View source for L-17-223, Application to Revise Technical Specifications to Adopt TSTF-547-A, Revision 1, Clarification of Rod Position Requirements.

{{Adams
| number = ML17181A464
| issue date = 06/30/2017
| title = Application to Revise Technical Specifications to Adopt TSTF-547-A, Revision 1, Clarification of Rod Position Requirements.
| author name = Bologna R
| author affiliation = FirstEnergy Nuclear Operating Co
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000334, 05000412
| license number = DPR-066, NPF-073
| contact person = 
| case reference number = L-17-223
| document type = Letter type:L, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 98
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:FENOC'                                                                         Beaver Valley Power Station P.O. Box 4 FirstEnergy Nuclear Operating Company                                              Shippingport, PA 15077 Richard D. Bologna                                                                           724-682-7773 General Plant Manager                                                                  Fax: 330-315-9767 June 30, 2017 L-17-223 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

==SUBJECT:==

Beaver Valley Power Station, Unit Nos. 1 and 2 Docket No. 50-334, License No. DPR-66 Docket No. 50-412, License No. NPF-73 Application to Revise Technical Specifications to Adopt TSTF-547-A Revision 1.
     "Clarification of Rod Position Requirements" Pursuant to 10 CFR 50.90, FirstEnergy Nuclear Operating Company (FENOC) is submitting a request for an amendment to the Technical Specifications for Beaver Valley Power Station (BVPS), Unit Nos. 1 and 2. The proposed amendment would modify requirements on control and shutdown rods, and rod and bank position indication for BVPS Unit No. 2. The proposed changes are consistent with the Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF)
Traveler TSTF-547-A, Revision 1, "Clarification of Rod Position Requirements" (Accession No. ML16012A126). Additional supporting changes to BVPS Unit Nos. 1 and 2 Technical Specifications are also proposed.
The FENOC evaluation of the proposed amendment is enclosed. NRC staff approval of the proposed amendment is requested by August 31, 2017. The amendment will be implemented within 30 days of approval.
There are no regulatory commitments included in this submittal. If there are any questions or if additional information is required, please contact Mr. Thomas A. Lentz, Manager - Fleet Licensing, at (330) 315-6810.
I declare under penalty of perjury that the foregoing is true and correct. Executed on June 30, 2017.

Beaver Valley Power Station, Unit Nos. 1 and 2 L-17-223 Page 2

==Enclosure:==
Evaluation of the Proposed Amendment cc: NRC Region I Administrator NRC Resident Inspector NRC Project Manager Director BRP/DEP Site BRP/DEP Representative

Evaluation of the Proposed Amendment Page 1 of 6

==Subject:==
License Amendment Request to Adopt TSTF-547-A, Revision 1, Clarification of Rod Position Requirements Table of Contents

==1.0 DESCRIPTION==

2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation 2.2 Variations

==3.0 REGULATORY ANALYSIS==

3.1 No Significant Hazards Consideration Analysis 4.0 ENVIRONMENTAL EVALUATION : Proposed Changes to Technical Specifications, Annotated Copy : Proposed Changes to Technical Specifications, Retyped Copy : Proposed Changes to Technical Specifications Bases, Annotated Copy

Evaluation of the Proposed Amendment Beaver Valley Power Station, Unit Nos. 1 and 2 Page 2 of 6

==1.0 DESCRIPTION==

The proposed amendment revises the requirements on control and shutdown rods, and rod and bank position indication in Technical Specification (TS) 3.1.4, "Rod Group Alignment Limits," TS 3.1.5, "Shutdown Bank Insertion Limits," TS 3.1.6, "Control Bank Insertion Limits," and TS 3.1.7, "Rod Position Indication for Beaver Valley Power Station (BVPS), Unit No. 2. The proposed change revises the requirements on control and shutdown rods, and rod and bank position indication to provide time to repair rod movement failures that do not affect rod Operability, to provide an alternative to frequent use of the movable incore detector system when position indication for a rod is inoperable, to correct conflicts between the TS, to eliminate an unnecessary action, and to increase consistency and to improve the presentation. Supporting changes are also proposed, including renumbering BVPS Unit Nos. 1 and 2 TSs 3.1.4, 3.1.5, and 3.1.6 to provide separate specifications for each unit. provides the existing TS pages annotated to show the proposed changes, and Attachment 2 provides retyped TS pages with the proposed changes incorporated. provides existing TS Bases pages annotated to show the proposed changes. Attachments 2 and 3 are provided for information only.
2.0 ASSESSMENT 2.1 Applicability of Safety Evaluation FENOC has reviewed the safety evaluation for TSTF-547-A, Revision 1, Clarification of Rod Position Requirements, provided to the Technical Specifications Task Force (TSTF) in a letter dated March 4, 2016 (Accession No. ML16012A126). This review included a review of the NRC staffs safety evaluation, as well as the information provided in TSTF-547-A, Revision 1. FENOC has concluded that the justifications presented in TSTF-547-A, Revision 1 and the safety evaluation prepared by the NRC staff are applicable to BVPS Unit No. 2.
2.2 Variations FENOC is proposing the following variations from the TS changes described in TSTF-547-A, Revision 1. These variations do not affect the applicability of TSTF-547-A, Revision 1 or the NRC staff's safety evaluation to the proposed license amendment.
: 1) TSs 3.1.4, 3.1.5, and 3.1.6 would be split into separate subsections for each BVPS unit.
: 2) TSs 3.1.4, 3.1.5, and 3.1.6 that have been split into subsections for each BVPS unit have renumbered Limiting Conditions for Operation that are referenced in TSs 3.1.9, PHYSICS TEST Exceptions - Mode 2, and 5.6.3, CORE OPERATING LIMITS REPORT (COLR). The references to Limiting Conditions for Operation 3.1.4, 3.1.5, and 3.1.6 are updated in the TS 3.1.9 Limiting

Evaluation of the Proposed Amendment Beaver Valley Power Station, Unit Nos. 1 and 2 Page 3 of 6 Condition for Operation. The references to Limiting Conditions for Operation 3.1.4 and 3.1.5 are updated in TS 5.6.3.a.
: 3) The note for renumbered BVPS Unit No. 1 Limiting Condition for Operation 3.1.4.1 would be revised to remove For Unit 1 only, as this specification would apply to Unit No. 1 only.
: 4) The note for renumbered BVPS Unit No. 1 Surveillance Requirement 3.1.4.1.1 would be revised to remove For Unit 1 only, as TS 3.1.4.1 only applies to Unit No. 1.
: 5) BVPS Unit No. 2 has digital rod position indication. Therefore, renumbered Surveillance Requirement 3.1.4.2.1 would be revised by changing the header for the note from NOTES to NOTE, as there is only one applicable note for this rod group alignment limit surveillance requirement.
: 6) Overlap was inadvertently left out of the TSTF-547-A, Revision 1 changes in TS 3.1.6. Overlap is therefore inserted before limits in Required Action A.3. This is consistent with proposed TS 3.1.6 Limiting Condition for Operation 3.1.6.2, Conditions A and C, Required Action C.2, and Surveillance Requirement 3.1.6.2.3.
: 7) Rods is changed to rod in TS 3.1.7.2 Required Action A.2.1 for consistency with Required Action A.1.
: 8) Required Actions C.1.1 and C.1.2 in current TS 3.1.7.2 state: C.1.1 Initiate action to verify the position of the rods with inoperable position indicators indirectly by using movable incore detectors. AND C.1.2 Complete rod position verification started in Required Action C.1.1. The Completion Time is immediately for Required Action C.1.1, and eight hours for Required Action C.1.2. The proposed Required Action C.1 in the TSTF replaces the current Required Actions with Verify the position of the rods with inoperable DRPIs indirectly by using movable incore detectors. The proposed Completion Time is eight hours, and therefore, is effectively the same as the current Technical Specifications.

==3.0 REGULATORY ANALYSIS==

3.1 No Significant Hazards Consideration Analysis FirstEnergy Nuclear Operating Company (FENOC) requests adoption of TSTF-547-A, Revision 1, "Clarification of Rod Position Requirements," which is an approved change to the Standard Technical Specifications, into the Beaver Valley Power Station Unit No. 2 Technical Specifications (TS). The proposed change revises the requirements on control and shutdown rods, and rod and bank position indication to provide time to repair rod movement failures that do not affect rod Operability, to provide an alternative to frequent use of the movable incore detector system when position indication for a rod is inoperable, to correct conflicts between the TS, to eliminate an unnecessary action, and to increase consistency and to improve the presentation. Supporting changes are

Evaluation of the Proposed Amendment Beaver Valley Power Station, Unit Nos. 1 and 2 Page 4 of 6 also proposed including renumbering BVPS Unit Nos. 1 and 2 TSs 3.1.4, 3.1.5, and 3.1.6 to provide separate specifications for each unit.
FENOC 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 Control and shutdown rods are assumed to insert into the core to shut down the reactor in evaluated accidents. Rod insertion limits ensure that adequate negative reactivity is available to provide the assumed shutdown margin (SDM).
Rod alignment and overlap limits maintain an appropriate power distribution and reactivity insertion profile.
Control and shutdown rods are initiators to several accidents previously evaluated, such as rod ejection. The proposed change does not change the limiting conditions for operation for the rods or make any technical changes to the Surveillance Requirements (SRs) governing the rods. Therefore, the proposed change has no significant effect on the probability of any accident previously evaluated.
Revising the TS Actions to provide a limited time to repair rod movement control has no effect on the SDM assumed in the accident analysis as the proposed Actions require verification that SDM is maintained. The effects on power distribution will not cause a significant increase in the consequences of any accident previously evaluated as all TS requirements on power distribution continue to be applicable.
Revising the TS Actions to provide an alternative to frequent use of the moveable incore detector system to verify the position of rods with inoperable rod position indicator does not change the requirement for the rods to be aligned and within the insertion limits.
Therefore, the assumptions used in any accidents previously evaluated are unchanged and there is no significant increase in the consequences.
The proposed change to resolve the conflicts in the TS ensure that the intended Actions are followed when equipment is inoperable. Actions taken with inoperable equipment are not assumptions in the accidents previously evaluated and have no significant effect on the consequences.
The proposed change to eliminate an unnecessary action has no effect on the

Evaluation of the Proposed Amendment Beaver Valley Power Station, Unit Nos. 1 and 2 Page 5 of 6 consequences of accidents previously evaluated as the analysis of those accidents did not consider the use of the action.
The proposed change to increase consistency within the TS has no effect on the consequences of accidents previously evaluated as the proposed change clarifies the application of the existing requirements and does not change the intent.
The proposed change to renumber the TS and make other supporting changes has no effect on the probability or consequences of previously evaluated accidents.
Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed amendment create the possibility of a new or different kind of accident from any previously evaluated?
Response: No The proposed change does not involve a physical alteration of the plant (that is, no new or different type of equipment will be installed). The change does not alter assumptions made in the safety analyses. The proposed change does not alter the limiting conditions for operation for the rods or make any technical changes to the SRs governing the rods.
The proposed change to actions maintains or improves safety when equipment is inoperable and does not introduce new failure modes.
The proposed change to renumber the TS and make other supporting changes will not create the possibility of a new or different kind of accident from those previously evaluated.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No The proposed change to allow an alternative method of verifying rod position has no effect on the safety margin as actual rod position is not affected. The proposed change to provide time to repair rods that are Operable but immovable does not result in a significant reduction in the margin of safety because all rods

Evaluation of the Proposed Amendment Beaver Valley Power Station, Unit Nos. 1 and 2 Page 6 of 6 must be verified to be Operable, and all other banks must be within the insertion limits.
The remaining proposed changes to make the requirements internally consistent and to eliminate unnecessary actions do not affect the margin of safety as the changes do not affect the ability of the rods to perform their specified safety function.
The proposed change to renumber the TS and make other supporting changes has no effect on a margin of safety.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.
Based on the above, FENOC 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.
In conclusion, based on the considerations discussed above, (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.
4.0 ENVIRONMENTAL EVALUATION A review has determined the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.
However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Attachment 1 Proposed Changes to Technical Specifications, Annotated Copy (22 pages follow)

Unit 1 Rod Group Alignment Limits 3.1.4.1 3.1     REACTIVITY CONTROL SYSTEMS 3.1.4      Rod Group Alignment Limits 3.1.4.1    Unit 1 Rod Group Alignment Limits LCO 3.1.4.1             All shutdown and control rods shall be OPERABLE.
AND Individual indicated rod positions shall be within 12 steps (as determined in accordance with Specification 3.1.7.1, Unit 1 Rod Position Indication) of their group step counter demand position.
                                                                 - NOTE -
For Unit 1 only, vVerification of rod OPERABILITY and that the individual indicated rod positions are within the 12 step limit is not required during rod motion and for the first hour following rod motion.
APPLICABILITY:          MODES 1 and 2.
ACTIONS CONDITION                            REQUIRED ACTION                             COMPLETION TIME A. One or more rod(s)             A.1.1       Verify SDM to be within the              1 hour inoperable.                                limits specified in the COLR.
OR A.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.2         Be in MODE 3.                            6 hours B. One rod not within             B.1         Restore rod to within                    1 hour alignment limits.                          alignment limits.
OR B.2.1.1 Verify SDM to be within the                  1 hour limits specified in the COLR.
OR Beaver Valley Units 1 and 2                      3.1.4.1 - 1                           Amendments 278 / 161

Unit 1 Rod Group Alignment Limits 3.1.4.1 ACTIONS (continued)
CONDITION                  REQUIRED ACTION                  COMPLETION TIME B.2.1.2 Initiate boration to restore    1 hour SDM to within limit.
AND B.2.2    Reduce THERMAL                 2 hours POWER to  75% RTP.
AND B.2.3   Verify SDM is within the        Once per limits specified in the         12 hours COLR.
AND B.2.4    Perform SR 3.2.1.1 and         72 hours SR 3.2.1.2.
AND B.2.5   Perform SR 3.2.2.1.             72 hours AND B.2.6   Re-evaluate safety              5 days analyses and confirm results remain valid for duration of operation under these conditions.
C. Required Action and     C.1      Be in MODE 3.                  6 hours associated Completion Time of Condition B not met.
D. More than one rod not   D.1.1   Verify SDM is within the        1 hour within alignment limit.         limits specified in the COLR.
OR Beaver Valley Units 1 and 2          3.1.4.1 - 2                   Amendments - 278 /-161  I

Unit 1 Rod Group Alignment Limits 3.1.4.1 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME D.1.2       Initiate boration to restore             1 hour required SDM to within limit.
AND D.2         Be in MODE 3.                            6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                      FREQUENCY SR 3.1.4.1.1       -------------------------------------------------------------------------
                                                 - NOTE -
For Unit 1 only, tThis Surveillance is not required to be performed during rod motion and for the first hour following rod motion.
Verify individual rod positions within alignment limit.                     In accordance with the Surveillance Frequency Control Program SR 3.1.4.1.2       Verify rod freedom of movement (trippability) by                            In accordance moving each rod not fully inserted in the core                              with the 10 steps in either direction.                                             Surveillance Frequency Control Program SR 3.1.4.1.3       Verify rod drop time of each rod, from the fully                            Prior to criticality withdrawn position, is  2.7 seconds from the beginning                     after each of decay of stationary gripper coil voltage to dashpot                      removal of the entry, with:                                                                reactor head
: a. Tavg  500F and
: b. All reactor coolant pumps operating.
Beaver Valley Units 1 and 2                        3.1.4.1 - 3                          Amendments 292 / 179

Unit 2 Rod Group Alignment Limits 3.1.4.2 3.1     REACTIVITY CONTROL SYSTEMS 3.1.4      Rod Group Alignment Limits 3.1.4.2    Unit 2 Rod Group Alignment Limits LCO 3.1.4.2             All shutdown and control rods shall be OPERABLE.
AND Individual indicated rod positions shall be within 12 steps (as determined in accordance with Specification 3.1.7.2, Unit 2 Rod Position Indication) of their group step counter demand position.
APPLICABILITY:          MODES 1 and 2.
ACTIONS CONDITION                        REQUIRED ACTION                   COMPLETION TIME A. One or more rod(s)           A.1.1    Verify SDM to be within the      1 hour inoperable.                           limits specified in the COLR.
OR A.1.2     Initiate boration to restore    1 hour SDM to within limit.
AND A.2       Be in MODE 3.                   6 hours B. One rod not within           B.1.1    Verify SDM to be within the      1 hour alignment limits.                     limits specified in the COLR.
OR Beaver Valley Units 1 and 2                  3.1.4.2 - 1                           Amendments    /

