Text

Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC
	ML22287A174
Person / Time
Site:	Vogtle, Farley
Issue date:	10/14/2022
From:	Gayheart C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-20-0170
	Download: ML22287A174 (165)
	v • d • e

Cheryl A. Gayheart 3535 Colonnade Parkway Regulatory Affairs Director Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com October 14, 2022 NL-20-0170 10 CFR 50.90 Docket Nos. 50-348, 50-364, 50-424, 50-425,52-025 & 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Joseph M. Farley Nuclear Plant - Units 1&2 Vogtle Electric Generating Plant - Units 1&2 Vogtle Electric Generating Plant - Units 3&4 Non-Voluntary License Amendment Request:

Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC FQ Surveillance Technical Specifications Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company hereby requests a license amendment to Vogtle Electric Generating Plant (VEGP) Units 1 and 2 renewed facility operating licenses NPF-68 and NPF-81, respectively, Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2 renewed facility operating licenses NPF-2 and NPF-8, respectively, and VEGP Units 3 and 4 combined licenses NPF-91 and NPF-92, respectively.

The proposed change would revise technical specifications (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), to adopt the TS changes described in Appendix A or Appendix D (as applicable) of Westinghouse topical report WCAP-17661-P-A, Revision 1, to address the issues identified in Westinghouse Nuclear Safety Advisory Letter (NSAL) 5, Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, and NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance. The proposed change includes, to the extent necessary, the adoption of several technical specification task force change travelers to align the VEGP 1&2 and FNP TS with the FQ formulations and required actions of TS 3.2.1B of NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 4. Additionally, this license amendment request (LAR) modifies the VEGP 1&2 and FNP TS 5.6.5 and VEGP 3&4 TS 5.6.3, Core Operating Limits Report (COLR), to include WCAP-17661-P-A, Revision 1, in the list of the NRC approved methodologies used to develop the cycle specific COLR.

These changes were previously discussed with the NRC Staff for Joseph M. Farley Nuclear Plant, Units 1 and 2; and Vogtle Electric Generating Plant, Units 1 and 2 at a public presubmittal meeting on March 4, 2021 (ADAMS Accession Number ML21063A328).

Similar changes have been added for VEGP Units 3 and 4 since the presubmittal meeting.

Approval of the proposed amendment is requested within one year from the date of this submittal. Due to the core design and safety analysis evaluation needed to support each

U. S. Nuclear Regulatory Commission NL-20-0170 Page 2 core design using the methodology in WCAP-17661-P-A, Revision 1, implementation of this amendment for each unit will coincide with the start of the respective fuel cycles for each unit allowing for the necessary implementation prior to the beginning of the fuel cycle. These fuel cycles are currently anticipated as follows: VEGP Unit 1 (Fall 2024) and VEGP Unit 2 (Spring 2025); FNP Unit 1 (Spring 2024) and FNP Unit 2 (Spring 2025); and VEGP Unit 3 (Spring 2024) and VEGP Unit 4 (Fall 2024).

This LAR is required to correct a non-conservative TS. NSAL-09-5, Revision 1, and NSAL-15-1 noted there are non-conservatisms in the methodology in Westinghouse Standard 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 methodology, and in the Vogtle 3&4 TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)

(CAOC-W(Z) Methodology). SNC is currently following the applicable compensatory measures as described in NSAL-09-5, Revision 1, and NSAL-15-1. In accordance with the guidance in NRC Administrative Letter (AL) 98-10, Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety, this LAR is required to resolve the non-conservative TS and is not a voluntary request to change the VEGP and FNP licensing basis. Therefore, this request is not subject to forward fit considerations as described in the letter from S. Burns (NRC) to E. Ginsberg (NEI), dated July 14, 2010 (NRC Agencywide Documents Access and Management System Accession Number ML101960180).

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

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the -

__th day of October 2022.

Respectfully submitted, C. A. Gayheart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/kgl/cg

U. S. Nuclear Regulatory Commission NL-20-0170 Page 3

Enclosure:

Evaluation of Proposed Change cc: Regional Administrator, Region ll NRR Project Manager - Vogtle 1 & 2 Senior Resident Inspector - Vogtle 1 & 2 NRR Project Manager - Farley 1 & 2 Senior Resident Inspector - Farley 1 & 2 NRR Project Manager - Vogtle 3 & 4 Senior Resident Inspector - Vogtle 3 & 4 State of Georgia Environmental Protection Division Director, State of Alabama Office of Radiation Protection RType: CFA04.054, CVC7000

ENCLOSURE Evaluation of Proposed Change

Subject:

Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC FQ Surveillance Technical Specifications

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 System Design and Operation 2.2 Current Technical Specification Requirements 2.3 Reason for Proposed Change 2.4 Description of Proposed Change A. VEGP 1&2 and FNP 1&2 B. VEGP 3&4

3. TECHNICAL EVALUATION A. VEGP 1&2 and FNP 1&2

3.1 Background

3.2 Current Licensing Basis 3.3 NUREG-1431, Rev. 4 Alignment 3.4 TSTF Change Traveler Adoption and Variations 3.5 Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations 3.6 WCAP-17661-P-A, Rev. 1 Approval Limitations B. VEGP 3&4

3.1 Background

3.2 Current Licensing Basis 3.3 TSTF Change Traveler Adoption and Variations 3.4 Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations 3.5 WCAP-17661-P-A, Rev. 1 Approval Limitations

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination Analysis

Enclosure to NL-20-0170 Evaluation of Proposed Change 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Vogtle Electric Generating Plant 1&2 Marked-up TS Pages

2. Vogtle Electric Generating Plant 1&2 Revised TS Pages

3. Farley Nuclear Plant 1&2 Marked-up TS Pages

4. Farley Nuclear Plant 1&2 Revised TS Pages

5. Vogtle Electric Generating Plant 3&4 Marked-up TS Pages

6. Vogtle Electric Generating Plant 3&4 Revised TS Pages

7. Vogtle Electric Generating Plant 1&2 Marked-up TS Bases Pages (Information only)

8. Farley Nuclear Plant 1&2 Marked-up TS Bases Pages (Information only)

9. Vogtle Electric Generating Plant 3&4 Marked-up TS Bases Pages (Information only)

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Enclosure to NL-20-0170 Evaluation of Proposed Change

1.

SUMMARY

DESCRIPTION The proposed amendment would revise the Technical Specifications for:

x Vogtle Electric Generating Plant (VEGP) Units 1 and 2 renewed facility operating licenses NPF-68 and NPF-81, respectively, x Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2 renewed facility operating licenses NPF-2 and NPF-8, respectively, and x Vogtle Electric Generating Plant (VEGP), Units 3 and 4 combined licenses NPF-91 and NPF-92, respectively.

The proposed amendment would revise technical specification (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), to adopt the TS changes described in Appendix A or Appendix D (as applicable) of Westinghouse topical report WCAP-17661-P-A, Improved RAOC and CAOC FQ Surveillance Technical Specifications, Revision 1 (Ref. 1). To accurately facilitate the incorporation of the improved relaxed axial offset control (RAOC) or Constant Axial Offset Control (CAOC) surveillance formulations (as applicable), the proposed change includes, to the extent necessary, the adoption of several technical specification task force (TSTF) change travelers to align the VEGP and FNP TS with the FQ formulations and required actions of TS 3.2.1B of NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 4, (STS) upon which the improved RAOC and CAOC surveillance formulations were based.

The following NRC approved TSTF change travelers are proposed for adoption, as applicable to TS 3.2.1:

x TSTF-99-A, Rev. 0, Extend the Completion Time for Fq(w) not within limits from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months x TSTF-241-A, Rev. 4, Allow time for stabilization after reducing power due to QPTR out of limit x TSTF-290-A, Rev. 0, Revisions to hot channel factor specifications Additionally, this change would modify VEGP 1&2 and FNP 1&2 TS 5.6.5, Core Operating Limits Report (COLR), and VEGP 3&4 TS 5.6.3, Core Operating Limits Report (COLR), to include WCAP-17661-P-A, Revision 1, in the list of the NRC approved methodologies used to develop the cycle specific COLR.

Nine attachments are provided with this enclosure. Attachments 1 and 2 provide the marked-up TS pages and revised TS pages, respectively, for VEGP 1&2.

Attachments 3 and 4 provide the marked-up TS pages and revised TS pages, respectively, for FNP. Attachments 5 and 6 provide the marked-up TS pages and revised TS pages, respectively, for VEGP 3&4. Attachments 7, 8, and 9 contain the marked-up TS bases pages for VEGP 1&2, FNP 1&2, and VEGP 3&4, respectively, showing the accompanying proposed changes consistent with Appendix B or Appendix E (as applicable) of WCAP-17661-P-A, Revision 1, for information only.

Each proposed change in the marked-up TS and TS bases pages are annotated to show the TSTF change traveler or topical report WCAP-17661-P-A, or both, that effected the change.

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Enclosure to NL-20-0170 Evaluation of Proposed Change Internally controlled licensing basis documents such as the COLR, the TS Bases and the FSAR will be updated to reflect these changes at the time of implementation of the LAR.

2. DETAILED DESCRIPTION 2.1 System Design and Operation FQ(Z) is a measure of the peak fuel pellet power within the reactor core and 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. Limiting condition for operation (LCO) 3.2.1 provides limits on the values of FQ(Z) to limit the local (i.e., pellet) peak power density. FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and axial power distribution. Limits on FQ(Z) maintain the value of the initial total peaking factor assumed within that assumed in the accident analyses.

FQ(Z) is measured periodically using the incore detector system to derive a measured value for FQ(Z) which is compared to the limit to maintain peak power density within the value assumed in the operational analysis.

2.2 Current Technical Specification Requirements VEGP 1&2 and FNP 1&2 LCO 3.2.1 requires FQ(Z) shall be within the steady state and transient limits specified in the COLR in Mode 1. Required actions are provided for conditions when FQ(Z) is not within the steady state or transient limit. Surveillance requirements (SRs) verify the FQ(Z) is within the steady state and transient limitations at various points during a plant startup and on a frequency established in accordance with the TS surveillance frequency control program.

TS 5.6.5.b lists specific NRC approved documents describing analytical methods used to determine the core operating limits, including heat flux hot channel factor limits.

VEGP 3&4 LCO 3.2.1 requires FQ(Z) shall be within the limits specified in the COLR in Mode 1 with THERMAL POWER 25% RTP and with On-Line Power Distribution Monitoring System (OPDMS) not monitoring parameters. Required actions are provided for conditions when FQ(Z) is not within the approximations provided for the steady state or transient limits. Surveillance requirements (SRs) verify the FQ(Z) is within the approximations provided for the steady state and transient limitations at various points during a plant startup and on a frequency of 31 effective full power days (EFPD) thereafter.

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Enclosure to NL-20-0170 Evaluation of Proposed Change TS 5.6.3.b lists specific NRC approved documents describing analytical methods used to determine the core operating limits, including heat flux hot channel factor limits.

2.3 Reason for Proposed Change In February 2019, WCAP-17661-P-A (Ref. 1) was approved by the NRC providing improved RAOC and CAOC methods of calculating heat flux hot channel factor to resolve non-conservative issues identified and described in Westinghouse Nuclear Safety Advisory Letter (NSAL) 09-5 and NSAL-15-1 (Refs. 2 and 3, respectively).

SNC determined that the VEGP and FNP TSs were non-conservative with relation to the FQ surveillance formulations. Therefore, the proposed VEGP 1&2 and FNP 1&2 amendment to update TS 3.2.1 consistent with TS 3.2.1B of the STS, Rev. 4 and adopt the TS changes described Appendix A of WCAP-17661-P-A, and the proposed VEGP 3&4 amendment to adopt the TS 3.2.1 changes described Appendix D of WCAP-17661-P-A, are needed to resolve these non-conservative TS requirements. The change to VEGP 1&2 and FNP 1&2 TS 5.6.5 and VEGP 3&4 TS 5.6.3 is needed to appropriately apply the improved method of calculating heat flux hot channel factor to the plant cycle specific COLRs.

2.4 Description of Proposed Change A. The proposed change would modify the following for VEGP 1&2 and FNP 1&2:

TS 3.2.1 Changes x Global Changes Where the TS actions and surveillance requirements refer to steady state in conjunction with FQ(Z), the proposed change deletes both FQ(Z) and steady C

state and replaces them with a common term FQ (Z).

Where the TS actions and surveillance requirements refer to transient in conjunction with FQ(Z), the proposed change deletes both FQ(Z) and W

transient and replaces them with a common term FQ (Z).

x VEGP only - TS 3.2.1 title is revised to delete (FQ Methodology).

x LCO 3.2.1 is revised to state (addition in italics and deletion in strikeout text):

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

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Enclosure to NL-20-0170 Evaluation of Proposed Change x Action A Two notes are added. Note 1 states: Required Action A.4 shall be completed whenever this Condition is entered. Note 2 states: SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after refueling.

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

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

after each FQ (Z) determination.

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

Perform SR 3.2.1.1 and SR 3.2.1.2.

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

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

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

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

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

FQ (Z) determination, Required Action B.2.2 states Reduce AFD limits by amount specified in the COLR, with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each W

FQ (Z) determination, Required Action B.2.3 states Reduce Power Range Neutron Flux High trip setpoints 1% for each 1% THERMAL POWER is limited below RTP by Required Action B.2.1, with a completion time of 72 W

hours after each FQ (Z) determination, Required Action B.2.4 states Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action B.2.1, with a completion time of 72 W

hours after each FQ (Z) determination, and Required Action B.2.5 states Perform SR 3.2.1.1 and SR 3.2.1.2, with a completion time of Prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

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Enclosure to NL-20-0170 Evaluation of Proposed Change A note modifies Required Action B.2.1 stating Required Action B.2.5 shall be completed whenever Required Action B.2.1 is performed.

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

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

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

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

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

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

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

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

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Enclosure to NL-20-0170 Evaluation of Proposed Change FNP only - Specification 5.6.5.a listing of Specifications for which core operating limits must be established is revised for items 5, 6 and 8 from:

5. Control Bank Insertion Limit for LCO 3.1.6,

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

8. Axial Flux Limits for LCO 3.2.3, to:

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

6. Heat Flux Hot Channel Factor FQRTP limit, K(Z) figure, T(Z)COLR values, and RAOC Operating Spaces for LCO 3.2.1,

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

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

TS 3.2.1 Changes x Condition A A second note is added to the entry Condition. Note 2 states: SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 75% RTP after refueling.

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

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

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

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

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

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Enclosure to NL-20-0170 Evaluation of Proposed Change Required Action B.1.2 states Perform SR 3.2.1.1 and SR 3.2.1.2, with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

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

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

FQ (Z) determination.

A note modifies Required Action B.2.1 stating Required Action B.2.3 shall be completed whenever Required Action B.2.1 is performed.

Required Action B.2.2 states Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RTP by Required Action W

B.2.1, with a completion time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQ (Z) determination.

