controls section, of the references used to determine the operating limits, and

3.

Maintain the limits in a COLR, which must be submitted to the NRC for information.

The proposed change does not affect WCGSs compliance with the intent of 10 CFR 50.36 and GL 88-16 would be met with NRC approval of the proposed changes and submittal of the COLR in accordance with TS 5.6.5d.

10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants 10 CFR 50, Appendix A, General Design Criterion (GDC) 10, Reactor design, states, The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any conditions of normal operation, including the effects of anticipated operational occurrences.

Conformance with GDC 10 is described in Section 3.1.4 of the Wolf Creek Updated Safety Analysis Report (USAR). The proposed change does not affect WCGSs conformance with the intent of GDC 10.

10 CFR 50, Appendix A, GDC 20, Protection system functions, states, The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety. Conformance with GDC 20 is described in Section 3.1.5 of the Wolf Creek USAR. The proposed change does not affect WCGSs conformance with the intent of GDC 20.

10 CFR 50, Appendix A, GDC 26, Reactivity control system redundancy and capability, states, Two independent reactivity control systems of different design principles shall be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding

Attachment I to 000269 Page 15 of 18 the reactor core subcritical under cold conditions. Conformance with GDC 26 is described in Section 3.1.5 of the Wolf Creek USAR. The proposed change does not affect WCGSs conformance with the intent of GDC 26.

4.2 Precedent The NRC has previously approved changes similar to the proposed change in this amendment request for other nuclear power plants including:

1.

Watts Bar Nuclear Plant, Units 1 and 2: Application dated March 2, 2020 (ADAMS Accession No. ML20058G833); NRC Safety Evaluation dated February 11, 2021 (ADAMS Accession No. ML20232C622).

2.

Beaver Valley Power Station, Unit Nos. 1 and 2: Application dated June 23, 2020 (ADAMS Accession No. ML20176A431); NRC Safety Evaluation dated March 10, 2021 (ADAMS Accession No. ML20346A022).

4.3 No Significant Hazards Consideration Determination The proposed change revises the Wolf Creek Generating Station (WCGS) Technical Specification (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), and associated references in TS 5.6.5, CORE OPERATING LIMITS REPORT (COLR), to implement the new FQ(Z) surveillance methodology of WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications. The proposed changes will reformulate the FQW(Z) approximation for FQ(Z),

revise the Surveillance Requirements, and revise the Required Actions when FQ(Z) is not within limits. These changes remove the potential non-conservatisms documented in Westinghouse Nuclear Safety Advisory Letter (NSAL-15-1), Heat Flux Hot Channel Factor Technical Specification Surveillance, and NSAL-09-05, Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions.

Wolf Creek Nuclear Operating Corporation (WCNOC) has evaluated whether or not a significant hazards consideration is involved with the proposed changes by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1.

Does the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The proposed change will reformulate the FQW(Z) approximation for FQ(Z), revise the surveillance requirements, and revise the required actions when FQ(Z) is not within limits.

This change does not result in any physical changes to plant safety related structures, systems, or components (SSC).

The proposed changes affect the Surveillance Requirements performed to ensure the Heat Flux Hot Channel Factor, FQ(Z), is within the limits assumed in the safety analyses for previously evaluated accidents. The new Surveillance activity involves a reformulation of the transient hot channel factor approximation, FQW(Z), and a more conservative application of applied factors to ensure FQW(Z) remains within limit during subsequent operation up until

Attachment I to 000269 Page 16 of 18 the next Surveillance performance. Both of these changes to the Surveillance activity provide assurance that the FQ W(Z) remains within the accident analyses assumptions.

The proposed changes also affect the Required Actions and Completion Times should FQ(Z) be found to not be within limit. The new Required Actions and Completion Times ensure the plant is placed in a condition whereby FQ(Z) is restored to within limit in a timely manner.

Should FQC(Z) be found not within limit, thermal power is reduced and the Nuclear Instrumentation System (NIS) and OPT reactor trip setpoints are reduced a conservative amount that retains the margin between the nominal thermal power and reactor trip setpoints. Should FQW(Z) be found not within limit, the core power distribution is constrained by reduced AXIAL FLUX DIFFERENCE (AFD) limits, more limiting bank insertion limits, and/or thermal power reductions. These changes to the Required Actions and Completion Times restore FQ(Z) to within the safety analyses assumptions in a timely manner.

Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

2.

Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

Response: No The proposed change will reformulate the FQW(Z) approximation for FQ(Z), revise the Surveillance Requirements, and revise the required actions when FQ(Z) is not within limits.

This change does not result in any physical changes to plant safety related structures, systems, or components (SSCs). Neither does this change alter the modes of plant operation in a manner that is outside the bounds of those previously evaluated.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3.

Does the proposed change involve a significant reduction in the margin of safety?

Response: No The proposed change will re-formulate the FQW(Z) approximation for FQ(Z), revise the surveillance requirements, and revise the required actions when FQ(Z) is not within limits.

This change does not result in any physical changes to plant safety related structures, systems, or components (SSCs)

The proposed changes affect the Surveillance Requirements performed to ensure the Heat Flux Hot Channel Factor, FQ(Z), is within the limits assumed in the safety analyses for previously evaluated accidents. The new Surveillance activity involves a reformulation of the transient hot channel factor approximation, FQW(Z), and a more conservative application of applied factors to ensure FQW(Z) remains within limit during subsequent operation up until the next Surveillance performance. Both of these changes to the Surveillance activity provide assurance that the FQW(Z) remains within the accident analyses assumptions.

The proposed changes also affect the Required Actions and Completion Times should FQ(Z) be found to not be within limit. The new Required Actions and Completion Times ensure

Attachment I to 000269 Page 17 of 18 the plant is placed in a condition whereby FQ(Z) is restored to within limit in a timely manner.

Should FQC(Z) be found not within limit, thermal power is reduced and the NIS and OPT reactor trip setpoints are reduced a conservative amount that retains the margin between the nominal thermal power and reactor trip setpoints. Should FQW(Z) be found not within limit, the core power distribution is constrained by reduced AFD limits, more limiting bank insertion limits, and/or thermal power reductions. These changes to the Required Actions and Completion Times restore FQ(Z) to within the safety analyses assumptions in a timely manner.

The proposed changes do not affect the FQ(Z) limit to which the FQC(Z) and FQW(Z) approximations are compared.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, WCNOC concludes that the requested change does not involve a significant hazards consideration as set forth in 10 CFR 50.92(c), Issuance of amendment.