Unit 2 Rod Group Alignment Limits 3.1.4.2 ACTIONS (continued)
CONDITION                 REQUIRED ACTION                   COMPLETION TIME B.1.2   Initiate boration to restore    1 hour SDM to within limit.
AND B.2    Reduce THERMAL                   2 hours POWER to  75% RTP.
AND B.3    Verify SDM is within the         Once per limits specified in the          12 hours COLR.
AND B.4    Perform SR 3.2.1.1,              72 hours SR 3.2.1.2, and SR 3.2.2.1.
AND B.5    Re-evaluate safety               5 days analyses and confirm results remain valid for duration of operation under these conditions.
C. Required Action and     C.1     Be in MODE 3.                   6 hours associated Completion Time of Condition B not met.
D. More than one rod not   D.1.1  Verify SDM is within the         1 hour within alignment limit.        limits specified in the COLR.
OR Beaver Valley Units 1 and 2          3.1.4.2 - 2                   Amendments 278 / 161

Unit 2 Rod Group Alignment Limits 3.1.4.2 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME D.1.2       Initiate boration to restore             1 hour required SDM to within limit.
AND D.2         Be in MODE 3.                            6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                      FREQUENCY SR 3.1.4.2.1       -------------------------------------------------------------------------
                                                 - NOTE -
Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
Verify position of individual rods within alignment limit.                  In accordance with the Surveillance Frequency Control Program SR 3.1.4.2.2       Verify rod freedom of movement (trippability) by                            In accordance moving each rod not fully inserted in the core                              with the 10 steps in either direction.                                             Surveillance Frequency Control Program SR 3.1.4.2.3       Verify rod drop time of each rod, from the fully                            Prior to criticality withdrawn position, is  2.7 seconds from the beginning                     after each of decay of stationary gripper coil voltage to dashpot                      removal of the entry, with:                                                                reactor head
: a. Tavg  500F and
: b. All reactor coolant pumps operating.
Beaver Valley Units 1 and 2                        3.1.4.2 - 3                          Amendments 292 / 179

Unit 1 Shutdown Bank Insertion Limits 3.1.5.1 3.1     REACTIVITY CONTROL SYSTEMS 3.1.5      Shutdown Bank Insertion Limits 3.1.5.1    Unit 1 Shutdown Bank Insertion Limits LCO 3.1.5.1              Each shutdown bank shall be within insertion limits specified in the COLR.
APPLICABILITY:           MODES 1 and 2.
                                                                     - NOTE -
This LCO is not applicable while performing SR 3.1.4.1.2.
ACTIONS CONDITION                              REQUIRED ACTION                             COMPLETION TIME A. One or more shutdown            A.1.1       Verify SDM is within the                 1 hour banks not within limits.                    limits specified in the COLR.
OR A.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.2         Restore shutdown banks to                2 hours within limits.
B. Required Action and             B.1         Be in MODE 3.                            6 hours associated Completion Time not met.
Beaver Valley Units 1 and 2                       3.1.5.1 - 1                           Amendments 278 / 161

Unit 1 Shutdown Bank Insertion Limits 3.1.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                    FREQUENCY SR 3.1.5.1.1       Verify each shutdown bank is within the insertion limits In accordance specified in the COLR.                                   with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2               3.1.5.1 - 2                   Amendments - 292 /-
179  I

Unit 2 Shutdown Bank Insertion Limits 3.1.5.2 3.1     REACTIVITY CONTROL SYSTEMS 3.1.5       Shutdown Bank Insertion Limits 3.1.5.2     Unit 2 Shutdown Bank Insertion Limits LCO 3.1.5.2              Each shutdown bank shall be within insertion limits specified in the COLR.
                                                              - NOTE -
Not applicable to shutdown banks inserted while performing SR 3.1.4.2.2.
APPLICABILITY:           MODES 1 and 2.
ACTIONS CONDITION                             REQUIRED ACTION                             COMPLETION TIME A. One shutdown bank               A.1         Verify all control banks are              1 hour inserted  12 steps                         within the insertion limits beyond the insertion limits                 specified in the COLR.
specified in the COLR.
AND A.2.1       Verify SDM is within the                  1 hour limits specified in the COLR.
OR A.2.2       Initiate boration to restore              1 hour SDM to within limit.
AND A.3         Restore the shutdown bank                 24 hours to within the insertion limits specified in the COLR.
B. One or more shutdown            B.1.1       Verify SDM is within the                 1 hour banks not within limits for                 limits specified in the reasons other than                          COLR.
Condition A.
OR Beaver Valley Units 1 and 2                       3.1.5.2 - 1                                      Amendments           /

Unit 2 Shutdown Bank Insertion Limits 3.1.5.2 ACTIONS (continued)
CONDITION                        REQUIRED ACTION                    COMPLETION TIME B.1.2   Initiate boration to restore    1 hour SDM to within limit.
AND B.2     Restore shutdown banks to       2 hours within limits.
C. Required Action and           C.1     Be in MODE 3.                   6 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                       FREQUENCY SR 3.1.5.2.1       Verify each shutdown bank is within the insertion limits   In accordance specified in the COLR.                                     with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2                3.1.5.2 - 2                           Amendments     /

Unit 1 Control Bank Insertion Limits 3.1.6.1 3.1     REACTIVITY CONTROL SYSTEMS 3.1.6        Control Bank Insertion Limits 3.1.6.1      Unit 1 Control Bank Insertion Limits LCO 3.1.6.1               Control banks shall be within the insertion, sequence, and overlap limits specified in the COLR.
APPLICABILITY:            MODE 1, MODE 2 with keff 1.0.
                                                                      - NOTE -
This LCO is not applicable while performing SR 3.1.4.1.2.
ACTIONS CONDITION                             REQUIRED ACTION                             COMPLETION TIME A. Control bank insertion           A.1.1       Verify SDM is within the                 1 hour limits not met.                              limits specified in the COLR.
OR A.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.2         Restore control bank(s) to               2 hours within limits.
B. Control bank sequence or         B.1.1       Verify SDM is within the                 1 hour overlap limits not met.                      limits specified in the COLR.
OR B.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND Beaver Valley Units 1 and 2                        3.1.6.1 - 1                           Amendments 278 / 161

Unit 1 Control Bank Insertion Limits 3.1.6.1 ACTIONS (continued)
CONDITION                           REQUIRED ACTION                   COMPLETION TIME B.2       Restore control bank            2 hours sequence and overlap to within limits.
C. Required Action and            C.1       Be in MODE 2 with keff          6 hours associated Completion                    < 1.0.
Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                         FREQUENCY SR 3.1.6.1.1       Verify estimated critical control bank position is within     Within 4 hours the limits specified in the COLR.                             prior to achieving criticality SR 3.1.6.1.2       Verify each control bank insertion is within the insertion    In accordance limits specified in the COLR.                                 with the Surveillance Frequency Control Program SR 3.1.6.1.3       Verify sequence and overlap limits specified in the           In accordance COLR are met for control banks not fully withdrawn            with the from the core.                                                Surveillance Frequency Control Program Beaver Valley Units 1 and 2                  3.1.6.1 - 2                                     --
Amendments 292 / 179       I

Unit 2 Control Bank Insertion Limits 3.1.6.2 3.1     REACTIVITY CONTROL SYSTEMS 3.1.6        Control Bank Insertion Limits 3.1.6.2      Unit 2 Control Bank Insertion Limits LCO 3.1.6.2                Control banks shall be within the insertion, sequence, and overlap limits specified in the COLR.
                                                                - NOTE -
Not applicable to control banks inserted while performing SR 3.1.4.2.2.
APPLICABILITY:             MODE 1, MODE 2 with keff 1.0.
ACTIONS CONDITION                              REQUIRED ACTION                             COMPLETION TIME A. Control bank A, B, or C           A.1         Verify all shutdown banks                1 hour inserted  12 steps                           are within the insertion limits beyond the insertion,                         specified in the COLR.
sequence, or overlap limits specified in the           AND COLR.
A.2.1       Verify SDM is within the                 1 hour limits specified in the COLR.
OR A.2.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.3         Restore the control bank to              24 hours within the insertion, sequence, and overlap limits specified in the COLR.
B. Control bank insertion            B.1.1       Verify SDM is within the                 1 hour limits not met for reasons                    limits specified in the COLR.
other than Condition A.
OR Beaver Valley Units 1 and 2                         3.1.6.2 - 1                                      Amendments           /

Unit 2 Control Bank Insertion Limits 3.1.6.2 ACTIONS (continued)
CONDITION                           REQUIRED ACTION                    COMPLETION TIME B.1.2     Initiate boration to restore     1 hour SDM to within limit.
AND B.2       Restore control bank(s) to       2 hours within limits.
C. Control bank sequence or        C.1.1     Verify SDM is within the         1 hour overlap limits not met for                limits specified in the COLR.
reasons other than Condition A.                         OR C.1.2     Initiate boration to restore     1 hour SDM to within limit.
AND C.2       Restore control bank             2 hours sequence and overlap to within limits.
D. Required Action and             D.1       Be in MODE 2 with keff           6 hours associated Completion                     < 1.0.
Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                           FREQUENCY SR 3.1.6.2.1        Verify estimated critical control bank position is within       Within 4 hours the limits specified in the COLR.                               prior to achieving criticality SR 3.1.6.2.2        Verify each control bank insertion is within the insertion      In accordance limits specified in the COLR.                                   with the Surveillance Frequency Control Program SR 3.1.6.2.3        Verify sequence and overlap limits specified in the             In accordance COLR are met for control banks not fully withdrawn              with the from the core.                                                  Surveillance Frequency Control Program Beaver Valley Units 1 and 2                    3.1.6.2 - 2                            Amendments       /

Unit 1 Rod Position Indication 3.1.7.1 3.1       REACTIVITY CONTROL SYSTEMS 3.1.7          Rod Position Indication 3.1.7.1        Unit 1 Rod Position Indication LCO 3.1.7.1                     The Rod Position Indication (RPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:                  MODES 1 and 2.
ACTIONS
                                                       - NOTE -
Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
CONDITION                                  REQUIRED ACTION                             COMPLETION TIME A.     ---------------------------------    A.1          Verify the affected rod                 15 minutes
                - NOTE -                                 position by measuring the Not required for                                  RPI channel primary misalignment indications                          voltage.
during rod motion and for up to 1 hour following rod           AND motion.
       ---------------------------------    A.2.1        Enter applicable Conditions             15 minutes and Required Actions of RPI System indicates                              LCO 3.1.4.1, "Unit 1 Rod one or more potentially                           Group Alignment Limits," for misaligned rods.                                  any rod determined to be misaligned by RPI channel primary voltage measurement.
OR A.2.2        Declare the affected RPI                15 minutes inoperable and enter the applicable Conditions and Required Actions of this Specification.
Beaver Valley Units 1 and 2                               3.1.7.1 - 1                          Amendments 278 / 161

Unit 2 Rod Position Indication 3.1.7.2 3.1      REACTIVITY CONTROL SYSTEMS 3.1.7          Rod Position Indication 3.1.7.2        Unit 2 Rod Position Indication LCO 3.1.7.2                     The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:                  MODES 1 and 2.
ACTIONS
                                                       - NOTE -
Separate Condition entry is allowed for each inoperable DRPI rod position indicator and each demand position indicator.
CONDITION                                  REQUIRED ACTION                             COMPLETION TIME A. One DRPI per group                    A.1         Verify the position of the               Once per 8 hours inoperable infor one or                           rods with inoperable DRPI more groups.                                      position indicators indirectly by using movable incore detectors.
OR A.2.1       Verify the position of the rod           8 hours with inoperable DRPI indirectly by using the                  AND moveable incore detectors.
Once per 31 EFPD thereafter AND                                            AND 8 hours after discovery of each unintended rod movement AND 8 hours after each movement of rod with inoperable DRPI
                                                                                                 > 12 steps AND

Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP A.2.2 Restore inoperable DRPI to    Prior to entering OPERABLE status.              MODE 2 from MODE 3 OR A.32  Reduce THERMAL POWER          8 hours to  50% RTP.
B. More than one DRPI per     B.1   Place the control rods under  Immediately group inoperable in one or       manual control.
more groups.
AND B.2   Monitor and record Reactor    Once per 1 hour Coolant System Tavg.
AND Beaver Valley Units 1 and 2           3.1.7.2 - 1                 Amendments 278 / 161

Unit 2 Rod Position Indication 3.1.7.2 ACTIONS (continued)
CONDITION                   REQUIRED ACTION                     COMPLETION TIME B.3    Verify the position of the        Once per 8 hours rods with inoperable position indicators indirectly by using the movable incore detectors.
AND B.24   Restore inoperable DRPIs          24 hours position indicators to OPERABLE status such that a maximum of one DRPI per group is inoperable.
C. One or more DRPI           C.1.1  Initiate action to vVerify the    Immediately8 hours inoperable in one or more         position of the rods with groups and associated rod         inoperable DRPIs position has One or more rods with         indicators indirectly by using inoperable position               movable incore detectors.
indicators have been moved > in excess of           AND 24 steps in one direction since the last             C.1.2  Complete rod position             8 hours determination of the rod's        verification started in position.                         Required Action C.1.1.
OR C.2    Reduce THERMAL POWER              8 hours to  50% RTP.
D. One or more demand         D.1.1  Verify by administrative          Once per 8 hours position indicators per           means all DRPIs for the bank inoperable forin one         affected banks are or more banks.                    OPERABLE.
AND D.1.2  Verify the most withdrawn         Once per 8 hours rod and the least withdrawn rod of the affected banks are  12 steps apart.
OR Beaver Valley Units 1 and 2            3.1.7.2 - 2                    Amendments 278 / 161

Unit 2 Rod Position Indication 3.1.7.2 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME D.2         Reduce THERMAL                           8 hours POWER to  50% RTP.
E. Required Action and               E.1         Be in MODE 3.                            6 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                     FREQUENCY SR 3.1.7.2.1       -------------------------------------------------------------------------   Once prior to
                                                 - NOTE -                                      criticality after Not required to be met for DRPIs associated with rods                       each removal of that do not meet LCO 3.1.4.2.                                               the reactor head Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.
Beaver Valley Units 1 and 2                        3.1.7.2 - 3                          Amendments 278 / 161

PHYSICS TESTS Exceptions - MODE 2 3.1.9 3.1     REACTIVITY CONTROL SYSTEMS 3.1.9       PHYSICS TESTS Exceptions - MODE 2 LCO 3.1.9               During the performance of PHYSICS TESTS, the requirements of:
LCO 3.1.3, "Moderator Temperature Coefficient,"
LCO 3.1.4.1, "Unit 1 Rod Group Alignment Limits,"
LCO 3.1.4.2, Unit 2 Rod Group Alignment Limits, LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limits,"
LCO 3.1.5.2, Unit 2 Shutdown Bank Insertion Limits, LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits,"
LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits, and LCO 3.4.2, "RCS Minimum Temperature for Criticality" may be suspended, and
: 1. The number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, and 17.e, may be reduced to 3 required channels provided:
: a.      RCS lowest loop average temperature is  531F,
: b.      SDM is within the limits specified in the COLR, and
: c.      THERMAL POWER is  5% RTP, and
: 2. For Unit 1 only, primary detector voltage measurements may be used to determine the position of rods in shutdown banks A and B and control banks A and B for the purpose of satisfying Specification 3.1.7.1.
APPLICABILITY:          During PHYSICS TESTS initiated in MODE 2.
ACTIONS CONDITION                      REQUIRED ACTION                     COMPLETION TIME A. SDM not within limit.       A.1      Initiate boration to restore      15 minutes SDM to within limit.
AND A.2      Suspend PHYSICS TESTS             1 hour exceptions.
B. THERMAL POWER not           B.1      Open reactor trip breakers.       Immediately within limit.
Beaver Valley Units 1 and 2                 3.1.9 - 1                     Amendments 278 / 161

Reporting Requirements 5.6 5.6   Reporting Requirements 5.6.3    CORE OPERATING LIMITS REPORT (COLR) (continued)
LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limits" LCO 3.1.5.2, Unit 2 Shutdown Bank Insertion Limits LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits" LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))"
LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor ( FNH )"
LCO 3.2.3, "Axial Flux Difference (AFD)"
LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation" - Overtemperature and Overpower T Allowable Value parameter values LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits" 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,"
WCAP-8745-P-A, "Design Bases for the Thermal Overtemperature T and Thermal Overpower T Trip Functions,"
WCAP-12945-P-A, Volumes 1 through 5, "Code Qualification Document for Best Estimate LOCA Analysis,"
(For Unit 1 only) WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using Automated Statistical Treatment of Uncertainty Method (ASTRUM),"
WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control/
FQ Surveillance Technical Specification,"
WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis,"
WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report,"
WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicating Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"
WCAP-13749-P-A, Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement, March 1997 (Westinghouse Proprietary),