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

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

The first frequency of SR 3.2.1.3 from Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER C

at which FQ (Z) was last verified, to Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER C

at which FQ (Z) was last verified.

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

The first frequency of SR 3.2.1.4 from Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER W

at which FQ (Z) was last verified, to Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER W

at which FQ (Z) was last verified.

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Enclosure to NL-20-0170 Evaluation of Proposed Change TS 5.6.3 Change Westinghouse topical report WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019 is added to the list of documents (as Item 8) describing the analytical methods used to determine the core operating limits specified in Specification 5.6.3.b of the VEGP Units 3 and 4 TS since as noted in the WCAP Appendix F, Section F.1, this methodology is now used to develop COLR input for TS 3.1.6, TS 3.2.1, and TS 3.2.3.

3. TECHNICAL EVALUATION A. The following information applies to the proposed changes for VEGP 1&2 and FNP 1&2:

3.1 Background

The purpose of TS 3.2.1 is to provide assurance that the heat flux hot channel factor FQ(Z), remains within the limits assumed in the plant safety analyses when the core is operated within its allowed operating space. Key operating space limits include:

x rated thermal power (RTP),

x control bank rod insertion limits, and x axial flux difference (AFD) limits.

Together, these operating space limits restrict the range of potential non-equilibrium core power shapes during normal operation, thereby limiting the maximum non-equilibrium FQ(Z).

The current FQ formulation relies on a combination of analytical factors and periodic measurements to provide assurance that core operation within the allowed operating space will be acceptable. When an FQ surveillance is performed, the equilibrium FQ(Z) is measured at or near steady-state conditions.

FQ(Z) is then multiplied by an analytical factor, W(Z), which characterizes the increase in FQ(Z) for non-equilibrium operation. The result, when uncertainties are included, is the maximum postulated transient FQ(Z), which is then compared to the FQ(Z) limit.

The FQ formulation has been shown to be problematic for plants that use the relaxed axial offset control (RAOC) methodology. The accuracy of the analytically derived W(Z) values is sensitive to how well the surveillance axial power shape is predicted. While the predicted axial power shape can be inaccurate under nominal full power conditions, the accuracy of predicting the axial power shape for part-power surveillances is even more problematic.

Additionally, the current required action of TS 3.2.1, to reduce the AFD limits if the transient FQ limit is not met, may be insufficient to maintain the peaking factor basis assumed in the licensing basis analysis for operating conditions.

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Enclosure to NL-20-0170 Evaluation of Proposed Change Westinghouse NSAL-09-5 and NSAL-15-1 (Refs. 2 and 3, respectively) document specific issues with regards to these general problems with the current TS. NSAL-09-5 notified Westinghouse customers of an issue associated with the required actions for Condition B of STS 3.2.1B, Heat Flux Hot Channel Factor (FQ(Z)

(RAOC-W(Z) Methodology), for plants that have implemented the RAOC W

methodology. In certain situations where transient FQ (Z) is not within its limit, the W

existing required actions may be insufficient to restore FQ (Z) to within its limit.

NSAL-09-5 provided clarification regarding the applicability of the recommended interim actions to address this issue in accordance with NRC Administrative Letter 98-10, Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety.

NSAL-15-1 notified Westinghouse customers of an issue associated with STS 3.2.1B and 3.2.1C (Heat Flux Hot Channel Factor (FQ(Z)). Specifically, STS SR 3.2.1.2 in STS 3.2.1B and 3.2.1C may not ensure that the transient FQ meets the LCO limit between the performance of the 31 effective full power days flux map measurements, under some conditions, for those plants that use the W(Z) FQ surveillance methodology.

Therefore, because of the issues identified in NSAL-09-5 and NSAL-15-1, SNC determined that TS 3.2.1 for VEGP Units 1 and 2 and FNP Units 1 and 2 constitute a non-conservative TS and entered this into the respective plants corrective action program. SNC implemented the NSAL-09-5 and NSAL-15-1 interim actions procedurally for both VEGP units and FNP units.

The improved FQ surveillance methodology in WCAP-17661-P-A, Rev. 1 (Ref. 1) resolves the issues described herein. The new surveillance methodology requires the measurement of FXY(Z), which is then multiplied by factors that characterize the maximum transient P(Z) values postulated to occur during non-equilibrium operation. This formulation essentially eliminates the sensitivity of the surveillance to the surveillance axial power shape. Additionally, the improved FQ surveillance methodology incorporates various RAOC operating spaces, consisting of combinations of control bank rod insertion, AFD, and thermal power limits that provide sufficient FQ margin for future operation.

3.2 Current Licensing Basis As stated in Subsection 4.3.2.2.6 of the VEGP Units 1 and 2 and FNP Units 1 and 2 FSARs, FQ is calculated using the RAOC methodology defined in WCAP-10216-P-A, Revision 1A, "Relaxation of Constant Axial Offset Control, FQ Surveillance Technical Specification, (Ref. 4) February 1994.

SNC is adopting the NRC-approved improved FQ surveillance methodology specified in WCAP-17661-P-A, Rev. 1 for VEGP Units 1 and 2 and FNP Units 1 and 2 to resolve the non-conservative issues identified in Westinghouse NSAL-09-5, Revision 1, and NSAL-15-1.

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Enclosure to NL-20-0170 Evaluation of Proposed Change 3.3 NUREG-1431, Rev. 4 Alignment C W TS 3.2.1B presents FQ(Z) in terms of FQ (Z) and FQ (Z) in NUREG-1431, Rev. 4.

C W The VEGP and FNP TS refer to terms FQ (Z) and FQ (Z) as steady state and transient, respectively. To more accurately align the VEGP and FNP specifications with the STS, the LCO is revised to include, as approximated by C W FQ (Z) and FQ (Z), and references to steady state and transient have been revised to refer to the equivalent STS term. These changes to the LCO, actions, and surveillance requirements are administrative with no technical impact to the TS requirements.

VEGP only - The first frequency of SR 3.2.1.1 is modified to be consistent with the frequency specified in STS 3.2.1B. The current frequency was approved by the NRC on September 19, 1991, as part of the initial loading of VANTAGE-5 fuel into VEGP Unit 1. The current frequency was adopted for both the steady state and transient limit surveillances allowing deletion of the surveillance note.

WCAP-17661-P-A, Appendix A, proposes deletion of the same SR note in STS 3.2.1B and proposes additional modifications to the frequencies of SRs 3.2.1.1 and 3.2.1.2 to resolve non-conservative issues identified in Westinghouse advisory letters NSAL-09-5 and NSAL-15-1 (Refs. 2 and 3, respectively). Therefore, the change to the first frequency of SR 3.2.1.1 in the VEGP TS is being proposed to align the frequency with the SR frequency of TS 3.2.1B in NUREG-1431, Rev. 4, upon which the improved RAOC surveillance formulations were based.

Several TSTF change travelers have been incorporated into TS 3.2.1B in previous revisions to NUREG-1431. To align the VEGP and FNP TS with the FQ formulations and required actions of TS 3.2.1B in NUREG-1431, Rev. 4, upon which the improved RAOC surveillance formulations were based, this change includes the adoption of several TSTF change travelers as described herein.

3.4 TSTF Change Traveler Adoption and Variations The following NRC approved TSTF change travelers are proposed for adoption, to the extent necessary, to align the VEGP and FNP TS with the FQ formulations and required actions of TS 3.2.1B of NUREG-1431, Rev. 4, upon which the improved RAOC surveillance formulations were based.

TSTF-99-A For VEGP TS 3.2.1, the completion time to reduce AFD limits associated with Required Action B.1 was originally 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , consistent with a previous version of STS LCO 3.2.1B. TSTF-99-A changed the completion time of STS 3.2.1B, Required Action B.1 from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months on the basis that the same action in STS LCO 3.2.1A was specified as 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . This TSTF change traveler was approved by the NRC on September 18, 1996, and incorporated in NUREG-1431, Rev. 2 in June 2001. A Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to reduce the thermal power and axial flux difference (AFD) limits in an orderly manner. Thus, the change from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is being proposed in Required Action B.2.1 and B.2.2 to be consistent with the Completion Time associated with E-10

Enclosure to NL-20-0170 Evaluation of Proposed Change NUREG-1431, Rev. 4. A number of Westinghouse PWR plants that use RAOC methodology allow 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to reduce AFD limits or thermal power when FQW(Z)

(i.e., FQ transient limit) is not within limits: for examples; FNP Units 1 and 2, Prairie Island Units 1 and 2, Byron Units 1 and 2, Braidwood Units 1 and 2, Comanche Peak Units 1 and 2, Diablo Canyon Units 1 and 2, and Beaver Valley Units 1 and 2.

There are no variations to this TSTF change traveler, however, the proposed changes to the required actions of Condition B specified in Appendix A of WCAP-17661-P-A, Rev. 1 supplant this change.

TSTF-241-A TSTF-241-A was approved by the NRC on January 13, 1999, and incorporated in NUREG-1431, Rev. 2 in June 2001. NUREG-1431, LCO 3.2.1B, was revised to provide more appropriate actions and surveillances. Required Actions A.1, A.2, and A.3 of LCO 3.2.1B were modified to be repeated after each subsequent FQC(Z) determination if FQC(Z) was not within the limit. This ensured that actions were continued until the parameter was restored to within its limit. The maximum allowable power level and trip setpoint reductions initially determined by Required Actions A.1, 2, and 3 may be affected by subsequent determinations of FQC(Z) and would require power and setpoint reductions within the specified time period of the FQC(Z) determination, if necessary to comply with the decreased maximum allowable power level and trip setpoint. Decreases in FQC(Z) would allow increasing the maximum allowable power level and trip setpoints and raising power and setpoints to the revised limits.

The following plant specific variations include:

x TSTF-95-A, Revise completion time for reducing Power Range High trip setpoint from 8 to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , modified the completion time of Required Action A.2 in TS 3.2.1B from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This TSTF change traveler was approved by the NRC for incorporation in NUREG-1431, Rev. 2 in September 1996. This TSTF change traveler was adopted for VEGP on June 9, 2016, in License Amendments 180 and 161, Units 1 and 2, respectively (NRC Agencywide Documents Access and Management System (ADAMS)

Accession No. ML15132A569) and for FNP on November 30, 1999, in License Amendments 146 and 137, Units 1 and 2, respectively (NRC ADAMS Accession No. ML993500015).

x This proposed change is not requesting adoption of the TSTF-241 changes associated with TS 3.2.4, QUADRANT POWER TILT RATIO (QPTR).

Therefore, TSTF-241 markup pages of TS 3.2.4 are not provided.

x TSTF-241 Inserts B.2 and B.3, in the TS bases markup, incorrectly refer to Required Actions A.3 and A.4 respectively. These references appear to be an error in the TSTF change traveler when copying text from Inserts A3 and A4.

The proposed TS bases changes refer to the correct required actions (Required Actions A.2 and A.3, respectively).

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Enclosure to NL-20-0170 Evaluation of Proposed Change The plant-specific variations to TSTF-241-A are considered administrative variations or changes previously approved and incorporated in the VEGP and FNP plant licenses. These variations have no adverse impact that precludes adoption of this TSTF change traveler to TS 3.2.1.

TSTF-290-A TSTF-290-A was approved by the NRC on June 30, 1999, and incorporated in NUREG-1431, Rev. 2 in June 2001. TSTF-290-A revised STS 3.2.1B, along with STS 3.2.1A, to reflect the approved methodologies and also added a new STS 3.2.1C to reflect that methodology.

Some Westinghouse designed cores began experiencing increases in the measured FQ(Z) between monthly flux maps over certain burnup ranges.

Therefore, for cores predicted to have larger increases in FQ(Z) over certain burnup ranges, a larger penalty factor was necessary. The NRC accepted the changes to STS TS 3.2.1B as documented in NRC acceptance letter for referencing the revised version of licensing topical report WCAP-10216, Rev. 1 "Relaxation of Constant Axial Offset Control - FQ Surveillance Technical Specification," from Thandani (NRC) to Liparulo (Westinghouse), dated November 26, 1993 (Ref. 4).

In proposing a new Action B for STS 3.2.1B and 3.2.1C, the completion times for Required Actions B.1 and B.2 were increased to be consistent with those specified in TSTF-99-A and TSTF-95-A.

The requirement to perform SR 3.2.1.2 was added to Required Action A.4 to be performed prior to increasing thermal power above the limit of Required Action A.1 to ensure that core conditions during operation at higher power levels are consistent with safety analyses assumptions, specifically FQ(Z) transient limits.

A note was added to Conditions A and B to require completion of Required Actions A.4 and B.4, respectively, to ensure the appropriate surveillances were performed prior to increasing thermal power above the limit of Required Action A.1 [B.1] even when Condition A [B] is exited prior to performing Required Action A.4 [B.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 above the required limit.

The following plant specific variations include:

x VEGP Only - The change from FQ Methodology to RAOC-W(Z)

Methodology is not incorporated into the title and header to VEGP TS 3.2.1.

Instead, the reference to (FQ Methodology) in the title of TS 3.2.1 and bases is being deleted. The description of the specific methodology in TSTF-290-A and NUREG-1431 is used to distinguish between the heat flux hot channel factor methodologies specified in STS 3.2.1A, 3.2.1B, and 3.2.1C. It is unnecessary to specify the methodology in the plant-specific specification title and header. This change is consistent with other specifications that do not provide the specific NUREG-1431 type in the plant-specific specification title E-12

Enclosure to NL-20-0170 Evaluation of Proposed Change and header (e.g., STS 3.3.1A, Reactor Trip System (RTS) Instrumentation (Without Setpoint Control Program), STS 3.3.1B, Reactor Trip System (RTS)

Instrumentation (With Setpoint Control Program), STS 3.6.4A, Containment Pressure (Atmospheric, Dual, and Ice Condenser), STS 3.6.4B, Containment Pressure (Subatmospheric), STS 3.6.6.C, Containment Spray System (Ice Condenser), and Quench Spray (QS) System (Subatmospheric)).

x TS ACTION A Note and TS ACTION B Insert 1 are revised to incorporate changes from WCAP-17661-P-A, Rev. 1, Appendix A. Refer to Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations, herein for further plant-specific variations.

x Note, this variation is superseded by WCAP-17661-P-A, Appendix B: TSTF-290 Insert Note B, in the TS bases markup, incorrectly refers to Condition A.

This reference appears to be an error in the TSTF change traveler when copying text from Insert Note A. The proposed TS bases changes refer to the correct condition (Condition B).

x Corresponding changes to TS 5.6.5 are not included in TSTF-290 but are necessary to reflect the use of the WCAP-17661 methodology for development of core operating limits.

x TSTF-290 Insert 4, in the TS bases markup, is a bracketed [ ] NRC reviewers note for NUREG-1431. This insert is not included in the plant-specific TS bases.

The plant-specific variations to TSTF-290-A are considered administrative variations and have no adverse impact that precludes adoption of this TSTF change traveler.

