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{{#Wiki_filter:ENCLOSURE 2 VOLUME 7
SEQUOYAH NUCLEAR PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION
ITS SECTION 3.2 POWER DISTRIBUTION LIMITS
Revision 0
LIST OF ATTACHMENTS
: 1. ITS 3.2.1, - Heat Flux Hot Channel Factor (F Q(X,Y, Z)) 2. ITS 3.2.2, - Nuclear Enthalpy Rise Hot Channel Factor (FH(X, Y)) 3. ITS 3.2.3 - Axial Flux Difference (AFD) 4. ITS 3.2.4 - Quadrant Power Tilt Ratio (QPTR)
ATTACHMENT 1 ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (F Q(X,Y,Z))
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS 3/4.2.2  HEAT FLUX HOT CHANNEL FACTOR-F Q(X,Y,Z)  LIMITING CONDITION FOR OPERATION 3.2.2  FQ(X,Y,Z) shall be maintained within the acceptable limits specified in the COLR:
APPLICABILITY
:  MODE 1
ACTION:
With FQ(X,Y,Z) exceeding its limit: 
: a. Reduce THERMAL POWER at least 1% for each 1%
FQ(X,Y,Z) exceeds the limit within 15 minutes, and similarly reduce the following:
: 1. Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours, and
: 2. The Power Range Neutron Flux-High Trip Setpoints within the next 4 hours. b. POWER OPERATION may proceed for up to 48 hours. Subsequent POWER OPERATION may proceed provided the Overpower Delta T Trip Setpoints (value of K
: 4) have been reduced at least 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR.
: c. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced limit required by Action
: a. and b., above; THERMAL POWER may then be increased provided FQ(X,Y,Z) is demonstrated through incore mapping to be within its limits.
SURVEILLANCE REQUIREMENTS 4.2.2.1  The provisions of Specification 4.0.4 are not applicable. 
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-5 Amendment No. 19, 95, 140, 155, 223 Page 1 of 10 LCO 3.2.1 Applicabilit y ACTION A Required Action A.4 Add proposed ACTION A Note M01Required Action A.1 Required Action A.3 Required Action A.5 LA01LA02Add proposed ACTION D M03Required Action A.2 SR NOTE M04M02after each F Q(X,Y,Z) determination )Z,Y,X(FCQsteady state A02A02)Z,Y,X(FCQL0172 M02after each F Q(X,Y,Z) determination A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued) 4.2.2.2 QMF(X,Y,Z) shall be evaluated to determine if F Q(X,Y,Z) is within its limit by:
: a. Using the moveable incore detectors to obtain a power distribution map (
QMF(X,Y,Z)*) at any THERMAL POWER greater than 5% of RATED THERMAL POWER.
: b. Satisfying the following relationship:
    (QMF(X,Y,Z)  BQNOM(X,Y,Z) where BQNOM (X,Y,Z)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.
The BQNOM (X,Y,Z) factors are not applicable in the following core plane regions as measured in percent of core height from the bottom of the fuel:
: 1. Lower core region from 0 to 15%, inclusive.
: 2. Upper core region from 85 to 100%, inclusive.
: c. If the above relationship is not satisfied, then
: 1. For that location, calculate the % margin to the maximum allowable design as follows:
where BQDES(X,Y,Z)** and BCDES(X,Y,Z)** represent the maximum allowable design peaking factors which insure that the licensing criteria will be preserved for operation within Limiting Condition for Operation limits, and include allowances for the calculational and measurement uncertainties.
* No additional uncertainties are required in the following equations for QMF(X,Y,Z), because the limits include uncertainties.
** BQNOM (X,Y,Z), BQDES(X,Y,Z), and BCDES(X,Y,Z) Data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 1    3/4 2-6      Amendment Nos. 19, 95, 140, 155, 223
% AFD Margin =  1 -
F(X,Y,Z)BQDES(X,Y,Z)  x 100%QM  % f(I) Margin =  1 -
F(X,Y,Z)BCDES(X,Y,Z)  x 100%2QM SR 3.2.1.2 SR 3.2.1.3 Page 2 of 10 LA03SR 3.2.1.2 SR 3.2.1.3 LA03LA03LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
: 2. Find the minimum margin of all locations examined in 4.2.2.2.c.1 above.
