View source for RS-21-007, Application to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0

{{Adams
| number = ML21097A226
| issue date = 04/07/2021
| title = Application to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0
| author name = Gudger D
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000456, 05000457, 05000454, 05000455, 05000244
| license number = DPR-018, NPF-037, NPF-066, NPF-072, NPF-077
| contact person = 
| case reference number = RS-21-007
| document type = Letter type:RS
| page count = 36
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 RS-21-007 April 7, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244

==Subject:==
Application to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0 In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (EGC) requests amendments to the Technical Specifications (TS) for Braidwood Station, Units 1 and 2 (Braidwood), Byron Station, Units 1 and 2 (Byron), and R. E. Ginna Nuclear Power Plant (Ginna).
The proposed License Amendment Request (LAR) revises Braidwood, Byron, and Ginna TS to address the issues identified in two Westinghouse communication documents. The proposed changes will address the issues identified in Westinghouse Nuclear Safety Advisory Letter NSAL-09-5, Rev. 1, Relaxed Axial Offset Control FQ Technical Specification Actions, by relocating required operating space reductions (power and Axial Flux Difference (AFD) limits) to the Core Operating Limits Report, accompanied by verification for each reload when required. The proposed changes will also address the issues identified in Westinghouse Nuclear Safety Advisory Letter NSAL-15-1, Rev. 0, Heat Flux Hot Channel Factor Technical Specification Surveillance, by defining TS surveillance requirements for steady-state and transient FQ(Z) and corresponding actions with which to apply an appropriate penalty factor to measured results. provides a discussion of the proposed change. The marked-up TS pages are included in Attachment 2. The marked-up TS Bases changes are provided for NRC information only in Attachment 3.

U.S. Nuclear Regulatory Commission Application to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0 April 7, 2021 Page 2 EGC has determined that there are no significant hazard considerations associated with the proposed change and that the change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9).
The proposed change has been reviewed by the Braidwood, Byron, and Ginna Plant Operations Review Committee in accordance with the requirements of the EGC Quality Assurance Program.
EGC requests approval of the proposed amendments by April 7, 2022. Once approved, the amendments shall be implemented within 90 days.
In accordance with 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), EGC is notifying the States of Illinois and New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Officials.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Jessie Hodge at (610) 765-5532.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of April 2021.
Respectfully, David T. Gudger Sr Manager - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes
: 2. Markup of Technical Specifications Pages
: 3. Markup of Technical Specifications Bases Pages cc:      NRC Regional Administrator - NRC Region I                  w/ attachments NRC Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood NRC Senior Resident Inspector - Byron NRC Senior Resident Inspector - Ginna NRC Project Manager, NRR - Braidwood and Byron NRC Project Manager, NRR - Ginna A. L. Peterson, NYSERDA Illinois Emergency Management Agency - Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Changes Braidwood Station Units 1 and 2 Byron Station Units 1 and 2 R. E. Ginna Nuclear Power Plant

==Subject:==
Application to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev.1 and NSAL-15-1, Rev. 0 1.0   

==SUMMARY==
DESCRIPTION 2.0   DETAILED DESCRIPTION

==3.0   TECHNICAL EVALUATION==

==4.0   REGULATORY EVALUATION==

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

==5.0   ENVIRONMENTAL CONSIDERATION==

==6.0   REFERENCES==

ATTACHMENT 1 Evaluation of Proposed Changes 1.0      

==SUMMARY==
DESCRIPTION In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Exelon Generation Company, LLC (EGC) is requesting license amendments to the Technical Specifications (TS) for Renewed Facility Operating License Nos. NPF-72 and NPF-77 for Braidwood Station, Units 1 and 2 (Braidwood), Renewed Facility Operating License Nos. NPF-37 and NPF-66 for Byron Station, Units 1 and 2 (Byron), and Renewed Facility Operating License No. DPR-18 for the R. E. Ginna Nuclear Power Plant (Ginna).
The changes address the issues identified in Westinghouse Nuclear Safety Advisory Letter NSAL-09-5, Rev. 1, Relaxed Axial Offset Control FQ Technical Specification Actions, (Reference 1) and Westinghouse Nuclear Safety Advisory Letter NSAL-15-1, Rev. 0, Heat Flux Hot channel Factor Technical Specification Surveillance, (Reference 2).
Westinghouse proposed a permanent resolution of these NSALs through WCAP-17661-P-A (Reference 5) which revises the Relaxed Axial Offset Control (RAOC) and Constant Axial Offset Control (CAOC) FQ Surveillance Technical Specifications to address several outstanding issues. EGC has strategically decided not to adopt WCAP-17661-P-A for Byron, Braidwood and Ginna and instead to permanently implement the interim compensatory actions as specified in the NSALs.
2.0      DETAILED DESCRIPTION 2.1      Reason for the Proposed Change The Technical Specification changes described in this document address issues identified in two Westinghouse Nuclear Safety Advisory Letters NSAL-09-5, Rev. 1 (Reference 1) and NSAL-15-1, Rev. 0 (Reference 2). The first letter notified Westinghouse customers about a potential problem with the Required Actions for Condition B of Standard Technical Specifications 3.2.1B, Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology) in NUREG-1431 (Reference 3). This letter notified that for plants that have implemented the RAOC methodology (Reference 4), the Required Actions for Condition B may not be sufficient to restore the transient  ,   , to within its limit. While these actions are sufficient to recover the  margin when the limiting   occurs away from the middle region of the core, they may not be sufficient when the limiting   occurs in the middle elevations of the core. Revision 1 of NSAL-09-5 provided clarification when the recommended interim actions to address this issue are applicable and how they should be implemented.
The second letter, NSAL-15-1, Rev. 0, notified Westinghouse customers that TS Surveillance Requirement (SR) 3.2.1.2 of TS 3.2.1B, Heat Flux Hot Channel Factor (FQ(Z)
(RAOC-W(Z) Methodology) in NUREG-1431 (Reference 3) may not be sufficient to assure that the peaking factor that is assumed in the licensing basis analysis is maintained under all conditions between the frequency of performance of TS SR 3.2.1.2. It has been determined by Westinghouse that there is possibility of decreasing nominal steady-state  ,   ,
value while the   is increasing. Therefore, additional surveillance is proposed to monitor the margin of the LCO   limit and make sure it can accommodate the penalty factor specified in the Core Operating Limits Report (COLR).
Page 1 of 13