4.4 Conclusion Based on the considerations discussed herein, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amount of effluent that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environment impact statement environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, dated February 2019. (ADAMS Accession No. ML19225C079) 6.2 Westinghouse Nuclear Safety Advisory Letter (NSAL-09-05), Relaxed Axial Offset Control FQ Technical Specification Actions, dated August 4, 2009.

6.3 NUREG-1431, Volume 1, Revision 4.0, Standard Technical Specifications Westinghouse Plants, USNRC, April 2012.

Attachment I to 000269 Page 18 of 18 6.4 Westinghouse Nuclear Safety Advisory Letter (NSAL-09-05), Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, dated September 23, 2009.

6.5 Westinghouse Nuclear Safety Advisory Letter (NSAL-15-1), Heat Flux Hot Channel Factor Technical Specification Surveillance, dated February 3, 2015.

6.6 PWROG letter OG-19-14 to USNRC, Transmittal of WCAP-17661-P-A / WCAP-17661-NP-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, (PA-LSC-0795 Revision 4), dated March 18, 2019. (ADAMS Accession No. ML19225C138) 6.7 USNRC letter to PWROG, Verification Letter of the Approval Version of the Pressurized Water Reactor Owners Group Topical Report WCAP-17661, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, dated August 23, 2019. (Adams Accession No. ML19225D179) 6.8 WCAP-10216-P-A, Revision 1A, Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification, dated February 1994.

Attachment II to 000269 Page 1 of 9 ATTACHMENT II PROPOSED TECHNICAL SPECIFICATION CHANGES (MARK-UP)

FQ(Z) (FQ Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-1 Amendment No. 123, 159, 188 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)

LCO 3.2.1 FQ(Z), as approximated by FQ C(Z) and FQ W(Z), shall be within the limits specified in the COLR.

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

FQ C(Z) not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% FQ C(Z) exceeds limit.

AND A.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% FQ C(Z) exceeds limit.

AND A.3 Reduce Overpower 'T trip setpoints 1% for each 1% FQ C(Z) exceeds limit.

AND A.4 Perform SR 3.2.1.1.

15 minutes after each FQ C(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQ C(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQ C(Z) determination Prior to increasing THERMAL POWER above the limit of Required Action A.1 (continued)

(Z)) (F (Z) (FQ Methodology)

RAOC - T(Z)

(Z)) (F (Z)) (F (Z)) (F (Z)) (F (Z)) (F (Z)) (F (Z)) (F (Z)) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F 1% FQ (Z) exceeds limit.

1% FQ (Z) exceeds limit.

that THERMAL POWER is limited below RTP by Required Action A.1.

T trip (Z) exceeds limit.

(Z) exceeds limit.

1% for each (Z) exceeds limit.

(Z) exceeds limit.

(Z) exceeds limit.

(Z) exceeds limit.

(Z) exceeds limit.

(Z) exceeds limit.

(Z) exceeds limit.

(Z) exceeds limit.

and SR 3.2.1.2 A.4 Perform SR 3.2.1.1.

A.4 Perform SR 3.2.1.1.

A.4 Perform SR 3.2.1.1.

A.4 Perform SR 3.2.1.1.


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

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1. SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling.

A.

F A.

F A.

F A.

F A.

F

, 188 Attachment II to 000269 Page 2 of 9

FQ(Z) (FQ Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-2 Amendment No. 123 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

FQ W(Z) not within limits.

B.1 Reduce AFD limits 1%

for each 1% FQ W(Z) exceeds limit.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> C.

Required Action and associated Completion Time not met.

C.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 /> B.

F (Z) not within limits.

B.1 Reduce AFD limits (Z) not within limits.

B.1 Reduce AFD limits 1%

for each 1% F W(Z) exceeds limit.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> INSERT 3.2-2 (Z) (FQ RAOC - T(Z)

(Z) (F (Z) (F (Z) (FQ (Z) (FQ Methodology)

(Z) (F (Z) (F (Z) (F (Z) (F Wolf Creek - Unit 1 3.2-2 Amendment No. 123 Attachment II to 000269 Page 3 of 9

CONDITION REQUIRED ACTION COMPLETION TIME INSERT 3.2-2 B.

FQW(Z) not within limits.

B.1.1 Implement a RAOC operating space specified in the COLR that restores FQW(Z) to within limits.

AND B.1.2 Perform SR 3.2.1.1 and SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

OR B.2.1


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

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

Limit THERMAL POWER to less than RTP and reduce AFD limits as specified in the COLR.

AND B.2.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after each FQW(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQW(Z) determination (continued)

Attachment II to 000269 Page 4 of 9

CONDITION REQUIRED ACTION COMPLETION TIME INSERT 3.2-2 (continued)

B.

(continued)

B.2.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQW(Z) determination Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 Attachment II to 000269 Page 5 of 9

FQ(Z) (FQ Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-3 Amendment No. 123, 188, SURVEILLANCE REQUIREMENTS


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

During power escalation following shutdown, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution measurement is obtained.

SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQC(Z) is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC(Z) was last verified AND In accordance with the Surveillance Frequency Control Program (continued)



(Z) (F RAOC-T(Z)

(Z) (F (Z) (FQ (Z) (FQ (Z) (F (Z) (F NOTE During power escalation following shutdown, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution measurement is obtained.



Attachment II to 000269 Page 6 of 9

FQ(Z) (FQ Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-4 Amendment No. 123, 188 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2


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

If FQ C(Z) measurements indicate maximum over z

K(Z)

(Z)

F C

Q has increased since the previous evaluation of FQ C(Z):

a.

Increase FQ W(Z) by the appropriate factor specified in the COLR and reverify FQ W(Z) is within limits; or b.

Repeat SR 3.2.1.2 once per 7 EFPD until two successive power distribution measurements indicate maximum over z

K(Z)

(Z)

F C

Q has not increased.

Verify FQ W(Z) is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND (continued)

.2.1.2


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

If FQ (Z) measurements indicate maximum over z

(Z)

K(Z)

FQ

K(Z) has increased since the previous evaluation of FQ (Z):

a.

Increase FQ (Z) by the appropriate factor specified in the COLR and reverify FQ (Z) is within limits; or b.