Beaver Valley Units 1 and 2 5.6 - 2 Amendments 291 / 178 Attachment 2 Proposed Changes to Technical Specifications, Retyped Copy (20 pages follow)

For Information Only                                                     Unit 1 Rod Group Alignment Limits 3.1.4.1 3.1     REACTIVITY CONTROL SYSTEMS 3.1.4      Rod Group Alignment Limits 3.1.4.1    Unit 1 Rod Group Alignment Limits LCO 3.1.4.1             All shutdown and control rods shall be OPERABLE.
AND Individual indicated rod positions shall be within 12 steps (as determined in accordance with Specification 3.1.7.1, Unit 1 Rod Position Indication) of their group step counter demand position.
                                                                 - NOTE -
Verification of rod OPERABILITY and that the individual indicated rod positions are within the 12 step limit is not required during rod motion and for the first hour following rod motion.
APPLICABILITY:          MODES 1 and 2.
ACTIONS CONDITION                            REQUIRED ACTION                             COMPLETION TIME A. One or more rod(s)             A.1.1       Verify SDM to be within the              1 hour inoperable.                                limits specified in the COLR.
OR A.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.2         Be in MODE 3.                            6 hours B. One rod not within             B.1         Restore rod to within                    1 hour alignment limits.                          alignment limits.
OR B.2.1.1 Verify SDM to be within the                  1 hour limits specified in the COLR.
OR Beaver Valley Units 1 and 2                      3.1.4.1 - 1                             Amendments 999 / 999

For Information Only                                     Unit 1 Rod Group Alignment Limits 3.1.4.1 ACTIONS (continued)
CONDITION                  REQUIRED ACTION                  COMPLETION TIME B.2.1.2 Initiate boration to restore    1 hour SDM to within limit.
AND B.2.2    Reduce THERMAL                 2 hours POWER to  75% RTP.
AND B.2.3   Verify SDM is within the        Once per limits specified in the         12 hours COLR.
AND B.2.4    Perform SR 3.2.1.1 and         72 hours SR 3.2.1.2.
AND B.2.5   Perform SR 3.2.2.1.             72 hours AND B.2.6   Re-evaluate safety              5 days analyses and confirm results remain valid for duration of operation under these conditions.
C. Required Action and     C.1      Be in MODE 3.                  6 hours associated Completion Time of Condition B not met.
D. More than one rod not   D.1.1   Verify SDM is within the        1 hour within alignment limit.         limits specified in the COLR.
OR Beaver Valley Units 1 and 2          3.1.4.1 - 2                    Amendments 999 / 999

For Information Only                                                       Unit 1 Rod Group Alignment Limits 3.1.4.1 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME D.1.2       Initiate boration to restore             1 hour required SDM to within limit.
AND D.2         Be in MODE 3.                            6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                      FREQUENCY SR 3.1.4.1.1       -------------------------------------------------------------------------
                                                 - NOTE -
This Surveillance is not required to be performed during rod motion and for the first hour following rod motion.
Verify individual rod positions within alignment limit.
In accordance with the Surveillance Frequency Control Program SR 3.1.4.1.2       Verify rod freedom of movement (trippability) by                            In accordance moving each rod not fully inserted in the core                              with the 10 steps in either direction.                                             Surveillance Frequency Control Program SR 3.1.4.1.3       Verify rod drop time of each rod, from the fully                            Prior to criticality withdrawn position, is  2.7 seconds from the beginning                     after each of decay of stationary gripper coil voltage to dashpot                      removal of the entry, with:                                                                reactor head
: a. Tavg  500F and
: b. All reactor coolant pumps operating.
Beaver Valley Units 1 and 2                        3.1.4.1 - 3                            Amendments 999 / 999

For Information Only                                             Unit 2 Rod Group Alignment Limits 3.1.4.2 3.1     REACTIVITY CONTROL SYSTEMS 3.1.4      Rod Group Alignment Limits 3.1.4.2    Unit 2 Rod Group Alignment Limits LCO 3.1.4.2             All shutdown and control rods shall be OPERABLE.
AND Individual indicated rod positions shall be within 12 steps (as determined in accordance with Specification 3.1.7.2, Unit 2 Rod Position Indication) of their group step counter demand position.
APPLICABILITY:          MODES 1 and 2.
ACTIONS CONDITION                        REQUIRED ACTION                   COMPLETION TIME A. One or more rod(s)           A.1.1     Verify SDM to be within the     1 hour inoperable.                            limits specified in the COLR.
OR A.1.2     Initiate boration to restore    1 hour SDM to within limit.
AND A.2       Be in MODE 3.                   6 hours B. One rod not within           B.1.1     Verify SDM to be within the     1 hour alignment limits.                      limits specified in the COLR.
OR Beaver Valley Units 1 and 2                  3.1.4.2 - 1                    Amendments 999 / 999

For Information Only                                     Unit 2 Rod Group Alignment Limits 3.1.4.2 ACTIONS (continued)
CONDITION                 REQUIRED ACTION                   COMPLETION TIME B.1.2   Initiate boration to restore    1 hour SDM to within limit.
AND B.2     Reduce THERMAL                  2 hours POWER to  75% RTP.
AND B.3    Verify SDM is within the         Once per limits specified in the          12 hours COLR.
AND B.4     Perform SR 3.2.1.1,             72 hours SR 3.2.1.2, and SR 3.2.2.1.
AND B.5    Re-evaluate safety               5 days analyses and confirm results remain valid for duration of operation under these conditions.
C. Required Action and     C.1     Be in MODE 3.                   6 hours associated Completion Time of Condition B not met.
D. More than one rod not   D.1.1  Verify SDM is within the         1 hour within alignment limit.        limits specified in the COLR.
OR Beaver Valley Units 1 and 2          3.1.4.2 - 2                    Amendments 999 / 999

For Information Only                                                       Unit 2 Rod Group Alignment Limits 3.1.4.2 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME D.1.2       Initiate boration to restore             1 hour required SDM to within limit.
AND D.2         Be in MODE 3.                            6 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                      FREQUENCY SR 3.1.4.2.1       -------------------------------------------------------------------------
                                                 - NOTE -
Not required to be performed for rods associated with inoperable rod position indicator or demand position indicator.
Verify position of individual rods within alignment limit.                  In accordance with the Surveillance Frequency Control Program SR 3.1.4.2.2       Verify rod freedom of movement (trippability) by                            In accordance moving each rod not fully inserted in the core                              with the 10 steps in either direction.                                             Surveillance Frequency Control Program SR 3.1.4.2.3       Verify rod drop time of each rod, from the fully                            Prior to criticality withdrawn position, is  2.7 seconds from the beginning                     after each of decay of stationary gripper coil voltage to dashpot                      removal of the entry, with:                                                                reactor head
: a. Tavg  500F and
: b. All reactor coolant pumps operating.
Beaver Valley Units 1 and 2                        3.1.4.2 - 3                            Amendments 999 / 999

For Information Only                                                 Unit 1 Shutdown Bank Insertion Limits 3.1.5.1 3.1     REACTIVITY CONTROL SYSTEMS 3.1.5      Shutdown Bank Insertion Limits 3.1.5.1    Unit 1 Shutdown Bank Insertion Limits LCO 3.1.5.1              Each shutdown bank shall be within insertion limits specified in the COLR.
APPLICABILITY:           MODES 1 and 2.
                                                                     - NOTE -
This LCO is not applicable while performing SR 3.1.4.1.2.
ACTIONS CONDITION                              REQUIRED ACTION                             COMPLETION TIME A. One or more shutdown            A.1.1       Verify SDM is within the                 1 hour banks not within limits.                    limits specified in the COLR.
OR A.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.2         Restore shutdown banks to                2 hours within limits.
B. Required Action and             B.1         Be in MODE 3.                            6 hours associated Completion Time not met.
Beaver Valley Units 1 and 2                       3.1.5.1 - 1                             Amendments 999 / 999

For Information Only                                     Unit 1 Shutdown Bank Insertion Limits 3.1.5.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE                                     FREQUENCY SR 3.1.5.1.1       Verify each shutdown bank is within the insertion limits  In accordance specified in the COLR.                                    with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2               3.1.5.1 - 2                     Amendments 999 / 999

For Information Only                                                 Unit 2 Shutdown Bank Insertion Limits 3.1.5.2 3.1     REACTIVITY CONTROL SYSTEMS 3.1.5       Shutdown Bank Insertion Limits 3.1.5.2     Unit 2 Shutdown Bank Insertion Limits LCO 3.1.5.2              Each shutdown bank shall be within insertion limits specified in the COLR.
                                                              - NOTE -
Not applicable to shutdown banks inserted while performing SR 3.1.4.2.2.
APPLICABILITY:           MODES 1 and 2.
ACTIONS CONDITION                             REQUIRED ACTION                             COMPLETION TIME A. One shutdown bank               A.1         Verify all control banks are              1 hour inserted  12 steps                         within the insertion limits beyond the insertion limits                 specified in the COLR.
specified in the COLR.
AND A.2.1       Verify SDM is within the                  1 hour limits specified in the COLR.
OR A.2.2       Initiate boration to restore              1 hour SDM to within limit.
AND A.3         Restore the shutdown bank                 24 hours to within the insertion limits specified in the COLR.
B. One or more shutdown            B.1.1       Verify SDM is within the                 1 hour banks not within limits for                 limits specified in the reasons other than                          COLR.
Condition A.
OR Beaver Valley Units 1 and 2                       3.1.5.2 - 1                             Amendments 999 / 999

For Information Only                                       Unit 2 Shutdown Bank Insertion Limits 3.1.5.2 ACTIONS (continued)
CONDITION                        REQUIRED ACTION                    COMPLETION TIME B.1.2   Initiate boration to restore    1 hour SDM to within limit.
AND B.2     Restore shutdown banks to       2 hours within limits.
C. Required Action and           C.1     Be in MODE 3.                   6 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                       FREQUENCY SR 3.1.5.2.1       Verify each shutdown bank is within the insertion limits   In accordance specified in the COLR.                                     with the Surveillance Frequency Control Program Beaver Valley Units 1 and 2                3.1.5.2 - 2                    Amendments 999 / 999

For Information Only                                                      Unit 1 Control Bank Insertion Limits 3.1.6.1 3.1     REACTIVITY CONTROL SYSTEMS 3.1.6        Control Bank Insertion Limits 3.1.6.1      Unit 1 Control Bank Insertion Limits LCO 3.1.6.1               Control banks shall be within the insertion, sequence, and overlap limits specified in the COLR.
APPLICABILITY:            MODE 1, MODE 2 with keff 1.0.
                                                                      - NOTE -
This LCO is not applicable while performing SR 3.1.4.1.2.
ACTIONS CONDITION                             REQUIRED ACTION                             COMPLETION TIME A. Control bank insertion           A.1.1       Verify SDM is within the                 1 hour limits not met.                              limits specified in the COLR.
OR A.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.2         Restore control bank(s) to               2 hours within limits.
B. Control bank sequence or         B.1.1       Verify SDM is within the                 1 hour overlap limits not met.                      limits specified in the COLR.
OR B.1.2       Initiate boration to restore             1 hour SDM to within limit.
AND Beaver Valley Units 1 and 2                        3.1.6.1 - 1                             Amendments 999 / 999

For Information Only                                           Unit 1 Control Bank Insertion Limits 3.1.6.1 ACTIONS (continued)
CONDITION                           REQUIRED ACTION                   COMPLETION TIME B.2       Restore control bank            2 hours sequence and overlap to within limits.
C. Required Action and            C.1       Be in MODE 2 with keff          6 hours associated Completion                    < 1.0.
Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                         FREQUENCY SR 3.1.6.1.1       Verify estimated critical control bank position is within     Within 4 hours the limits specified in the COLR.                             prior to achieving criticality SR 3.1.6.1.2       Verify each control bank insertion is within the insertion    In accordance limits specified in the COLR.                                 with the Surveillance Frequency Control Program SR 3.1.6.1.3       Verify sequence and overlap limits specified in the           In accordance COLR are met for control banks not fully withdrawn            with the from the core.                                                Surveillance Frequency Control Program Beaver Valley Units 1 and 2                  3.1.6.1 - 2                     Amendments 999 / 999

For Information Only                                                       Unit 2 Control Bank Insertion Limits 3.1.6.2 3.1     REACTIVITY CONTROL SYSTEMS 3.1.6        Control Bank Insertion Limits 3.1.6.2      Unit 2 Control Bank Insertion Limits LCO 3.1.6.2                Control banks shall be within the insertion, sequence, and overlap limits specified in the COLR.
                                                                - NOTE -
Not applicable to control banks inserted while performing SR 3.1.4.2.2.
APPLICABILITY:             MODE 1, MODE 2 with keff 1.0.
ACTIONS CONDITION                              REQUIRED ACTION                             COMPLETION TIME A. Control bank A, B, or C           A.1         Verify all shutdown banks                1 hour inserted  12 steps                           are within the insertion limits beyond the insertion,                         specified in the COLR.
sequence, or overlap limits specified in the           AND COLR.
A.2.1       Verify SDM is within the                 1 hour limits specified in the COLR.
OR A.2.2       Initiate boration to restore             1 hour SDM to within limit.
AND A.3         Restore the control bank to              24 hours within the insertion, sequence, and overlap limits specified in the COLR.
B. Control bank insertion            B.1.1       Verify SDM is within the                 1 hour limits not met for reasons                    limits specified in the COLR.
other than Condition A.
OR Beaver Valley Units 1 and 2                         3.1.6.2 - 1                             Amendments 999 / 999

For Information Only                                               Unit 2 Control Bank Insertion Limits 3.1.6.2 ACTIONS (continued)
CONDITION                           REQUIRED ACTION                    COMPLETION TIME B.1.2     Initiate boration to restore     1 hour SDM to within limit.
AND B.2       Restore control bank(s) to       2 hours within limits.
C. Control bank sequence or        C.1.1     Verify SDM is within the         1 hour overlap limits not met for                limits specified in the COLR.
reasons other than Condition A.                         OR C.1.2     Initiate boration to restore     1 hour SDM to within limit.
AND C.2       Restore control bank             2 hours sequence and overlap to within limits.
D. Required Action and             D.1       Be in MODE 2 with keff           6 hours associated Completion                     < 1.0.
Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                           FREQUENCY SR 3.1.6.2.1        Verify estimated critical control bank position is within       Within 4 hours the limits specified in the COLR.                               prior to achieving criticality SR 3.1.6.2.2        Verify each control bank insertion is within the insertion      In accordance limits specified in the COLR.                                   with the Surveillance Frequency Control Program SR 3.1.6.2.3        Verify sequence and overlap limits specified in the             In accordance COLR are met for control banks not fully withdrawn              with the from the core.                                                  Surveillance Frequency Control Program Beaver Valley Units 1 and 2                    3.1.6.2 - 2                     Amendments 999 / 999

For Information Only                                                                    Unit 1 Rod Position Indication 3.1.7.1 3.1       REACTIVITY CONTROL SYSTEMS 3.1.7          Rod Position Indication 3.1.7.1        Unit 1 Rod Position Indication LCO 3.1.7.1                     The Rod Position Indication (RPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:                  MODES 1 and 2.
ACTIONS
                                                       - NOTE -
Separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator.
CONDITION                                  REQUIRED ACTION                             COMPLETION TIME A.     ---------------------------------    A.1          Verify the affected rod                 15 minutes
                - NOTE -                                 position by measuring the Not required for                                  RPI channel primary misalignment indications                          voltage.
during rod motion and for up to 1 hour following rod           AND motion.
       ---------------------------------    A.2.1        Enter applicable Conditions             15 minutes and Required Actions of RPI System indicates                              LCO 3.1.4.1, "Unit 1 Rod one or more potentially                           Group Alignment Limits," for misaligned rods.                                  any rod determined to be misaligned by RPI channel primary voltage measurement.
OR A.2.2        Declare the affected RPI                15 minutes inoperable and enter the applicable Conditions and Required Actions of this Specification.
Beaver Valley Units 1 and 2                               3.1.7.1 - 1                            Amendments 999 / 999