ATTACHMENT 1 Evaluation of Proposed Changes Both NSALs were evaluated by EGC and were determined to be applicable to Byron, Braidwood, and Ginna plants since they utilize the RAOC methodology. Westinghouse proposed a permanent resolution through WCAP-17661-P-A (Reference 5) which revises the RAOC and CAOC FQ Surveillance Technical Specifications. EGC has strategically decided to permanently implement the interim compensatory actions from the NSALs for Byron, Braidwood, and Ginna in lieu of adopting the solution proposed in WCAP-17661-P-A.
Under this approach, EGC would propose changes to TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)) which are consistent with the actions of the NSALs with the relocation of the thermal power reduction and AFD limit reductions to the COLR such that margins can be validated for every cycle, similar to what was done for North Anna Power Station Units 1 and 2 (Reference 8). Initial implementation will adopt the bounding conservative values from NSAL-09-5 which will be updated using the RAOC methodology when required.
2.2     Description of the proposed Change for Byron and Braidwood TS Marked up Technical Specification changes are provided below. Deleted text is struck through and added text is provided in bold and italic font.
2.2.1   Technical Specification LCO 3.2.1 Changes Current REQUIRED ACTIONS            A.1    Reduce THERMAL POWER  1% RTP for each for CONDITION A                            1%   exceeds limit.
AND A.2    Reduce Power Range Neutron Flux - High trip setpoints  1% for each 1%   exceeds limit.
AND A.3    Reduce Overpower T trip setpoints  1% for each 1%   exceeds limit.
New REQUIRED ACTIONS for            A.1    Reduce THERMAL POWER  1% RTP for each CONDITION A                                1%   exceeds limit.
AND A.2    Reduce Power Range Neutron Flux - High trip setpoints  1% for each 1%   exceeds limit.
AND A.3    Reduce Overpower T trip setpoints  1% for each 1%   exceeds limit.
AND A.4    Perform SR 3.2.1.1 and SR 3.2.1.2.
Current COMPLETION TIME              A.1  15 minutes for CONDITION A                          A.2  72 hours A.3  72 hours New COMPLETION TIME for              A.1  15 minutes CONDITION A                          A.2  72 hours Page 2 of 13

ATTACHMENT 1 Evaluation of Proposed Changes A.3 72 hours A.4 Prior to increasing THERMAL POWER above the limit of Required Actions A.1 Current REQUIRED ACTIONS    B.1    Reduce THERMAL POWER  1% RTP for each for CONDITION B                    1%   exceeds limit.
AND B.2    Reduce Power Range Neutron Flux - High trip setpoints  1% for each 1%   exceeds limit.
AND B.3    Reduce Overpower T trip setpoints  1% for each 1%   exceeds limit.
New REQUIRED ACTIONS for    B.1    Reduce THERMAL POWER  1% RTP for each CONDITION B                        1%   exceeds limit as specified in the COLR.
AND B.2    Reduce AFD limits as specified in the COLR.
AND B.3    Reduce Power Range Neutron Flux - High trip setpoints  1% for each 1%   exceeds limit that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.1.
AND B.4    Reduce Overpower T trip setpoints  1% for each 1%   exceeds limit that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.1.
AND B.5    Perform SR 3.2.1.1 and SR 3.2.1.2.
Current COMPLETION TIME     B.1   4 hours for CONDITION B                 B.2   72 hours B.3   72 hours New COMPLETION TIME for     B.1   4 hours CONDITION B                 B.2   4 hours B.3   72 hours B.4   72 hours B.5   Prior to increasing THERMAL POWER and AFD limits above the limits of Required Actions B.1 and B.2.
Page 3 of 13

ATTACHMENT 1 Evaluation of Proposed Changes 2.2.2  Technical Specification SR 3.2.1.2 Changes Current SR 3.2.1.2                 --------------------------NOTES----------------------------
: 1. During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.
: 2. If   measurements indicate that the maximum over z has increased since the previous evaluation of
: a. Increase   by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR and reverify is within limits specified in the COLR; or
: b. Repeat SR 3.2.1.2 once per 7 EFPD until either a. above is met or two successive flux maps indicate that the maximum over z has not increased.
: 3. Not required to be performed until 12 hours after declaring PDMS inoperable. Performance of SR 3.2.1.4 satisfies the initial performance of this SR after declaring PDMS inoperable.
Verify   is within limit specified in the COLR.
New SR 3.2.1.2                     ---------------------------------NOTES----------------------------
: 1. During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.
: 2. If        measurements indicate that either the maximum over z OR maximum over z has increased since the previous evaluation of or if        is expected to increase prior to next evaluation of   :
: a. Increase   by the greater of a factor of 1.02 or by an appropriate factor specified in Page 4 of 13

ATTACHMENT 1 Evaluation of Proposed Changes the COLR and reverify   is within limits specified in the COLR; or
: b. Repeat SR 3.2.1.2 once per 7 EFPD until either a. above is met or two successive flux maps indicate that the maximum over z                            and maximum over Z             has not increased.
: 3. Not required to be performed until 12 hours after declaring PDMS inoperable. Performance of SR 3.2.1.4 satisfies the initial performance of this SR after declaring PDMS inoperable.
Verify   is within limit specified in the COLR.
2.2.3    Technical Specification Bases 3.2.1 Changes Several changes to the Bases were made to reflect the changes made in the TS sections as described above. Below is a summary list of key changes:
Added description of new REQUIRED ACTION A.4 to become consistent with changes in TS 3.2.1 REQUIRED ACTION A.4 Changes to conform with renumbered Condition B REQUIRED ACTIONS Changes to description of REQUIRED ACTION B.1 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.1 Added description of new REQUIRED ACTION B.2 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.2 Added description of new REQUIRED ACTION B.3 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.3 Added description of new REQUIRED ACTION B.4 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.4 Added description of new REQUIRED ACTION B.5 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.5 Changes to descriptions of SURVEILLANCE REQUIREMENTS to conform with changes in Note 2 in TS 3.2.1 SURVEILLANCE REQUIREMENT 3.2.1.2 2.3      Description of Proposed change for Ginna TS 2.3.1    Technical Specification LCO 3.2.1 Changes Current REQUIRED ACTIONS           B.1      Reduce AFD limits  1% for each 1%
for CONDITION B                             exceeds limit.
AND B.2      Reduce Power Range Neutron Flux - High trip setpoints  1% for each 1% that the maximum allowable power of the AFD limits is reduced.
Page 5 of 13

ATTACHMENT 1 Evaluation of Proposed Changes AND B.3    Reduce Overpower T trip setpoints  1% for each 1% that the maximum allowable power of the AFD limits is reduced.
AND B.4    Perform SR 3.2.1.1 and SR 3.2.1.2.
New REQUIRED ACTIONS for           B.1    Reduce THERMAL POWER as specified in CONDITION B                               the COLR.
AND B.2    Reduce AFD limits  1% for each 1%
exceeds limit as specified in the COLR.
AND B.3    Reduce Power Range Neutron Flux - High trip setpoints  1% for each 1% that the maximum allowable power of the AFD limits is reduced that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.1.
AND B.4    Reduce Overpower T trip setpoints  1% for each 1% that the maximum allowable power of the AFD limits is reduced that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.1.
AND B.5    Perform SR 3.2.1.1 and SR 3.2.1.2.
Current COMPLETION TIME          B.1 4 hours for CONDITION B                      B.2 72 hours B.3 72 hours B.4 Prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits of Required Actions B.1 and B.2.
New COMPLETION TIME for          B.1   4 hours CONDITION B                      B.2   4 hours B.3   72 hours B.4   72 hours B.5   Prior to increasing THERMAL POWER and AFD limits above the maximum allowable power of the AFD limits of Required Actions B.1 and B.2.
2.3.2  Technical Specification SR 3.2.1.2 Changes Page 6 of 13