Repeat SR 3.2.1.2 once per 7 EFPD until two successive power distribution measurements indicate maximum over z

(Z)

K(Z)

FQ

K(Z) has not increased.

refueling prior to THERMAL POWER exceeding 75% RTP within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER exceeds 75% RTP refueling prior to refueling prior to Once after each refueling prior to refueling prior to refueling prior to (Z) (F Methodology)

RAOC-T(Z)

(Z) (FQ Methodology)

Q Methodology)

(Z) (FQ (Z) (FQ

, 188 Attachment II to 000269 Page 7 of 9

FQ(Z) (FQ Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-5 Amendment No. 123, SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2 (continued)

Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQW(Z) was last verified AND In accordance with the Surveillance Frequency Control Program



(Z) (FQ RAOC-T(Z)

(Z) (F (Z) (F (Z) (FQ (Z) (F (Z) (F



Attachment II to 000269 Page 8 of 9

Reporting Requirements 5.6 Wolf Creek - Unit 1 5.0-26 Amendment No. 123, 142, 144, 158, 164, 179, 209, 213, 216, 221 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued) 4.

WCAP-16009-P-A, Realistic Large Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM).

5.

WCAP-16045-P-A, Qualification of the Two-Dimensional Transport Code PARAGON.

6.

WCAP-16045-P-A, Addendum 1-A, Qualification of the NEXUS Nuclear Data Methodology.

7.

WCAP 10965-P-A, ANC: A Westinghouse Advanced Nodal Computer Code.

8.

WCAP-12610-P-A, VANTAGE+ Fuel Assembly Reference Core Report.

9.

WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO TM.

10.

WCAP-8745-P-A, Design Bases for the Thermal Power T and Thermal Overtemperature T Trip Functions.

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

(continued)

 :&$33$ ,PSURYHG 5$2& DQG &$2& )4 6XUYHLOODQFH 7HFKQLFDO 6SHFLILFDWLRQs

The core operating limits shall be determined such that all

, 216, 221 Attachment II to 000269 Page 9 of 9

Attachment III to 000269 Page 1 of 7 ATTACHMENT III REVISED TECHNICAL SPECIFICATION PAGES

FQ(Z) (RAOC - T(Z) Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-1 Amendment No. 123, 159, 188, 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ(Z)) (RAOC - T(Z) Methodology)

LCO 3.2.1 FQ(Z), as approximated by FQC(Z) and FQW(Z), shall be within the limits specified in the COLR.

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.


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

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1. SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75%

RTP after a refueling.

FQC(Z) not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% FQC(Z) exceeds limit.

AND A.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

AND A.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

AND A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

15 minutes after each FQC(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQC(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQC(Z) determination Prior to increasing THERMAL POWER above the limit of Required Action A.1 (continued)

FQ(Z) (RAOC - T(Z) Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-2 Amendment No. 123, ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

FQW(Z) not within limits.

B.1.1 Implement a RAOC operating space specified in the COLR that restores FQW(Z) to within limits.

AND B.1.2 Perform SR 3.2.1.1 and SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

OR B.2.1


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

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

Limit THERMAL POWER to less than RTP and reduce AFD limits as specified in the COLR.

AND B.2.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after each FQW(Z) determination 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQW(Z) determination (continued)

FQ(Z) (RAOC - T(Z) Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-3 Amendment No. 123, ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

(continued)

B.2.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1.

AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each FQW(Z) determination Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 C.

Required Action and associated Completion Time not met.

C.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 />

FQ(Z) (RAOC - T(Z) Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-4 Amendment No. 123, 188, 227, SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQC(Z) is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC(Z) was last verified AND In accordance with the Surveillance Frequency Control Program (continued)

FQ(Z) (RAOC - T(Z) Methodology) 3.2.1 Wolf Creek - Unit 1 3.2-5 Amendment No. 123, 188, SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2 Verify FQW(Z) is within limit.

Once after each refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER exceeds 75% RTP AND Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQW(Z) was last verified AND In accordance with the Surveillance Frequency Control Program

Reporting Requirements 5.6 Wolf Creek - Unit 1 5.0-26 Amendment No. 123, 142, 144, 158, 164, 179, 209, 213, 216, 221, 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued) 4.

WCAP-16009-P-A, Realistic Large Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM).

5.

WCAP-16045-P-A, Qualification of the Two-Dimensional Transport Code PARAGON.

6.

WCAP-16045-P-A, Addendum 1-A, Qualification of the NEXUS Nuclear Data Methodology.

7.

WCAP 10965-P-A, ANC: A Westinghouse Advanced Nodal Computer Code.

8.

WCAP-12610-P-A, VANTAGE+ Fuel Assembly Reference Core Report.

9.

WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO TM.

10.

WCAP-8745-P-A, Design Bases for the Thermal Power T and Thermal Overtemperature T Trip Functions.

11.

WCAP-17661-P-A, Improved RAOC and CAOC FQ Surveillance Technical Specifications.

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

(continued)

Attachment IV to 000269 Page 1 of 18 ATTACHMENT IV PROPOSED TS BASES CHANGES (for information only)

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-1 Revision 48 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 Heat Flux Hot Channel Factor (FQ(Z)) (FQ Methodology)

BASES BACKGROUND The purpose of the limits on the values of FQ(Z) is to limit the local (i.e., pellet) peak power density. The value of FQ(Z) varies along the axial height (Z) of the core.

FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions. Therefore, FQ(Z) is a measure of the peak fuel pellet power within the reactor core.

During power operation, the global power distribution is limited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT TILT POWER RATIO (QPTR)," which are directly and continuously measured process variables. These LCOs, along with LCO 3.1.4, Rod Group Alignment Limits, LCO 3.1.5, Shutdown Bank Insertion Limits, and LCO 3.1.6, "Control Bank Insertion Limits," maintain the core limits on power distributions on a continuous basis.

FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution.

FQ(Z) is not directly measurable but is inferred from a power distribution measurement obtained with either the movable incore detector system or the Power Distribution Monitoring System (PDMS). The results of the three-dimensional power distribution measurement are analyzed to derive a measured value for FQ(Z). These measurements are generally taken with the core at or near equilibrium conditions. However, because this value represents an equilibrium condition, it does not include the variations in the value of FQ(Z) that are present during nonequilibrium situations, such as load following.

To account for these possible variations, the steady state value of FQ(Z) is adjusted by an elevation dependent factor that accounts for the calculated worst case transient conditions.

Core monitoring and control under nonsteady state conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion.

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RAOC - T(Z)

(Z) (FQ Methodology)

(Z)) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F Methodology)

Methodology)

Methodology)

Methodology)

To account for these possible variations, the steady state value of FQ(Z) is adjusted by an elevation dependent factor that accounts for the calculated worst case transient conditions.

variations in the value of F situations, such as load following.

To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F To account for these possible variations, the steady state value of F Attachment IV to 000269 Page 2 of 18 POWER TILT

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-2 Revision 0 BASES APPLICABLE This LCO precludes core power distributions that violate the following fuel SAFETY ANALYSES design criteria:

a.