3.5 Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations SNC has reviewed the NRC safety evaluation (SE) provided in the NRC letter to Westinghouse Electric Company dated November 23, 2018 (Ref. 6) that supported approval of WCAP-17661-P-A, Revision 1 (Ref. 1). SNC has concluded that the STS 3.2.1B and accompanying bases changes provided in Appendices A and B of the WCAP and the justification of changes provided in Sections 4.2 through 4.8 of the SE are applicable to VEGP Units 1 and 2 and FNP Units 1 and 2. A list is provided herein of plant-specific variations to the proposed TS changes in Appendix A of WCAP-17661-P-A, Rev. 1 with justification for the variations:

1. VEGP only - The change from RAOC-W(Z) Methodology to RAOC-T(Z)

Methodology is not incorporated into the title and header to VEGP TS 3.2.1.

The description of the specific methodology in NUREG-1431 is used to distinguish between the heat flux hot channel factor methodologies specified in STS 3.2.1A, 3.2.1B, and 3.2.1C. It is unnecessary to specify this methodology in the plant-specific specification title and header. This change is consistent with other specifications that do not provide the specific NUREG-1431 type in the plant-specific specification title and header (e.g., STS 3.3.1A, Reactor Trip E-13

Enclosure to NL-20-0170 Evaluation of Proposed Change System (RTS) Instrumentation (Without Setpoint Control Program), STS 3.3.1B, Reactor Trip System (RTS) Instrumentation (With Setpoint Control Program), STS 3.6.4A, Containment Pressure (Atmospheric, Dual, and Ice Condenser), STS 3.6.4B, Containment Pressure (Subatmospheric),

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

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

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

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

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

4. VEGP only - The Note to the Surveillance Requirements is not included in VEGP TS 3.2.1. Therefore, it is not annotated for deletion.

5. The addition to the Condition A note and the note to proposed required action B.2.1 are modified. The phrase, prior to increasing THERMAL POWER above the limit of Required Action A.1 [B.2.1], is not included in these notes because it is redundant to the completion time of Required Action A.4 [B.2.4] to which the note refers.

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Enclosure to NL-20-0170 Evaluation of Proposed Change Embedding a completion time of a required action in a note is inappropriate and could create unintended consequences due to the verboseness. This additional wording was added as a response to NRC RAI No. 10 to WCAP-17661-P-A due to mis-understanding of the application of the Condition note as it relates to LCO 3.0.2. LCO 3.0.2 states that if the LCO is met or is no longer applicable prior to expiration of the specified completion time(s),

completion of the required action(s) is not required unless otherwise stated.

The note to Condition A [Required Action B.2.1] is an example of unless otherwise stated, and requires Required Action A.4 [B.2.4] to be performed, within the required completion time [emphasis added], when Condition A is entered [Required Action B.2.1 is performed] regardless of whether LCO 3.2.1 is subsequently met as a result of the power reduction required by Required Action A.1 [B.2.1]. Therefore, it is not necessary to repeat the action completion time in the note and thus, the additional phrase is not included in the plant specific TS.

The additional wording does not make the note more explicit as indicated in Section 4.2 of the WCAP-17661-P-A SE. Rather, with the additional wording proposed for Condition A in Appendix A of the WCAP, one could confuse the requirement that the required action is only required to be completed when the condition is entered prior to increasing thermal power above the limit.

Typically upon entry into the condition, no power reduction has occurred. As a result, one could misinterpret the requirement as not being required since a power reduction has not occurred. The intent of the note to Condition A is to ensure the specified required action is performed within its associated completion time [emphasis added] whenever the condition is entered even if the LCO is subsequently met as a result of a power reduction. The intent of this type of note is clearly defined in LCO 3.0.2 and the associated bases and further clarified in the bases of TS 3.2.1.

The additional wording regarding prior to increasing THERMAL POWER was not included in a similar TS change for North Anna Units 1 and 2 TS, which was approved in Amendments 278 and 261, respectively, on October 17, 2016 (NRC ADAMS Accession No. ML16252A478) (Ref. 7). This variation is considered administrative with the benefit of reducing the possibility of unintended consequences by improving and simplifying readability of the intended requirement, which is to ensure that SR 3.2.1.1 and SR 3.2.1.2 are performed within the required completion time (i.e., prior to increasing thermal power above the limit) even if the LCO is subsequently met (i.e., FQ(Z) restored to within limits).

6. The second sentence of the addition to Condition A note is separated into a separate note (Note 2) to Condition A, and revised appropriately to address this change in format. This change is made for clarity of the user. Changed NOTE to NOTES and numbered the two notes. TS bases are revised to reflect two notes to Condition A. Section 2.1.4 of the ISTS Writers Guide (Ref. 5) states that when more than one issue is addressed in a note, separate the items as an ordered list. In addition, Section 3.3.1.a of the ISTS Writers Guide states that the use of compound sentences that combine related actions or thoughts should be minimized and do not combine unrelated actions or E-15

Enclosure to NL-20-0170 Evaluation of Proposed Change thoughts into a compound sentence. Separating the requirement to complete a required action when the Condition is entered and the allowance to not perform a surveillance under certain conditions into two separate notes disconnects these two unrelated thoughts.

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

7. Deleted unnecessary use of articles the and a in several instances of the TS markups in accordance with Sections 3.1.1.e and 4.1.6.d of the ISTS Writers Guide (Ref. 5). Consistent with the concept conveyed in Sections 3.1.1.e and 4.1.6.d of the ISTS Writers Guide, additional descriptors (i.e., its and that) are deleted in the TS actions since these words are not required to understand the requirement. This variation is a presentation preference, considered administrative, and does not alter the intent of the affected requirements.

8. By combining two actions, the wording of Required Action B.2.1 in Appendix A of WCAP-17661-P-A could be mis-read as limit thermal power to less than rated thermal power, which is already required by the plant operating license rendering the action redundant. Proposed Required Action B.2.1 is revised to more clearly reflect the intent of the action to limit thermal power to less than the rated thermal power by the amount specified in the COLR. To further reduce confusion, the requirement to reduce the AFD limits by the amount specified in the COLR is revised to be a separate required action (Required Action B.2.2) with a completion time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . Subsequent required actions are re-numerated and TS bases associated with the change are revised to reflect two separate actions. Section 3.3.1.a of the ISTS Writers Guide (Ref. 5) states that the use of compound sentences that combine related actions or thoughts should be minimized and do not combine unrelated actions or thoughts into a compound sentence. Separating the requirement to limit thermal power and the requirement to reduce AFD limits into two separate actions disconnects these two distinct actions.

Specifying separate actions of reducing thermal power and reducing AFD limits was approved for North Anna Units 1 and 2 TS in Amendments 278 and 261, respectively, on October 17, 2016 (NRC ADAMS Accession No. ML16252A478) (Ref. 7). This variation is considered administrative and continues to meet the intent of the requirement specified in Appendix A of WCAP-17661-P-A.

9. The Frequency of SR 3.2.1.2 is revised to include the phrase after achieving equilibrium conditions consistent with other Surveillances that are required after a power change. As noted in the WCAP proposed Bases for SR 3.2.1.1, the equilibrium conditions are needed after the power level change since these are the intended operating conditions for performing the Surveillance.

10. The change to list WCAP-17661-P-A in the COLR Specification is not discussed in the SER but is consistent with the changes identified in the WCAP.

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Enclosure to NL-20-0170 Evaluation of Proposed Change VEGP only - The change to delete the parenthetical phrase identifying the Heat Flux Hot Channel Factor as the (W(Z) surveillance requirements for FQ Methodology) is consistent with the change from W(Z) methodology as discussed in WCAP-17661-P-A, Sections 3.1 and 4.

FNP only - The changes to identify the inclusion of RAOC Operating Spaces and the change from W(Z) values to T(Z)COLR values, and from FQ RTP limits to a single FQ RTP limit consistent with the change from W(Z) methodology as discussed in WCAP-17661-P-A, Sections 3.1 and 4, and with the identification of a single FQ RTP limit in the COLR.

3.6 WCAP-17661-P-A, Rev. 1 Approval Limitations Chapter 5.0 of the WCAP-17661-P-A, Rev. 1 SE includes two limitations, adherence to which are necessary to ensure acceptable implementation of the WCAP-17661. SNC has reviewed the limitations and determined that the limitations apply to VEGP and FNP. SNC complies with the SE limitations, as described herein, for VEGP Units 1 and 2 and FNP Units 1 and 2.

Limitation 1: Use of AXY and AQ As discussed in Section 4.1.1 of the WCAP-17661-P-A, Rev. 1 SE, the use of Methods 1 and 2 are acceptable for calculating AXY and AQ when performing RAOC and constant axial offset control (CAOC) W(Z) surveillances, respectively, subject to the limitations provided herein. VEGP and FNP utilize the RAOC methodology; therefore, the limitations associated with calculating AXY will apply to the VEGP Units 1 and 2 and FNP Units 1 and 2 TS. The WCAP-17661-P-A, Rev. 1 SE limitations are listed as follows:

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

SNC uses NRC-approved methods to perform the surveillance-specific AXY calculations for VEGP Units 1 and 2 and FNP Units 1 and 2.

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

SNC performs depletion calculations to determine the numerator and denominator of the AXY factor similarly to the original design calculations, that is, either with the BEACONTM core monitoring system without using nodal calibration factors, or with Advanced Nodal Code using the same nuclear model and depletion basis used to generate the original T(Z) function.

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 E-17

Enclosure to NL-20-0170 Evaluation of Proposed Change Offset must be within 1.5-percent of the target AO, and there must be W

assurance that the limiting FQ (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.

This limitation applies to plants that utilize the CAOC methodology and does not apply to the VEGP and FNP TS, which use the RAOC methodology.

Limitation 2: Power Level Reduction to 50 Percent RTP As noted in Section 4.3.2 of this SE, the use of 50 percent 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 percent, must be implemented on a plant-specific basis and included in COLR input generated using this methodology, in order to use this TR.

SNC is applying a final power level of 50% RTP in the event of a failed FQ surveillance. This is on a plant-specific basis for VEGP and FNP and included in COLR input generated using this methodology upon implementing the topical report at VEGP Units 1 and 2 and FNP Units 1 and 2.

B. The following information applies to the proposed changes for VEGP 3&4:

3.1 Background

The purpose of TS 3.2.1 is to provide assurance that the heat flux hot channel factor FQ(Z), remains within the limits assumed in the plant safety analyses when the core is operated within its allowed operating space. Key operating space limits include:

x rated thermal power (RTP),

x control bank rod insertion limits, and x axial flux difference (AFD) limits.

Together, these operating space limits restrict the range of potential non-equilibrium core power shapes during normal operation, thereby limiting the maximum non-equilibrium FQ(Z).

The current FQ formulation relies on a combination of analytical factors and periodic measurements to provide assurance that core operation within the allowed operating space will be acceptable. When an FQ surveillance is performed, the equilibrium FQ(Z) is measured at or near steady-state conditions.

FQ(Z) is then multiplied by an analytical factor, W(Z), which characterizes the increase in FQ(Z) for non-equilibrium operation. The result, when uncertainties are included, is the maximum postulated transient FQ(Z), which is then compared to the FQ(Z) limit.

The FQ formulation has been shown to be problematic for plants that use the relaxed axial offset control (RAOC) methodology. The accuracy of the analytically E-18

Enclosure to NL-20-0170 Evaluation of Proposed Change derived W(Z) values is sensitive to how well the surveillance axial power shape is predicted. While the predicted axial power shape can be inaccurate under nominal full power conditions, the accuracy of predicting the axial power shape for part-power surveillances is even more problematic.

Additionally, the current required actions of TS 3.2.1, to reduce the power if the transient FQ limits are not met, may be insufficient to maintain the peaking factor basis assumed in the licensing basis analysis for operating conditions.

NSAL-15-1 notified Westinghouse customers of an issue associated with TS 3.2.1 (Heat Flux Hot Channel Factor (FQ(Z)) which was determined to be applicable to the AP1000. Specifically, TS SR 3.2.1.4 may not be sufficient when performed on a frequency of 31 effective full power days to confirm that the transient FQ peaking factor limit would be consistent with that assumed in the licensing basis analysis under all conditions between surveillances.

Therefore, SNC determined that TS 3.2.1 for VEGP Units 3 and 4 constitutes a non-conservative TS and entered this issue into the corrective action program.

SNC implemented the NSAL-15-1 interim actions procedurally for VEGP Units 3 and 4.

The improved FQ surveillance methodology in WCAP-17661-P-A, Rev. 1 (Ref. 1) resolves the issues described herein.

3.2 Current Licensing Basis As stated in Subsection 4.3.2.2.6 of the VEGP Units 3 and 4 UFSAR, FQ is calculated using the RAOC methodology defined in WCAP-10216-P-A, Revision 1A, "Relaxation of Constant Axial Offset Control, FQ Surveillance Technical Specification, (Ref. 4) February 1994.

SNC is adopting the NRC-approved improved FQ surveillance methodology specified in WCAP-17661-P-A, Rev. 1 for VEGP Units 3 and 4 to resolve the non-conservative issues identified in Westinghouse NSAL-15-1.

3.3 TSTF Change Traveler Adoption and Variations The following NRC approved TSTF change travelers are proposed for adoption, to the extent necessary, to align the VEGP Units 3 and 4 TS with the basis for the improved FQ surveillance formulations.

TSTF-241-A and TSTF-290-A TSTF-241-A was approved by the NRC on January 13, 1999, and incorporated in NUREG-1431, Rev. 2 in June 2001. NUREG-1431, LCO 3.2.1B, was revised to provide more appropriate actions and surveillances. STS Required Actions A.1, A.2, and A.3 of LCO 3.2.1B were modified to be repeated after each subsequent FQC(Z) determination if FQC(Z) was not within the limit. This caused the actions to be repeated for each subsequent determination until the parameter was restored E-19

Enclosure to NL-20-0170 Evaluation of Proposed Change to within its limit. These changes have been previously incorporated into the Vogtle Units 3 and 4 TS 3.2.1 Required A.1 and A.2.

However, with the proposed revisions, proposed Required Actions B.2.1 and B.2.2 W

would be similarly affected by subsequent determinations of FQ (Z) and should similarly require power and setpoint reductions within the specified time period W

following the subsequent FQ (Z) determination, if necessary to comply with the decreased maximum allowable power level and trip setpoint.

Related to the above variation of TSTF-241, is TSTF-290-A which was approved by the NRC on June 30, 1999, and have been previously incorporated into the Vogtle Units 3 and 4 TS 3.2.1 Required B.1 and B.2. These Required Actions, which are the base of the proposed Required Actions B.2.1, B.2.2, and B.2.3, were first proposed while TSTF-241 was still under review and is the apparent reason for missing the impact of the subsequent determinations.