For Information Only                                                                    Unit 2 Rod Position Indication 3.1.7.2 3.1      REACTIVITY CONTROL SYSTEMS 3.1.7          Rod Position Indication 3.1.7.2        Unit 2 Rod Position Indication LCO 3.1.7.2                     The Digital Rod Position Indication (DRPI) System and the Demand Position Indication System shall be OPERABLE.
APPLICABILITY:                  MODES 1 and 2.
ACTIONS
                                                       - NOTE -
Separate Condition entry is allowed for each inoperable DRPI and each demand position indicator.
CONDITION                                  REQUIRED ACTION                            COMPLETION TIME A. One DRPI per group                    A.1         Verify the position of the rod           Once per 8 hours inoperable in one or                              with inoperable DRPI more groups.                                      indirectly by using movable incore detectors.
OR A.2.1       Verify the position of the rod           8 hours with inoperable DRPI indirectly by using the                  AND moveable incore detectors.
Once per 31 EFPD thereafter AND                                            AND 8 hours after discovery of each unintended rod movement AND 8 hours after each movement of rod with inoperable DRPI
                                                                                                 > 12 steps AND Beaver Valley Units 1 and 2                              3.1.7.2 - 1                             Amendments 999 / 999

For Information Only                                             Unit 2 Rod Position Indication 3.1.7.2 ACTIONS (continued)
CONDITION                    REQUIRED ACTION                    COMPLETION TIME Prior to THERMAL POWER exceeding 50% RTP AND 8 hours after reaching RTP A.2.2  Restore inoperable DRPI to       Prior to entering OPERABLE status.                  MODE 2 from MODE 3 OR A.3    Reduce THERMAL POWER             8 hours to  50% RTP.
B. More than one DRPI per      B.1    Place the control rods under     Immediately group inoperable in one or        manual control.
more groups.
AND B.2    Restore inoperable DRPIs         24 hours to OPERABLE status such that a maximum of one DRPI per group is inoperable.
C. One or more DRPI            C.1    Verify the position of the       8 hours inoperable in one or more         rods with inoperable DRPIs groups and associated rod         indirectly by using movable has been moved                    incore detectors.
    > 24 steps in one direction since the last              OR determination of the rod's position.                   C.2    Reduce THERMAL POWER             8 hours to  50% RTP.
Beaver Valley Units 1 and 2             3.1.7.2 - 2                     Amendments 999 / 999

For Information Only                                                               Unit 2 Rod Position Indication 3.1.7.2 ACTIONS (continued)
CONDITION                                REQUIRED ACTION                            COMPLETION TIME D. One or more demand                 D.1.1       Verify by administrative                 Once per 8 hours position indicators per                        means all DRPIs for the bank inoperable in one or                      affected banks are more banks.                                    OPERABLE.
AND D.1.2       Verify the most withdrawn                Once per 8 hours rod and the least withdrawn rod of the affected banks are  12 steps apart.
OR D.2         Reduce THERMAL                           8 hours POWER to  50% RTP.
E. Required Action and                E.1         Be in MODE 3.                            6 hours associated Completion Time not met.
SURVEILLANCE REQUIREMENTS SURVEILLANCE                                                     FREQUENCY SR 3.1.7.2.1        -------------------------------------------------------------------------   Once prior to
                                                  - NOTE -                                      criticality after Not required to be met for DRPIs associated with rods                       each removal of that do not meet LCO 3.1.4.2.                                               the reactor head Verify each DRPI agrees within 12 steps of the group demand position for the full indicated range of rod travel.
Beaver Valley Units 1 and 2                         3.1.7.2 - 3                            Amendments 999 / 999

For Information Only                                     PHYSICS TESTS Exceptions - MODE 2 3.1.9 3.1     REACTIVITY CONTROL SYSTEMS 3.1.9       PHYSICS TESTS Exceptions - MODE 2 LCO 3.1.9               During the performance of PHYSICS TESTS, the requirements of:
LCO 3.1.3, "Moderator Temperature Coefficient,"
LCO 3.1.4.1, "Unit 1 Rod Group Alignment Limits,"
LCO 3.1.4.2, Unit 2 Rod Group Alignment Limits, LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limits,"
LCO 3.1.5.2, Unit 2 Shutdown Bank Insertion Limits, LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits,"
LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits, and LCO 3.4.2, "RCS Minimum Temperature for Criticality" may be suspended, and
: 1. The number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, and 17.e, may be reduced to 3 required channels provided:
: a.      RCS lowest loop average temperature is  531F,
: b.      SDM is within the limits specified in the COLR, and
: c.      THERMAL POWER is  5% RTP, and
: 2. For Unit 1 only, primary detector voltage measurements may be used to determine the position of rods in shutdown banks A and B and control banks A and B for the purpose of satisfying Specification 3.1.7.1.
APPLICABILITY:          During PHYSICS TESTS initiated in MODE 2.
ACTIONS CONDITION                      REQUIRED ACTION                     COMPLETION TIME A. SDM not within limit.       A.1      Initiate boration to restore      15 minutes SDM to within limit.
AND A.2      Suspend PHYSICS TESTS             1 hour exceptions.
B. THERMAL POWER not           B.1      Open reactor trip breakers.       Immediately within limit.
Beaver Valley Units 1 and 2                 3.1.9 - 1                     Amendments 999 / 999

For Information Only                                                    Reporting Requirements 5.6 5.6    Reporting Requirements 5.6.3     CORE OPERATING LIMITS REPORT (COLR) (continued)
LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limits" LCO 3.1.5.2, Unit 2 Shutdown Bank Insertion Limits LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits" LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))"
LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor ( FNH )"
LCO 3.2.3, "Axial Flux Difference (AFD)"
LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation" - Overtemperature and Overpower T Allowable Value parameter values LCO 3.4.1, "RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits" 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,"
WCAP-8745-P-A, "Design Bases for the Thermal Overtemperature T and Thermal Overpower T Trip Functions,"
WCAP-12945-P-A, Volumes 1 through 5, "Code Qualification Document for Best Estimate LOCA Analysis,"
(For Unit 1 only) WCAP-16009-P-A, "Realistic Large Break LOCA Evaluation Methodology Using Automated Statistical Treatment of Uncertainty Method (ASTRUM),"
WCAP-10216-P-A, "Relaxation of Constant Axial Offset Control/
FQ Surveillance Technical Specification,"
WCAP-14565-P-A, "VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis,"
WCAP-12610-P-A, "VANTAGE+ Fuel Assembly Reference Core Report,"
WCAP-15025-P-A, "Modified WRB-2 Correlation, WRB-2M, for Predicating Critical Heat Flux in 17x17 Rod Bundles with Modified LPD Mixing Vane Grids,"
WCAP-13749-P-A, Safety Evaluation Supporting the Conditional Exemption of the Most Negative EOL Moderator Temperature Coefficient Measurement, March 1997 (Westinghouse Proprietary),
Beaver Valley Units 1 and 2                  5.6 - 2                    Amendments 999 / 999

Attachment 3 Proposed Changes to Technical Specifications Bases, Annotated Copy (45 pages follow)

For Information Only                                                   Rod Group Alignment Limits No Changes - Provided for Context                                                           B 3.1.4 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.4   Rod Group Alignment Limits BASES BACKGROUND            The OPERABILITY (i.e., trippability) of the shutdown and control rods is an initial assumption in all safety analyses that assume rod insertion upon reactor trip. Maximum rod misalignment is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available SDM.
The applicable criteria for these reactivity and power distribution design requirements are 10 CFR 50, Appendix A, GDC 10, "Reactor Design,"
GDC 26, "Reactivity Control System Redundancy and Capability" as discussed in Reference 1, and 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Plants" (Ref. 2).
Mechanical or electrical failures may cause a control or shutdown rod to become inoperable or to become misaligned from its group. Rod inoperability or misalignment may cause increased power peaking, due to the asymmetric reactivity distribution and a reduction in the total available rod worth for reactor shutdown. Therefore, rod alignment and OPERABILITY are related to core operation in design power peaking limits and the core design requirement of a minimum SDM.
Limits on rod alignment have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.
Rod cluster control assemblies (RCCAs), or rods, are moved by their control rod drive mechanisms (CRDMs). Each CRDM moves its RCCA one step (approximately 5/8 inch) at a time, but at varying rates (steps per minute) depending on the signal output from the Rod Control System.
The RCCAs are divided among control banks and shutdown banks. Each bank is further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that are electrically paralleled to step simultaneously. A bank of RCCAs consists of two groups, the groups are moved in a staggered fashion, but always within one step of each other. There are four control banks and two shutdown banks.
The shutdown banks are maintained either in the fully inserted or fully withdrawn position. The control banks are moved in an overlap pattern, Beaver Valley Units 1 and 2                 B 3.1.4 - 1                                  Revision 0

For Information Only                                                     Rod Group Alignment Limits No Changes - Provided for Context                                                              B 3.1.4 BASES BACKGROUND (continued) using the following withdrawal sequence: When control bank A reaches a predetermined height in the core, control bank B begins to move out with control bank A. Control bank A stops at the position of maximum withdrawal, and control bank B continues to move out. When control bank B reaches a predetermined height, control bank C begins to move out with control bank B. This sequence continues until control banks A, B, and C are at the fully withdrawn position, and control bank D is approximately halfway withdrawn. The insertion sequence is the opposite of the withdrawal sequence. The control rods are arranged in a radially symmetric pattern, so that control bank motion does not introduce radial asymmetries in the core power distributions.
The axial position of shutdown rods and control rods is indicated by two separate and independent systems, which are the Bank Demand Position Indication System (commonly called group step counters) and the Rod Position Indication (RPI) System for Unit 1 and the Digital Rod Position Indication (DRPI) System for Unit 2.
The Bank Demand Position Indication System counts the pulses from the rod control system that moves the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise ( 1 step or  5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.
The RPI and DRPI systems provide an accurate indication of actual rod position, but at a lower precision than the step counters. These systems are based on inductive analog signals from a series of coils spaced along a hollow tube. The RPI System is capable of monitoring rod position within  12 steps. To increase the reliability of the DRPI System, the inductive coils are connected alternately to data system A or B. Thus, if one data system fails, the DRPI will go on half accuracy. The DRPI System is capable of monitoring rod position within  4 steps, for full accuracy, and +4, -10 steps at half accuracy with data system A, and
                      +10, -4 steps at half accuracy with data system B.
APPLICABLE            Control rod misalignment accidents are analyzed in the safety analysis SAFETY                (Ref. 3). The acceptance criteria for addressing control rod inoperability ANALYSES              or misalignment are that:
: a. There be no violations of:
: 1. Specified acceptable fuel design limits or Beaver Valley Units 1 and 2                   B 3.1.4 - 2                                   Revision 0

For Information Only                                                   Rod Group Alignment Limits No Changes - Provided for Context                                                             B 3.1.4 BASES APPLICABLE SAFETY ANALYSIS (continued)
: 2. Reactor Coolant System (RCS) pressure boundary integrity and
: b. The core remains subcritical after accident transients.
Two types of misalignment are distinguished. During movement of a control rod group, one rod may stop moving, while the other rods in the group continue. This condition may cause excessive power peaking.
The second type of misalignment occurs if one rod fails to insert upon a reactor trip and remains stuck fully withdrawn. This condition requires an evaluation to determine that sufficient reactivity worth is held in the control rods to meet the SDM requirement, with the maximum worth rod stuck fully withdrawn.
Two types of analysis are performed in regard to static rod misalignment (Ref. 4). With control banks at their insertion limits, one type of analysis considers the case when any one rod is completely inserted into the core.
The second type of analysis considers the case of a completely withdrawn single rod from a bank inserted to its insertion limit. Satisfying limits on departure from nucleate boiling ratio in both of these cases bounds the situation when a rod is misaligned from its group by 12 steps.
The Required Actions in this LCO ensure that either deviations from the alignment limits will be corrected or that THERMAL POWER will be adjusted so that excessive local linear heat rates (LHRs) will not occur, and that the requirements on SDM and ejected rod worth are preserved.
Continued operation of the reactor with a misaligned control rod is allowed if the heat flux hot channel factor ( FQ(Z)) and the nuclear enthalpy hot channel factor (FNH) are verified to be within their limits in the COLR and the safety analysis is verified to remain valid. When a control rod is misaligned, the assumptions that are used to determine the rod insertion limits, AFD limits, and quadrant power tilt limits are not preserved. Therefore, the limits may not preserve the design peaking factors, and FQ(Z) and FNH must be verified directly by incore mapping.
Bases Section 3.2 (Power Distribution Limits) contains more complete discussions of the relation of FQ(Z) and FNH to the operating limits.
Shutdown and control rod OPERABILITY and alignment are directly related to power distributions and SDM, which are initial conditions assumed in safety analyses. Therefore they satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).
Beaver Valley Units 1 and 2                  B 3.1.4 - 3                                  Revision 0

For Information Only                                                    Rod Group Alignment Limits No Changes - Provided for Context                                                              B 3.1.4 BASES LCO                   The limits on shutdown or control rod alignments ensure that the assumptions in the safety analysis will remain valid. The requirements on control rod OPERABILITY ensure that upon reactor trip, the assumed reactivity will be available and will be inserted. The control rod OPERABILITY requirements (i.e., trippability) are separate from the alignment requirements, which ensure that the RCCAs and banks maintain the correct power distribution and rod alignment. The rod OPERABILITY requirement is satisfied provided the rod will fully insert in the required rod drop time assumed in the safety analysis. Rod control malfunctions that result in the inability to move a rod (e.g., rod lift coil failures), but that do not impact trippability, do not result in rod inoperability.
The requirement to maintain the rod alignment to within plus or minus 12 steps is conservative. The minimum misalignment assumed in safety analysis is 24 steps (15 inches), and in some cases a total misalignment from fully withdrawn to fully inserted is assumed.
Failure to meet the requirements of this LCO may produce unacceptable power peaking factors and LHRs, or unacceptable SDMs, all of which may constitute initial conditions inconsistent with the safety analysis.
The rod alignment requirements of this LCO may be met by determining rod position in accordance with Rod Position Indication Specifications 3.1.7.1 (Unit 1) and 3.1.7.2 (Unit 2). The ACTIONS of the Rod Position Indication specifications provide alternate methods for determining rod position if a position indicator is inoperable. If the ACTIONS of a Rod Position Indication specification are applicable, the alternate method(s) for determining rod position specified in the applicable ACTIONS may be used to meet the alignment requirements of this LCO.
The LCO requirements are modified by a Note that is only applicable to Unit 1. The Note provides an exception to verifying the LCO requirements are met during rod motion and for the first hour following rod motion. The exception is necessary to accommodate the thermal stabilization required after rod movement for the Unit 1 RPI System. The RPI System requires time to achieve thermal equilibrium after rod movement in order to provide indication within the required accuracy.
During rod motion and the time allowed for thermal soak after rod motion, the group demand counters provide the primary indication of precise rod position with the RPI channels displaying general rod movement information. Therefore, comparison between the two indications to verify the LCO requirements are met is not required during the time specified in this Note.
Beaver Valley Units 1 and 2                  B 3.1.4 - 4                                   Revision 0

For Information Only                                                    Rod Group Alignment Limits B 3.1.4 BASES APPLICABILITY         The requirements on RCCA OPERABILITY and alignment are applicable in MODES 1 and 2 because these are the only MODES in which the reactor is critical and power is generated, and the OPERABILITY (i.e.,
trippability) and alignment of rods have the potential to affect the safety of the plant. In MODES 3, 4, 5, and 6, the alignment limits do not apply because the control rods are typically bottomed and the reactor is shut down and not producing power. In the shutdown MODES, the OPERABILITY of the shutdown and control rods has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the RCS. See LCO 3.1.1, "SHUTDOWN MARGIN," for SDM in MODES 3, 4, and 5 and LCO 3.9.1, "Boron Concentration," for boron concentration requirements during refueling.
ACTIONS               A.1.1 and A.1.2 When one or more rods are inoperable (i.e., untrippable), there is a possibility that the required SDM may be adversely affected. Under these conditions, it is important to determine the SDM, and if it is less than the required value, initiate boration until the required SDM is recovered. The Completion Time of 1 hour is adequate for determining SDM and, if necessary, for initiating emergency boration and restoring SDM.
In this situation, SDM verification must include the worth of the untrippable rod, as well as a rod of maximum worth.
A.2 If the inoperable rod(s) cannot be restored to OPERABLE status, the plant must be brought to a MODE or condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours.
The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
B.1 (Unit 1)
When a rod becomes misaligned, it can usually be moved and is still trippable. If the rod can be realigned within the Completion Time of 1 hour, local xenon redistribution during this short interval will not be significant, and operation may proceed without further restriction.
Beaver Valley Units 1 and 2                  B 3.1.4 - 5                                  Revision 0- I

For Information Only                                                Rod Group Alignment Limits B 3.1.4 BASES ACTIONS (continued)
An alternative to realigning a single misaligned RCCA to the group average position is to align the remainder of the group to the position of the misaligned RCCA. However, this must be done without violating the bank sequence, overlap, and insertion limits specified in LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits." The Completion Time of 1 hour gives the operator sufficient time to adjust the rod positions in an orderly manner.
B.2.1.1 and B.2.1.2 (Unit 1)
With a misaligned rod, SDM must be verified to be within limit or boration must be initiated to restore SDM to within limit.
In many cases, realigning the remainder of the group to the misaligned rod may not be desirable. For example, realigning control bank B to a rod that is misaligned 15 steps from the top of the core would require a significant power reduction, since control bank D must be moved fully in and control bank C must be moved in to approximately 100 to 115 steps.
Power operation may continue with one RCCA trippable but misaligned, provided that SDM is verified within 1 hour. The Completion Time of 1 hour represents the time necessary for determining the actual unit SDM and, if necessary, aligning and starting the necessary systems and components to initiate boration.
B.1.1 and B1.2 (Unit 2)
When a rod becomes misaligned, it can usually be moved and is still trippable.
An alternative to realigning a single misaligned RCCA to the group average position is to align the remainder of the group to the position of the misaligned RCCA. However, this must be done without violating the bank sequence, overlap, and insertion limits specified in LCO 3.1.5.2, "Unit 2 Shutdown Bank Insertion Limits," and LCO 3.1.6.2, "Unit 2 Control Bank Insertion Limits."
In many cases, realigning the remainder of the group to the misaligned rod may not be desirable. For example, realigning control bank B to a rod that is misaligned 15 steps from the top of the core would require a significant power reduction, since control bank D must be moved fully in and control bank C must be moved in to approximately 100 to 115 steps.
Power operation may continue with one RCCA trippable but misaligned, provided that SDM is verified within 1 hour. The Completion Time of 1 hour represents the time necessary for determining the actual unit SDM and, if necessary, aligning and starting the necessary systems and components to initiate boration.