During a large break loss of coolant accident (LOCA), the peak cladding temperature must not exceed 2200°F (Ref. 1);

b.

During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a departure from nucleate boiling (DNB) condition; c.

During an ejected rod accident, the average fuel pellet enthalpy at the hot spot in irradiated fuel must not exceed 200 cal/gm (Ref. 2);

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).

Limits on FQ(Z) ensure that the value of the initial total peaking factor assumed in the accident analyses remains valid. Other criteria must also be met (e.g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling). However, the LOCA peak cladding temperature is typically most limiting.

FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the FQ(Z) limit assumed in safety analyses for other postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents.

FQ(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The Heat Flux Hot Channel Factor, FQ(Z), shall be limited by the following relationships:

(

)

(

)

(

)

(

)

0.5 P

for Z

K 0.5 CFQ Z

F 0.5 P

for Z

K P

CFQ Z

F Q

Q

where:

CFQ = FQ RTP is the FQ(Z) limit at RTP provided in the COLR, RAOC - T(Z)

(Z) (F (Z) (F (Z) (F (Z) (FQ (Z) (F (Z) (FQ (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F Attachment IV to 000269 Page 3 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-3 Revision 48 BASES LCO K(Z) is the normalized FQ(Z) as a function of core height provided in the (continued)

COLR, and RTP POWER THERMAL

=

P The actual values of CFQ and K(Z) are given in the COLR.

For Relaxed Axial Offset Control operation, FQ(Z) is approximated by FQ C(Z) and FQ W(Z). Thus, both FQ C(Z) and FQ W(Z) must meet the preceding limits on FQ(Z).

An FQ C(Z) evaluation requires obtaining a power distribution measurement in MODE 1, from which we obtain the measured value (FQ M(Z)) of FQ(Z).

If the power distribution measurement is obtained with the movable incore detector system, FQ C(Z) = FQ M(Z) (1.03) (1.05) = FQ M(Z) (1.0815) (Eq. 1) where 1.03 is a factor that accounts for fuel manufacturing tolerances and 1.05 is a factor that accounts for flux map measurement uncertainty.

(Ref. 4)

If the power distribution measurement is obtained with the Power Distribution Monitoring System, FQ C(Z) = FQ M(Z) (1.03) (1.00 + UQ/100) where 1.03 is a factor that accounts for fuel manufacturing tolerances and UQ is a factor that accounts for Power Distribution Monitoring System measurement uncertainty (%), determined as described in Reference 6.

FQ C(Z) is an excellent approximation for FQ(Z) when the reactor is at the steady state power at which the power distribution measurement was taken.

The expression for FQ W(Z) is:

FQ W(Z) = FQ C(Z) W(Z) where FQ C(Z) is per Eq. 1 and W(Z) is a cycle dependent function that accounts for power distribution transients encountered during normal operation. W(Z) information is included in the COLR. For the PDMS, FQ M(Z) reflects the measured power distribution at HFP, ARO, equilibrium Xe conditions.

);<0 = [7 = ]&2/5$;< = 5M[]

3 (Z) as a function of core height provided in the (Z) as a function of core height provided in the (Z) as a function of core height provided in the (Z) as a function of core height provided in the (Z) = FQ (Z) W(Z) where FQ (Z) is per Eq. 1 and W(Z) is a cycle dependent function that (Z) (1.0815) (Eq. 1) accounts for power distribution transients encountered during normal operation. W(Z) information is included in the COLR. For the PDMS, FQ (Z) reflects the measured power distribution at HFP, ARO, equilibrium Xe conditions.

INSERT B 3.2.1-3 where F where F where F where F (Z) (FQ Methodology)

RAOC - T(Z)

(Z) (F (Z) (F (Z) (F (Z) (FQ (Z) (F (Z) (F (Z) (F (Z) (F limit Attachment IV to 000269 Page 4 of 18 for P > 0.5 FQW(Z) = FXYM(Z) [T(Z)]COLR AXY(Z) Rj [1.0815]

P for P 0.5 0.5

INSERT B 3.2.1-3 The various factors in this expression are defined below:

FXYM(Z) is the measured radial peaking factor at axial location Z and is equal to the value of FQM(Z)/PM(Z), where PM(Z) is the measured core average axial power shape.

[T(Z)]COLR is the cycle and burnup dependent function, specified in the COLR, which accounts for power distribution transients encountered during non-equilibrium normal operation.

[T(Z)]COLR functions are specified for each analyzed RAOC operating space (i.e., each unique combination of AFD limits and Control Bank Insertion Limits). The [T(Z)]COLR functions account for the limiting non-equilibrium axial power shapes postulated to occur during normal operation for each RAOC operating space. Limiting power shapes at both full and reduced power operation are considered in determining the maximum values of [T(Z)]COLR. The [T(Z)]COLR functions also account for the following effects: (1) the presence of spacer grids in the fuel assembly, (2) the increase in radial peaking in rodded core planes due to the presence of control rods during non-equilibrium normal operation, (3) the increase in radial peaking that occurs during part-power operation due to reduced fuel and moderator temperatures, and (4) the increase in radial peaking due to non-equilibrium xenon effects. The [T(Z)]COLR functions are normally calculated assuming that the Surveillance is performed at nominal RTP conditions with all shutdown and control rods full withdrawn, i.e., all rods out (ARO) Surveillance specific

[T(Z)]COLR values may be generated for a given surveillance core condition.

P is the THERMAL POWER / RTP.

AXY(Z) is a function that adjusts the FQW(Z) Surveillance for differences between the reference core condition assumed in generating the [T(Z)]COLR function and the actual core condition that exists when the Surveillance is performed. Normally, this reference core condition is 100%

RTP, all rods out, and equilibrium xenon. For simplicity, AXY(Z) may be assumed to be 1.0, as this will typically result in an accurate FQW(Z) Surveillance result for a Surveillance that is performed at or near the reference core condition, and an underestimation of the available margin to the FQ limit for Surveillances that are performed at core conditions different from the reference condition. Alternately, the AXY(Z) function may be calculated using the NRC approved methodology in Reference 7.

1.0815 is a factor that accounts for fuel manufacturing tolerances and measurement uncertainty.

Rj is a cycle and burnup dependent analytical factor specified in the COLR that accounts for potential increases in FQW(Z) between Surveillances. Rj values are provided for each RAOC operating space.

Attachment IV to 000269 Page 5 of 18

Wolf Creek - Unit 1 B 3.2.1-4 Revision 48 BASES LCO (continued)

T FQ(Z) li he mits define limiting values for core power peaking that precludes peak cladding temperatures above 2200qF during either a large or small break LOCA.