ATTACHMENT 1 Evaluation of Proposed Changes Current SR 3.2.1.2        ---------------------------------------------------------------------
                                                        - NOTE -
If measurements indicate that the maximum over z has increased since the previous evaluation of   :
: a. Increase   by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR and reverify   is within limits or
: b. Repeat SR 3.2.1.2 once per 7 EFPD until either a.
above is met or two successive flux maps indicate that the maximum over z has not increased.
Verify   is within limit.
New SR 3.2.1.2            ---------------------------------------------------------------------
                                                        - NOTE -
If measurements indicate that either the maximum over z or the maximum over z has increased since the previous evaluation of or if   is expected to increase prior to next evaluation of   :
: a. Increase   by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR and reverify   is within limits specified in the COLR; or
: b. Repeat SR 3.2.1.2 once per 7 EFPD until either a.
above is met or two successive flux maps indicate that the maximum over z and maximum over z has not increased.
Verify   is within limit.
Page 7 of 13

ATTACHMENT 1 Evaluation of Proposed Changes 2.3.3    Technical Specification Bases 3.2.1 Changes Several changes to the Bases were made to reflect the changes made in the TS sections as described above. Below is a summary list of key changes:
Changes to conform with renumbered Condition B REQUIRED ACTIONS Changes to description of REQUIRED ACTION B.1 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.1 Added description of new REQUIRED ACTION B.2 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.2 Changes to description of REQUIRED ACTION B.3 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.3 Changes to description of REQUIRED ACTION B.4 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.4 Added description of new REQUIRED ACTION B.5 to become consistent with changes in TS 3.2.1 REQUIRED ACTION B.5 Changes to descriptions of SURVEILLANCE REQUIREMENTS to conform with changes in Note 2 in TS 3.2.1 SURVEILLANCE REQUIREMENT 3.2.1.2

==3.0      TECHNICAL EVALUATION==

3.1      Technical Evaluation of TS 3.2.1 changes EGC is currently operating with administrative measures in accordance with NRC Administrative Letter 98-10 (Reference 6). The proposed changes resolve the issues identified in two Westinghouse Nuclear Safety Advisory Letters NSAL-09-5, Rev. 1 (Reference 1) and NSAL-15-1, Rev. 0 (Reference 2). The proposed changes are modifications of an existing section of the TS related to LCO 3.2.1.
New Required Action A.4 for Braidwood and Byron is added for consistency with the NUREG-1431 Standard Technical Specifications for LCO 3.2.1 (Reference 3).
New Required Action B.1 in existing LCO 3.2.1 for Ginna is introduced to implement a power reduction as described in the recommended actions of NSAL-09-5. New Required Action B.2 in existing LCO 3.2.1 for Byron and Braidwood is introduced to adopt the Axial Flux Difference (AFD) limit reductions which is a modified version of Required Action B.1 in the Standard Technical Specifications as specified in NUREG-1431 (Reference 3). With these modifications all three plants, Byron, Braidwood, and Ginna will have consistent Required Actions B.1 and B.2 of power reduction and AFD limit reductions. As pointed out by NSAL-09-5, both actions are needed to recover the required F Z margin if Condition B is entered.
Proposed Required Actions B.1 through B.5 are a modified version of the interim actions identified in NSAL-09-5. Rev. 1 (Reference 1). NSAL-09-5, Rev. 1 (Reference 1) determined that the previous guidance of reducing THERMAL POWER  1% RTP for each 1% F Z exceeding its limit was non-conservative. Therefore, the values will now be confirmed with the values as specified in the COLR. The power and AFD limit reductions are relocated in the COLR, see sample Table 1 below, which will allow for their evaluation using the RAOC methodology (Reference 4) when required. RAOC power distribution analysis will be performed using discrete maximum power levels and reduced AFD bands which will be used to quantify the expected margin improvement through reduction of the Page 8 of 13

ATTACHMENT 1 Evaluation of Proposed Changes power level and AFD limits. Calculations will confirm that for a given loss of F Z margin, a specified combination of power reduction and RAOC band changes will recover at least the required F Z margin deficiency at core elevation Z. The Z elevation will correspond to the limiting elevation with respect to the F Z limit. The required value will be specified in a new table which will be specified in the COLR. This table will provide the power and AFD limits in relation to the required F Z margin improvement. As initially implemented, the values in the COLR will match the bounding conservative values from NSAL-09-5 as shown in Table 1. These values will be updated using the RAOC methodology when required.
Table 1 Required Operating Space Reduction when            Exceeds Its Limits (Sample Values)
Required F              THERMAL POWER         Negative AFD Band         Positive AFD Band Margin Improvement          Reduction (% RTP)      Reduction (% AFD)        Reduction (% AFD) 1%                       3%                   1%                       1%
      > 1% AND  2%                  6%                    2%                       2%
      > 2% AND  3%                  9%                    3%                       3%
           > 3%                      50%                   N/A                      N/A The relocation of the operating space to the COLR is based on Generic Letter (GL) 88-16, Guidance for Technical Specification Changes for Cycle-Specific Parameter Limits, (Reference 7) which states that licensees can modify cycle specific parameters as long as the modifications are evaluated by NRC-approved methodology and consistent with all applicable limits of the plant safety analysis. The relocation of these values in the COLR will permit evaluation and update using RAOC methodology when required.
3.2      Technical Evaluation of SR 3.2.1.2 changes The note preceding SR 3.2.1.2 for all three plants is changed to add trending of F Z in addition to F Z . This is required due to the possibility of decreasing nominal   value while the   is increasing. Adding the explicit trending of F Z resolves this problem and is consistent with the interim changes proposed in NSAL-15-1, Rev. 0 (Reference 2).
With this change, the F Z will be increased by the appropriate factor in the COLR when any of the following conditions are met:
Increase of maximum over z             since the previous evaluation, Increase of maximum over z             since the previous evaluation, Expected increase of maximum over z              prior to next evaluation.
The last condition is met if:
F Z,      ,                F Z,       ,
K Z                             K Z where,  is the burnup when the surveillance is performed and            is the burnup when the next surveillance will be performed.
Page 9 of 13

ATTACHMENT 1 Evaluation of Proposed Changes The specification of the appropriate penalty factor in the COLR, required to accommodate potential increase in F Z over the surveillance period, allows evaluation of this factor using NRC-approved methodology when required. The values of the appropriate penalty factor are listed in Table 2.6.2.c in the Byron and Braidwood COLRs and Table COLR-2 for Ginna.