For Information Only B.2.2, B.2.3, B.2.4, B.2.5, and B.2.6 (Unit 1) and B.2, B.3, B.4, and B.5 (Unit 2)
For continued operation with a misaligned rod, THERMAL POWER must be reduced, SDM must periodically be verified within limits, hot channel factors (FQ(Z) and FNH) must be verified within limits, and the safety analyses must be re-evaluated to confirm continued operation is permissible.
Reduction of power to  75% RTP ensures that local LHR increases due to a misaligned RCCA will not cause the core design criteria to be exceeded. The Completion Time of 2 hours gives the operator sufficient time to accomplish an orderly power reduction without challenging the Reactor Protection System.
When a rod is known to be misaligned, there is a potential to impact the SDM. Since the core conditions can change with time, periodic verification of SDM is required. A Frequency of 12 hours is sufficient to ensure this requirement continues to be met.
Beaver Valley Units 1 and 2                 B 3.1.4 - 6                                  Revision 0

For Information Only                                                  Rod Group Alignment Limits B 3.1.4 No Changes - Provided for Context BASES ACTIONS (continued)
Verifying that FQ(Z), as approximated by FCQ(Z) and FWQ(Z), and FNH are within the required limits ensures that current operation at  75% RTP with a rod misaligned is not resulting in power distributions that may invalidate safety analysis assumptions at full power. The Completion Time of 72 hours allows sufficient time to obtain flux maps of the core power distribution using the incore flux mapping system and to calculate FQ(Z) and FNH.
Once current conditions have been verified acceptable, time is available to perform evaluations of accident analysis to determine that core limits will not be exceeded during a Design Basis Event for the duration of operation under these conditions. The accident analyses presented in UFSAR Chapter 14 (Unit 1) and Chapter 15 (Unit 2) (Ref. 3) that may be adversely affected will be evaluated to ensure that the analysis results remain valid for the duration of continued operation under these conditions. A Completion Time of 5 days is sufficient time to obtain the required input data and to perform the analysis.
C.1 When Required Actions cannot be completed within their Completion Time, the unit must be brought to a MODE or Condition in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours, which obviates concerns about the development of undesirable xenon or power distributions. The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging the plant systems.
D.1.1 and D.1.2 More than one rod becoming misaligned from its group average position is not expected, and has the potential to reduce SDM. Therefore, SDM must be evaluated. One hour allows the operator adequate time to determine SDM. Restoration of the required SDM, if necessary, requires increasing the RCS boron concentration to provide negative reactivity, as described in the Bases of LCO 3.1.1. The required Completion Time of 1 hour for initiating boration is reasonable, based on the time required for potential xenon redistribution, the low probability of an accident occurring, and the steps required to complete the action. This allows the operator sufficient time to align the required valves and start the boric acid pumps.
Boration will continue until the required SDM is restored.
Beaver Valley Units 1 and 2                  B 3.1.4 - 7                                 Revision 0

For Information Only                                                  Rod Group Alignment Limits B 3.1.4 BASES ACTIONS (continued)
D.2 If more than one rod is found to be misaligned or becomes misaligned because of bank movement, the unit conditions fall outside of the accident analysis assumptions. Since automatic bank sequencing would continue to cause misalignment, the unit must be brought to a MODE in which the LCO requirements are not applicable. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours.
The allowed Completion Time is reasonable, based on operating experience, for reaching MODE 3 from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE        SR 3.1.4.1.1 (Unit 1)
REQUIREMENTS Verification that individual rod positions are within alignment limits provides a history that allows the operator to detect a rod that is beginning to deviate from its expected position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
The SR is modified by a Note that is only applicable to Unit 1. The Note provides an exception to performing the SR during rod motion and for the first hour following rod motion. The exception is consistent with the Unit 1 LCO exception Note and is necessary to allow for thermal stabilization and accurate rod position indication. During rod motion and the time allowed for thermal soak after rod motion, the group demand counters provide the primary indication of precise rod position with the RPI channels displaying general rod movement information. Therefore, comparison between the two indications to verify the LCO requirements are met is not required during the time specified in this Note. If the SR comes due during the time allowed by the Note, and the RPI has not stabilized within the required accuracy, the SR should be performed as soon as possible after the time provided by the Note expires. In order to facilitate the thermal stabilization of the RPI during the one-hour thermal soak, absolute rod motion should be limited to six steps.
SR 3.1.4.2.1 (Unit 2)
Verification that the position of individual rods is within alignment limits provides a history that allows the operator to detect a rod that is beginning to deviate from its expected position. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
The SR is modified by a Note that permits it to not be performed for rods associated with an inoperable demand position indicator or an inoperable rod position indicator. The alignment limit is based on the demand position indicator which is not available if the indicator is inoperable.
LCO 3.1.7.2, Unit 2 Rod Position Indication, provides Actions to verify

For Information Only the rods are in alignment when one or more rod position indicators are inoperable.
Beaver Valley Units 1 and 2                B 3.1.4 - 8                              Revision 29

For Information Only                                                     Rod Group Alignment Limits B 3.1.4 BASES SURVEILLANCE REQUIREMENTS (continued)
SR 3.1.4.1.2 (Unit 1) and SR 3.1.4.2.2 (Unit 2)
Verifying each rod is OPERABLE would require that each rod be tripped.
However, in MODES 1 and 2 with Keff  1.0, tripping each rod would result in radial or axial power tilts, or oscillations. Exercising each individual rod provides increased confidence that all rods continue to be OPERABLE without exceeding the alignment limit, even if they are not regularly tripped. Moving each rod by 10 steps will not cause radial or axial power tilts, or oscillations, to occur. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Between required performances of SRs 3.1.4.1.2 and 3.1.4.2.2 (determination of rod OPERABILITY by movement), if a rod(s) is discovered to be immovable, but remains trippable the rod(s) is considered to be OPERABLE. At any time, if a rod(s) is immovable, a determination of the trippability (OPERABILITY) of the rod(s) must be made, and appropriate action taken.
For Unit 1 only. The RPI System requires time to achieve thermal equilibrium after rod movement in order to provide accurate rod position indication. During rod motion and the time allowed for thermal soak after rod motion, the group demand counters provide the primary indication of precise rod position with the RPI channels displaying general rod movement information. Considering the time it takes to stabilize the RPI and the relatively short time it takes to perform this SR, it is not required that the RPI show a full 10 step movement in order to confirm freedom of movement. The 10-step requirement of this SR is the minimum required change in demand counter indication that should result in a sufficient change in the RPI to determine freedom of movement.
SR 3.1.4.1.3 (Unit 1) and SR 3.1.4.2.3 (Unit 2)
Verification of rod drop times allows the operator to determine that the maximum rod drop time permitted is consistent with the assumed rod drop time used in the safety analysis. Measuring rod drop times prior to reactor criticality, after reactor vessel head removal, ensures that the reactor internals and rod drive mechanism will not interfere with rod motion or rod drop time, and that no degradation in these systems has occurred that would adversely affect rod motion or drop time. This testing is performed with all RCPs operating and the average moderator temperature  500F to simulate a reactor trip under actual conditions.
Beaver Valley Units 1 and 2                    B 3.1.4 - 9                                         -
Revision 29  I

For Information Only                                                  Rod Group Alignment Limits B 3.1.4 No Changes - Provided for Context BASES SURVEILLANCE REQUIREMENTS (continued)
This Surveillance is performed during a plant outage, due to the plant conditions needed to perform the SR and the potential for an unplanned plant transient if the Surveillance were performed with the reactor at power.
REFERENCES            1. Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."
: 2. 10 CFR 50.46.
: 3. UFSAR, Chapter 14 (Unit 1) and Chapter 15 (Unit 2).
: 4. UFSAR, Section 14.1.3 (Unit 1) and Section 15.4.3 (Unit 2).
Beaver Valley Units 1 and 2                  B 3.1.4 - 10                              Revision 0

For Information Only                                                 Shutdown Bank Insertion Limits B 3.1.5 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.5   Shutdown Bank Insertion Limits BASES BACKGROUND            The insertion limits of the shutdown and control rods are initial assumptions in all safety analyses that assume rod insertion upon reactor trip. The insertion limits directly affect core power and fuel burnup distributions and assumptions of available ejected rod worth, SDM and initial reactivity insertion rate.
The applicable criteria for these reactivity and power distribution design requirements are 10 CFR 50, Appendix A, GDC 10, "Reactor Design,"
GDC 26, "Reactivity Control System Redundancy and Protection,"
GDC 28, "Reactivity Limits" as discussed in Reference 1, and 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors" (Ref. 2). Limits on control rod insertion have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.
The rod cluster control assemblies (RCCAs) are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that are electrically paralleled to step simultaneously.
A bank of RCCAs consists of two groups that are moved in a staggered fashion, but always within one step of each other. There are four control banks and two shutdown banks. See LCOs 3.1.4.1 (Unit 1) and 3.1.4.2 (Unit 2), "Rod Group Alignment Limits," for control and shutdown rod OPERABILITY and alignment requirements, and LCOs 3.1.7.1 (Unit
: 1) and 3.1.7.2 (Unit 2), "Rod Position Indication," for position indication requirements.
The control banks are used for precise reactivity control of the reactor.
The positions of the control banks are normally automatically controlled by the Rod Control System, but they can also be manually controlled.
They are capable of adding negative reactivity very quickly (compared to borating). The control banks must be maintained above designed insertion limits and are typically near the fully withdrawn position during normal full power operations.
Hence, they are not capable of adding a large amount of positive reactivity. Boration or dilution of the Reactor Coolant System (RCS) compensates for the reactivity changes associated with large changes in RCS temperature. The design calculations are performed with the assumption that the shutdown banks are withdrawn first. The shutdown banks can be fully withdrawn without the core going critical. This Beaver Valley Units 1 and 2                    B 3.1.5 - 1                                         -
Revision 0 I

For Information Only                                               Shutdown Bank Insertion Limits B 3.1.5 BASES BACKGROUND (continued) provides available negative reactivity in the event of boration errors. The shutdown banks are controlled manually by the control room operator.
During normal unit operation, the shutdown banks are either fully withdrawn or fully inserted. The shutdown banks must be completely withdrawn from the core, prior to withdrawing any control banks during an approach to criticality. The shutdown banks are then left in this position until the reactor is shut down. They affect core power and burnup distribution, and add negative reactivity to shut down the reactor upon receipt of a reactor trip signal.
APPLICABLE            On a reactor trip, all RCCAs (shutdown banks and control banks), except SAFETY                the most reactive RCCA, are assumed to insert into the core. The ANALYSES              shutdown banks shall be at or above their insertion limits and available to insert the maximum amount of negative reactivity on a reactor trip signal.
The control banks may be partially inserted in the core, as allowed by LCOs 3.1.6.1 (Unit 1) and 3.1.6.2 (Unit 2), "Control Bank Insertion Limits."
The shutdown bank and control bank insertion limits are established to ensure that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required SDM (see LCO 3.1.1, "SHUTDOWN MARGIN (SDM)") following a reactor trip from full power.
The combination of control banks and shutdown banks (less the most reactive RCCA, which is assumed to be fully withdrawn) is sufficient to take the reactor from full power conditions at rated temperature to zero power, and to maintain the required SDM at rated no load temperature (Ref. 3). The shutdown bank insertion limit also limits the reactivity worth of an ejected shutdown rod.
The acceptance criteria for addressing shutdown and control rod bank insertion limits and inoperability or misalignment is that:
: a. There be no violations of:
: 1. Specified acceptable fuel design limits or
: 2. RCS pressure boundary integrity and
: b. The core remains subcritical after accident transients.
As such, the shutdown bank insertion limits affect safety analysis involving core reactivity and SDM (Ref. 3).
The shutdown bank insertion limits preserve an initial condition assumed in the safety analyses and, as such, satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).
Beaver Valley Units 1 and 2                  B 3.1.5 - 2                                 Revision 0

For Information Only                                             Shutdown Bank Insertion Limits B 3.1.5 BASES LCO               The shutdown banks must be within their insertion limits any time the reactor is critical or approaching criticality. This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required SDM following a reactor trip.
The shutdown bank insertion limits are defined in the COLR.
For Unit 2, the LCO is modified by a Note indicating the LCO requirement is not applicable to shutdown banks being inserted while performing SR 3.1.4.2.2. This SR verifies the freedom of the rods to move, and may require the shutdown bank to move below the LCO limits, which would normally violate the LCO. This Note applies to each shutdown bank as it is moved below the insertion limit to perform the SR. This Note is not applicable should a malfunction stop performance of the SR.
APPLICABILITY     The shutdown banks must be within their insertion limits, with the reactor in MODES 1 and 2. This ensures that a sufficient amount of negative reactivity is available to shut down the reactor and maintain the required SDM following a reactor trip. The shutdown banks do not have to be within their insertion limits in MODE 3, unless an approach to criticality is being made. In MODE 3, 4, 5, or 6, the shutdown banks are typically fully inserted in the core and contribute to the SDM. Refer to LCO 3.1.1 for SDM requirements in MODES 3, 4, and 5. LCO 3.9.1, "Boron Concentration," ensures adequate SDM in MODE 6.
For Unit 1, Tthe Applicability requirements have been modified by a Note indicating the LCO requirement is suspended during SR 3.1.4.1.2. This SR verifies the freedom of the rods to move, and requires the shutdown banks to move below the LCO limits, which would normally violate the LCO.
ACTIONS           A.1.1, A.1.2, and A.2 (Unit 1)
When one or more shutdown banks is not within insertion limits, 2 hours is allowed to restore the shutdown banks to within the insertion limits.
This is necessary because the available SDM may be significantly reduced, with one or more of the shutdown banks not within their insertion limits. Also, verification of SDM or initiation of boration within 1 hour is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1). If shutdown banks are not within their insertion limits, then SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.
The allowed Completion Time of 2 hours provides an acceptable time for evaluating and repairing minor problems without allowing the plant to remain in an unacceptable condition for an extended period of time.
A.1, A.2.1, A.2.2, and A.3 (Unit 2)
If one shutdown bank is inserted less than or equal to 12 steps below the insertion limit, 24 hours is allowed to restore the shutdown bank to within the limit. This is necessary because the available SDM may be reduced