AFD min margin = minimum % margin value of all locations examined.
f2(I) OPT min margin = minimum % margin value of all locations examined.
: 3. If the AFD min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.
  (a) Within 2 hours, administratively reduce the negative AFD limit lines at each power level by:
Reduced AFD Limit = (AFDLimit from COLR) + absolute value of (NSLOPE AFD* % x AFD min margin of 4.2.2.2.c.2)
  (b) Within 2 hours, administratively reduce the positive AFD limit lines at each power level by:
Reduced AFD Limit = (AFDLimit from COLR) absolute value of (PSLOPE AFD* % X AFD min margin) 
: 4. If the f 2(I) min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.
  (a) Within 48 hours, reduce the OPT negative f 2(I) breakpoint limit by:
Reduced OPT negative f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) + absolute value of
* NSLOPE AFD and PSLOPE AFD are the amount of AFD adjustment required to compensate for each 1%  that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14
  ** PSLOPE and NSLOPEI)(fI)(f22 are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14   
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-7 Amendment No. 19, 95, 140, 155, 216, 223 margin) min I)(
f x % NSLOPE(2)I(f**2 LA03Page 3 of 10 ACTION B REQUIRED ACTION B.2 REQUIRED ACTION B.1 REQUIRED ACTION C.2 ACTION C REQUIRED ACTION B.1/B.2 REQUIRED  ACTION C.1/C.2 LA03LA03LA03LA03M05M05LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
    (b) Within 48 hours, reduce the OPT positive f 2(I) breakpoint limit by:
Reduced OPT positive f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) absolute value of margin) min I)(
f x % **PSLOPE(2I)(f2  d. Measuring QMF(X,Y,Z) according to the following schedule:
: 1. Upon achieving equilibrium conditions after exceeding by 10 percent or more of RATED THERMAL POWER, the THERMAL POWER at which F Q(X,Y,Z) was last determined,***
or    2. At least once per 31 Effective Full Power Days, whichever occurs first.
: e. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding QMF(X,Y,Z)  BQNOM(X,Y,Z), either of the following actions specified shall be taken. 1. QMF(X,Y,Z) shall be increased over that specified in 4.2.2.2.a by the appropriate factor specified in the COLR, and 4.2.2.2.c repeated, or
: 2. QMF(X,Y,Z) shall be evaluated according to 4.2.2.2 at or before the time when the margin is projected to result in one of the actions specified in 4.2.2.2.c.3 or 4.2.2.2.c.4.
4.2.2.3  When FQ(X,Y,Z) is measured for reasons other than meeting the requirements of Specification 4.2.2.2 an overall measured FQ(X,Y,Z) shall be obtained from a power distribution map, increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR according to Specification 3.2.2.
___________________________
** PSLOPE and NSLOPEI)(fI)(f22 are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14  *** During power escalation at the beginning of each cycle, power level may be increased until a power level for extended operation has been achieved and power distribution map obtained.
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-8 Amendment No. 19, 140, 223 Page 4 of 10 M08thereafter LA04In accordance with the Surveillance Frequency Control ProgramSR Note INSERT 1 andM06SR 3.2.1.1 SR 3.2.1.2 SR 3.2.1.3 LA02LA03REQUIRED ACTION C.1 SR 3.2.1.2/SR 3.2.1.3 NOTE SR 3.2.1.2 /  SR 3.2.1.3 
NOTE a. SR 3.2.1.2 /
SR 3.2.1.3 
NOTE b. SR 3.2.1.1 LA03REQUIRED  ACTION C.1/C.2 M08M04M07M09INSERT 2 Once within 12 hours after A02)Z,Y,X(FCQNot required to be performed until 12 hours after an equilibrium can be 3.2.1 Insert Page 3/4 2-8  CTS (Page 4 of 10)
INSERT 1  Once after each refueling prior to THERMAL POWER exceeding 75% RTP
INSERT 2  Once after each refueling prior to THERMAL POWER exceeding 75% RTP
AND Once within 12 hours after achieving equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which  )Z,Y,X(FCQ was last verified AND  At least once per 31 Effective Full Power Days
DOC M09 DOC M06 LA04In accordance with the Surveillance Frequency Control Program A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS
This page intentionally deleted.