==4.0      REGULATORY EVALUATION==

4.1      Applicable Regulatory Requirements/Criteria The following NRC requirements and guidance document are applicable to the review of the proposed change.
The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. EGC has determined that the proposed change does not require any exemptions or relief from the applicable regulatory requirements. The following current applicable regulations and regulatory requirements were reviewed in making this determination:
Criterion 10, Reactor Design The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any condition of normal operation, including the effects of anticipated operational occurrences.
10 CFR 50.36, Technical Specifications, paragraph (c)(2) states that technical specifications will include limiting conditions for operation. Paragraph (c)(3) states that technical specifications will include surveillance requirements. Both of these paragraphs are applicable to the proposed change.
Section (c)(2)(ii) provides that LCOs must be established for each item meeting one or more criteria. For the power distribution items affected by the proposed change, the following criterion applies:
(b) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The association with the relevant design basis accident analysis is described below.
10 CFR 50.46, Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors, establishes acceptable limits for the performance of Emergency Core Cooling System (ECCS), and requirements for the analytical models used to validate the performance. The analyses of ECCS performance use various inputs and assumptions that reflect the conditions and features of a given plant. In accordance with Byron, Braidwood, and Ginna TS 3.2.1.b, Heat Flux Hot Channel Factor (FQ(Z)), the ECCS analysis establishes limits for FQ(Z), Heat Flux Hot Channel Factor, which is the subject of the proposed TS changes.
The proposed change maintains compliance with these requirements.
Page 10 of 13

ATTACHMENT 1 Evaluation of Proposed Changes 4.2     Precedent The proposed changes to the Braidwood, Byron, and Ginna TS are fundamentally the same as those approved in the following Safety Evaluations. These precedents also address additional issues associated with NSAL-09-5 that are not applicable to Braidwood, Byron, and Ginna. NSAL-15-1, Rev. 0 issues were addressed using Relaxed Axial Offset Control (RAOC) methodology.
: 1. Letter from V. Sreenivas, U.S. Nuclear Regulatory Commission (NRC), to David A. Heacock (Virginia Electric and Power Company), North Anna Power Station, Unit Nos. 1 and 2 - Issuance of Amendments to Revise Technical Specifications to Address Issues Identified in Westinghouse NSAL-09-5, Revision 1, and NSAL-15-1, Rev. 0 (CAC Nos. MF7186 and MF7187), dated October 17, 2016, (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16252A478).
: 2. Letter from Richard V. Guzman, NRC, to David A Heacock (Dominion Nuclear),
Millstone Power Station, Unit No. 3 - Issuance of Amendment Adopting Dominion Core Design and Safety Analysis Methods and Addressing the Issues Identified in Three Westinghouse Communication Documents (CAC No.
MF6251). dated July 28, 2016, (ADAMS Accession Number ML16131A728).
4.3     No Significant Hazards Consideration An evaluation of the proposed change has been performed in accordance with 10 CFR 50.91(a)(1) regarding no significant hazards considerations using the standards in 10 CFR 50.92(c). A discussion of these standards as they relate to these amendments request follows:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change for resolution of Westinghouse notification documents Westinghouse Nuclear Safety Advisory Letter NSAL-09-5, Rev. 1, Relaxed Axial Offset Control FQ Technical Specification Actions, and Westinghouse Nuclear Safety Advisory Letter NSAL-15-1, Rev. 0, Heat Flux Hot channel Factor Technical Specification Surveillance, is intended to address deficiencies identified within the existing Braidwood, Byron, and Ginna Technical Specifications (TS) and to return them to their as-designed function. Operation in accordance with the revised TS ensures that the assumptions for initial conditions of key parameter values in the safety analyses remain valid and does not result in actions that would increase the probability of consequences of any accident previously evaluated.
Therefore, the proposed change does not involve a significant increase in the probability or the consequences of any accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Page 11 of 13

ATTACHMENT 1 Evaluation of Proposed Changes Response: No.
Operation in accordance with the revised TS and its limits precludes new challenges to Systems, Structures, or Components that might introduce a new type of accident.
All design and performance criteria will continue to be met and no new single failure mechanisms will be created. The proposed change for resolution of Westinghouse notification documents NSAL-09-5, Rev. 1 and NSAL-15-1, Rev. 0 does not involve the alteration of plant equipment or introduce unique operational modes or accident precursors. It thus does not create the potential for a different kind of accident.
Therefore, the proposed change does not create a new or different kind of accident from any accident previously evaluated.
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
Operation in accordance with the revised TS and its limits preserves the margins assumed in the initial conditions for key parameters assumed in the safety analysis.
This ensures that all design and performance criteria associated with the safety analysis will continue to be met and that the margin of safety is not affected.
Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.
Based on the above, EGC concludes that the proposed amendments do not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.
4.4       Conclusions In conclusion, based on the considerations discussed 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 approval of the proposed change will not be inimical to the common defense and security or to the health and safety of the public.

==5.0       ENVIRONMENTAL CONSIDERATION==

A review has determined that the proposed amendments 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 amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet 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 amendments.
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ATTACHMENT 1 Evaluation of Proposed Changes

==6.0    REFERENCES==
: 1. Westinghouse Nuclear Safety Advisory Letter, NSAL-09-5, Rev. 1, Relaxed Axial Offset Control FQ Technical Specification Actions, September 23, 2009.
: 2. Westinghouse Nuclear Safety Advisory Letter, NSAL-15-1, Rev. 0, Heat Flux Hot Channel Factor Technical Specification Surveillance, February 3, 2015.
: 3. NUREG-1431, Revision 4, Vol. 1, Standard Technical Specifications Westinghouse Plants
: 4. WCAP-10216-P-A, Revision 1A, Relaxation of Constant Axial Offset Control - FQ Surveillance Technical Specification, February 1994.
: 5. WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019.
: 6. NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety, December 29, 1998.
: 7. NRC Generic Letter 88-16, Guidance for Technical Specification Changes for Cycle-Specific Parameter Limits, October 4, 1988.
: 8. Letter from V. Sreenivas, U.S. Nuclear Regulatory Commission (NRC), to David A.
Heacock (Virginia Electric and Power Company), North Anna Power Station, Unit Nos. 1 and 2 - Issuance of Amendments to Revise Technical Specifications to Address Issues Identified in Westinghouse NSAL-09-5, Revision 1, and NSAL-15-1, Rev. 0 (CAC Nos. MF7186 and MF7187), dated October 17, 2016, (Agencywide Documents Access and Management System (ADAMS) Accession Number ML16252A478)
Page 13 of 13

ATTACHMENT 2 Markup of Technical Specifications Pages Braidwood Station Units 1 and 2 Byron Station Units 1 and 2 R. E. Ginna Nuclear Power Plant Revised Technical Specifications Pages (red texts)
TS Pages Braidwood     3.2.1-1 3.2.1-2 3.2.1-4 Byron         3.2.1-1 3.2.1-2 3.2.1-4 Ginna         3.2.1-2 3.2.1-4