For Information Only with a shutdown bank not within its insertion limit. Also, verification of SDM or initiation of boration within 1 hour is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1). If a shutdown bank is not within its insertion limit, SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.
While the shutdown bank is outside the insertion limit, all control banks must be within their insertion limits to ensure sufficient shutdown margin is available. The 24 hour Completion Time is sufficient to repair most rod control failures that would prevent movement of a shutdown bank.
B.1 (Unit 1)
If the shutdown banks cannot be restored to within their insertion limits within 2 hours, the unit must be brought to a MODE where the LCO is not applicable. The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
B.1.1, B.1.2, and B.2 (Unit 2)
When one or more shutdown banks is not within insertion limits for reasons other than Condition A, 2 hours is allowed to restore the shutdown banks to within the insertion limits. This is necessary because the available SDM may be significantly reduced, with one or more of the shutdown banks not within their insertion limits. Also, verification of SDM or initiation of boration within 1 hour is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1). If shutdown banks are not within their insertion limits, then SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.
The allowed Completion Time of 2 hours provides an acceptable time for evaluating and repairing minor problems without allowing the plant to remain in an unacceptable condition for an extended period of time.
C.1 (Unit 2)
If the Required Actions and associated Completion Times are not met, the unit must be brought to a MODE where the LCO is not applicable.
The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
Beaver Valley Units 1 and 2                   B 3.1.5 - 3                                Revision 0

For Information Only                                               Shutdown Bank Insertion Limits B 3.1.5 BASES SURVEILLANCE          SR 3.1.5.1.1 (Unit 1) and SR 3.1.5.2.1 (Unit 2)
REQUIREMENTS Verification that the shutdown banks are within their insertion limits prior to an approach to criticality ensures that when the reactor is critical, or being taken critical, the shutdown banks will be available to shut down the reactor, and the required SDM will be maintained following a reactor trip.
This SR and Frequency ensure that the shutdown banks are withdrawn before the control banks are withdrawn during a unit startup.
The primary means for verifying that the insertion limits are met is the associated group demand position indicators. Variations in individual rod position indication from the demand position indication are acceptable.
Specifications 3.1.4, "Rod Group Alignment Limits," 3.1.7.1 (Unit 1) and 3.1.7.2 (Unit 2), "Rod Position Indication" provide the appropriate limits and Actions for individual rod position indication.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
REFERENCES            1. Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."
: 2. 10 CFR 50.46.
: 3. UFSAR, Chapter 14 (Unit 1) and Chapter 15 (Unit 2).
Beaver Valley Units 1 and 2                  B 3.1.5 - 4                               Revision 29

For Information Only                                                   Control Bank Insertion Limits B 3.1.6 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.6   Control Bank Insertion Limits BASES BACKGROUND            The insertion limits of the shutdown and control rods are initial assumptions in all safety analyses that assume rod insertion upon reactor trip. The insertion limits directly affect core power and fuel burnup distributions and assumptions of available SDM, and initial reactivity insertion rate.
The applicable criteria for these reactivity and power distribution design requirements are 10 CFR 50, Appendix A, GDC 10, "Reactor Design,"
GDC 26, "Reactivity Control System Redundancy and Protection,"
GDC 28, "Reactivity Limits" as discussed in Reference 1, and 10 CFR 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors" (Ref. 2). Limits on control rod insertion have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.
The rod cluster control assemblies (RCCAs) are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control. A group consists of two or more RCCAs that are electrically paralleled to step simultaneously.
A bank of RCCAs consists of two groups that are moved in a staggered fashion, but always within one step of each other. There are four control banks and two shutdown banks. See LCOs 3.1.4.1 (Unit 1) and 3.1.4.2 (Unit 2), "Rod Group Alignment Limits," for control and shutdown rod OPERABILITY and alignment requirements, and LCOs 3.1.7.1 (Unit
: 1) and 3.1.7.2 (Unit 2), "Rod Position Indication," for position indication requirements.
The control bank insertion limits are specified in the COLR. An example is provided for information only in Figure B 3.1.6-1. The control banks are required to be at or above the insertion limit lines.
Figure B 3.1.6-1 also indicates how the control banks are moved in an overlap pattern. Overlap is the distance traveled together by two control banks. Overlap is a function of the fully withdrawn position defined in the COLR, and the tip-to-tip relationship shown on the figure. On the figure, the tip-to-tip relationship is shown as the difference between control bank C and D positions at 8% power, or 130 steps.
Beaver Valley Units 1 and 2                   B 3.1.6 - 1                                          -
Revision 0 I

For Information Only                                                  Control Bank Insertion Limits B 3.1.6 BASES BACKGROUND (continued)
The control banks are used for precise reactivity control of the reactor.
The positions of the control banks are normally controlled automatically by the Rod Control System, but can also be manually controlled. They are capable of adding reactivity very quickly (compared to borating or diluting).
The power density at any point in the core must be limited, so that the fuel design criteria are maintained. Together, LCOs 3.1.4.1 and 3.1.4.2, LCOs 3.1.5.1 and 3.1.5.2, "Shutdown Bank Insertion Limits,"
LCOs 3.1.6.1 and 3.1.6.2, LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR),"
provide limits on control component operation and on monitored process variables, which ensure that the core operates within the fuel design criteria.
The shutdown and control bank insertion and alignment limits, AFD, and QPTR are process variables that together characterize and control the three dimensional power distribution of the reactor core. Additionally, the control bank insertion limits control the reactivity that could be added in the event of a rod ejection accident, and the shutdown and control bank insertion limits ensure the required SDM is maintained.
Operation within the subject LCO limits will prevent fuel cladding failures that would breach the primary fission product barrier and release fission products to the reactor coolant in the event of a loss of coolant accident (LOCA), loss of flow, ejected rod, or other accident requiring termination by a Reactor Trip System (RTS) trip function.
APPLICABLE            The shutdown and control bank insertion limits, AFD, and QPTR LCOs SAFETY                are required to prevent power distributions that could result in fuel ANALYSES              cladding failures in the event of a LOCA, loss of flow, ejected rod, or other accident requiring termination by an RTS trip function.
The acceptance criteria for addressing shutdown and control bank insertion limits and inoperability or misalignment are that:
: a. There be no violations of:
: 1. Specified acceptable fuel design limits or
: 2. Reactor Coolant System pressure boundary integrity and
: b. The core remains subcritical after accident transients.
As such, the shutdown and control bank insertion limits affect safety analysis involving core reactivity and power distributions (Ref. 3).
Beaver Valley Units 1 and 2                  B 3.1.6 - 2                                  Revision 0

For Information Only                                                Control Bank Insertion Limits B 3.1.6 BASES APPLICABLE SAFETY ANALYSES (continued)
The SDM requirement is ensured by limiting the control and shutdown bank insertion limits so that the allowable inserted worth of the RCCAs is such that sufficient reactivity is available in the rods to shut down the reactor to hot zero power with a reactivity margin that assumes the maximum worth RCCA remains fully withdrawn upon trip (Ref. 4).
Operation at the insertion limits or AFD limits may approach the maximum allowable linear heat generation rate or peaking factor with the allowed QPTR present. Operation at the insertion limit may also indicate the maximum ejected RCCA worth could be equal to the limiting value in fuel cycles that have sufficiently high ejected RCCA worths.
The control and shutdown bank insertion limits ensure that safety analyses assumptions for SDM, ejected rod worth, and power distribution peaking factors are preserved (Ref. 5).
The insertion limits satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii), in that they are initial conditions assumed in the safety analysis.
LCO               The limits on control banks sequence, overlap, and physical insertion, as defined in the COLR, must be maintained because they serve the function of preserving power distribution, ensuring that the SDM is maintained, ensuring that ejected rod worth is maintained, and ensuring adequate negative reactivity insertion is available on trip. The overlap between control banks provides more uniform rates of reactivity insertion and withdrawal and is imposed to maintain acceptable power peaking during control bank motion.
For Unit 2, the LCO is modified by a Note indicating the LCO requirement is not applicable to control banks being inserted while performing SR 3.1.4.2.2. This SR verifies the freedom of the rods to move, and may require the control bank to move below the LCO limits, which would normally violate the LCO. This Note applies to each control bank as it is moved below the insertion limit to perform the SR. This Note is not applicable should a malfunction stop performance of the SR.
APPLICABILITY     The control bank sequence, overlap, and physical insertion limits shall be maintained with the reactor in MODES 1 and 2 with keff  1.0. These limits must be maintained, since they preserve the assumed power distribution, ejected rod worth, SDM, and reactivity rate insertion assumptions. Applicability in MODES 3, 4, and 5 is not required, since neither the power distribution nor ejected rod worth assumptions would be exceeded in these MODES.
For Unit 1, Tthe applicability requirements have been modified by a Note indicating the LCO requirements are suspended during the performance of SR 3.1.4.1.2. This SR verifies the freedom of the rods to move, and requires the control bank to move below the LCO limits, which would violate the LCO.

For Information Only Beaver Valley Units 1 and 2 B 3.1.6 - 3 Revision 0

For Information Only                                               Control Bank Insertion Limits B 3.1.6 BASES ACTIONS           A.1.1, A.1.2, A.2, B.1.1, B.1.2, and B.2 (Unit 1)
When the control banks are outside the acceptable insertion limits, they must be restored to within those limits. This restoration can occur in two ways:
: a. Reducing power to be consistent with rod position or
: b. Moving rods to be consistent with power.
Also, verification of SDM or initiation of boration to regain SDM is required within 1 hour, since the SDM in MODES 1 and 2 normally ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1, "SHUTDOWN MARGIN (SDM)") has been upset. If control banks are not within their insertion limits, then SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.
Similarly, if the control banks are found to be out of sequence or in the wrong overlap configuration, they must be restored to meet the limits.
Operation beyond the LCO limits is allowed for a short time period in order to take conservative action because the simultaneous occurrence of either a LOCA, loss of flow accident, ejected rod accident, or other accident during this short time period, together with an inadequate power distribution or reactivity capability, has an acceptably low probability.
The allowed Completion Time of 2 hours for restoring the banks to within the insertion, sequence, and overlaps limits provides an acceptable time for evaluating and repairing minor problems without allowing the plant to remain in an unacceptable condition for an extended period of time.
A.1, A.2.1, A.2.2, and A.3 (Unit 2)
If Control Bank A, B, or C is inserted less than or equal to 12 steps below the insertion, sequence, or overlap limits, 24 hours is allowed to restore the control bank to within the limits. Verification of SDM or initiation of boration within 1 hour is required, since the SDM in MODES 1 and 2 is ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1). If a control bank is not within its insertion limit, SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.
While the control bank is outside the insertion, sequence, or overlap limits, all shutdown banks must be within their insertion limits to ensure sufficient shutdown margin is available and that power distribution is controlled. The 24 hour Completion Time is sufficient to repair most rod control failures that would prevent movement of a shutdown bank.
Condition A is limited to Control banks A, B, or C. The allowance is not required for Control Bank D because the full power bank insertion limit can be met during performance of the SR 3.1.4.2.2 control rod freedom of movement (trippability) testing.

For Information Only B.1.1, B.1.2, B.2, C.1.1, C.1.2, and C.2 (Unit 2)
When the control banks are outside the acceptable insertion limits for reasons other than Condition A, they must be restored to within those limits. This restoration can occur in two ways:
: a. Reducing power to be consistent with rod position or
: b. Moving rods to be consistent with power.
Also, verification of SDM or initiation of boration to regain SDM is required within 1 hour, since the SDM in MODES 1 and 2 normally ensured by adhering to the control and shutdown bank insertion limits (see LCO 3.1.1, "SHUTDOWN MARGIN (SDM)") has been upset. If control banks are not within their insertion limits, then SDM will be verified by performing a reactivity balance calculation, considering the effects listed in the BASES for SR 3.1.1.1.
Similarly, if the control banks are found to be out of sequence or in the wrong overlap configuration for reasons other than Condition A, they must be restored to meet the limits.
Operation beyond the LCO limits is allowed for a short time period in order to take conservative action because the simultaneous occurrence of either a LOCA, loss of flow accident, ejected rod accident, or other accident during this short time period, together with an inadequate power distribution or reactivity capability, has an acceptably low probability.
The allowed Completion Time of 2 hours for restoring the banks to within the insertion, sequence, and overlaps limits provides an acceptable time for evaluating and repairing minor problems without allowing the plant to remain in an unacceptable condition for an extended period of time.
C.1 (Unit 1)
If Required Actions A.1 and A.2, or B.1 and B.2 cannot be completed within the associated Completion Times, the plant must be brought to MODE 2 with keff < 1.0, where the LCO is not applicable. The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
D.1 (Unit 2)
If the Required Actions cannot be completed within the associated Completion Times, the plant must be brought to MODE 2 with keff < 1.0, where the LCO is not applicable. The allowed Completion Time of 6 hours is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
Beaver Valley Units 1 and 2                  B 3.1.6 - 4                                 Revision 0

For Information Only                                                   Control Bank Insertion Limits B 3.1.6 BASES SURVEILLANCE          SR 3.1.6.1.1 (Unit 1) and SR 3.1.6.2.1 (Unit 2)
REQUIREMENTS This Surveillance is required to ensure that the reactor does not achieve criticality with the control banks below their insertion limits. The required insertion limits are specified in the COLR.
The primary means for verifying the required control bank position is the associated group demand position indicators. Variations in individual rod position indication from the demand position indication are acceptable.
Specifications 3.1.4, "Rod Group Alignment Limits," 3.1.7.1 (Unit 1) and 3.1.7.2 (Unit 2), "Rod Position Indication" provide the appropriate limits and Actions for individual rod position indication.
The estimated critical position (ECP) depends upon a number of factors, one of which is xenon concentration. If the ECP was calculated long before criticality, xenon concentration could change to make the ECP substantially in error. Conversely, determining the ECP immediately before criticality could be an unnecessary burden. There are a number of unit parameters requiring operator attention at that point. Performing the ECP calculation within 4 hours prior to criticality avoids a large error from changes in xenon concentration, but allows the operator some flexibility to schedule the ECP calculation with other startup activities.
SR 3.1.6.1.2 (Unit 1) and SR 3.1.6.2.2 (Unit 2)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
The primary means for verifying that the insertion limits are met is the associated group demand position indicators. Variations in individual rod position indication from the demand position indication are acceptable.
Specifications 3.1.4.1 (Unit 1) and 3.1.4.2 (Unit 2), "Rod Group Alignment Limits," 3.1.7.1 (Unit 1) and 3.1.7.2 (Unit 2), "Rod Position Indication" provide the appropriate limits and Actions for individual rod position indication.
SR 3.1.6.1.3 (Unit 1) and SR 3.1.6.2.3 (Unit 2)
When control banks are maintained within their insertion limits as checked by SRs 3.1.6.1.2 and 3.1.6.2.2 above, it is unlikely that their sequence and overlap will not be in accordance with requirements provided in the COLR. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
Beaver Valley Units 1 and 2                  B 3.1.6 - 5                                 Revision 29

For Information Only                                                   Control Bank Insertion Limits B 3.1.6 BASES SURVEILLANCE REQUIREMENTS (continued)
The primary means for verifying that the sequence and overlap limits are met is the associated group demand position indicators. Variations in individual rod position indication from the demand position indication are acceptable. Specifications 3.1.4.1 and 3.1.4.2, "Rod Group Alignment Limits," 3.1.7.1 (Unit 1) and 3.1.7.2 (Unit 2), "Rod Position Indication" provide the appropriate limits and Actions for individual rod position indication.
REFERENCES            1. Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance" and Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."
: 2. 10 CFR 50.46.
: 3. UFSAR, Chapter 14 (Unit 1) and Chapter 15 (Unit 2).
: 4. UFSAR, Section 3.3.2.6 (Unit 1) and Section 4.3.2.5 (Unit 2).
: 5. UFSAR, Section 3.3.2.5 (Unit 1) and Section 4.3.2.4 (Unit 2).
Beaver Valley Units 1 and 2                  B 3.1.6 - 6                                 Revision 0

For Information Only                                                                                                                                    Control Bank Insertion Limits No Changes - Provided for Context                                                                                                                                            B 3.1.6
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0
                                                         .,v I              8, 0             I 0                           20                                        40                                  60               80                 100 Relative Power (Percent)
Figure B 3.1.6-1 (page 1 of 1)
Control Bank Insertion vs. Percent RTP Beaver Valley Units 1 and 2                                                                                        B 3.1.6 - 7                                                                 Revision 0