This LCO requires operation within the bounds assumed in the safety analyses. Calculations are performed in the core design process to confirm that the core can be controlled in such a manner during operation that it can stay within the LOCA FQ(Z) limits. If )4: = cannot be maintained within the LCO limits, reduction of the core power is required.

Violating the LCO limits for FQ(Z) may produce unacceptable consequences if a design basis event occurs while FQ(Z) is outside its specified limits.

APPLICABILITY The FQ(Z) limits must be maintained in MODE 1 to prevent core power distributions from exceeding the limits assumed in the safety analyses.

Applicability in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require a limit on the distribution of core power.

ACTIONS A.1 Reducing THERMAL POWER by 1% RTP for each 1% by which FQ C(Z) exceeds its limit, maintains an acceptable absolute power density. FQ C(Z) is FQ M(Z) multiplied by factors which account for manufacturing tolerances and measurement uncertainties. FQ M(Z) is the measured value of FQ(Z).

The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of FQ C(Z) and would require power reductions within 15 minutes of the FQ C(Z) determination, if necessary to comply with the decreased maximum allowable power level.

Decreases in FQ C(Z) would allow increasing the maximum allowable power level and increasing power up to this revised limit.

Calculate the percent FQ C(Z) exceeds its limit by the following expression:

maximum over Z CFQ P

X K 1

X 100 F

Z Z

Q C ( )

( )

for P 0.5 FQ(Z) (FQ Methodology)

B 3.2.1 9LRODWLQJ WKH /&2 OLPLWs IRU )4 = FRXOG UHsXOW LQ XQDFFHSWDEOH FRQsHTXHQFHs LI D GHsLJQ EDsLs HYHQW ZHUH WR RFFXU ZKLOH

)4 = H[FHHGs LWs sSHFLILHG OLPLWs

Violating the LCO limits for F Violating the LCO limits for F Violating the LCO limits for Q(Z) may produce unacceptable consequences if a consequences if a consequences if design basis event occurs while FQ(Z) is outside its specified limits (Z) (F RAOC - T(Z)

(Z) (F (Z) (F (Z) (FQ (Z) (F (Z) (FQ (Z) (F (Z) (F (Z) (F (Z) (F (Z) (F mits define limiting values for precludes peak cladding temperatures above 2200 eak LOCA.

LCO requires operation within the bounds assumed in the safety Calculations are performed in the core design process to Calculations are performed in the core design process to LCO requires operation within the bounds assumed in the safety Calculations are performed in the core design process to Calculations are performed in the core design process to Calculations are performed in the core design process to equired.

Calculate the percent FQ (Z) exceeds its limit by the following expression:

CFQ

F Z

F Z

Q F

Z

( )

INSERT B 3.2.1-4

, a more restrictive RAOC operating space must be implemented or core power limits and AFD limits must be reduced.

Attachment IV to 000269 Page 6 of 18

INSERT B 3.2.1-4 If an FQ surveillance is performed at 100% RTP conditions, and both FQC(Z) and FQW(Z) exceed their limits, the option to reduce the THERMAL POWER limit in accordance with Required Action B.2.1 instead of implementing a new operating space in accordance with Required Action B.1.1, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. In the event the evaluated THERMAL POWER reduction in the COLR for Required Action B.2.1 did not result in a further power reduction (for example, if both Condition A and Condition B were entered at less than 100% RTP conditions), then the THERMAL POWER level established as a result of completing Required Action A.1 will take precedence, and will establish the effective operating power level limit for the unit until both Conditions A and B are exited.

Attachment IV to 000269 Page 7 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-5 Revision 48 BASES ACTIONS A.1 (continued) maximum over Z CFQ 0.5 X K 1

X 100 F

Z Z

Q C ( )

( )

for P < 0.5 A.2 A reduction of the Power Range Neutron Flux - High trip setpoints by 1%

for each 1% by which FQ C(Z) exceeds its limit, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1. The maximum allowable Power Range Neutron Flux - High trip setpoints initially determined by Required Action A.2 may be affected by subsequent determinations of FQ C(Z) and would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of FQ C(Z) determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints.

A.3 Reduction in the Overpower T trip setpoints by 1% for each 1% by which FQ C(Z) exceeds its limit, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1. The maximum allowable Overpower T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of FQ C(Z) and would require Overpower T trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the FQ C(Z) determination, if necessary to comply with the decreased maximum allowable Overpower T trip setpoints. Decreases in FQ C(Z) would allow increasing the maximum Overpower T trip setpoints.

A.4 Verification that FQ C(Z) has been restored to within its limit, by performing SR 3.2.1.1 prior to increasing THERMAL POWER above the limit

CFQ

F Z

Q

for each 1% by which FQ (Z) exceeds its limit, is a conservative action for that THERMAL POWER is limited below RTP by Required Action A.1 for each 1% by which F for each 1% by which F for each 1% by which F protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period for each 1% by which F for each 1% by which F for each 1% by which F protection against the consequences of severe transients with unanalyzed for each 1% by which F for each 1% by which F 1% for each 1% by which FQ (Z) exceeds its limit, is a conservative action for protection which F which F which F which F which F which F which F which F which F which F which F which F and SR 3.2.1.2 cation that F SR 3.2.1.1 prior to increasing THERMAL POWER above the limit SR 3.2.1.1 prior to increasing THERMAL POWER above the limit cation that F SR 3.2.1.1 prior to increasing THERMAL POWER above the limit SR 3.2.1.1 prior to increasing THERMAL POWER above the limit SR 3.2.1.1 prior to increasing THERMAL POWER above the limit (Z) (F RAOC - T(Z)

(Z) (FQ Methodology)

(Z) (FQ (Z) (FQ Attachment IV to 000269 Page 8 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-6 Revision 48 BASES ACTIONS A. 4 (continued) imposed by Required Action A.1, ensures that core conditions during operation at higher power levels are consistent with safety analyses assumptions. Inherent in this action is identification of the cause of the out of limit condition and the correction of the cause to the extent necessary to allow safe operation at the higher power level.

B.1 If it is found that the maximum calculated value of FQ(Z) that can occur during normal maneuvers, FQ W(Z), exceeds its specified limits, there exists a potential for FQ C(Z) to become excessively high if a normal operational transient occurs. Tightening both the positive and negative AFD limits by 1% for each 1% by which FQ W(Z) exceeds its limit within the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded.