FQ(Z) 3.2.1 3.2POWERDISTRIBUTIONLIMITS 3.2.1HeatFluxHotChannelFactor(FQ(Z))
LCO 3.2.1             FQ(Z),asapproximatedby  and            ,shallbewithinthelimitspecifiedintheCOLR.
APPLICABILITY:  MODE1.
ACTIONS CONDITION                          REQUIREDACTION                       COMPLETIONTIME A. notwithin         A.1      ReduceTHERMALPOWER1%RTPfor          15minutes limit.                         each1%  exceedslimit.
AND A.2      ReducePowerRangeNeutronFluxHigh     72hours tripsetpoints1%foreach1%
exceedslimit.
AND A.3      ReduceOverpowerTtripsetpoints      72hours 1%foreach1%  exceedslimit.
AND A.4      PerformSR3.2.1.1andSR3.2.1.2.        PriortoincreasingTHERMALPOWER abovethelimitofRequiredActionA.1 (continued)
BRAIDWOOD - UNITS 1 & 2                             3.2.1  1                                  Amendment 110

FQ(Z) 3.2.1 ACTIONS(continued)
CONDITION                     REQUIREDACTION                        COMPLETIONTIME B.          notwithin   B.1  ReduceTHERMALPOWERasspecifiedin limit.                                                          4hours theCOLR.
1%RTPforeach1%            exceeds limit.
AND B.2  ReduceAFDlimits asspecifiedintheCOLR. 4hours AND B.32 ReducePowerRangeNeutronFluxHigh      72hours tripsetpoints1%foreach1%that THERMALPOWERislimitedbelowRATED THERMALPOWERbyRequiredAction B.1.
FQW(Z)exceedslimit.
AND B.43 ReduceOverpowerTtripsetpoints1%     72hours foreach1%thatTHERMALPOWERis limitedbelowRATEDTHERMALPOWER byRequiredActionB.1.
FQW(Z)exceedslimit.
AND B.5  PerformSR3.2.1.1andSR3.2.1.2          PriortoincreasingTHERMAL POWERandAFDlimitsabovethe limitsofRequiredActionsB.1and B.2.
C. RequiredActionand C.1  BeinMODE2.                            6hours associatedCompletion Timenotmet.
BRAIDWOOD - UNITS 1 & 2                       3.2.1  2                               Amendment 110

FQ(Z) 3.2.1 SURVEILLANCEREQUIREMENTS(continued)
SURVEILLANCE                                   FREQUENCY SR 3.2.1.2        NOTES
: 1.          Duringpowerescalationatthebeginningofeachcycle, THERMALPOWERmaybeincreaseduntilanequilibriumpower levelhasbeenachieved,atwhichapowerdistributionmapis obtained.
: 2.          If         measurementsindicatethateitherthemaximum overz OR maximumoverz hasincreasedsincethepreviousevaluationof  orif isexpectedtoincreasepriortothenextevaluationof
: a.        Increase  bythegreaterofafactorof1.02orby anappropriatefactorspecifiedintheCOLRandreverify iswithinlimitsspecifiedintheCOLR;or
: b.        RepeatSR3.2.1.2onceper7EFPD untileithera.aboveis metortwosuccessivefluxmapsindicatethatthe maximumoverz and maximumoverz hasnotincreased.
(continued)
BRAIDWOOD - UNITS 1 & 2                                                  3.2.1  4             Amendment 110

FQ(Z) 3.2.1 3.2 POWERDISTRIBUTIONLIMITS 3.2.1 HeatFluxHotChannelFactor(FQ(Z))
LCO 3.2.1               FQ(Z),asapproximatedby  and         ,shallbewithinthelimitspecifiedintheCOLR.
APPLICABILITY:          MODE1.
ACTIONS CONDITION                            REQUIREDACTION                       COMPLETIONTIME A.      notwithinlimit.               A.1      ReduceTHERMALPOWER                 15minutes 1%RTPforeach1%
exceedslimit.
AND A.2      ReducePowerRangeNeutron            72hours FluxHightripsetpoints 1%for each1%  exceedslimit.
AND A.3      ReduceOverpowerTtrip              72hours setpoints1%foreach 1%  exceedslimit.
AND A.4      PerformSR3.2.1.1andSR3.2.1.2.      Priortoincreasing THERMALPOWER abovethelimitof RequiredActionA.1 B.         notwithinlimit.            B.1      ReduceTHERMALPOWER as              4hours specifiedintheCOLR.1%RTPfor each1%  exceedslimit.
AND B.2      ReduceAFDlimitsasspecifiedin theCOLR.                           4hours (continued)
BYRONUNITS1& 2                                 3.2.11                                         Amendment116

FQ(Z) 3.2.1 ACTIONS CONDITION                     REQUIREDACTION                  COMPLETIONTIME B.   (continued)                 AND B.32     ReducePowerRangeNeutron       72hours FluxHightripsetpoints 1%for each1%thatTHERMALPOWER islimitedbelowRATEDTHERMAL POWERbyRequiredActionB.1.
exceedslimit.
AND B.43     ReduceOverpowerTtrip         72hours setpoints1%foreach1%that THERMALPOWERislimited belowRATEDTHERMALPOWER byRequiredActionB.1.
exceedslimit.
AND B.5     PerformSR3.2.1.1andSR3.2.1.2. Priortoincreasing THERMALPOWERand AFDlimitsabovethe limitsofRequiredActions B.1andB.2.
C. RequiredActionandassociated C.1      BeinMODE2.                    6hours CompletionTimenotmet.
BYRONUNITS1& 2                         3.2.12                                   Amendment116

FQ(Z) 3.2.1 SURVEILLANCEREQUIREMENTS (continued)
SURVEILLANCE                                    FREQUENCY SR 3.2.1.2        NOTES
: 1.          Duringpowerescalationatthebeginningofeachcycle, THERMALPOWERmaybeincreaseduntilanequilibrium powerlevelhasbeenachieved,atwhichapowerdistribution mapisobtained.
: 2.          If         measurementsindicatethateitherthe FQ (Z)
C maximumoverz K(Z)
OR maximumover hasincreasedsincethepreviousevaluationof  orif isexpectedtoincreasepriortothenextevaluationof
: a.        Increase  bythegreaterofafactorof1.02orby anappropriatefactorspecifiedintheCOLRandreverify iswithinlimitsspecifiedintheCOLR;or
: b.        RepeatSR3.2.1.2onceper7EFPD untileithera.
aboveismetortwosuccessivefluxmapsindicate thatthe FQ (Z)
C maximumoverz K(Z) and maximumover hasnotincreased.
(continued)
BYRONUNITS1&2                                                  3.2.14                     Amendment116