As such, the following plant specific variation of these TSTFs is requested:

x The Completion Time for proposed Required Actions B.2.1 and B.2.2 is proposed to be revised from the WCAP identified 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months W

respectively, to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each FQ (Z) determination and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after W

each FQ (Z) determination respectively, in order to address the subsequent determinations. Without these additions to the Completion Times, proposed Required Actions B.2.1 and B.2.2 would potentially be not met immediately upon each subsequent determination that occurs beyond the initial 4-hour or 72-hour Completion Time.

x Corresponding changes to TS 5.6.5 are not included in TSTF-290 but are necessary to reflect the use of the WCAP-17661 methodology for development of core operating limits.

The plant-specific variation to TSTF-241-A and TSTF-290-A is a variation consistent with the basis for changes previously approved and incorporated in the VEGP Units 3 and 4 TS.

3.4 Applicability of WCAP-17661-P-A, Rev. 1 Safety Evaluation and Variations SNC has reviewed the NRC safety evaluation (SE) provided in the NRC letter to Westinghouse Electric Company dated November 23, 2018 (Ref. 6) that supported approval of WCAP-17661-P-A, Revision 1 (Ref. 1). SNC has concluded that the STS 3.2.1B and accompanying bases changes provided in Appendices D and E of the WCAP and the justification of changes provided in Sections 4.2 through 4.8 of the SE are applicable to VEGP Units 3 and 4. A list is provided herein of plant-specific variations to the proposed TS changes in Appendix D of WCAP-17661-P-A, Rev. 1 with justification for the variations:

1. Uses of RATED THERMAL POWER in the TS markup of WCAP-17661-P-A Appendix A are changed to RTP. The abbreviation RTP is defined in the E-20

Enclosure to NL-20-0170 Evaluation of Proposed Change definition of RATED THERMAL POWER in Section 1.1 of the TS. Section 3.2.2.g of the ISTS Writers Guide (Ref. 5) states, for abbreviations already defined for terms of Section 1.1 of TS, the abbreviation should not be redefined on first time use (e.g., AFD, QPTR, COLR). This is also consistent with other uses of the abbreviation RTP throughout the STS and the VEGP and FNP TS. This variation is administrative in nature and continues to meet the intent of the requirements specified in Appendix A of WCAP-17661-P-A.

2. The addition to the Condition A note and the note to proposed required action B.2.1 are modified. The phrase, prior to increasing THERMAL POWER above the limit of Required Action A.1 [B.2.1], is not included in these notes because it is redundant to the completion time of Required Action A.4 [B.2.4] to which the note refers.

Embedding a completion time of a required action in a note is inappropriate and could create unintended consequences due to the verboseness. This additional wording was added as a response to NRC RAI No. 10 to WCAP-17661-P-A due to mis-understanding of the application of the Condition note as it relates to LCO 3.0.2. LCO 3.0.2 states that if the LCO is met or is no longer applicable prior to expiration of the specified completion time(s),

completion of the required action(s) is not required unless otherwise stated.

The note to Condition A [Required Action B.2.1] is an example of unless otherwise stated, and requires Required Action A.4 [B.2.4] to be performed, within the required completion time [emphasis added], when Condition A is entered [Required Action B.2.1 is performed] regardless of whether LCO 3.2.1 is subsequently met as a result of the power reduction required by Required Action A.1 [B.2.1]. Therefore, it is not necessary to repeat the action completion time in the note and thus, the additional phrase is not included in the plant specific TS.

The additional wording does not make the note more explicit as indicated in Section 4.2 of the WCAP-17661-P-A SE. Rather, with the additional wording proposed for Condition A in Appendix A of the WCAP, one could confuse the requirement that the required action is only required to be completed when the condition is entered prior to increasing thermal power above the limit.

Typically, upon entry into the condition, no power reduction has occurred. As a result, one could misinterpret the requirement as not being required since a power reduction has not occurred. The intent of the note to Condition A is to ensure the specified required action is performed within its associated completion time [emphasis added] whenever the condition is entered even if the LCO is subsequently met as a result of a power reduction. The intent of this type of note is clearly defined in LCO 3.0.2 and the associated bases and further clarified in the bases of TS 3.2.1.

The additional wording regarding prior to increasing THERMAL POWER was not included in a similar TS change for North Anna Units 1 and 2 TS, which was approved in Amendments 278 and 261, respectively, on October 17, 2016 (NRC ADAMS Accession No. ML16252A478) (Ref. 7). This variation is considered administrative with the benefit of reducing the possibility of unintended consequences by improving and simplifying readability of the E-21

Enclosure to NL-20-0170 Evaluation of Proposed Change intended requirement, which is to ensure that SR 3.2.1.1 and SR 3.2.1.2 are performed within the required completion time (i.e., prior to increasing thermal power above the limit) even if the LCO is subsequently met (i.e., FQ(Z) restored to within limits).

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

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

4. Deleted unnecessary use of the article the and a in several instances of the TS markups in accordance with Sections 3.1.1.e and 4.1.6.d of the ISTS Writers Guide (Ref. 5). Consistent with the concept conveyed in Sections 3.1.1.e and 4.1.6.d of the ISTS Writers Guide, additional descriptors (i.e., its and that) are deleted in the TS actions since these words are not required to understand the requirement. This variation is a presentation preference, considered administrative, and does not alter the intent of the affected requirements.

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

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

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Enclosure to NL-20-0170 Evaluation of Proposed Change

6. The Frequency of SR 3.2.1.2 is revised to include the phrase after achieving equilibrium conditions consistent with other Surveillances that are required after a power change. As noted in the WCAP proposed Bases for SR 3.2.1.1, the equilibrium conditions are needed after the power level change since these are the intended operating conditions for performing the Surveillance.

7. The change to list WCAP-17661-P-A in the COLR Specification 5.6.3 is not discussed in the SER but is consistent with the changes identified in the WCAP.

3.5 WCAP-17661-P-A, Rev. 1 Approval Limitations Chapter 5.0 of the WCAP-17661-P-A, Rev. 1 SE includes limitations, adherence to which are necessary to ensure acceptable implementation of the WCAP-17661.

SNC has reviewed the limitations and determined that the limitations apply to VEGP and FNP. SNC complies with the SE limitations, as described herein, for VEGP Units 3 and 4.

Limitation 1: Use of AXY and AQ As discussed in Section 4.1.1 of the WCAP-17661-P-A, Rev. 1 SE, the use of Methods 1 and 2 are acceptable for calculating AXY and AQ when performing RAOC and CAOC W(Z) surveillances, respectively, subject to the limitations provided herein. VEGP Units 3 and 4 utilize the CAOC methodology; therefore, the limitations associated with calculating AQ apply to the VEGP Units 3 and 4 TS.

The WCAP-17661-P-A, Rev. 1 SE limitations are listed as follows:

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

SNC uses NRC-approved methods to perform the surveillance-specific AQ calculations for VEGP Units 3 and 4.

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

SNC performs depletion calculations to determine the numerator and denominator of the AQ factor similarly to the original design calculations, that is, either with the BEACONTM core monitoring system without using nodal calibration factors, or with Advanced Nodal Code using the same nuclear model and depletion basis used to generate the original T(Z) function.

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 E-23

Enclosure to NL-20-0170 Evaluation of Proposed Change W

assurance that the limiting FQ (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.

SNC uses Method 1 for calculating AQ subject to the constraints discussed in the response to RAI 15.a. The surveillance Axial Offset (AO) must be within 1.5-W percent of the target AO, and assurance is provided that the limiting FQ (Z) location does not lie within a rodded elevation at the time of surveillance. Alternatively, the use of Method 1 may use surveillance-specific W(Z) functions.

Limitation 2: Power Level Reduction to 50 Percent RTP As noted in Section 4.3.2 of this SE, the use of 50 percent 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 percent, must be implemented on a plant-specific basis and included in COLR input generated using this methodology, in order to use this TR.

SNC is applying a final power level of 50% RTP in the event of a failed FQ surveillance. This is on a plant-specific basis for VEGP Units 3 and 4 and included in COLR input generated using this methodology upon implementing the topical report at VEGP Units 3 and 4.

4 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Technical Specifications (TS) are included in the Part 50 operating licenses and in the Part 52 combined licenses in accordance with 10 CFR 50.36. The TS include limiting conditions for operation which provide the lowest functional capability or performance levels of equipment required for safe operation of the facility. NRC Administrative Letter 98-10 indicates that when a TS is determined to be insufficient to assure plant safety, an amendment should be requested to revise the non-conservative TS. WCAP-17661-P was developed to provide revised TSs to resolve the non-conservatism. This WCAP-17661-P was reviewed and approved by the NRC as appropriate resolve the issue.

SNC has reviewed the NRC Safety Evaluation (SE) provided in the NRC letter to Westinghouse Electric Company dated November 23, 2018 (Ref. 6) that supported approval of WCAP-17661-P-A, Revision 1 (Ref. 1). SNC has concluded that the applicable regulatory performance and technical specification requirements and design criteria listed in Sections 2.1 and 2.2 of the SE are applicable to VEGP Units 1, 2, 3, and 4 and FNP Units 1 and 2.

The NRC concluded in the SE that the modified TS contained in WCAP-17661 are acceptable. Thus, the proposed change is consistent with the regulatory requirements identified in the SE. In particular, (1) the revised TS LCOs maintain facility operation within the bounds established by the safety analysis, (2) the E-24

Enclosure to NL-20-0170 Evaluation of Proposed Change reformulated SRs confirm that facility operation meets the LCOs, and (3) the revised required actions and completion times, applicable if the LCO is not met, are appropriate to restore compliance with the unmet LCO, and maintain safe facility operation.

Other changes are included based on Technical Specification Task Force (TSTF) travelers TSTF-99, TSTF-241, and TSTF-290. TSTF travelers identify revisions to the Standardized Technical Specification and represent NRC-approved changes for consideration with plant-specific Technical Specification amendments in order to streamline reviews and reduce unnecessary regulatory burden.

4.2 Precedent Approved license amendment requests associated with revising the heat flux hot channel factor utilizing the NRC approved methodology in WCAP-17661-P-A, recently included:

x Tennessee Valley Authority submittal on September 23, 2020 (ML20267A617) for Sequoyah, which was NRC approved on October 26, 2021 (ML21245A267).

x Pacific Gas and Electric submittal on August 31, 2020 (ML20244A192) for Diablo Canyon, which was NRC approved September 2, 2021 (ML21160A174).

x Nextera Energy submittal on August 17, 2020 (ML20230A425) for Seabrook, which was NRC approved September 22, 2021 (ML21190A177).

4.3 No Significant Hazards Consideration Determination Analysis Pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), Southern Nuclear Operating Company (SNC) hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Units 1 and 2 renewed facility operating licenses NPF-68 and NPF-81, respectively, to Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2 renewed operating licenses NPF-2 and NPF-8, respectively, and to VEGP Units 3 and 4 combined licenses NPF-91 and NPF-92, respectively.

The proposed change would revise technical specifications (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), to adopt the TS changes described in Appendix A or Appendix D, as applicable, of Westinghouse topical report WCAP-17661-P-A, Revision 1, to address the issues identified in Westinghouse Nuclear Safety Advisory Letter (NSAL) 5, Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, and NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance. The proposed change includes, to the extent necessary, the adoption of several pertinent technical specification task force change travelers as applicable to the TS for VEGP Units 1, 2, 3 and 4 and FNP Units 1 and 2. Additionally, the proposed change modifies the VEGP Units 1 and 2 and FNP Units 1 and 2 TS 5.6.5, Core Operating Limits Report (COLR),

and VEGP Units 3 and 4 TS 5.6.3, Core Operating Limits Report (COLR), to E-25

Enclosure to NL-20-0170 Evaluation of Proposed Change include WCAP-17661-P-A, Revision 1, in the list of the NRC approved methodologies used to develop the cycle specific COLR.

SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change resolves non-conservative TS required actions identified via Westinghouse NSAL-09-5, Revision 1. The proposed change also resolves non-conservative TS surveillance requirements identified via Westinghouse NSAL-15-1. Operation in accordance with the revised TS maintains the assumptions for initial conditions of key parameter values in the safety analyses as valid and does not result in actions that would increase the probability or consequences of any accident previously evaluated.

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

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

Response: No The proposed change does not involve a physical alteration of the plant (i.e.,

no new or different type of equipment will be installed). Operation in accordance with the revised TS and its limits precludes new challenges to systems, structures, or components that might introduce a new type of accident. Applicable design and performance criteria will continue to be met and no new single failure mechanisms will be created. The proposed change for resolution of Westinghouse NSAL-09-5, Revision 1 and NSAL-15-1 does not involve the alteration of plant equipment or introduce unique operational modes or accident precursors.

Therefore, the proposed change will 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 a margin of safety?

Response: No.

The margin of safety is related to the ability of the fission product barriers to perform their design functions during and following an accident. These barriers include the fuel cladding, the reactor coolant system, and the E-26

Enclosure to NL-20-0170 Evaluation of Proposed Change containment. The performance of these fission product barriers is not adversely affected by the proposed change.

The proposed change resolves non-conservative TS required actions identified via Westinghouse NSAL-09-5, Revision 1. The proposed change also resolves non-conservative TS surveillance requirements identified via Westinghouse NSAL-15-1. Operation in accordance with the revised TS maintains the assumptions for initial conditions of key parameter values in the safety analyses as valid. This confirms applicable design and performance criteria associated with the safety analysis will continue to be met and that the margin of safety is not adversely affected.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, SNC concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusions In 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 Commissions 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 ENVIRONMENTAL CONSIDERATION A review has determined that 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 Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6 REFERENCES

1. Westinghouse Topical Report WCAP-17661-P-A, Improved RAOC and CAOC FQ Surveillance Technical Specifications, Revision 1, February 2019 (NRC ADAMS Accession No. ML19225C081 - Nonproprietary version).

E-27

Enclosure to NL-20-0170 Evaluation of Proposed Change

2. Westinghouse Letter NSAL-09-5, Rev. 1, Relaxed Axial Offset Control FQ Technical Specification Actions, September 23, 2009.

3. Westinghouse Letter NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance, February 3, 2015.

4. Westinghouse Topical Report WCAP-10216, "Relaxation of Constant Axial Offset Control, FQ Surveillance Technical Specification, Revision 1A, February 1994.

(NRC ADAMS Accession Nos. 9311090186 & 9312090230 - Proprietary version).

5. Technical Specification Task Force Document TSTF-GG-05-01, Writers Guide for Plant-Specific Improved Technical Specifications, June 2005. (NRC ADAMS Accession No. ML070660229)

6. Letter from D. C. Morey (NRC) to Nowinowski (Westinghouse), Final Safety Evaluation for Pressurized Water Reactor Owners Group Topical Report WCAP-17661-P-A, Rev. 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications (CAC NO. MF3348), dated November 23, 2018.

7. North Anna Power Station, Units 1 and 2 - Issuance of Amendments to Revise Technical Specifications to Address Issues Identified in Westinghouse NSAL-09-5.