For Information Only                                                 Unit 1 Rod Position Indication No Changes - Provided for Context                                                         B 3.1.7.1 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.7   Rod Position Indication B.3.1.7.1     Unit 1 Rod Position Indication BASES BACKGROUND            According to GDC 13, as discussed in Reference 1, instrumentation to monitor variables and systems over their operating ranges during normal operation, anticipated operational occurrences, and accident conditions must be OPERABLE. LCO 3.1.7.1 is required to ensure OPERABILITY of the control rod position indication system to determine control rod positions and thereby ensure compliance with the control rod alignment and insertion limits.
The OPERABILITY, including rod position, of the shutdown and control rods is an initial assumption in all safety analyses that assume rod insertion upon reactor trip. Maximum rod misalignment is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available SDM. Rod position indication is required to assess OPERABILITY and misalignment.
Mechanical or electrical failures may cause a control rod to become inoperable or to become misaligned from its group. Control rod inoperability or misalignment may cause increased power peaking, due to the asymmetric reactivity distribution and a reduction in the total available rod worth for reactor shutdown. Therefore, control rod alignment and OPERABILITY are related to core operation in design power peaking limits and the core design requirement of a minimum SDM.
Limits on control rod alignment and OPERABILITY have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.
Rod cluster control assemblies (RCCAs), or rods, are moved out of the core (up or withdrawn) or into the core (down or inserted) by their control rod drive mechanisms. The RCCAs are divided among control banks and shutdown banks. Each bank is further subdivided into two groups to provide for precise reactivity control.
The axial position of shutdown rods and control rods are determined by two separate and independent systems: the Bank Demand Position Indication System (commonly called group step counters) and the Rod Position Indication (RPI) System.
Beaver Valley Units 1 and 2                 B 3.1.7.1 - 1                               Revision 9

For Information Only                                                   Unit 1 Rod Position Indication No Changes - Provided for Context                                                             B 3.1.7.1 BASES BACKGROUND (continued)
The Bank Demand Position Indication System counts the pulses from the Rod Control System that move the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise ( 1 step or  5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.
The RPI System provides an accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from coils spaced along a hollow tube.
The maximum uncertainty is  12 steps ( 7.5 inches). With an indicated deviation of 12 steps between the group step counter and RPI, the maximum deviation between actual rod position and the demand position could be 24 steps, or 15 inches.
One method for determining each rod position is the indicators on the vertical board. A secondary method of determining rod position is the in-plant computer. Either the vertical board indicators or in-plant computer is sufficient to comply with this specification. The in-plant computer receives the same inputs from ARPI as the vertical board indicators and provides resolution equivalent to or better than the vertical board indicators. The in-plant computer also provides a digital readout of each rod position which eliminates interpolation and parallax errors inherent to analog scales. When an IPC computer point(s) is used as the primary means of rod position indication, administrative controls require the control room staff to continuously display the IPC computer point(s) in the control room.
Due to the need for the control rod drive shaft to reach thermal equilibrium for accurate individual rod position indication, the group demand counter is considered the primary indicator of precise rod position information during rod movement and for the first hour following rod motion. The RPI channels may only display general rod movement information during this time. A one-hour thermal soak is allowed before the RPI channels must perform within the required accuracy. In order to facilitate the thermal stabilization of the RPI during the one-hour thermal soak, absolute rod motion should be limited to six steps.
Beaver Valley Units 1 and 2                  B 3.1.7.1 - 2                                  Revision 9

For Information Only                                                  Unit 1 Rod Position Indication B 3.1.7.1 BASES APPLICABLE            Control and shutdown rod position accuracy is essential during power SAFETY                operation. Power peaking, ejected rod worth, or SDM limits may be ANALYSES              violated in the event of a Design Basis Accident (Ref. 2), with control or shutdown rods operating outside their limits undetected. Therefore, the acceptance criteria for rod position indication is that rod positions must be known with sufficient accuracy in order to verify the core is operating within the group sequence, overlap, design peaking limits, ejected rod worth, and with minimum SDM (LCO 3.1.5.1, "Shutdown Bank Insertion Limits," and LCO 3.1.6.1, "Control Bank Insertion Limits"). The rod positions must also be known in order to verify the alignment limits are preserved (LCO 3.1.4.1, "Rod Group Alignment Limits"). Control rod positions are continuously monitored to provide operators with information that ensures the plant is operating within the bounds of the accident analysis assumptions.
The control rod position indication system channels satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii). The control rod position indication system monitors control rod position, which is an initial condition of the accident analyses.
LCO                   LCO 3.1.7.1 specifies that the RPI System and the Bank Demand Position Indication System be OPERABLE. For the control rod position indication system to be OPERABLE requires meeting the SR of the LCO and the following:
: a. The RPI System indicates within 12 steps of the group step counter demand position as required by LCO 3.1.4.1, "Rod Group Alignment Limits,"
: b. For the RPI System there are no failed coils, and
: c. The Bank Demand Indication System has been calibrated either in the fully inserted position or to the RPI System.
The 12 step agreement limit between the Bank Demand Position Indication System and the RPI System indicates that the Bank Demand Position Indication System is adequately calibrated, and can be used for indication of the measurement of control rod bank position.
A deviation of less than the allowable limit, given in LCO 3.1.4.1, in position indication for a single control rod, ensures high confidence that the position uncertainty of the corresponding control rod group is within the assumed values used in the safety analysis (that specified control rod group insertion limits).
Beaver Valley Units 1 and 2                 B 3.1.7.1 - 3                                 Revision 9

For Information Only                                                   Unit 1 Rod Position Indication B 3.1.7.1 BASES LCO (continued)
These requirements ensure that rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged.
OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
APPLICABILITY         The requirements on the RPI and step counters are only applicable in MODES 1 and 2 (consistent with LCO 3.1.4.1, LCO 3.1.5.1, and LCO 3.1.6.1), because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.
ACTIONS               The ACTIONS Table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.
A.1, A.2.1, and A.2.2 When the RPI System indicates one or more potentially misaligned rods, prompt action must be taken to determine if the rod is actually misaligned or if there is a problem with the RPI System. In order to make the prompt determination, Required Action A.1 specifies that the affected rod position must be verified by measuring the associated RPI channel primary voltage within 15 minutes. If the results of the RPI channel primary voltage measurement indicate that the affected rod is misaligned, Required Action A.2.1 specifies that the applicable Conditions and Required Actions of LCO 3.1.4.1, "Rod Group Alignment Limits" be entered within 15 minutes. If the results of the RPI channel primary voltage measurement do not indicate a misaligned rod, Required Action A.2.2 specifies that the affected RPI is declared inoperable and the applicable Conditions and Required Actions of LCO 3.1.7.1, "Unit 1 Rod Position Indication" be entered within 15 minutes.
Beaver Valley Units 1 and 2                 B 3.1.7.1 - 4                                 Revision 9

For Information Only                                                Unit 1 Rod Position Indication No Changes - Provided for Context                                                          B 3.1.7.1 BASES ACTIONS (continued)
Condition A is modified by a Note that provides an exception to applying Condition A to misalignment indications that occur during rod motion and for up to one hour following rod motion. The exception is necessary to accommodate the thermal stabilization required after rod movement for the RPI. The RPI System requires time to achieve thermal equilibrium after rod movement in order to provide indication within the required accuracy. During rod motion and the time allowed for thermal soak after rod motion, the group demand counters provide the primary indication of precise rod position with the RPI channels displaying general rod movement information. Reliance on the demand counter indication for up to one hour following rod motion is acceptable for determining rod position and therefore, Condition A is not applicable until after the one hour thermal soak provided by the Note.
B.1 When one RPI channel per group fails, the position of the rod may still be determined indirectly by use of the movable incore detectors or by measuring the rod position channel primary voltage. The Required Action may also be satisfied by using the movable incore detectors to ensure at least once per 8 hours that FQ(Z) satisfies LCO 3.2.1, FNH satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Actions of Condition D below are applicable. Therefore, verification of RCCA position within the Completion Time of 8 hours is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.
B.2 Reduction of THERMAL POWER to  50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors.
The allowed Completion Time of 8 hours is reasonable, based on operating experience, for reducing power to  50% RTP from full power conditions without challenging plant systems and allowing for rod position determination by Required Action B.1 above.
Beaver Valley Units 1 and 2                B 3.1.7.1 - 5                                 Revision 9

For Information Only                                                  Unit 1 Rod Position Indication No Changes - Provided for Context                                                          B 3.1.7.1 BASES ACTIONS (continued)
C.1, C.2, C.3, and C.4 When more than one RPI per group fail, additional actions are necessary to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. Placing the Rod Control System in manual assures unplanned rod motion will not occur. Placing the Rod Control System in manual together with the indirect position determination available via movable incore detectors or by measuring the rod position channel primary voltage will minimize the potential for rod misalignment. The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this Condition.
Monitoring and recording Reactor Coolant System Tavg help assure that significant changes in power distribution and SDM are avoided. The once per hour Completion Time is acceptable because only minor fluctuations in RCS temperature are expected at steady state plant operating conditions.
The position of the rods may be determined indirectly by use of the movable incore detectors or by measuring the rod position channel primary voltage. The Required Action may also be satisfied by using the movable incore detectors to ensure at least once per 8 hours that FQ(Z) satisfies LCO 3.2.1, FNH satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the non-indicating rods have not been moved. Verification of control rod position once per 8 hours is adequate for allowing continued full power operation for a limited, 24 hour period, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. The 24 hour Completion Time provides sufficient time to troubleshoot and restore the RPI system to operation while avoiding the plant challenges associated with the shutdown without full rod position indication.
Based on operating experience, normal power operation does not require excessive rod movement. If one or more rods has been significantly moved, the Required Actions of Condition D below is required.
D.1.1, D.1.2, and D.2 These Required Actions clarify that when one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction, since the position was last determined, the Required Actions of B.1 or C.3, as applicable are still appropriate but must be initiated immediately under Required Action D.1.1 to begin verifying that these rods are still properly positioned, relative to their group positions.
Beaver Valley Units 1 and 2                 B 3.1.7.1 - 6                                 Revision 9

For Information Only                                                 Unit 1 Rod Position Indication No Changes - Provided for Context                                                         B 3.1.7.1 BASES ACTIONS (continued)
If, within 8 hours, the rod positions have not been determined, THERMAL POWER must be reduced to  50% RTP to avoid undesirable power distributions that could result from continued operation at > 50% RTP, if one or more rods are misaligned by more than 24 steps. The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions or reduce power to  50% RTP.
E.1.1 and E.1.2 With one demand position indicator per bank inoperable, the rod positions can be determined by the RPI System. Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indication system for each control and shutdown rod is OPERABLE and the most withdrawn rod and the least withdrawn rod are  12 steps apart within the allowed Completion Time of once every 8 hours is adequate.
E.2 Reduction of THERMAL POWER to  50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factor limits. The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions per Condition D or reduce power to  50% RTP.
F.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE          SR 3.1.7.1.1 REQUIREMENTS Verification that each control bank benchboard group step demand counter agrees within 2 steps with the solid state indicators in the logic cabinet helps to assure that the benchboard demand counters are indicating correctly and that the demand counters may be relied on during rod movement and for the first hour following rod movement for the primary indication of precise rod position.
Beaver Valley Units 1 and 2                 B 3.1.7.1 - 7                                Revision 9

For Information Only                                                  Unit 1 Rod Position Indication No Changes - Provided for Context                                                          B 3.1.7.1 BASES SURVEILLANCE REQUIREMENTS (continued)
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
SR 3.1.7.1.2 Verification that the RPI agrees with the demand position within 12 steps ensures that the RPI is operating correctly. The verification of RPI and demand position indication within the required 12 steps over the full range of indicated rod travel is accomplished by comparisons of the indications at specific rod positions (identified in the applicable surveillance procedure) and calibrations as necessary to ensure the required accuracy is achieved.
This Surveillance is performed prior to reactor criticality after each removal of the reactor head, as there is the potential for unnecessary plant transients if the SR were performed with the reactor at power.
The SR is modified by a Note. The Note provides an exception to the SR during rod motion and for the first hour following rod motion. The exception is necessary to allow for thermal stabilization and accurate rod position indication. During rod motion and the time allowed for thermal soak after rod motion, the group demand counters provide the primary indication of precise rod position with the RPI channels displaying general rod movement information. Therefore, comparison between the two indications to verify the LCO requirements are met is not required during the time specified in this Note. If the SR comes due during the time allowed by the Note, and the RPI has not stabilized within the required accuracy, the SR should be performed as soon as possible after the time provided by the Note expires. In order to facilitate the thermal stabilization of the RPI during the one-hour thermal soak, absolute rod motion should be limited to six steps.
REFERENCES            1. Unit 1 UFSAR Appendix 1A, "1971 AEC General Design Criteria Conformance."
: 2. UFSAR, Chapter 14 (Unit 1).
Beaver Valley Units 1 and 2                 B 3.1.7.1 - 8                                Revision 29

For Information Only                                                 Unit 2 Rod Position Indication No Changes - Provided for Context                                                         B 3.1.7.2 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.7   Rod Position Indication B.3.1.7.2     Unit 2 Rod Position Indication BASES BACKGROUND            According to GDC 13, as discussed in Reference 1, instrumentation to monitor variables and systems over their operating ranges during normal operation, anticipated operational occurrences, and accident conditions must be OPERABLE. LCO 3.1.7.2 is required to ensure OPERABILITY of the control rod position indicators to determine control rod positions and thereby ensure compliance with the control rod alignment and insertion limits.
The OPERABILITY, including rod position, of the shutdown and control rods is an initial assumption in all safety analyses that assume rod insertion upon reactor trip. Maximum rod misalignment is an initial assumption in the safety analysis that directly affects core power distributions and assumptions of available SDM. Rod position indication is required to assess OPERABILITY and misalignment.
Mechanical or electrical failures may cause a control rod to become inoperable or to become misaligned from its group. Control rod inoperability or misalignment may cause increased power peaking, due to the asymmetric reactivity distribution and a reduction in the total available rod worth for reactor shutdown. Therefore, control rod alignment and OPERABILITY are related to core operation in design power peaking limits and the core design requirement of a minimum SDM.
Limits on control rod alignment and OPERABILITY have been established, and all rod positions are monitored and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.
Rod cluster control assemblies (RCCAs), or rods, are moved out of the core (up or withdrawn) or into the core (down or inserted) by their control rod drive mechanisms. The RCCAs are divided among control banks and shutdown banks. Each bank is further subdivided into two groups to provide for precise reactivity control.
The axial position of shutdown rods and control rods are determined by two separate and independent systems: the Bank Demand Position Indication System (commonly called group step counters) and the Digital Rod Position Indication (DRPI) System.
Beaver Valley Units 1 and 2                 B 3.1.7.2 - 1                               Revision 0

For Information Only                                                   Unit 2 Rod Position Indication B 3.1.7.2 BASES BACKGROUND (continued)
The Bank Demand Position Indication System counts the pulses from the Rod Control System that move the rods. There is one step counter for each group of rods. Individual rods in a group all receive the same signal to move and should, therefore, all be at the same position indicated by the group step counter for that group. The Bank Demand Position Indication System is considered highly precise ( 1 step or  5/8 inch). If a rod does not move one step for each demand pulse, the step counter will still count the pulse and incorrectly reflect the position of the rod.
The DRPI System provides a highly accurate indication of actual control rod position, but at a lower precision than the step counters. This system is based on inductive analog signals from a series of coils spaced along a hollow tube with a center to center distance of 3.75 inches, which is 6 steps. To increase the reliability of the system, the inductive coils are connected alternately to data system A or B. Thus, if one system fails, the DRPI will go on half accuracy with an effective coil spacing of 7.5 inches, which is 12 steps. Therefore, the normal indication accuracy of the DRPI System is  4 steps, for full accuracy, and +4, -10 steps at half accuracy with data system A, and +10, -4 steps at half accuracy with data system B. As such, only one data system (A or B) is required for an OPERABLE DRPI System indicating within 12 steps of the group step counter demand position indicator. With an indicated deviation of 12 steps between the group step counter and DRPI, the maximum deviation between actual rod position and the demand position could be 22 steps, or 13.75 inches.
APPLICABLE            Control and shutdown rod position accuracy is essential during power SAFETY                operation. Power peaking, ejected rod worth, or SDM limits may be ANALYSES              violated in the event of a Design Basis Accident (Ref. 2), with control or shutdown rods operating outside their limits undetected. Therefore, the acceptance criteria for rod position indication is that rod positions must be known with sufficient accuracy in order to verify the core is operating within the group sequence, overlap, design peaking limits, ejected rod worth, and with minimum SDM (LCO 3.1.5.2, "Unit 2 Shutdown Bank Insertion Limits," and LCO 3.1.6.2, "Unit 2 Control Bank Insertion Limits").
The rod positions must also be known in order to verify the alignment limits are preserved (LCO 3.1.4.2, "Unit 2 Rod Group Alignment Limits").
Control rod positions are continuously monitored to provide operators with information that ensures the plant is operating within the bounds of the accident analysis assumptions.
The control rod position indicator channels satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii). The control rod position indicators monitor control rod position, which is an initial condition of the accident analyses.
Beaver Valley Units 1 and 2                  B 3.1.7.2 - 2                                  Revision 0