Calculate the percent FQ W(Z) exceeds its limit by the following expression:

maximum over Z X W CFQ P

X K 1

X 100 F

Z Z

Z Q

C ( )

( )

( )

for P 0.5 maximum over Z X W CFQ 0.5 X K 1

X 100 F

Z Z

Z Q

C ( )

( )

( )

for P < 0.5 C.1 If Required Actions A.1 through A.4 or B.1 are not met within their associated Completion Times, the plant must be placed in a mode or condition in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

This allowed Completion Time is reasonable based on operating experience regarding the amount of time it takes to reach MODE 2 from full power operation in an orderly manner and without challenging plant systems.

(Z) (FQ Methodology)

RAOC - T(Z)

Q Methodology)

Q INSERT B 3.2.1-6A transient occurs. Tightening both the positive and negative AFD limits by 1% for each 1% by which F 1% for each 1% by which FQ (Z) exceeds its limit within the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded.

Calculate the percent FQ (Z) exceeds its limit by the following expression:

F Z

Z C

F Z

Z C

F Z

Z

( )

( )

X W

( )

( )

X W F

Z Z

( )

( )

F Z

Z X W F

Z Z

X W

( )

( )

X W F

Z Z

X W

CFQ

CFQ

F Z

Z

( )

( )

F Z

Z

( )

( )

F Z

Z

INSERT B 3.2.1-6B transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by 1% for each 1% by which F 1% for each 1% by which F Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, restricts the axial flux distribution such that 1% for each 1% by which F transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by transient occurs. Tightening both the positive and negative AFD limits by B.1 B.1.1 and future operation imposed by Required Action A.1, ensures that core conditions during operation at higher power levels are consistent with safety analyses operation at higher power levels are consistent with safety analyses imposed by Required Action A.1, ensures that core conditions during operation at higher power levels are consistent with safety analyses imposed by Required Action A.1, ensures that core conditions during operation at higher power levels are consistent with safety analyses operation at higher power levels are consistent with safety analyses Required Actions A.1 through A.4 or B.1 are not met within their B.1.1 through B.2.4 Required Actions A.1 through A.4 or B.1 are not met within their Required Actions A.1 through A.4 or B.1 are not met within their Required Actions A.1 through A.4 or B.1 are not met within their Required Actions A.1 through A.4 or B.1 are not met within their Required Actions A.1 through A.4 or B.1 are not met within their Required Actions A.1 through A.4 or B.1 are not met within their Attachment IV to 000269 Page 9 of 18

INSERT B 3.2.1-6A Condition A is modified by a Note that requires Required Action A.4 to be performed whenever the Condition is entered prior to increasing THERMAL POWER above the limit of Required Action A.1. The Note also states that SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after a refueling. This ensures that SR 3.2.1.1 and SR 3.2.1.2 (if required) will be performed prior to increasing THERMAL POWER above the limit of Required Action A.1, even when Condition A is exited prior to performing Required Action A.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.

INSERT B 3.2.1-6B Implementing a more restrictive RAOC operating space, as specified in the COLR, within the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> will restrict the AFD such that peaking factor limits will not be exceeded during non-equilibrium normal operation. Several RAOC operating spaces, representing successively smaller AFD envelopes and, optionally, shallower Control Bank Insertion Limits, may be specified in the COLR. The corresponding T(Z) functions for these operating spaces can be used to determine which RAOC operating space will result in acceptable non-equilibrium operation within the FQW(Z) limit.

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

B.2.1 When FQW(Z) exceeds it limit, Required Action B.2.1 may be implemented instead of Required Action B.1. Required Action B.2.1 limits THERMAL POWER to less than RTP by the amount specified in the COLR. It also requires reductions in the AFD limits by the amount specified in the COLR. This maintains an acceptable absolute power density relative to the maximum power density value assumed in the safety analyses.

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

RTP.

Attachment IV to 000269 Page 10 of 18

INSERT B 3.2.1-6B (continued)

The Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides an acceptable time to reduce the THERMAL POWER and AFD limits in an orderly manner to preclude entering an unacceptable condition during future non-equilibrium operation. The limit on THERMAL POWER initially determined by Required Action B.2.1 may be affected by subsequent determinations of FQW(Z) that are not within limit and could require power reductions within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the of the subsequent FQW(Z) determination, if necessary, to comply with the decreased THERMAL POWER limit. In short, the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Completion Time for Required Action B.2.1 applies after each FQW(Z) determination.

Decreases in subsequent FQW(Z) measurements while in Condition B would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

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

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

B.2.2 A reduction of the Power Range Neutron Flux - High trip setpoints by 1% for each 1% by which the maximum allowable power is reduced is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Action B.2.1. The maximum allowable Power Range Neutron Flux -

High trip setpoints initially determined by Required Action B.2.2 may be affected by subsequent determinations of FQW(Z) that are not within limit and could require Power Range Neutron Flux -

High trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the subsequent FQW(Z) determination, if necessary, to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. In short, the 72-hour Completion Time for Required Action B.2.2 applies after each FQW(Z) determination.

Attachment IV to 000269 Page 11 of 18

INSERT B 3.2.1-6B (continued)

B.2.3 Reduction in the Overpower T trip setpoints value of K4 by 1% for each 1% by which the maximum allowable power is reduced is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with the Required Action B.2.1. The maximum allowable Overpower T trip setpoints initially determined by Required Action B.2.3 may be affected by subsequent determinations of FQW(Z) that are not within limit and could require Overpower T trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the subsequent FQW(Z) determination, if necessary, to comply with the decreased maximum allowable Overpower T trip setpoints. In short, the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time for Required Action B.2.3 applies after each FQW(Z) determination. Decreases in subsequent FQW(Z) measurements while in Condition B would allow increasing the maximum allowable Overpower T trip setpoints.

B.2.4 Verification that FQW(Z) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.2.1, ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.

Attachment IV to 000269 Page 12 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-7 Revision 48 BASES SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.2 are modified by a Note. The Note applies REQUIREMENTS during power ascensions following a plant shutdown (leaving MODE 1).

The Note allows for power ascensions if the surveillances are not current.

It states that THERMAL POWER may be increased until an equilibrium power level (i.e., equilibrium conditions) has been achieved at which a power distribution measurement can be obtained. This allowance is modified,however, by one of the Frequency conditions that requires verification that FQ C(Z) and FQ W(Z) are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits. Because FQ C(Z) and FQ W(Z) could not have previously been measured in a reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP.

This ensures that some determination of FQ C(Z) and FQ W(Z) are made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of FQ C(Z) and FQ W(Z) following a power increase of more than 10%, ensures that they are verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from when equilibrium conditions are achieved at RTP (or any other level for extended operation). Equilibrium conditions are achieved when the core is sufficiently stable at the intended operating conditions to perform a power distribution measurement. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of FQ C(Z) and FQ W(Z). The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which FQ was last measured.