Revision 1, and NSAL-15-1, Revision 0 (CAC Nos. MF7186 and MF7187), dated October 17, 2016, ADAMS Accession No. ML16252A478.

E-28 to NL-20-0170 Vogtle Electric Generating Plant 1&2 Marked-up TS Pages Attachment 1 Vogtle Electric Generating Plant 1&2 Marked-up TS Pages (12 total pages including cover page)

)4 =

32:(5',675,%87,21/,0,76

TSTF-290-A

+HDW)OX[+RW&KDQQHO)DFWRU )4 = )40HWKRGRORJ\

/&2 )4 = VKDOOEHZLWKLQWKHVWHDG\VWDWHDQGWUDQVLHQWOLPLWVVSHFLILHGLQWKH

&2/5

, as approximated by FQC(Z) and FQW(Z),

NUREG-1431 TS 3.2.1B

$33/,&$%,/,7< 02'(

NUREG-1431 TS 3.2.1B FQC(Z)

$&7,216

&21',7,21 5(48,5('$&7,21 &203/(7,217,0(

$ )4 = QRWZLWKLQVWHDG\ $ 5HGXFH7+(50$/ PLQXWHV

VWDWHOLPLW 32:(5t573IRU

HDFK)4 = H[FHHGV

Insert 3.2.1-1 VWHDG\VWDWHOLPLW

NUREG-1431 FQC(Z)

TSTF-290-A $1' TS 3.2.1B WCAP-17661-P-A

$ 5HGXFH3RZHU5DQJH KRXUV

1HXWURQ)OX[²+LJKWULS

VHWSRLQWV tIRUHDFK

)4 = H[FHHGV after each FQC(Z)

VWHDG\VWDWHOLPLW determination WCAP-17661-P-A WCAP-17661-P-A $1' TSTF-241-A

$ 5HGXFH2YHUSRZHU'7 KRXUV

that THERMAL WULSVHWSRLQWVtIRU

POWER is limited HDFK)4 = H[FHHGV

below RATED VWHDG\VWDWHOLPLW

THERMAL WCAP-17661-P-A POWER by $1' RTP Required Action A.1 $ 3HUIRUP65 3ULRUWRLQFUHDVLQJ

7+(50$/32:(5

DERYHWKHOLPLWRI

and SR 3.2.1.2 5HTXLUHG$FWLRQ$

TSTF-290-A FRQWLQXHG 9RJWOH8QLWVDQG $PHQGPHQW1R 8QLW

$PHQGPHQW1R 8QLW

Insert 3.2.1-1 (TSTF-290-A, Insert NOTE A)

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

NOTES-----------

1. Required Action A.4 shall be completed whenever this Condition is entered.

prior to increasing THERMAL POWER above the limit of Required Action A.1.

2. 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.

)4 =

Insert 3.2.1-2 TSTF-290-A

WCAP-17661-P-A

$&7,216 FRQWLQXHG

&21',7,21 5(48,5('$&7,21 &203/(7,217,0(

TSTF-99-A

% )4 = QRWZLWKLQWUDQVLHQW % 5HGXFH$)'OLPLWV KRXUV OLPLW IRUHDFK)4 =

H[FHHGVWUDQVLHQWOLPLW 4 DQGFRQWURO$)'ZLWKLQ UHGXFHGOLPLWV

& 5HTXLUHG$FWLRQDQG & %HLQ02'( KRXUV DVVRFLDWHG&RPSOHWLRQ 7LPHQRWPHW

9RJWOH8QLWVDQG $PHQGPHQW1R 8QLW

$PHQGPHQW1R 8QLW

Insert 3.2.1-2 (TSTF-290-A, Insert 1)

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

W B. FQ (Z) not within limits. B.1.1 -----------NOTE------------

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

Implement a RAOC 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months operating space specified in the COLR W

that rRestores FQ (Z) to within its limits specified in the COLR.

AND B.1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

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

Required Action B.2.45 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each W

POWER to less than FQ (Z) determination RATED THERMAL POWER RTP by TSTF-241-A amount and reduce based CT AFD limits as specified in the COLR.

AND

B.2.2 Reduce AFD limits by 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each W

amount specified in the FQ (Z) determination COLR.

TSTF-241-A AND based CT B.2.23 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each Neutron Flux High W FQ (Z) determination trip setpoints 1% for each 1% that THERMAL POWER is TSTF-241-A limited below RTP based CT RATED THERMAL POWER by Required Action B.2.1.

AND B.2.34 Reduce Overpower T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each W

trip setpoints 1% for FQ (Z) determination each 1% that THERMAL POWER is TSTF-241-A limited below RTP based CT RATED THERMAL POWER by Required Action B.2.1.

AND B.2.45 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action B.2.1

prior to THERMAL FQ(Z)

NUREG-1431 TS 3.2.1B 3.2.1 POWER exceeding 75% RTP SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQ(Z) is within steady state limit. Once after each refueling after NUREG-1431 TS 3.2.1B achieving equilibrium conditions at any FQC(Z) power level exceeding 50% RTP AND WCAP-17661-P-A within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once after achieving equilibrium conditions after exceeding, by 20% RTP, the NUREG-1431 THERMAL POWER TS 3.2.1B NUREG-1431 TS 3.2.1B 10 at which FQ(Z) was last verified FQC(Z)

AND In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.2.1-3 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

FQ(Z) 3.2.1 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE-------------------------------

(Z)ºº F (Z)

If maximum over Z << Q >>

WCAP-17661-P-A ¬ K(Z) 1/4 has increased since the previous evaluation of FQ(Z): after achieving equilibrium conditions a

a. Increase FQ(Z) by an appropriate penalty factor specified in the COLR and verify this value is within the transient limits; or b

b. Repeat SR 3 2 1 2 once per 7 EFPD until either 3.2.1.2 a above is met or two successive surveillances a.

indicate F (Z) º within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after maximum over Z << Q >> THERMAL POWER

¬ K(Z) 1/4 exceeds 75% RTP has not increased increased.

Verify FQ(Z) is within transient limit.

Once after each NUREG-1431 TS 3.2.1B aft refueling after achievingg equilibrium e

FQC(Z) conditionss at a any power level vel exceeding 50% RTP P AND WCAP-17661-P-A (continued)

Vogtle Units 1 and 2 3.2.1-4 Amendment No. 212 21 (Unit 1)

Amendment No. 195 (Unit 2)

FQ(Z) 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.2.1.2 (continued) Once after achieving WCAP-17661-P-A equilibrium conditions after exceeding, by 20% RTP, the NUREG-1431 THERMAL POWER TS 3.2.1B NUREG-1431 TS 3.2.1B 10 at which FQ(Z) was last verified FQW(Z)

AND In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.2.1-5 Amendment No. 158 (Unit 1)

Amendment No. 140 (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements (continued) 5.6.5 Core Operating Limits Report (COLR)

a. Core operating limits shall be established prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR for the following:

LCO 3.1.1 "SHUTDOWN MARGIN" LCO 3.1.3 "Moderator Temperature Coefficient" LCO 3.1.5 "Shutdown Bank Insertion Limits" LCO 3.1.6 "Control Bank Insertion Limits" LCO 3.2.1 "Heat Flux Hot Channel Factor" LCO 3.2.2 "Nuclear Enthalpy Rise Hot Channel Factor" LCO 3.2.3 "Axial Flux Difference" LCO 3.9.1 "Boron Concentration"

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

WCAP-9272-P-A, "WESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY," July 1985 (W Proprietary). (Methodology for Moderator Temperature Coefficient, Shutdown Bank Insertion Limit, Control Bank Insertion Limits, and Nuclear Enthalpy Rise Hot Channel Factor.)

WCAP-10216-P-A, Revision 1A, "RELAXATION OF CONSTANT AXIAL OFFSET CONTROL FQ SURVEILLANCE TECHNICAL SPECIFICATION," February, 1994 (W Proprietary). (Methodology for Axial Flux Difference (Relaxed Axial Offset Control) and Heat Flux Hot Channel Factor (W(Z) surveillance requirements for FQ Methodology).)

WCAP-17661-P-A WCAP-10266-P-A, Revision 2, "The 1981 Version of the Westinghouse ECCS Evaluation Model Using the BASH Code," March 1987.

(W Proprietary) (Methodology for Axial Flux Difference (Relaxed Axial Offset Control) and Heat Flux Hot Channel Factor (W(Z) surveillance requirements for FQ Methodology).)

WCAP-13749-P-A, Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement, March 1997.

WCAP-16045-P-A, Qualification of the Two-Dimensional Transport Code PARAGON, August 2004 (Methodology for Moderator Temperature Coefficient.)

WCAP-16045-P-A, Addendum 1-A, Qualification of the NEXUS Nuclear Data Methodology, August 2007 (Methodology for Moderator Temperature Coefficient.)

(continued)

Vogtle Units 1 and 2 5.6-3 Amendment No. 182 (Unit 1)

Amendment No. 163 (Unit 2)

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Insert VEGP 5.6.5-1 WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019 (W Proprietary). (Methodology for Control Bank Insertion Limits, Heat Flux Hot Channel Factor, and Axial Flux Difference (Relaxed Axial Offset Control).)

to NL-20-0170 Vogtle Electric Generating Plant 1&2 Revised TS Pages Attachment 2 Vogtle Electric Generating Plant 1&2 Revised TS Pages (9 total pages including cover page)

FQ(Z) 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))

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. ------NOTES----------

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

entered.

AND

2. SR 3.2.1.2 is not required to be A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each performed if this Neutron Flux High trip FQC(Z) determination Condition is entered setpoints t 1% for each prior to THERMAL 1% that THERMAL POWER exceeding POWER is limited below 75% RTP after RTP by Required Action refueling. A.1.

AND FQC(Z) not within limit.

A.3 Reduce Overpower 'T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each trip setpoints t 1% for FQC(Z) determination each 1% that THERMAL POWER is limited below RTP by Required Action A.1.

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

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

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to NL-20-0170 Farley Nuclear Plant 1&2 Marked-up TS Pages Attachment 3 Farley Nuclear Plant 1&2 Marked-up TS Pages (12 total pages including cover page)

FQ(Z) 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))

LCO 3.2.1 FQ(Z) shall be within the steady state and transient limits specified in the COLR.

, as approximated by FQC(Z) and FQW(Z),

NUREG-1431 TS 3.2.1B APPLICABILITY: MODE 1.

FQC(Z) NUREG-1431 TS 3.2.1B ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. FQ(Z) not within steady A.1 Reduce THERMAL 15 minutes state limit. POWER 1% RTP for each 1% FQ(Z) exceeds Insert 3.2.1-1 steady state limit.

TSTF-290-A NUREG-1431 FQC(Z)

AND TS 3.2.1B WCAP-17661-P-A A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Neutron Flux High trip setpoints 1% for each 1% FQ(Z) exceeds after each steady state limit. FQC(Z)

WCAP-17661-P-A determination WCAP-17661-P-A AND that THERMAL TSTF-241-A A.3 Reduce Overpower T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months POWER is limited trip setpoints 1% for below RATED each 1% FQ(Z) exceeds THERMAL steady state limit.

POWER by RTP Required Action WCAP-17661-P-A AND A.1 (continued)

Farley Units 1 and 2 3.2.1-1 Amendment No. 146 (Unit 1)

Amendment No. 137 (Unit 2)

Insert 3.2.1-1 (TSTF-290-A, Insert NOTE A)

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

NOTES-----------

1. Required Action A.4 shall be completed whenever this Condition is entered.

prior to increasing THERMAL POWER above the limit of Required Action A.1.

2. 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.

FQ(Z)

TSTF-290-A 3.2.1 Insert 3.2.1-2 WCAP-17661-P-A ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Perform SR 3.2.1.1. Prior to increasing THERMAL POWER TSTF-290-A and SR 3.2.1.2 above the limit of Required Action A.1 B. FQ(Z) not within transient B.1 Reduce AFD limits 1% 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months limits. for each 1% FQ(Z) exceeds transient limit and control AFD within reduced limits.

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

Farley Units 1 and 2 3.2.1-2 Amendment No. 146 (Unit 1)

Amendment No. 137 (Unit 2)

Insert 3.2.1-2 (TSTF-290-A, Insert 1)

(TSTF-241-A based Completion Times)

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

W B. FQ (Z) not within limits. B.1.1 -----------NOTE------------

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

Implement a RAOC 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months operating space specified in the COLR W

that rRestores FQ (Z) to within its limits specified in the COLR.

AND B.1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

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

Required Action B.2.45 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each W

POWER to less than FQ (Z) determination RATED THERMAL POWER RTP by TSTF-241-A amount and reduce based CT AFD limits as specified in the COLR.

AND

B.2.2 Reduce AFD limits by 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each W

amount specified in the FQ (Z) determination COLR.

TSTF-241-A AND based CT B.2.23 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each Neutron Flux High W FQ (Z) determination trip setpoints 1% for each 1% that THERMAL POWER is TSTF-241-A limited below RTP based CT RATED THERMAL POWER by Required Action B.2.1.

AND B.2.34 Reduce Overpower T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each W

trip setpoints 1% for FQ (Z) determination each 1% that THERMAL POWER is limited below RTP TSTF-241-A RATED THERMAL based CT POWER by Required Action B.2.1.

AND B.2.45 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action B.2.1

FQ(Z) 3.2.1 SURVEILLANCE REQUIREMENTS WCAP-17661-P-A

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

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 map is obtained SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQ(Z) is within steady state limit. Once after each refueling prior to FQC(Z)

THERMAL POWER NUREG-1431 TS 3.2.1B exceeding 75% RTP AND within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once after achieving WCAP-17661-P-A equilibrium conditions after NUREG-1431 exceeding, by TS 3.2.1B 20% RTP, the THERMAL POWER 10 at which FQ(Z) was last verified FQC(Z)

AND In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.2.1-3 Amendment No. 185 (Unit 1)

Amendment No. 180 (Unit 2)

FQ(Z) 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE-------------------------------

If measurements indicate WCAP-17661-P-A FQ(Z) º maximum over

¬<< K(Z) >>

1/4>>

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

a. Increase FQ(Z) by the appropriate penalty factor specified in the COLR and reverify that this value is within the transient limits; or

b. Repeat SR 3.2.1.2 once per 7 EFPD until either "a." above is met or two successive flux maps indicate FQ(Z) º maximum over achieving equilibrium

¬<< K(Z) >>

1/4>> conditions after has not increased. within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after Verify FQ(Z) is within the transient limit. Once after each refueling prior to FQW(Z) NUREG-1431 TS 3.2.1B THERMAL POWER exceeding 75%

RTP exceeds AND WCAP-17661-P-A (continued)

Farley Units 1 and 2 3.2.1-4 Amendment No. 146 (Unit 1)

Amendment No. 137 (Unit 2)

FQ(Z)

WCAP-17661-P-A 3.2.1 within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.2 (continued) Once after achieving equilibrium conditions after exceeding, by 20% RTP, the THERMAL 10 POWER at which FQW(Z) FQ(Z) was last verified NUREG-1431 TS 3.2.1B AND In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.2.1-5 Amendment No. 185 (Unit 1)

Amendment No. 180 (Unit 2)

Reporting Requirements and RAOC 5.6 Operating Spaces 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

WCAP-17661-P-A 4. Shutdown Bank Insertion Limits for LCO 3.1.5, T(Z)COLR

5. Control Bank Insertion Limit for LCO 3.1.6,

6. Heat Flux Hot Channel Factor FQRTP limits, K(Z) figure, W(Z) values, and FQ(Z) Penalty Factors for LCO 3.2.1, and RAOC Operating Spaces 7. Nuclear Enthalpy Rise Hot Channel Factor limits, F'HRTP, and Power Factor Multiplier, PF'H, for LCO 3.2.2.