FQ(Z) 3.2.1 B.1 Reduce THERMAL POWER as specified in the COLR.
AND as specified in the 2          COLR.
ACTIONS (continued)
CONDITION                             REQUIRED ACTION             COMPLETION TIME 4 hours
              - NOTE -
Required Action B.54 shall be completed               B.1 Reduce AFD limits > 1% for 4 hours whenever this Condition          each1% FQW(Z) exceeds limit.
is entered.
AND                 3 B.      FQW(Z)   not within limit.
B.2 Reduce Power Range              4 hours Neutron Flux - High trip s THERMAL POWER is limited setpoints 1% for each 1%
below RATED THERMAL                          that the maximum allowable POWER by Required Action                     power of the AFD limits is B.1.                                         reduced.
4 AND B.3      Reduce Overpower T trip   72 hours setpoints 1% for each 1%
that the maximum allowable power of the AFD limits is reduced.
AND               5 B.4      Perform SR 3.2.1.1 and SR  Prior to increasing 3.2.1.2.                   THERMAL POWER and AFD limits allowable power of the AFD limits of Required Actions B.1 and B.2.
C. Required Action and               C.1      Be in MODE 2.              6 hours associated Completion Time not met.
R.E. Ginna Nuclear Power Plant                    3.2.1-2                          Amendment 94

FQ(Z) 3.2.1 SURVEILLANCE                                                       FREQUENCY SR 3.2.1.2      --------------------------------------
                                              - NOTE -
If       measurements indicate that either the maximum over or maximum over has increased since the previous evaluation of or if   is expected to increase prior to the next evaluation of   :
: a.       Increase   by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR and reverify   is within limits specified in the COLR; or
: b.       Repeat SR 3.2.1.2 once per 7 EFPD until either
: a. above is met or two successive flux maps indicate that the maximum over and maximum over has not increased.
Verify FQW(Z) is within limit.                                                Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND (continued)
R.E. Ginna Nuclear Power Plant                                  3.2.1-4                                  Amendment 122

ATTACHMENT 3 Markup of Technical Specifications Bases Pages Braidwood Station Units 1 and 2 Byron Station Units 1 and 2 R. E. Ginna Nuclear Power Plant Revised Technical Specifications Pages (red texts)
TS Bases Pages Braidwood     3.2.1-5 3.2.1-6 3.2.1-10 3.2.1-11 Byron         3.2.1-5 3.2.1-6 3.2.1-10 Ginna         3.2.1-6 3.2.1-7 3.2.1-10

FQ(Z) 3.2.1 BASES ACTIONS          A.1,A.2,andA.3 ReducingTHERMALPOWERby1%RTPforeach1%bywhich FQC(Z) exceedsitslimit, maintainsanacceptableabsolutepowerdensity. TheCompletionTimeof15minutesprovides anacceptabletimetoreducepowerinanorderlymannerandwithoutallowingtheunitto remaininanunacceptableconditionforanextendedperiodoftime.
AreductionofthePowerRangeNeutronFluxHightripsetpointsby1%foreach1%bywhich FQC(Z) exceedsitslimit,isaconservativeactionforprotectionagainsttheconsequencesofsevere transientswithunanalyzedpowerdistributions. TheCompletion Timeof72hoursissufficient consideringthesmalllikelihoodofaseveretransientinthis timeperiodandtheprecedingprompt reductioninTHERMALPOWERinaccordancewithRequiredActionA.1.
ReductionintheOverpowerTtripsetpoints(valueofK4)by1%foreach1%bywhich FQC(Z) exceedsitslimit,isaconservativeactionforprotectionagainsttheconsequencesofsevere transientswithunanalyzedpowerdistributions. TheCompletion Timeof72hoursissufficient consideringthesmalllikelihoodofaseveretransientinthis timeperiod,andtheprecedingprompt reductioninTHERMALPOWERinaccordancewithRequiredActionA.1.
A.4 Verificationthat  hasbeenrestoredtowithinitslimit,byperformingSR3.2.1.1andSR 3.2.1.2priortoincreasingTHERMALPOWERabovethelimitimposedbyRequiredActionA.1 ensuresthatcoreconditionsduringoperationathigherpowerlevelsandfutureoperationare consistentwithsafetyanalysesassumptions.
B.1 IfitisfoundthatthemaximumcalculatedvalueofFQ(Z)thatcanoccurduringnormalmaneuvers, FQW(Z) ,exceedsitsspecifiedlimits,thereexistsapotentialfor FQC(Z) tobecomeexcessivelyhighif anormaloperationaltransientoccurs. ReducingTHERMALPOWERby1%RTPforeach1%by which  exceedsitslimitasspecifiedintheCOLRwithintheallowedCompletionTimeof 4hours,maintainsanacceptable absolutepowerdensitysuchthatevenifatransientoccurred, corepeakingfactorsarenotexceeded.
BRAIDWOODUNITS1&2                          B3.2.15                                           Revision22

FQ(Z) 3.2.1 BASES ACTIONS(continued)
B.2 IfitisfoundthatthemaximumcalculatedvalueofFQ(Z)thatcanoccurduringnormalmaneuvers,
                       ,exceedsitsspecifiedlimits,thereexistsapotentialfor  tobecomeexcessively highifanormaloperationaltransientoccurs. ReducingtheAFDlimitsasspecifiedintheCOLR withintheallowedCompletionTimeof4hours,restrictstheaxialfluxdistributionsuchthatevenif atransientoccurred,corepeakingfactorsarenotexceeded.
B.23 AreductionofthePowerRangeNeutronFluxHightripsetpointsby1%foreach1%bywhich exceedsthelimit themaximumallowableTHERMALPOWERisreduced,isa conservativeactionforprotectionagainsttheconsequencesofseveretransientswithunanalyzed powerdistributions. TheCompletionTimeof72hoursissufficientconsideringthesmalllikelihood ofaseveretransientinthistimeperiodandtheprecedingpromptreductioninTHERMALPOWER andAFDlimitsinaccordancewithRequiredActionsB.1andB.2.
B.34 ReductionintheOverpowerTtripsetpoints(valueofK4)by1%foreach1%bywhich exceedsthelimitthemaximumallowableTHERMALPOWERisreduced,isaconservativeaction forprotectionagainsttheconsequencesofseveretransientswithunanalyzedpowerdistributions.
TheCompletionTimeof72hoursissufficientconsideringthesmalllikelihoodofaseveretransient inthistimeperiodandtheprecedingpromptreductioninTHERMALPOWERandAFDlimitsin accordancewithRequiredActionsB.1andB.2.
B.5 Verificationthat  hasbeenrestoredtowithinitslimit,byperformingSR3.2.1.1andSR 3.2.1.2priortoincreasingTHERMALPOWERandAFDlimitsabovethelimitimposedbyRequired ActionsB.1andB.2,ensuresthatcoreconditionsduringoperationathigherpowerlevelsand futureoperationareconsistentwithsafetyanalysesassumptions.
C.1 IftheRequiredActionsofA.1throughA.34orB.1throughB.35arenotmetwithintheirassociated CompletionTimes,theunitmustbeplacedinaMODEorconditioninwhichthe LCOrequirementsarenotapplicable. ThisisdonebyplacingtheunitinatleastMODE2within 6hours. TheallowedCompletionTimeisreasonablebasedonoperatingexperienceregarding theamountoftimeittakestoreachMODE2fromfullpoweroperationinanorderlymannerand withoutchallengingplantsystems.
BRAIDWOOD  UNITS 1 & 2                        B 3.2.1  6                                      Revision 22