For Information Only                                                   Unit 2 Rod Position Indication B 3.1.7.2 BASES LCO                   LCO 3.1.7.2 specifies that the DRPI System (data system A or B) and the Bank Demand Position Indication System be OPERABLE. For the control rod position indicators to be OPERABLE requires meeting the SR of the LCO and the following:
: a. The required DRPI System indicates within 12 steps of the group step counter demand position as required by LCO 3.1.4.2, "Unit 2 Rod Group Alignment Limits,"
: b. For the required DRPI System there are no failed coils, and
: c. The Bank Demand Indication System has been calibrated either in the fully inserted position or to the DRPI System.
The 12 step agreement limit between the Bank Demand Position Indication System and the DRPI System indicates that the Bank Demand Position Indication System is adequately calibrated, and can be used for indication of the measurement of control rod bank position.
A deviation of less than the allowable limit, given in LCO 3.1.4.2, in position indication for a single control rod, ensures high confidence that the position uncertainty of the corresponding control rod group is within the assumed values used in the safety analysis (that specified control rod group insertion limits).
These requirements ensure that control rod position indication during power operation and PHYSICS TESTS is accurate, and that design assumptions are not challenged.
OPERABILITY of the position indicator channels ensures that inoperable, misaligned, or mispositioned control rods can be detected. Therefore, power peaking, ejected rod worth, and SDM can be controlled within acceptable limits.
APPLICABILITY         The requirements on the DRPI and step counters are only applicable in MODES 1 and 2 (consistent with LCO 3.1.4.2, LCO 3.1.5.2, and LCO 3.1.6.2), because these are the only MODES in which power is generated, and the OPERABILITY and alignment of rods have the potential to affect the safety of the plant. In the shutdown MODES, the OPERABILITY of the shutdown and control banks has the potential to affect the required SDM, but this effect can be compensated for by an increase in the boron concentration of the Reactor Coolant System.
Beaver Valley Units 1 and 2                 B 3.1.7.2 - 3                                 Revision 0

For Information Only                                                 Unit 2 Rod Position Indication B 3.1.7.2 BASES ACTIONS           The ACTIONS Table is modified by a Note indicating that a separate Condition entry is allowed for each inoperable rod position indicator and each demand position indicator. This is acceptable because the Required Actions for each Condition provide appropriate compensatory actions for each inoperable position indicator.
A.1, A.2.1, and A.2.2 When one DRPI channel per group in one or more groups fails, the position of the rod may still be determined indirectly by use of the movable incore detectors. The Required Action may also be satisfied by using the movable incore detectors to ensure at least once per 8 hours that FQ(Z) satisfies LCO 3.2.1, FNH satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Based on experience, normal power operation does not require excessive movement of banks. If a bank has been significantly moved, the Required Action of C.1.1 andor C.1.2 below is required. Therefore, verification of RCCA position within the Completion Time of 8 hours is adequate for allowing continued full power operation, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small.
Required Action A.1 requires verification of the position of a rod with an inoperable DRPI once per 8 hours which may put excessive wear and tear on the moveable incore detector system, Required Action A.2.1 provides an alternative. Required Action A.2.1 requires verification of rod position using the moveable incore detectors every 31 EFPD, which coincides with the normal use of the system to verify core power distribution.
Required Action A.2.1 includes six distinct requirements for verification of the position of rods associated with an inoperable DRPI using the movable incore detectors:
: a. Initial verification within 8 hours of the inoperability of the DRPI;
: b. Re-verification once every 31 Effective Full Power Days (EFPD) thereafter;
: c. Verification within 8 hours if rod control system parameters indicate unintended rod movement. An unintended rod movement is defined as the release of the rods stationary gripper when no action was demanded either manually or automatically from the rod control system, or a rod motion in a direction other than the direction demanded by the rod control system. Verifying that no unintended rod movement has occurred is performed by monitoring the rod control system stationary gripper coil current for indications of rod movement;
: d. Verification within 8 hours if the rod with an inoperable DRPI is intentionally moved greater than 12 steps;

For Information Only e.         Verification prior to exceeding 50% RTP if power is reduced below 50% RTP; and
: f. Verification within 8 hours of reaching 100% RTP if power is reduced to less than 100% RTP.
Should the rod with the inoperable DRPI be moved more than 12 steps, or if reactor power is changed, the position of the rod with the inoperable DRPI must be verified.
Required Action A.2.2 states that the inoperable DRPI must be restored to OPERABLE status prior to entering MODE 2 from MODE 3. The repair of the inoperable RPI must be performed prior to returning to power operation following a shutdown.
A.23
                         ~
Reduction of THERMAL POWER to  50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factors.
The allowed Completion Time of 8 hours is reasonable, based on operating experience, for reducing power to  50% RTP from full power conditions without challenging plant systems and allowing for rod position determination by Required Action A.1 above.
B.1, B.2, B.3, and B.24 When more than one DRPI per group in one or more groups fail, additional actions are necessary. to ensure that acceptable power distribution limits are maintained, minimum SDM is maintained, and the potential effects of rod misalignment on associated accident analyses are limited. Placing the Rod Control System in manual assures unplanned rod motion will not occur. Placing the Rod Control System in manual together with the indirect position determination available via movable incore detectors will minimize the potential for rod misalignment. The immediate Completion Time for placing the Rod Control System in manual reflects the urgency with which unplanned rod motion must be prevented while in this Condition.
Beaver Valley Units 1 and 2                  B 3.1.7.2 - 4                               Revision 0

For Information Only                                                 Unit 2 Rod Position Indication B 3.1.7.2 BASES ACTIONS (continued)
Monitoring and recording reactor coolant Tavg help assure that significant changes in power distribution and SDM are avoided. The once per hour Completion Time is acceptable because only minor fluctuations in RCS temperature are expected at steady state plant operating conditions.
The position of the rods may be determined indirectly by use of the movable incore detectors. The Required Action may also be satisfied by using the movable incore detectors to ensure at least once per 8 hours that FQ(Z) satisfies LCO 3.2.1, FNH satisfies LCO 3.2.2, and SHUTDOWN MARGIN is within the limits provided in the COLR, provided the nonindicating rods have not been moved. Verification of control rod position once per 8 hours is adequate for allowing continued full power operation for a limited, 24 hour period, since the probability of simultaneously having a rod significantly out of position and an event sensitive to that rod position is small. The inoperable DRPIs must be restored, such that a maximum of one DRPI per group is inoperable, within 24 hours. The 24 hour Completion Time provides sufficient time to troubleshoot and restore the DRPI system to operation while avoiding the plant challenges associated with the shutdown without full rod position indication.
Based on operating experience, normal power operation does not require excessive rod movement. If one or more rods has been significantly moved, the Required Action of C.1.1 andor C.1.2 below is required.
C.1.1, C.1.2, and C.2 With one DRPI inoperable in one or more groups and the affected groups have moved greater than 24 steps in one direction since the last determination of rod position, additional actions are needed to verify the position of rods within inoperable DRPI. Within 8 hours, the position of the rods with inoperable position indication must be determined using the moveable incore detectors to verify These Required Actions clarify that when one or more rods with inoperable position indicators have been moved in excess of 24 steps in one direction, since the position was last determined, the Required Actions of A.1 or B.3, as applicable are still appropriate but must be initiated immediately under Required Action C.1.1 to begin verifying that these rods are still properly positioned, relative to their group positions.
If, within 8 hours, the rod positions have not been determined, THERMAL POWER must be reduced to  50% RTP to avoid undesirable power distributions that could result from continued operation at > 50% RTP, if one or more rods are misaligned by more than 24 steps. The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions or reduce power to  50% RTP.
Beaver Valley Units 1 and 2                 B 3.1.7.2 - 5                                Revision 0

For Information Only                                              Unit 2 Rod Position Indication B 3.1.7.2 BASES ACTIONS (continued)
D.1.1 and D.1.2 With one or more demand position indicator per bank inoperable in one or more banks, the rod positions can be determined by the DRPI System.
Since normal power operation does not require excessive movement of rods, verification by administrative means that the rod position indicators are OPERABLE and the most withdrawn rod and the least withdrawn rod are  12 steps apart within the allowed Completion Time of once every 8 hours is adequate.
D.2 Reduction of THERMAL POWER to  50% RTP puts the core into a condition where rod position is not significantly affecting core peaking factor limits. The allowed Completion Time of 8 hours provides an acceptable period of time to verify the rod positions per Required Action A.1 or reduce power to  50% RTP.
E.1 If the Required Actions cannot be completed within the associated Completion Time, the plant must be brought to a MODE in which the requirement does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours. The allowed Completion Time is reasonable, based on operating experience, for reaching the required MODE from full power conditions in an orderly manner and without challenging plant systems.
SURVEILLANCE        SR 3.1.7.2.1 REQUIREMENTS Verification that the DRPI agrees with the demand position within 12 steps ensures that the DRPI is operating correctly. Since the DRPI does not display the actual shutdown rod positions between 18 and 210 steps, only points within the indicated ranges are required in comparison.
This Surveillance is performed prior to reactor criticality after each removal of the reactor head, as there is the potential for unnecessary plant transients if the SR were performed with the reactor at power.
The Surveillance is modified by a Note which states it is not required to be met for DRPIs associated with rods that do not meet LCO 3.1.4.2. If a rod is known to not to be within 12 steps of the group demand position, the ACTIONS of LCO 3.1.4.2 provide the appropriate Actions.

For Information Only REFERENCES            1. Unit 2 UFSAR Section 3.1, "Conformance with U.S. Nuclear Regulatory Commission General Design Criteria."
: 2. UFSAR, Chapter 15.
Beaver Valley Units 1 and 2             B 3.1.7.2 - 6                            Revision 0

For Information Only                                      PHYSICS TESTS Exceptions - MODE 2 No Changes - Provided for Context                                                            B 3.1.9 B 3.1 REACTIVITY CONTROL SYSTEMS B 3.1.9   PHYSICS TESTS Exceptions - MODE 2 BASES BACKGROUND            The primary purpose of the MODE 2 PHYSICS TESTS exceptions is to permit relaxations of existing LCOs to allow certain PHYSICS TESTS to be performed.
Section XI of 10 CFR 50, Appendix B (Ref. 1), requires that a test program be established to ensure that structures, systems, and components will perform satisfactorily in service. All functions necessary to ensure that the specified design conditions are not exceeded during normal operation and anticipated operational occurrences must be tested. This testing is an integral part of the design, construction, and operation of the plant. Requirements for notification of the NRC, for the purpose of conducting tests and experiments, are specified in 10 CFR 50.59 (Ref. 2).
The requirements for reload fuel cycle PHYSICS TESTS are defined in ANSI/ANS-19.6.1-1997 (Ref. 3). The PHYSICS TESTS requirements for reload fuel cycles ensure that the operating characteristics of the core are consistent with the design predictions and that the core can be operated as designed (Ref. 3).
PHYSICS TESTS procedures are written and approved in accordance with established formats. The procedures include all information necessary to permit a detailed execution of the testing required to ensure that the design intent is met. PHYSICS TESTS are performed in accordance with these procedures and test results are approved prior to continued power escalation and long term power operation.
The MODE 2 PHYSICS TESTS required for reload fuel cycles (Ref. 3) are performed in accordance with the requirements described in Reference 3. The required MODE 2 tests are listed below:
: a. Critical Boron Concentration - Control Rods Withdrawn,
: b. Critical Boron Concentration - Reference Bank Inserted,
: c. Control Rod Worth, and
: d. Isothermal Temperature Coefficient (ITC).
Beaver Valley Units 1 and 2                 B 3.1.9 - 1                                  Revision 0

For Information Only                                       PHYSICS TESTS Exceptions - MODE 2 B 3.1.9 BASES APPLICABLE            The fuel is protected by LCOs that preserve the initial conditions of the SAFETY                core assumed during the safety analyses. The methods for development ANALYSES              of the LCOs that are excepted by this LCO are described in the Westinghouse Reload Safety Evaluation Methodology Report (Ref. 4).
The above mentioned PHYSICS TESTS, and other tests that may be required to calibrate nuclear instrumentation or to diagnose operational problems, may require the operating control or process variables to deviate from their LCO limitations.
Requirements for reload fuel cycle PHYSICS TESTS are defined in ANSI/ANS-19.6.1-1997 (Ref. 3). Although these PHYSICS TESTS are generally accomplished within the limits for all LCOs, conditions may occur when one or more LCOs must be suspended to make completion of PHYSICS TESTS possible or practical. This is acceptable as long as the fuel design criteria are not violated. When one or more of the requirements specified in LCO 3.1.3, "Moderator Temperature Coefficient (MTC),"
LCO 3.1.4.1, "Unit 1 Rod Group Alignment Limits," LCO 3.1.4.2, Unit 2 Rod Group Alignment Limits, LCO 3.1.5.1, "Unit 1 Shutdown Bank Insertion Limit," LCO 3.1.4.2, Unit 2 Shutdown Bank Insertion Limit, LCO 3.1.6.1, "Unit 1 Control Bank Insertion Limits," LCO 3.1.6.2, Unit 2 Control Bank Insertion Limits, and LCO 3.4.2, "RCS Minimum Temperature for Criticality" are suspended for PHYSICS TESTS, the fuel design criteria are preserved as long as the power level is limited to 5% RTP, the reactor coolant temperature is kept  531F, and SDM is within the limits provided in the COLR.
The PHYSICS TESTS include measurement of core nuclear parameters or the exercise of control components that affect process variables.
Among the process variables involved are AFD and QPTR, which represent initial conditions of the unit safety analyses. Also involved are the movable control components (control and shutdown rods), which are required to shut down the reactor. The limits for these variables are specified for each fuel cycle in the COLR.
As described in LCO 3.0.7, compliance with Test Exception LCOs is optional, and therefore no criteria of 10 CFR 50.36(c)(2)(ii) apply. Test Exception LCOs provide flexibility to perform certain operations by appropriately modifying requirements of other LCOs. A discussion of the criteria satisfied for the other LCOs is provided in their respective Bases.
LCO                   This LCO allows the reactor parameters of MTC and minimum temperature for criticality to be outside their specified limits. In addition, it allows selected control and shutdown rods to be positioned outside of their specified alignment and insertion limits. One power range neutron flux channel may be bypassed, reducing the number of required channels from 4 to 3. Operation beyond specified limits is permitted for the purpose of performing PHYSICS TESTS and poses no threat to fuel integrity, provided the SRs are met.
Beaver Valley Units 1 and 2                   B 3.1.9 - 2                                  Revision 0

For Information Only                                      PHYSICS TESTS Exceptions - MODE 2 B 3.1.9 BASES LCO (continued)
The requirements of LCO 3.1.3, LCO 3.1.4.1, LCO 3.1.4.2, LCO 3.1.5.1, LCO 3.1.5.2, LCO 3.1.6.1, LCO 3.1.6.2, and LCO 3.4.2 may be suspended and the number of required channels for LCO 3.3.1, "RTS Instrumentation," Functions 2, 3, and 17.e may be reduced to 3 required channels during the performance of PHYSICS TESTS provided:
: a. RCS lowest loop average temperature is  531F,
: b. SDM is within the limits provided in the COLR, and
: c. THERMAL POWER is  5% RTP.
In addition to the LCOs listed above the Test Exception provides the following Unit 1 specific exception that may also be used during PHYSICS TESTING:
For Unit 1 only, primary detector voltage measurements may be used to determine the position of rods in shutdown banks A and B and control banks A and B in lieu of the benchboard indicators required by LCO 3.1.7.1.
APPLICABILITY         This LCO is applicable when performing low power PHYSICS TESTS.
The Applicability is stated as "during PHYSICS TESTS initiated in MODE 2" to ensure that the 5% RTP maximum power level is not exceeded. Should the THERMAL POWER exceed 5% RTP, and consequently the unit enter MODE 1, this Applicability statement prevents exiting this Specification and its Required Actions.
ACTIONS               A.1 and A.2 If the SDM requirement is not met, boration must be initiated promptly. A Completion Time of 15 minutes is adequate for an operator to correctly align and start the required systems and components. The operator should begin boration with the best source available for the plant conditions. Boration will be continued until SDM is within limit.
Suspension of PHYSICS TESTS exceptions requires restoration of each of the applicable LCOs to within specification.
Beaver Valley Units 1 and 2                  B 3.1.9 - 3                                         -
Revision 0 I}}