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

9. Reactor Trip System Instrumentation Overtemperature 'T (OT'T) and Overpower 'T (OP'T) setpoint parameter values for Table 3.3.1-1,

10. Reactor Coolant System pressure, temperature, and flow in LCO 3.4.1,

11. Refueling Operations Boron Concentration for LCO 3.9.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. WCAP-9272-P-A, Westinghouse Reload Safety Evaluation Methodology, July 1985 (W Proprietary).

(Methodology for LCOs 3.1.1 - SHUTDOWN MARGIN, 3.1.3 -

Moderator Temperature Coefficient, 3.1.5 - Shutdown Bank Insertion Limit, 3.1.6 - Control Bank Insertion Limits, 3.2.3 - Axial Flux Difference, 3.2.1 - Heat Flux Hot Channel Factor, 3.2.2 -

Nuclear Enthalpy Rise Hot Channel Factor and 3.9.1 - Boron Concentration)

2. WCAP-10216-P-A, Rev.1A, Relaxation of Constant Axial Offset Control / FQ Surveillance Technical Specification, February 1994 (W Proprietary).

(Methodology for LCOs 3.2.3 - Axial Flux Difference and 3.2.1 -

Heat Flux Hot Channel Factor.)

(continued)

Farley Units 1 and 2 5.6-3 Amendment No. 151 (Unit 1)

Amendment No. 143 (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

7. WCAP-11397-P-A "Revised Thermal Design Procedure," April 1989 (Methodology for LCO 2.1.1-Reactor Core Safety Limits, LCO 3.4.1-RCS Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

8. WCAP-13749-P-A, Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature WCAP-17661-P-A Coefficient Measurement, March 1997.

Insert FNP 5.6.5-1 (Methodology for LCO 3.1.3 - Moderator Temperature Coefficient.)

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.

5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. The reactor coolant system pressure and temperature limits, including heatup and cooldown rates and the LTOP System applicability temperature, shall be established and documented in the PTLR for the following:

LCO 3.4.3, RCS Pressure and Temperature (P/T) Limits, and LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System.

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in WCAP-14040-A, Revision 4, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, May 2004.

WCAP-18124-NP-A, Revision 0, Fluence Determination with RAPTOR-M3G and FERRET, July 2018, may be used as an alternative to Section 2.2 of WCAP-14040-A.

c. The PTLR shall be provided to the NRC upon issuance for each reactor fluence period and for any revision or supplement thereto.

(continued)

Farley Units 1 and 2 5.6-5 Amendment No. 230 (Unit 1)

Amendment No. 227 (Unit 2)

Insert FNP 5.6.5-1

9. WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019. (W Proprietary)

(Methodology for LCOs 3.1.6 - Control Bank Insertion Limits, 3.2.1 - Heat Flux Hot Channel Factor, and 3.2.3 - Axial Flux Difference) to NL-20-0170 Farley Nuclear Plant 1&2 Revised TS Pages Attachment 4 Farley Nuclear Plant 1&2 Revised TS Pages (10 total pages including cover page)

FQ(Z) 3.2.1 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))

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

1. Required Action A.4 POWER t 1% RTP for FQC(Z) determination shall be completed each 1% FQC(Z) whenever this exceeds limit.

Condition is entered.

2. SR 3.2.1.2 is not AND required to be performed if this A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each Condition is entered Neutron Flux High trip FQC(Z) determination prior to THERMAL setpoints t 1% for each POWER exceeding 1% that THERMAL 75% RTP after POWER is limited below refueling. RTP by Required Action

A.1.

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

AND (continued)

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

Amendment No. (Unit 2)

FQ(Z) 3.2.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1 B. FQW(Z) not within limits. B.1.1 -----------NOTE------------

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

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

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

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

Required Action B.2.5 shall be completed whenever Required Action B.2.1 is performed.

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

AND (continued)

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

Amendment No. (Unit 2)

FQ(Z) 3.2.1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.2.2 Reduce AFD limits by 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each amount specified in the FQW(Z) determination COLR.

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

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

AND B.2.5 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2 THERMAL POWER above the limit of Required Action B.2.1 C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

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

Amendment No. (Unit 2)

FQ(Z) 3.2.1 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by t 10% RTP, the THERMAL POWER at which FQC(Z) was last verified AND In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.2.1-4 Amendment No. (Unit 1)

Amendment No. (Unit 2)

FQ(Z) 3.2.1 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after THERMAL POWER exceeds 75% RTP AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by t 10% RTP, the THERMAL POWER at which FQW(Z) was last verified AND In accordance with the Surveillance Frequency Control Program Farley Units 1 and 2 3.2.1-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

4. Shutdown Bank Insertion Limits for LCO 3.1.5,

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

6. Heat Flux Hot Channel Factor FQRTP limits, K(Z) figure, T(Z) values, and RAOC Operating Spaces for LCO 3.2.1,

7. Nuclear Enthalpy Rise Hot Channel Factor limits, F'HRTP, and Power Factor Multiplier, PF'H, for LCO 3.2.2.

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

9. Reactor Trip System Instrumentation Overtemperature 'T (OT'T) and Overpower 'T (OP'T) setpoint parameter values for Table 3.3.1-1,

10. Reactor Coolant System pressure, temperature, and flow in LCO 3.4.1,

11. Refueling Operations Boron Concentration for LCO 3.9.1.

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC, specifically those described in the following documents:

1. WCAP-9272-P-A, Westinghouse Reload Safety Evaluation Methodology, July 1985 (W Proprietary).

(Methodology for LCOs 3.1.1 - SHUTDOWN MARGIN, 3.1.3 -

Moderator Temperature Coefficient, 3.1.5 - Shutdown Bank Insertion Limit, 3.1.6 - Control Bank Insertion Limits, 3.2.3 - Axial Flux Difference, 3.2.1 - Heat Flux Hot Channel Factor, 3.2.2 -

Nuclear Enthalpy Rise Hot Channel Factor and 3.9.1 - Boron Concentration)

2. WCAP-10216-P-A, Rev.1A, Relaxation of Constant Axial Offset Control / FQ Surveillance Technical Specification, February 1994 (W Proprietary).

(Methodology for LCOs 3.2.3 - Axial Flux Difference and 3.2.1 -

Heat Flux Hot Channel Factor.)

(continued)

Farley Units 1 and 2 5.6-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

7. WCAP-11397-P-A "Revised Thermal Design Procedure," April 1989 (Methodology for LCO 2.1.1-Reactor Core Safety Limits, LCO 3.4.1-RCS Pressure, Temperature and Flow Departure from Nucleate Boiling Limits.)

8. WCAP-13749-P-A, Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement, March 1997.

(Methodology for LCO 3.1.3 - Moderator Temperature Coefficient.)

9. WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019. (W Proprietary)

(Methodology for LCOs 3.1.6 - Control Bank Insertion Limits, 3.2.1 - Heat Flux Hot Channel Factor, and 3.2.3 - Axial Flux Difference)

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.

5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR)

a. The reactor coolant system pressure and temperature limits, including heatup and cooldown rates and the LTOP System applicability temperature, shall be established and documented in the PTLR for the following:

LCO 3.4.3, RCS Pressure and Temperature (P/T) Limits, and LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System.

(continued)

Farley Units 1 and 2 5.6-5 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.6 Reactor Coolant System (RCS) PRESSURE AND TEMPERATURE LIMITS REPORT (PTLR) (continued)

b. The analytical methods used to determine the RCS pressure and temperature limits shall be those previously reviewed and approved by the NRC, specifically those described in WCAP-14040-A, Revision 4, Methodology Used to Develop Cold Overpressure Mitigating System Setpoints and RCS Heatup and Cooldown Limit Curves, May 2004.

WCAP-18124-NP-A, Revision 0, Fluence Determination with RAPTOR-M3G and FERRET, July 2018, may be used as an alternative to Section 2.2 of WCAP-14040-A.

c. The PTLR shall be provided to the NRC upon issuance for each reactor fluence period and for any revision or supplement thereto.

5.6.7 EDG Failure Report If an individual emergency diesel generator (EDG) experiences four or more valid failures in the last 25 demands, these failures shall be reported within 30 days.

Reports on EDG failures shall include a description of the failures, underlying causes, and corrective actions taken per the Emergency Diesel Generator Reliability Monitoring Program.

5.6.8 PAM Report When a report is required by Condition B or F of LCO 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

5.6.9 Deleted 5.6.10 Steam Generator (SG) Tube Inspection Report A report shall be submitted within 180 days after the initial entry into MODE 4 following completion of an inspection performed in accordance with the Specification 5.5.9, Steam Generator (SG) Program. The report shall include:

a. The scope of inspections performed on each SG;

b. The nondestructive examination techniques utilized for tubes with increased degradation susceptibility; (continued)

Farley Units 1 and 2 5.6-6 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.10 Steam Generator (SG) Tube Inspection Report (continued)

c. For each degradation mechanism found:

1. The nondestructive examination techniques utilized;

2. The location, orientation (if linear), measured size (if available), and voltage response for each indication. For tube wear at support structures less than 20 percent through-wall, only the total number of indications needs to be reported;

3. A description of the condition monitoring assessment and results, including the margin to the tube integrity performance criteria and comparison with the margin predicted to exist at the inspection by the previous forward-looking tube integrity assessment; and

4. The number of tubes plugged during the inspection outage;

d. An analysis summary of the tube integrity conditions predicted to exist at the next scheduled inspection (the forward-looking tube integrity assessment) relative to the applicable performance criteria, including the analysis methodology, inputs, and results;

e. The number and percentage of tubes plugged to date, and the effective plugging percentage in each SG; and

f. The results of any SG secondary side inspections.

5.6.11 Alternate AC (AAC) Source Out of Service Report The NRC shall be notified if the AAC source is out of service for greater than 10 days.

Farley Units 1 and 2 5.6-7 Amendment No. (Unit 1)

Amendment No. (Unit 2) to NL-20-0170 Vogtle Electric Generating Plant 3&4 Marked-up TS Pages Attachment 5 Vogtle Electric Generating Plant 3&4 Marked-up TS Pages (13 total pages including cover page)

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- NOTES -

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whenever this

Condition is entered

prior to increasing

THERMAL POWER above the limit of Required Action A.1.

2. 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.

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Insert 3.2.1-2 (WCAP-17661, Appendix D)

W B. FQ (Z) not within limits. B.1.1 --------------------------------

- NOTE -

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

Implement a CAOC 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months operating space specified in the COLR W

that rRestores FQ (Z) to within its limits specified in the COLR.

AND B.1.2 Perform SR 3.2.1.1 and 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

OR B.2.1 --------------------------------

- NOTE -

Required Action B.2.43 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1.

Limit THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after each W

POWER to less than FQ (Z) determination RATED THERMAL POWER RTP by TSTF-241-A amount and reduce based CT AFD limits as specified in the COLR.

AND

Insert 3.2.1-2 (continued)

B.2.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Neutron Flux - High trip setpoints 1% for each Removed by 1% that THERMAL VEGP 3&4 POWER is limited Amendment below RATED Nos. 144, 143 THERMAL POWER by Required Action B.2.1.

AND B.2.32 Reduce Overpower T 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each W

trip setpoints 1% for FQ (Z) determination each 1% that THERMAL POWER is TSTF-241-A limited below RTP based CT RATED THERMAL POWER by Required Action B.2.1.

AND B.2.43 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action B.2.1

Technical Specifications FQ(Z) (CAOC W(Z) Methodology) 3.2.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 -----------------------------------------------------------------------

- NOTE -

Not required to be performed if OPDMS was monitoring parameters upon exceeding 75% RTP.

Verify FQC ( Z) within limit. Once after each refueling prior to THERMAL POWER exceeding 75% RTP SR 3.2.1.2 -----------------------------------------------------------------------

- NOTE -

Not required to be performed if OPDMS was WCAP-17661-P-A monitoring parameters upon exceeding 75% RTP. within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium

conditions after Verify FQW ( Z) within limits. Once after each refueling prior to THERMAL POWER exceeds exceeding 75% RTP VEGP Units 3 and 4 3.2.1 - 3 Amendment No. 52 (Unit 3)

Amendment No. 52 (Unit 4)

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Insert 5.6.5-1 (WCAP-17661, Appendix E, Section F.1)

8. WCAP-17667-P-A, Revision 1, "Improved RAOC and CAOC FQ Surveillance Technical Specifications," November 2018 (Westinghouse Proprietary).

(Methodology for Specifications 3.1.6 - Control Bank Insertion Limits, 3.2.1 - Heat Flux Hot Channel Factor (W(Z) surveillance requirements for FQ Methodology), and 3.2.3 - AXIAL FLUX DIFFERENCE.)

to NL-20-0170 Vogtle Electric Generating Plant 3&4 Revised TS Pages Attachment 6 Vogtle Electric Generating Plant 3&4 Revised TS Pages (10 total pages including cover page)

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to NL-20-0170 Vogtle Electric Generating Plant 1&2 Marked-up TS Bases Pages (Information Only)

Attachment 7 Vogtle Electric Generating Plant 1&2 Marked-up TS Bases Pages (Information only)

(24 total pages including cover page)

FQ(Z)

B 3.2.1 B 3.2 POWER DISTRIBUTION LIMITS TSTF-290-A 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 POWER TILT RATIO (QPTR)," which are directly and continuously measured process variables. These LCOs, along with LCO 3.1.6, "Control Bank Insertion Limits," maintain the core within power distribution limits on a continuous basis.

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

TSTF-290-A FQ(Z) is measured periodically using the incore detector system.

equilibrium These measurements are generally taken with the core at or near steady state conditions.

Using the measured three dimensional power distributions, it is an equilibrium possible to derive a measured value for FQ(Z). However, because this value represents a steady state condition, it does not include the TSTF-290-A variations in the value of FQ(Z) that are present during nonequilibrium situations. which TSTF-290-A To account for these possible variations, the steady state value of TSTF-290-A FQ(Z) is adjusted by an elevation dependent factor that accounts for the calculated worst case transient conditions. equilibrium TSTF-290-A as FQW(Z)

Core monitoring and control under non-steady state conditions are accomplished by operating the core within the limits of the appropriate Insert B 3.2.1-1 LCOs, including the limits on AFD, QPTR, and control rod insertion.