SR 3.2.1.1 Verification that FQ C(Z) is within its specified limits involves increasing FQ M(Z) to allow for manufacturing tolerance and measurement uncertainties in order to obtain FQ C(Z), as described in the preceeding LCO section.

The limit with which FQ C(Z) is compared varies inversely with power above 50% RTP and directly with a function called K(Z) provided in the COLR.

Performing this Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the FQ C(Z) limit is met when RTP is achieved, because peaking factors generally decrease as power level is increased.

sRPH GHWHUPLQDWLRQ RI )4& = Ls PDGH SULRU WR DFKLHYLQJ D sLJQLILFDQW SRZHU OHYHO ZKHUH WKH SHDN OLQHDU KHDW UDWH FRXOG DSSURDFK WKH OLPLWs DssXPHG LQ WKH sDIHW\\ DQDO\\sHs

(Z) (F RAOC - T(Z)

(Z) (F (Z) (F (Z) (F (Z) (F (Z) (FQ (Z) (FQ Methodology)

(Z) (F (Z) (F (Z) (F (Z) (F (Z) (F SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.2 are modified by a Note. The Note applies REQUIREMENTS during power ascensions following a plant shutdown (leaving MODE 1).

The Note allows for power ascensions if the surveillances are not current.

It states that THERMAL POWER may be increased until an equilibrium power level (i.e., equilib power distribution measurement can be obtained. This allowance is modified,however, by one of the Frequency conditions that requires C(Z) and F power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits. Because F (Z) could not have previously been measured in a reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP.

This ensures that some determination of F lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency (Z) and F increase of more than 10%, ensures that they are verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> hieved at RTP (or any other level ons are achieved when the core is sufficiently stable at the intended operating conditions to perform a power distribution measurement. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for (Z). The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation REQUIREMENTS during power ascensions following a plant shutdown (leaving MODE 1).

The Note allows for power ascensions if the surveillances are not current.

It states that THERMAL POWER may be increased until an equilibrium achieved at which a power distribution measurement can be obtained. This allowance is modified,however, by one of the Frequency conditions that requires (Z) are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits. Because F (Z) could not have previously been measured in a reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP.

This ensures that some determination of F lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of F increase of more than 10%, ensures that they are verified within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from when equilibrium conditions are ac on). Equilibrium conditi core is sufficiently stable at the intended operating conditions to perform a power distribution measurement. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of F condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which F ensures that the FQ (Z) limit is met when RTP is achieved, because peaking factors generally decrease as power level is increased.

following a refueling ensures that the F ensures that the F ensures that the F peaking factors generally decrease as power level is increased.

peaking factors generally decrease as power level is increased.

ensures that the F ensures that the F peaking factors generally decrease as power level is increased.

ensures that the F Attachment IV to 000269 Page 13 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-8 Revision 89 BASES SURVEILLANCE SR 3.2.1.1 (continued)

REQUIREMENTS If THERMAL POWER has been increased by 10% RTP since the last determination of FQC(Z), another evaluation of this factor is required within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions at this higher power level (to ensure that FQC(Z) values are being reduced sufficiently with power increase to stay within the LCO limits).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.2.1.2 The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because power distribution measurements are taken at or near equilibrium conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the measurements. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, FQC(Z), by W(Z) gives the maximum FQ(Z) calculated to occur in normal operation, FQW(Z).

The limit with which FQW(Z) is compared varies inversely with power and directly with the function K(Z) provided in the COLR.

The W(Z) are provided for discrete core elevations. Flux map data are typically taken for 30 to 75 core elevations. FQW(Z) evaluations are not applicable for the following axial core regions, measured in percent of core height:

a.

Lower core region, from 0 to 15% inclusive; and b.

Upper core region, from 85 to 100% inclusive.

The amount of the axial core region that can be excluded during the performance of SR 3.2.1.2 shall not exceed 15% of the upper and lower core regions, and may be reduced on a cycle-specific basis as determined during the core reload design process. The amount of the axial core region that can be excluded during the performance of SR 3.2.1.2 is identified in the COLR. The axial core regions are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making 7KH [7 = ]&2/5 IXQFWLRQs DUH sSHFLILHG LQ WKH &2/5 RAOC - T(Z)

(Z) (FQ (Z) (F (Z) (FQ (Z) (FQ (Z) (FQ (Z) (F RTP since the last initial or most recent RTP since the last RTP since the last RTP since the last RTP since the last RTP since the last INSERT B 3.2.1-8A maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, FQ (Z), by W(Z) gives the maximum F (Z) calculated to occur in normal operation, FQW(Z).

INSERT B 3.2.1-8B applicable for the following axial core regions, measured in percent of The W(Z) are provided for discrete core elevations. Flux map data are directly with the function K(Z) provided in the COLR.

are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are are provided for discrete core elevations. Flux map data are the axial core region that can be excluded during the performance of SR 3.2.1.2 shall not exceed 15% of the upper and lower specific basis as determined during the core reload design process. The amount of the axial core region that can be excluded during the performance of SR axial core region that can be excluded during the performance of SR 3.2.1.2 is identified in the COLR. The axial core regions are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the diffic of making The amount of performance of SR 3.2.1.2 shall not exceed 15% of the upper and lower core regions, and may be reduced on a cycle determined during the core reload design process. The amount of the axial core region that can be excluded during the performance of SR axial core region that can be excluded during the performance of SR 3.2.1.2 is identified in the COLR. The axial core regions are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the diffic axial core region that can be excluded during the performance of SR 15% inclusive; and 100% inclusive.

15% inclusive; and 15% inclusive; and 15% inclusive; and 15% inclusive; and 15% inclusive; and 15% inclusive; and 100% inclusive.

100% inclusive.

100% inclusive.

INSERT B 3.2.1-8C The amount of The amount of The amount of The amount of Attachment IV to 000269 Page 14 of 18 above 50% RTP

INSERT B 3.2.1-8A Equilibrium conditions are achieved when the core is sufficiently stable at the intended operating conditions required to perform the Surveillance.

The allowance of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions at the increased THERMAL POWER level to complete the next FQC(Z) surveillance applies to situations where the FQC(Z) has already been measured at least once at a reduced THERMAL POWER level.

The observed margin in the previous Surveillance will provide assurance that increasing power up to the next plateau will not exceed the FQ limit, and that the core is behaving as designed.