FQ(Z) 3.2.1 BASES SURVEILLANCEREQUIREMENTS(continued)
FQW(Z) evaluationsarenotapplicableforthefollowingaxialcoreregions,measuredinpercentof coreheight:
: a.       Lowercoreregion,from0to15%inclusive;and
: b.       Uppercoreregion,from85to100%inclusive.
Ifthetopandbottomexclusion zonesarereducedto8%,then FQW(Z) evaluationsarenot applicableforthefollowingaxialcoreregions,measuredinpercentofcoreheight:
: c.       Lowercoreregion,from0to8%inclusive;and
: d.       Uppercoreregion,from92to100%inclusive.
Typically,thetopandbottom15% ofthecoreareexcludedfromtheevaluationbecauseofthe lowprobabilitythattheseregionswouldbemorelimitinginthesafetyanalysesandbecauseofthe difficultyofmakingaprecisemeasurementintheseregions. However,thetopandbottom exclusionzonescanbereducedto8%ifthepredictedtransientpeakFQ(Z)islocatedwithinthetop andbottom8%to15%ofthecore. Thereductionofthetopand bottomexclusionzonesfrom 15%to8%ofthecorestillmeetsthe FQC(Z) measurementuncertaintyof5%.
ThisSurveillancehasbeenmodifiedbythreeNotes. Note2mayrequirethatmorefrequent surveillancesbeperformed. If FQW(Z) isevaluated,anevaluationoftheexpressionsbelowis requiredtoaccountforanyincreaseto FQM(Z) thatmayoccurandcausetheFQ(Z)limittobe exceededbeforethenextrequiredFQ(Z)evaluation.
IfthetwomostrecentFQ(Z)evaluationsshowanincreaseinanyoftheexpressions FQC(Z) maximum over z                                    ,
K(Z)
Increaseofmaximumoverz               sincethepreviousevaluation BRAIDWOOD  UNITS 1 & 2                        B 3.2.1  10                                       Revision 58

FQ(Z) 3.2.1 Increaseofmaximumoverz              sincethepreviousevaluation, Expectedincreaseofmaximumoverz               priortothenextevaluation itisrequiredtomeettheFQ(Z)limitwiththelast FQW(Z) increasedbythegreaterofthefactorof 1.02orbyanappropriatefactorspecifiedintheCOLR(Ref.7),ortoevaluateFQ(Z)morefrequently, each7EFPD.
Thelastconditionismetif:
WhereBnisburnupwhenthesurveillanceisperformedandBn+1istheburnupwhenthenext surveillancewillbeperformed.
BRAIDWOOD  UNITS 1 & 2                       B 3.2.1  11                                      Revision 58

FQ(Z) 3.2.1 BASES ACTIONS        A.1,A.2,andA.3 ReducingTHERMALPOWERby1%RTPforeach1%bywhich  exceedsitslimit, maintainsanacceptableabsolutepowerdensity. TheCompletionTimeof15minutesprovides anacceptabletimetoreducepowerinanorderlymannerandwithoutallowingtheunitto remaininanunacceptableconditionforanextendedperiodoftime.
AreductionofthePowerRangeNeutronFluxHightripsetpointsby1%foreach1%bywhich exceedsitslimit,isaconservativeactionforprotectionagainsttheconsequencesofsevere transientswithunanalyzedpowerdistributions. TheCompletion Timeof72hoursissufficient consideringthesmalllikelihoodofaseveretransientinthis timeperiodandtheprecedingprompt reductioninTHERMALPOWERinaccordancewithRequiredActionA.1.
ReductionintheOverpowerTtripsetpoints(valueofK4)by1%foreach1%bywhich exceedsitslimit,isaconservativeactionforprotectionagainsttheconsequencesofsevere transientswithunanalyzedpowerdistributions. TheCompletion Timeof72hoursissufficient consideringthesmalllikelihoodofaseveretransientinthis timeperiod,andtheprecedingprompt reductioninTHERMALPOWERinaccordancewithRequiredActionA.1.
A.4 Verificationthat  hasbeenrestoredtowithinitslimit,byperformingSR3.2.1.1andSR 3.2.1.2priortoincreasingTHERMALPOWERabovethelimitimposedbyRequiredActionA.1 ensuresthatcoreconditionsduringoperationathigherpowerlevelsandfutureoperationare consistentwithsafetyanalysesassumptions.
B.1 IfitisfoundthatthemaximumcalculatedvalueofFQ(Z)thatcanoccurduringnormalmaneuvers,
                 ,exceedsitsspecifiedlimits,thereexistsapotentialfor  tobecomeexcessivelyhigh ifanormaloperationaltransientoccurs. ReducingTHERMALPOWERby1%RTPforeach1%by which  exceedsitslimitasspecifiedintheCOLRwithintheallowedCompletionTimeof 4hours,maintainsanacceptable absolutepowerdensitysuchthatevenifatransientoccurred, corepeakingfactorsarenotexceeded.
B.2 IfitisfoundthatthemaximumcalculatedvalueofFQ(Z)thatcanoccurduringnormalmaneuvers,
                 ,exceedsitsspecifiedlimits,thereexistsapotentialfor  tobecomeexcessively highifanormaloperationaltrasientoccurs. ReducingtheAFDlimitsasspecifiedintheCOLR withintheallowedCompletionTimeof4hours,restrictstheaxialfluxdistributionsuchthat evenifatransientoccurred,corepeakingfactorsarenotexceeded.
BYRONUNITS1&2                            B3.2.15                                         Revision15

FQ(Z) 3.2.1 BASES ACTIONS(continued)
B.32 AreductionofthePowerRangeNeutronFluxHightripsetpointsby1%foreach1%bywhich exceedsthelimit,themaximumallowableTHERMALPOWERisreduced,isa conservativeactionforprotectionagainsttheconsequencesofseveretransientswithunanalyzed powerdistributions. TheCompletionTimeof72hoursissufficientconsideringthesmalllikelihood ofaseveretransientinthistimeperiodandtheprecedingpromptreductioninTHERMALPOWER andAFDlimitsinaccordancewithRequiredActionsB.1andB.2.
B.43 ReductionintheOverpowerTtripsetpoints(valueofK4)by1%foreach1%bywhich exceedsthelimit,themaximumallowableTHERMALPOWERisreduced,isaconservativeaction forprotectionagainsttheconsequencesofseveretransientswithunanalyzedpowerdistributions.
TheCompletionTimeof72hoursissufficientconsideringthesmalllikelihoodofaseveretransient inthistimeperiodandtheprecedingpromptreductioninTHERMALPOWERandAFDlimitsin accordancewithRequiredActionsB.1andB.2.
B.5 Verificationthat  hasbeenrestoredto withinitslimit,byperformingSR3.2.1.1andSR 3.2.1.2priortoincreasingTHERMALPOWERandAFDlimitsabovethelimitimposedbyRequired ActionsB.1andB.2,ensuresthatcoreconditionsduringoperationathigherpowerlevelsand futureoperationareconsistentwithsafetyanalysesassumptions.
C.1 IftheRequiredActionsofA.1throughA.3,orB.1throughB.3,arenotmetwithintheirassociated CompletionTimes,theunitmustbeplacedinaMODEorconditioninwhichthe LCOrequirementsarenotapplicable. ThisisdonebyplacingtheunitinatleastMODE2within 6hours. TheallowedCompletionTimeisreasonablebasedonoperatingexperienceregarding theamountoftimeittakestoreachMODE2fromfullpoweroperationinanorderlymannerand withoutchallengingplantsystems.
BYRONUNITS1&2                               B3.2.16                                         Revision15