WCAP-17661 non-equilibrium Appendix B TSTF-290-A (continued)

Vogtle Units 1 and 2 B 3.2.1-1 Revision No. 0

Insert B 3.2.1-1 (NUREG-1431, Rev. 4, B 3.2.1B)

(WCAP-17661, Appendix B)

To account these possible variations, the elevation dependent measured planar radial peaking factors, IRUFXY(Z), are increased by an elevation dependent factor, [T(Z)]COLR, that accounts for the expected maximum values of the transient axial power shapes postulated to occur during relaxed axial offset control (RAOC) operation. Thus, [T(Z)]COLR accounts for the worst case non-equilibrium power shapes that are expected for the assumed RAOC operating space.

The RAOC operating space is defined as the combination of AFD and control bank insertion limits assumed in the calculation of a particular [T(Z)]COLR function. The [T(Z)]COLR factors are directly dependent on the AFD and control bank insertion limit assumptions. The COLR may contain different [T(Z)]COLR functions that reflect different operating space assumptions. If the limit on FQ(Z) is exceeded, a more restrictive operating space may be implemented to gain margin for future non-equilibrium operation.

FQ(Z)

B 3.2.1 BASES (continued)

APPLICABLE This LCO precludes core power distributions that violate the SAFETY ANALYSES following fuel design criteria:

a. During a large break loss of coolant accident (LOCA), the peak cladding temperature must not exceed 2200qF (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 fission energy input to the fuel will be below 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 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 To ensure that the Heat Flux Hot Channel Factor, FQ(Z), will remain within limits during steady state operation, FQ(Z) shall be limited by NUREG-1431, B 3.2.1B the following relationships which define the steady state limits:

WCAP-17661, Appendix B Insert B 3.2.1-2 (continued)

Vogtle Units 1 and 2 B 3.2.1-2 Rev. 1-10/01

Insert B 3.2.1-2 (NUREG-1431, Rev. 4, B 3.2.1B)

(WCAP-17661, Appendix B, Insert #1)

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

FQ(Z) (CFQ / P) K(Z) for P > 0.5 FQ(Z) (CFQ / 0.5) K(Z) for P 0.5 where: CFQ is the FQ(Z) limit at RTP provided in the COLR, K(Z) is the normalized FQ(Z) limit as a function of core height provided in the COLR, and P = THERMAL POWER / RTP For this facility, the actual values of CFQ and K(Z) are given in the COLR; however, CFQ is normally a number on the order of 2.50, and K(Z) is a function that looks like the one provided in Figure B 3.2.1-1.

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

C An FQ (Z) evaluation requires obtaining an incore flux map in MODE 1. From the incore flux M

map results we obtain the measured value (FQ (Z) ) of FQ(Z).

Then, when using 44 detector thimbles:

FQC(Z) = (FQM(Z) x 1.0815 where 1.0815 is a factor that accounts for fuel manufacturing tolerances (3%) and flux map measurement uncertainty (5%), or when using 29 and < 44 thimbles:

FQC(Z) = (FQM(Z) x 1.03 x [1.05 + [2.0 {3-T/(14.5)}]/100],

where 1.03 accounts for fuel manufacturing tolerances with a more conservative flux map measurement uncertainty factor to account for the fewer detector thimbles available, and T is the number of thimbles being used. A bounding measurement uncertainty of 7.0%, which is based on 29 thimbles, can be used for 29 and < 44 detector thimbles, if desired. FQ(Z) evaluations for comparison to the steady state limits are applicable in all axial core regions, i.e.,

from 0 to 100% inclusive.

C M FQ (Z) = FQ (Z) 1.0815 where 1.0815 is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.

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

W The expression for FQ (Z) is:

W M FQ (Z) = FXY (Z) {[T(Z)]COLR/P} AXY(Z) Rj 1.0815 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 fully 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.

W AXY(Z) is a function that adjusts the FQ (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 ARO, and equilibrium xenon. For simplicity, AXY(Z) may be assumed W

to be 1.0, as this will typically result in an accurate FQ (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 6.

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 W

potential increases in FQ (Z) between Surveillances. Rj values are provided for each RAOC operating space.

FQ(Z)

B 3.2.1 BASES LCO (continued)

RTP FQ K (Z )

FQ (Z ) for P > 0.5 P

RTP FQ FQ (Z ) K (Z ) for P 0.5 0.5 RTP where: F Q is the FQ(Z) limit at RTP provided in the COLR, K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and THERMAL POWER P=

RTP RTP For this facility, the actual values of F Q and K(Z) are given in the RTP COLR; however, F Q is normally a number on the order of 2.50, and K(Z) is a function that looks like the one provided in Figure B 3.2.1-1.

An FQ(Z) evaluation requires obtaining an incore flux map in MODE 1.

From the incore flux map results we obtain the measured value M

( F Q (Z)) of FQ(Z). Then, when using 44 detector thimbles:

M FQ(Z) = F Q (Z) X 1.0815 where 1.0815 is a factor that accounts for fuel manufacturing tolerances (3%) and flux map measurement uncertainty (5%), or when using 29 and < 44 thimbles:

M FQ(Z) = F Q (Z) x 1.03 x [1.05 + [2.0 {3-T/(14.5)}]/100],

where 1.03 accounts for fuel manufacturing tolerances with a more conservative flux map measurement uncertainty factor to account for the fewer detector thimbles available, and T is the number of thimbles being used. A bounding measurement uncertainty of 7.0 %, which is based on 29 thimbles, can be used for 29 and < 44 detector thimbles, if desired. FQ(Z) evaluations for comparison to the steady (continued)

Vogtle Units 1 and 2 B 3.2.1-3 REVISION 15

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Appendix

B TSTF-241-A Insert B 3.2.1-4 Insert B 3.2.1-5 $

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WCAP-17661, Appendix B that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1

Insert B 3.2.1-3 (TSTF-290-A, Insert 2)

(WCAP-17661, Appendix B)

W and if FQ (Z) cannot be maintained within the LCO limits, a more restrictive RAOC operating space must be implemented or core power limits and AFD limits must be reduced.

Insert B 3.2.1-4 (TSTF-241-A, Insert B1)

The maximum allowable power level initially determined by Required Action A.1 may be C

affected by subsequent determinations of FQ (Z) and would require power reductions within 15 C

minutes of the FQ (Z) determination, if necessary to comply with the decreased maximum C

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

Insert B 3.2.1-5 (WCAP-17661-P-A, Rev. 1, Appendix B)

C W If an FQ surveillance is performed at 100% RTP conditions, and both F Q (Z) and FQ (Z) exceed their limits, the option to reduce THERMAL POWER limit in accordance with Required Action B.2.1 instead of implementing a new operating space in accordance with proposed Required Action B.1.1, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In the event the evaluated THERMAL POWER reduction in the COLR for proposed Required Action B.2.1 did not result in a further power reduction (for example, if both Conditions 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.

Insert B 3.2.1-6 (TSTF-241-A, Insert B2)

The maximum allowable Power Range Neutron Flux - High trip setpoints initially determined by C

Required Action A.2 may be affected by subsequent determinations of FQ (Z) and would require C

Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQ (Z) determination, if necessary to comply with the decreased maximum allowable Power Range C

Neutron Flux - High trip setpoints. Decreases in FQ (Z) would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

FQ(Z)

B 3.2.1 BASES ACTIONS A.3 (continued) action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1.

TSTF-241-A Insert B 3.2.1-7 A.4 Verification that FQ(Z) has been restored to within its limit, by TSTF-290-A performing SR 3.2.1.1 prior to increasing THERMAL POWER above the limit imposed by Required Action A.1, ensures that core conditions and SR 3.2.1.2 during operation at higher power levels are consistent with safety analyses assumptions.

TSTF-290-A Insert B 3.2.1-8

.1 WCAP-17661, Appendix B WCAP-17661 B.1 Appendix B If it is found that FQ(Z) exceeds its specified transient limits, there TSTF-99-A exists a potential for FQ(Z) to become excessively high if a normal operational transient occurs. Reducing the AFD limit by 1% for 4 each 1% by which FQ(Z) exceeds its transient limits within the allowed Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded (Ref. 5). The percent FQ(Z) exceeds its transient limit is calculated based on the following expressions:

F (Z) W (Z) º 1/2

°maximum << Q RTP ° over Z << FQ K (Z) >>>> 13/4 x 100 for P > 0.5

° ¬ P 1/4 °¿ Insert B 3.2.1-9 NUREG-1431, B 3.2.1B TSTF-290-A WCAP-17661, Appendix B (continued)

Vogtle Units 1 and 2 B 3.2.1-6 Revision No. 0

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

The maximum allowable Overpower T trip setpoints initially determined by Required Action A.3 C

may be affected by subsequent determinations of FQ (Z) and would require Overpower T trip C

setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQ (Z) determination, if necessary to comply with the C

decreased maximum allowable Overpower T trip setpoints. Decreases in FQ (Z) would allow increasing the maximum Overpower T trip setpoints.

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

(WCAP-17661, Appendix B)

Condition A is modified by a Note that two Notes. Note 1 requires Required Action A.4 to be performed whenever the Condition is entered. prior to increasing THERMAL POWER above the W

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

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

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

(WCAP-17661, Appendix B)

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

Required Action B.1.1 is modified by a Note that states Required Action B.1.2 shall be completed whenever Required Action B.1.1 is performed and control rod motion is required to comply with the new operating space implemented by Required Action B.1.1. Required Action B.1.2 requires the performance of SR 3.2.1.1 and SR 3.2.1.2 within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The Note W

ensures that the SRs will be performed even though Required Action B.1.1 restores FQ (Z) to within limits and Condition B is exited.

B.1.2 If it is found that the maximum calculated value of FQ(Z) that can occur during normal W C maneuvers, FQ (Z), exceeds its specified limits, there exists a potential for FQ (Z) to become excessively high if a normal operational transient occurs. As discussed above, Required Action W

B.1.1 requires that a new RAOC operating space be implemented to restore FQ (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 and B.2.2 W

When FQ (Z) exceeds its limit, Required Action B.2.1 may be implemented instead of Required Action B.1.1. Required Action B.2.1 limits THERMAL POWER to less than RATED THERMAL POWER RTP by the amount specified in the COLR. It also Required Action B.2.2 requires reductions in the AFD limits by the amount specified in the COLR. If the RAOC operating W

spaces specified in the COLR are insufficient to ensure margin to the FQ (Z) limit, then Required Actions B.2.1 and B.2.2 must be entered are performed and THERMAL POWER must be limited to less than or equal to 50% RTP and AFD limits must be reduced by the amounts specified in the COLR. This maintains an acceptable absolute power density relative to the maximum power density value assumed in the safety analyses.

W If the required FQ (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.

The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to reduce the THERMAL POWER and AFD limits in an orderly manner to preclude entering an unacceptable condition during future non-equilibrium operation. The limit on THERMAL POWER initially determined by W

Required Action B.2.1 may be affected by subsequent determinations of FQ (Z) and would W

require power reductions within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the FQ (Z) determination, if necessary to comply with W

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

Required Action B.2.1 is modified by a Note that states Required Action B.2.45 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.2.45 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.2.45. The performance of SR 3.2.1.1 and SR 3.2.1.2 is necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.

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

B.2.23 A reduction of the Power Range Neutron Flux-High trip setpoints by 1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Actions B.2.1 and B.2.2. The limit on THERMAL POWER initially W

determined by Required Action B.2.1 may be affected by subsequent determinations of FQ (Z)

W and would require power reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQ (Z) determination, if necessary to W

comply with the decreased THERMAL POWER limit. Decreases in FQ (Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

B.2.34 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in the THERMAL POWER limit and AFD limits in accordance with Required Actions B.2.1 and B.2.2. The limit on THERMAL POWER initially W

determined by Required Action B.2.1 may be affected by subsequent determinations of FQ (Z)

W and would require power reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQ (Z) determination, if necessary to W

comply with the decreased THERMAL POWER limit. Decreases in FQ (Z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

B.2.45 W

Verification that FQ (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.

FQ(Z)

B 3.2.1 BASES ACTIONS B.1 (continued)

FQ (Z) W (Z) º 1/2

°maximum << RTP >> ° over Z << FQ K (Z) >> 13/4 x 100 for P 0.5

° °

- ¬<< 0.5 1/4>> ¿ TSTF-290-A C.1 through B.4 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 2.5 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

WCAP-17661, This allowed Completion Time is reasonable based on operating Appendix B 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.

SURVEILLANCE During power ascension following a refueling, the first determination REQUIREMENTS of FQ(Z) is not required until after achieving equilibrium conditions at any power level above 50% RTP. This Frequency condition, together WCAP-17661, with the Frequency condition requiring verification of FQ(Z) and Appendix B following a power increase of more than 20%, ensures that FQ(Z) is verified as soon as RTP (or any other level for extended operation) is achieved. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of FQ(Z). The Frequency condition is not intended to require verification of these parameters after every 20% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is at least 20% higher than that power at which FQ(Z) was last measured.

(continued)

Vogtle Units 1 and 2 B 3.2.1-7 Revision No. 0

FQ(Z)

B 3.2.1 BASES SURVEILLANCE SR 3.2.1.1 FQC(Z) NUREG-1431, B 3.2.1B REQUIREMENTS (continued) Verification that FQ(Z) is within its specified limits involves FQC(Z) increasing FMQ(Z) to allow for manufacturing tolerance and measurement uncertainties in order to obtain FQ(Z). Specifically, FMQ(Z) is the measured value of FQ(Z) obtained from incore flux map results. When using 44 detector thimblesthimbles, FQ(Z) = FMQ (Z) X 1.0815 1 (Ref. 4) 0815 (Ref 4), and when using 29 and < 44 thimbles thimbles, FQ(Z) =

Insert B 3.2.1-10 M F Q (Z) x 11.03 03 x [1

[1.05 05 + [2

[2.0 0 {3-T/(14

{3-T/(14.5)}]/100],

5)}]/100] where T = the NUREG-1431, B 3.2.1B number of detector thimbles used (Ref (Ref. 6) 6). A bounding measurement uncertainty of 7.0 70% %, which is based on 29 thimbles thimbles, WCAP-17661, Appendix B can be used for 29 and < 44 detector thimbles thimbles, if desired desired.

During the initial startup after a refueling outage up to and including performance of the first flux map at 100% RTP RTP, 44 thimbles, with 2 detector thimbles per core quadrant as detector thimbles identified in TRM Figure 13 13.3.1-1 3 1-1 are required required. This Note does not have to be met for Vogtle Unit 1 1, Cycle 17 based on the successful performance of the flux map at 30% RTP RTP. FQ(Z) is then compared to its steady state and transient limits specified in the COLR COLR.