This Frequency condition is not intended to require verification of these parameters after every 10% increase in RTP above the THERMAL POWER at which the last verification was performed. It only requires verification after a THERMAL POWER is achieved for extended operation that is 10% higher than the THERMAL POWER at which FQC(Z) was last measured.

INSERT B 3.2.1-8B The measured FQ(Z) can be determined through a synthesis of the measured planar radial peaking factors, FXYM(Z), and the measured core average axial power shape, PM(Z). Thus, FQC(Z) is given by the following expression:

FQC(Z) = FXYM(Z) PM(Z)[1.0815] = FQM (Z)[1.0815]

For RAOC operation, the analytical [T(Z)]COLR functions, specified in the COLR for each RAOC operating space, are used together with the measured FXY(Z) values to estimate FQ(Z) for non-equilibrium operation within the RAOC operating space. When the FXY(Z) values are measured at HFP ARO conditions (AXY(Z) equals 1.0), FQW(Z) is given by the following expression:

FQW(Z) = FXYM(Z) [T(Z)]COLR Rj [1.0815]

Non-equilibrium operation can result in significant changes to the axial power shape. To a lesser extent, non-equilibrium operation can increase the radial peaking factors, FXY(Z), through control rod insertion and through reduced Doppler and moderator feedback at part-power conditions.

The [T(Z)]COLR functions quantify these effects for the range of power shapes, control rod insertion, and power levels characteristic of the operating space. Multiplying [T(Z)]COLR by the measured full power, unrodded FXYM(Z) value, and the factor that accounts for manufacturing and measurement uncertainties gives FQW(Z), the maximum total peaking factor postulated for non-equilibrium RAOC operation.

INSERT B 3.2.1-8C c.

Grid plane regions, +/- 2% inclusive, and d.

Core plane regions, within +/- 2% of the bank demand position of the control banks.

These regions of the core are excluded from the evaluation because of the low probability that they would be more limiting in the safety analyses and because of the difficulty of making a Attachment IV to 000269 Page 15 of 18

INSERT B 3.2.1-8C (continued) precise measurement in these regions. The excluded regions at the top and bottom of the core are specified in the COLR and are defined to ensure that the minimum margin location is adequately surveilled. A slightly smaller exclusion zone may be specified, if necessary, to include the limiting margin location in the surveilled region of the core.

SR 3.2.1.2 requires a Surveillance of FQW(Z) during the initial startup following each refueling within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding 75% RTP. THERMAL POWER levels below 75% are typically non-limiting with respect to the limit for FQW(Z). Furthermore, startup physics testing and flux symmetry measurements, also performed at low power, provide confirmation that the core is operating as expected. This Frequency ensures that verification of FQW(Z) is performed prior to extended operation at power levels where the maximum permitted peak LHR could be challenged and that the first required performance of SR 3.2.1.2 after a refueling is performed at a power level high enough to provide a high level of confidence in the accuracy of the Surveillance result.

Equilibrium conditions are achieved when the core is sufficiently stable at the intended operating conditions required to perform the Surveillance.

If a previous Surveillance of FQW(Z) was performed at part power conditions, SR 3.2.1.2 also requires the FQW(Z) be verified at power levels 10% RTP above the THERMAL POWER of its last verification within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions. This ensures that FQW(Z) is within its limit using radial peaking factors measured at the higher power level.

The allowance of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions will provide a more accurate measurement of FQW(Z) by allowing sufficient time to achieve equilibrium conditions and obtain the power distribution measurement.

Attachment IV to 000269 Page 16 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-9 Revision 89 BASES SURVEILLANCE SR 3.2.1.2 (continued)

REQUIREMENTS a precise measurement in these regions. It should be noted that while the transient FQ(Z) limits are not measured in these axial core regions, the analytical transient FQ(Z) limits in these axial core regions are demonstrated to be satisfied during the core reload design process.

This Surveillance has been modified by a Note that may require more frequent surveillances be performed. When FQC(Z) is measured, an evaluation of the expression below is required to account for any increase to FQ(Z) that may occur and cause the FQ(Z) limit to be exceeded before the next required FQ(Z) evaluation.

If the two most recent FQ(Z) evaluations show an increase in the expression maximum over z K(Z)

(Z)

F C

Q

it is required to meet the FQ(Z) limit with the last FQW(Z) increased by the appropriate factor specified in the COLR, or to evaluate FQ(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.

Performing the Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the FQ(Z) limit will be met when RTP is achieved, because peaking factors are generally decreased as power level is increased.

FQ(Z) is verified at power levels 10% RTP above the THERMAL POWER of its last verification, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions to ensure that FQ(Z) is within its limit at higher power levels.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

a precise measurement in these regions.

the transient F analytical transient F demonstrated to be satisfied during the core reload design process.

Surveillance has been modified by a Note that may require more frequent surveillances be performed. When F evaluation of the expression below is required to account for any increase (Z) that may occur and cause the F (Z) evaluation.

(Z) evaluations show an increase in the (Z) limit with the last F appropriate factor specified in the COLR, or to evaluate F EFPD. These alternative requirements prevent F from exceeding its limit for any significant period of time without detection.

1 prior to exceeding 75%

(Z) limit will be met when RTP is achieved, because peaking factors are generally decreased as power level is increased.

POWER of its last verification, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium (Z) limits are not measured in these axial core regions, the demonstrated to be satisfied during the core reload design process.

Surveillance has been modified by a Note that may require more (Z) is measured, an evaluation of the expression below is required to account for any increase (Z) limit to be exceeded before (Z) evaluations show an increase in the (Z) limit with the last F appropriate factor specified in the COLR, or to evaluate F EFPD. These alternative requirements prevent F from exceeding its limit for any significant period of time without detection.

orming the Surveillance in MODE ensures that the F peaking factors are generally decreased as power level is increased.

(Z) is verified at power levels POWER of its last verification, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions to ensure that F (Z) (FQ RAOC - T(Z)

Q Methodology)

Q Attachment IV to 000269 Page 17 of 18

FQ(Z) (FQ Methodology)

B 3.2.1 Wolf Creek - Unit 1 B 3.2.1-10 Revision 70 BASES REFERENCES 1.

10 CFR 50.46, 1974.

2.

USAR, Section 15.4.8.

3.

10 CFR 50, Appendix A, GDC 26.

4.

WCAP-7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.

5.

Performance Improvement Request 2005-3311.

6.

WCAP-12472-P-A, BEACON Core Monitoring and Operations Support System, August 1994 (including Addendum 4, September 2012).

7. WCAP-17661-P-A, Revision 1, "Improved RAOC and CAOC FQ Surveillance Technical Specifications," February 2019.

Attachment IV to 000269 Page 18 of 18