FQ(Z) 3.2.1 BASES SURVEILLANCEREQUIREMENTS(continued) evaluationsarenotapplicableforthefollowingaxialcoreregions,measuredinpercentof coreheight:
: a.       Lowercoreregion,from0to15%inclusive;and
: b.       Uppercoreregion,from85to100%inclusive.
Ifthetopandbottomexclusion zonesarereducedto8%,then  evaluationsarenot applicableforthefollowingaxialcoreregions,measuredinpercentofcoreheight:
: e.       Lowercoreregion,from0to8%inclusive;and
: f.       Uppercoreregion,from92to100%inclusive.
Typically,thetopandbottom15% ofthecoreareexcludedfromtheevaluationbecauseofthe lowprobabilitythattheseregionswouldbemorelimitinginthesafetyanalysesandbecauseofthe difficultyofmakingaprecisemeasurementintheseregions. However,thetopandbottom exclusionzonescanbereducedto8%ifthepredictedtransientpeakFQ(Z)islocatedwithinthetop andbottom8%to15%ofthecore. Thereductionofthetopand bottomexclusionzonesfrom 15%to8%ofthecorestillmeetsthe  measurementuncertaintyof5%.
ThisSurveillancehasbeenmodifiedbythreeNotes. Note2mayrequirethatmorefrequent surveillancesbeperformed. If  isevaluated,anevaluationoftheexpressionbelowis requiredtoaccountforanyincreaseto  thatmayoccurandcausetheFQ(Z)limittobe exceededbeforethenextrequiredFQ(Z)evaluation.
IfthetwomostrecentFQ(Z)evaluationsshowanincreaseinanyoftheexpressions FQC(Z) maximum over z                                     ,
K(Z)
Increaseofmaximumoverz           sincethepreviousevaluation, Increaseofmaximumoverz            sincethepreviousevaluation, Expectedincreaseofmaximumoverz              priortothenextevaluation itisrequiredtomeettheFQ(Z)limitwiththelast  increasedbythegreaterofthefactorof 1.02orbyanappropriatefactorspecifiedintheCOLR(Ref.7),ortoevaluateFQ(Z)morefrequently, each7EFPD.
Thelastconditionismetif:
WhereBnisburnupwhenthesurveillanceisperformedandBn+1istheburnupwhenthenext surveillancewillbeperformed.
BYRONUNITS1&2                                  B3.2.110                                         Revision54

FQ(Z)
B 3.2.1 A.4 Verification that FQC(Z) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the limit imposed by Required Action A.1, ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.
Condition A is modified by a Note that requires Required Action A.4 to be performed whenever the Condition is entered. This ensures that SR 3.2.1.1 and SR 3.2.1.2 will be performed prior to increasing THERMAL POWER above the limit of Required Action A.1, even when Condition A is exited prior to performing Required Action A.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.
B.1 If it is found that the maximum calculated value of FQ(Z) that can occur during normal maneuvers,   , exceeds its specified limits, there exists a potential for   to become excessively high if a normal operational transient occurs.
Reducing THERMAL POWER as specified in the COLR within the allowed Completion Time of 4 hours, maintains an acceptable absolute power density such that even if a transient occurred, core peaking factors are not exceeded.
B.21 If it is found that the maximum calculated value of   that can occur during normal maneuvers,   , exceeds its specified limits, there exists a potential for   to become excessively high if a normal operational transient occurs. Reducing the AFD limits as specified in the COLR by  1% for each 1% by which FQW(Z) exceeds its limit within the allowed Completion Time of 4 hours, restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded (Ref. 5).
The percent that FQ(Z) exceeds its transient limit is calculated based on the following expression:
R.E. Ginna Nuclear Power Plant B 3.2.1-6                                   Revision 78

FQ(Z)
B 3.2.1 The implicit assumption is that if W(Z) values were recalculated (consistent with the reduced AFD limits), then FQC(Z) times the recalculated W(Z) values would meet the FQ(Z) limit. Note that complying with this action (of reducing AFD limits) may also result in a power reduction. Hence the need for Required Actions B.2, B.3, B.4 and B.5.
B.23 A reduction of the Power Range Neutron Flux-High trip setpoints by  1%
for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER and as a result of reducing AFD limits in accordance with Required Actions B.1 and B.2.
B.34 Reduction in the Overpower T trip setpoints value of K4 by  1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER and as a result of reducing AFD limits in accordance with Required Actions B.1 and B.2.
B.45 Verification that FQW(Z) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER and AFD limits above the maximum allowable power limits imposed by Required Actions B.1 and B.2 ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.
Condition B is modified by a Note that requires Required Action B.45 to be performed whenever the Condition is entered. This ensures that SR 3.2.1.1 and SR 3.2.1.2 will be performed prior to increasing THERMAL POWER and AFD limits above the limit of Required Actions B.1 and B.2, even when Condition B is exited prior to performing Required Action B.45.
Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.
R.E. Ginna Nuclear Power Plant B 3.2.1-7                                  Revision 78

FQ(Z)
B 3.2.1 The limit with which FQW(Z) is compared varies inversely with power above 50% RTP and directly with the function K(Z) provided in the COLR.
The W(Z) curve is provided in the COLR for discrete core elevations. Flux map data are typically taken for 61 core elevations. FQW(Z) evaluations are not applicable for the following axial core regions, measured in percent of core height:
: a.      Lower core region, from 0 to 8% inclusive and
: b.      Upper core region, from 92 to 100% inclusive.
The top and bottom 8% of the core are excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making a precise measurement in these regions.
This Surveillance has been modified by a Note that may require that more frequent surveillances be performed. If FQW (Z) is evaluated, an evaluation of the expression below is required to account for any increase to FQM(Z) that may occur and cause the FQ(Z) limit to be exceeded before the next required FQ(Z) evaluation.
If the two most recent FQ(Z) evaluations show an increase in any of the expressions maximum over z [FQC(Z) I K(Z) ],
Increase of maximum over z              since the previous evaluation, Increase of maximum over z               since the previous evaluation, Expected increase of maximum over z                 prior to the next evaluation it is required to meet the FQ(Z) limit with the last FQW(Z) increased by the greater of a factor of 1.02 or by an appropriate factor specified in the COLR or to evaluate FQ(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.
The last condition is met if:
Where Bn is burnup when the surveillance is performed and Bn+1 is the burnup when the next surveillance will be performed.
R.E. Ginna Nuclear Power Plant B 3.2.1-10                                   Revision 78}}