Performing this Surveillance in MODE 1 after exceeding 50% R RTP follow wing refueling ensures that the FQ(Z) limit is met when following n RTP is achieved, because peaking factors generally decrease as power achieved level is increaseed In addition increased. addition, at power levels above 50% RTP RTP, equilibrium Xenon co conditions onditions approach those more closely at RTP. Therefore RTP Therefore, performi performing ng the Surveillance at a power level above 50% RTP ensures a mo more re accurate measurement of FQ(Z) (Z).

If THERMAL POWER has been increased by 20% RTP since the last determination of FQ(Z), another evaluation of this factor is required after achieving equilibrium conditions at this higher power level (to ensure that FQ(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 This surveillance determines if FQ(Z) will remain within its limit Insert B 3.2.1-11 during a normal operational transient. If FQ(Z) is determined to NUREG-1431, B 3.2.1B exceed the transient limit, Action B.1 requires that the AFD limit be reduced 1% for each 1% FQ(Z) exceeds the transient limit. This WCAP-17661, Appendix B (continued)

Vogtle Units 1 and 2 B 3.2.1-8 REVISION 17

Insert B 3.2.1-10 (NUREG-1431, Rev. 4, B 3.2.1B)

(WCAP-17661, Appendix B)

C M C and FQ (Z) = FQ (Z) 1.0815 (Ref. 4). FQ (Z) is then compared to its specified limits.

When using 44 detector thimbles, FQC(Z) = (FQM(Z) x 1.0815 (Ref. 4), and when using 29 and < 44 thimbles, FQC(Z) = (FQM(Z) x 1.03 x [1.05 + [2.0 {3-T/(14.5)}]/100], where T = the number of detector thimbles used (Ref. 6). A bounding measurement uncertainty of 7.0%,

which is based on 29 thimbles, can be used for 29 and < 44 detector thimbles, if desired.

During the initial startup after a refueling outage up to and including performance of the first flux map at 100% RTP, 44 detector thimbles, with 2 detector thimbles per core quadrant as identified in TRM Figure 13.3.1-1 are required. FQ(Z) is then compared to its steady state and transient limits specified in the COLR.

C The limit with which FQ (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 following a refueling C

ensures that some determination of FQ (Z) is made prior to achieving a significant power level where the peak linear heat rate could approach the limits assumed in the safety analyses..

If THERMAL POWER has been increased by 10% RTP since the initial or most recent C

determination of FQ (Z), another evaluation of this factor is required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving C

equilibrium conditions at this higher power level (to ensure that FQ (Z) values are being reduced sufficiently with power increase to stay within the LCO limits). 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions at the increased C

THERMAL POWER level to complete the next FQ (Z) surveillance applies to situations where the C

FQ (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 C

operation that is 10% higher than the THERMAL POWER at which FQ (Z) was last measured.

Insert B 3.2.1-11 (NUREG-1431, Rev. 4, B 3.2.1B)

(WCAP-17661, Appendix B)

The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation.

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, C

FQ (Z) is given by the following expression:

W M FQ (Z) = FXYM(Z) PM(Z) 1.0815 = FQ (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 W

measured at HFP hot full power ARO conditions (AXY(Z) equals 1.0), FQ (Z) is given by the following expression:

W FQ (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 W

and measurement uncertainties gives FQ (Z), the maximum total peaking factor postulated for non-equilibrium RAOC operation.

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

The [T(Z)]COLR functions are specified in the COLR for discrete core elevations. Flux map data W

are typically taken for 30 to 75 core elevations. FQ (Z) evaluations are not applicable for axial core regions, measured in percent of core height:

a. Lower core region, from 0 to 815% inclusive,

b. Upper core region, from 9285 to 100% inclusive,

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 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.

W SR 3.2.1.2 requires a Surveillance of FQ (Z) during the initial startup following each refueling within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding 75% RTP. THERMAL W

POWER levels below 75% are typically non-limiting with respect to the limit for FQ (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 W

that verification of FQ (Z) is performed prior to extended operation at power levels where the maximum permitted peak linear heat rate 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.

W If a previous Surveillance of FQ (Z) was performed at part power conditions, SR 3.2.1.2 also W

requires that FQ (Z) be verified at power levels 10% RTP above the THERMAL POWER of its W

last verification within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions. This ensures that FQ (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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions will provide a more W

accurate measurement of FQ (Z) by allowing sufficient time to achieve equilibrium conditions and obtain the power distribution measurement.

FQ(Z)

B 3.2.1 BASES SURVEILLANCE SR 3.2.1.2 (continued)

REQUIREMENTS will ensure that FQ(Z) will not exceed the transient limit during a normal operational transient within the reduced AFD limit.

Demonstrating that FQ(Z) is within the transient limit or reducing the AFD limit if the transient FQ(Z) limit was initially exceeded, only ensures that the transient FQ(Z) limit will not be exceeded at the time FQ(Z) was evaluated. This does not ensure that the limit will not be exceeded during the following surveillance interval. Both the steady state and transient FQ(Z) change as a function of core burnup.

If the two most recent FQ(Z) evaluations show an increase in the quantity F (Z) º maximum over z << Q >> ,

¬ k(Z) 1/4 it is not guaranteed that FQ(Z) will remain within the transient limit during the following surveillance interval. SR 3.2.1.2 is modified by a Note to determine if there is sufficient margin to the transient FQ(Z) limit to ensure that the limit will not be exceeded during the following surveillance interval. This is accomplished by increasing FQ(Z) by a penalty specified in the COLR and comparing this value to the transient FQ(Z) limit. If there is insufficient margin, i.e., this value exceeds the limit, SR 3.2.1.2 must be repeated once per 7 EFPD until either FQ(Z) increased by the penalty factor is within the transient limit or, two successive (i.e., subsequent consecutive) flux maps indicate F (Z) º maximum over z << Q >> ,

¬ k(Z) 1/4 has not increased.

Performing the Surveillance in MODE 1 after exceeding 50% RTP following refueling ensures that the FQ(Z) limits are met when RTP is achieved, because peaking factors are generally decreased as power level is increased. In addition, at power levels above 50% RTP, equilibrium Xenon conditions approach more closely those at RTP.

Therefore, performing the Surveillance at a power level above 50%

RTP ensures a more accurate measurement of FQ(Z).

FQ(Z) is verified at power levels 20% RTP above the THERMAL POWER of its last verification, after achieving (continued)

Vogtle Units 1 and 2 B 3.2.1-9 REVISION 15

FQ(Z)

B 3.2.1 BASES SURVEILLANCE SR 3.2.1.2 (continued)

REQUIREMENTS 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.

REFERENCES 1. 10 CFR 50.46, 1974.

2. FSAR Subsection 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. WCAP-10216-P-A, Revision 1A, "Relaxation of Constant Axial Offset Control FQ Surveillance Technical Specification,"

February 1994.

6. GP-18735, Evaluation of a Reduction in the Required Number of Movable Incore Detector Thimbles, January 31, 2011.

7. GP-18767, Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 1 and 2, Cycle 17 Movable Incore Detector Thimble Evaluation, April 4, 2011.

WCAP-17661-P-A, "Improved RAOC and CAOC FQ WCAP-17661, Appendix B Surveillance Technical Specifications," February 2019.

Vogtle Units 1 and 2 B 3.2.1-10 REVISION 15

to NL-20-0170 Farley Nuclear Plant 1&2 Marked-up TS Bases Pages (Information Only)

Attachment 8 Farley Nuclear Plant 1&2 Marked-up TS Bases Pages (Information only)

(24 total pages including cover page)

FQ(Z)

B 3.2.1 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))

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 3.1.6, "Control Bank Insertion Limits," maintain the core within power distribution limits on a continuous basis.

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

TSTF-290-A FQ(Z) is measured periodically using the incore detector system.

equilibrium These measurements are generally taken with the core at or near steady state conditions.

Using the measured three dimensional power distributions, it is an equilibrium possible to derive a measured value for FQ(Z). However, because TSTF-290-A this value represents a steady state condition, it does not include the variations in the value of FQ(Z) that are present during nonequilibrium situations, such as load following. which TSTF-290-A To account for these possible variations, the steady state value of TSTF-290-A F (Z) is adjusted by an elevation dependent factor that accounts for Q

as F W(Z) the calculated worst case transient conditions. equilibrium TSTF-290-A Q

Core monitoring and control under nonsteady state conditions are accomplished by operating the core within the limits of the appropriate Insert B 3.2.1-1 LCOs, including the limits on AFD, QPTR, and control rod insertion.

WCAP-17661 Appendix B non-equilibrium TSTF-290-A Farley Units 1 and 2 B 3.2.1-1 Revision 0

Insert B 3.2.1-1 (NUREG-1431, Rev. 4, B 3.2.1B)

(WCAP-17661, Appendix B)

To account these possible variations, the elevation dependent measured planar radial peaking factors, IRUFXY(Z), are increased by an elevation dependent factor, [T(Z)]COLR, that accounts for the expected maximum values of the transient axial power shapes postulated to occur during relaxed axial offset control (RAOC) operation. Thus, [T(Z)]COLR accounts for the worst case non-equilibrium power shapes that are expected for the assumed RAOC operating space.

The RAOC operating space is defined as the combination of AFD and control bank insertion limits assumed in the calculation of a particular [T(Z)]COLR function. The [T(Z)]COLR factors are directly dependent on the AFD and control bank insertion limit assumptions. The COLR may contain different [T(Z)]COLR functions that reflect different operating space assumptions. If the limit on FQ(Z) is exceeded, a more restrictive operating space may be implemented to gain margin for future non-equilibrium operation.

FQ(Z)

B 3.2.1 BASES LCO To ensure that the Heat Flux Hot Channel Factor, FQ(Z), will remain within limits during steady state operation, FQ(Z) shall be limited by the following relationships which define the steady state limits:

FQ RTP FQ Z d K Z for P > 0.5 P

Insert B 3.2.1-2 FQ RTP FQ Z d K Z for P d 0.5 0.5 NUREG-1431, B 3.2.1B where: FQRTP is the FQ(Z) limit at RTP provided in the COLR, WCAP-17661, Appendix B K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and THERMAL POWER P=

RTP For this facility, the actual values of FQRTP and K(Z) are given in the COLR.

An FQ(Z) evaluation requires obtaining an incore flux map in MODE 1.

From the incore flux map results we obtain the measured value ( FQM (Z))

of FQ(Z). Then, when using 38 detector thimbles:

FQ(Z) = FQM (Z) X 1.0815 where 1.0815 is a factor that accounts for fuel manufacturing tolerances (3%) and flux map measurement uncertainty (5%), or when using 25 and < 38 thimbles:

FQ(Z) = FQM (Z) X 1.03 X [1.05 + [2{3 - (T/12.5)}]/100],

where 1.03 accounts for fuel manufacturing tolerances with a more conservative flux map measurement uncertainty factor to account for fewer detector thimbles available, and T is the number of thimbles being used (Ref. 6). A bounding flux map measurement uncertainty of 7.0%, which is based on 25 thimbles, can be used for 25 and

< 38 detector thimbles, if desired.

FQ(Z) evaluations for comparison to the steady state limits are applicable in all axial core regions, i.e., from 0 to 100% inclusive.

(continued)

Farley Units 1 and 2 B 3.2.1-3 Revision 79

Insert B 3.2.1-2 (NUREG-1431, Rev. 4, B 3.2.1B)

(WCAP-17661, Appendix B, Insert #1)

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

FQ(Z) (CFQ / P) K(Z) for P > 0.5 FQ(Z) (CFQ / 0.5) K(Z) for P 0.5 where: CFQ is the FQ(Z) limit at RTP provided in the COLR, K(Z) is the normalized FQ(Z) limit as a function of core height provided in the COLR, and P = THERMAL POWER / RTP For this facility, the actual values of CFQ and K(Z) are given in the COLR; however, CFQ is normally a number on the order of 2.50, and K(Z) is a function that looks like the one provided in Figure B 3.2.1-1.

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

C An FQ (Z) evaluation requires obtaining an incore flux map in MODE 1. From the incore flux M

map results we obtain the measured value (FQ (Z) ) of FQ(Z).

Then, when using 38 detector thimbles:

FQC(Z) = (FQM(Z) x 1.0815 where 1.0815 is a factor that accounts for fuel manufacturing tolerances (3%) and flux map measurement uncertainty (5%), or when using 25 and < 38 thimbles:

FQC(Z) = (FQM(Z) x 1.03 x [1.05 + [2.0 {3-T/(12.5)}]/100],

where 1.03 accounts for fuel manufacturing tolerances with a more conservative flux map measurement uncertainty factor to account for the fewer detector thimbles available, and T is the number of thimbles being used. A bounding measurement uncertainty of 7.0%, which is based on 25 thimbles, can be used for 25 and < 38 detector thimbles, if desired. FQ(Z) evaluations for comparison to the steady state limits are applicable in all axial core regions, i.e.,

from 0 to 100% inclusive.

C M FQ (Z) = FQ (Z) 1.0815 where 1.0815 is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.

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

W The expression for FQ (Z) is:

W M FQ (Z) = FXY (Z) {[T(Z)]COLR/P} AXY(Z) Rj 1.0815 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 fully 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.

W AXY(Z) is a function that adjusts the FQ (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 ARO, and equilibrium xenon. For simplicity, AXY(Z) may be assumed to W

be 1.0, as this will typically result in an accurate FQ (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 6.

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 W

potential increases in FQ (Z) between Surveillances. Rj values are provided for each RAOC operating space.

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The maximum allowable power level initially determined by Required Action A.1 may be C

affected by subsequent determinations of FQ (Z) and would require power reductions within 15 C

minutes of the FQ (Z) determination, if necessary to comply with the decreased maximum C

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

Insert B 3.2.1-5 (WCAP-17661-P-A, Rev. 1, Appendix B)

C W If an FQ surveillance is performed at 100% RTP conditions, and both F Q (Z) and FQ (Z) exceed their limits, the option to reduce THERMAL POWER limit in accordance with Required Action B.2.1 instead of implementing a new operating space in accordance with proposed Required Action B.1.1, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . In the event the evaluated THERMAL POWER reduction in the COLR for proposed Required Action B.2.1 did not result in a further power reduction (for example, if both Conditions 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.

Insert B 3.2.1-6 (TSTF-241-A, Insert B2)

The maximum allowable Power Range Neutron Flux - High trip setpoints initially determined by C

Required Action A.2 may be affected by subsequent determinations of FQ (Z) and would require C

Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQ (Z) determination, if necessary to comply with the decreased maximum allowable Power Range C

Neutron Flux - High trip setpoints. Decreases in FQ (Z) would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

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

The maximum allowable Overpower T trip setpoints initially determined by Required Action A.3 C

may be affected by subsequent determinations of FQ (Z) and would require Overpower T trip C

setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQ (Z) determination, if necessary to comply with the C

decreased maximum allowable Overpower T trip setpoints. Decreases in FQ (Z) would allow increasing the maximum Overpower T trip setpoints.

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