October 23, 1991 SEQUOYAH - UNIT 1    3/4 2-9  Amendment No. 12, 140, 155 Page 5 of 10 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS 3/4.2.2  HEAT FLUX HOT CHANNEL FACTOR- F Q(X,Y,Z)  LIMITING CONDITION FOR OPERATION 3.2.2  FQ(X,Y,Z) shall be maintained within the acceptable limits specified in the COLR.
APPLICABILITY
:  MODE 1 ACTION:
With FQ(X,Y,Z) exceeding its limit:
: a. Reduce THERMAL POWER at least 1% for each 1%
FQ(X,Y,Z) exceeds the limit within 15 minutes, and similarly reduce the following:
: 1. Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours, and
: 2. The Power Range Neutron Flux-High Trip Setpoints within the next 4 hours. 
: b. POWER OPERATION may proceed for up to 48 hours. Subsequent POWER OPERATION may proceed provided the Overpower Delta T Trip Setpoints (value of K
: 4) have been reduced at least 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR.
: c. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced limit required by Action
: a. and b., above; THERMAL POWER may then be increased provided FQ(X,Y,Z) is demonstrated through incore mapping to be within its limits.
SURVEILLANCE REQUIREMENTS 4.2.2.1  The provisions of Specification 4.0.4 are not applicable. 
April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-4        Amendment Nos. 21, 95, 131, 146, 214 LCO 3.2.1 Applicabilit y ACTION A Required Action A.4 Required Action A.1 Required Action A.3 Required Action A.5 LA01Page 6 of 10 M01Add proposed ACTION D M03Required Action A.2 SR NOTE M04M02after each F Q(X,Y,Z) determination A02)Z,Y,X(FCQAdd proposed ACTION A Notesteady state A02)Z,Y,X(FCQLA02M02after each F Q(X,Y,Z) determination L0172 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued) 4.2.2.2  Z)Y,(X,FMQ shall be evaluated to determine if F Q(X,Y,Z) is within its limit by:
: a. Using the moveable incore detectors to obtain a power distribution map (
QMF(X,Y,Z)*) at any THERMAL POWER greater than 5% of RATED THERMAL POWER.
: b. Satisfying the following relationship:
QMF(X,Y,Z)  BQNOM(X,Y,Z) where BQNOM (X,Y,Z)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.
The BQNOM (X,Y,Z) factors are not applicable in the following core plane regions as measured in percent of core height from the bottom of the fuel:
: 1. Lower core region from 0 to 15%, inclusive.
: 2. Upper core region from 85 to 100%, inclusive.
: c. If the above relationship is not satisfied, then      1. For that location, calculate the % margin to the maximum allowable design as follows:
where BQDES (X,Y,Z)** and BCDES(X,Y,Z)** represent the maximum allowable design peaking factors which insure that the licensing criteria w ill be preserved for operation within Limiting Condition for Operation limits, and include allowances for the calculational and measurement uncertainties.
* No additional uncertainties are required in the following equations for QMF(X,Y,Z), because the limits include uncertainties.
  ** BQNOM (X,Y,Z), BQDES (X,Y,Z), and BCDES (X,Y,Z) Data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-5 Amendment No. 21, 95, 131, 146, 214
% AFD Margin =  1 -
F(X,Y,Z)BQDES(X,Y,Z)  x 100%QM % f(I) Margin =  1 -
F(X,Y,Z)BCDES(X,Y,Z)  x 100%2QMPage 7 of 10 LA03SR 3.2.1.2 SR 3.2.1.3 LA03SR 3.2.1.2 SR 3.2.1.3 LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
: 2. Find the minimum margin of all locations examined in 4.2.2.2.c.1 above.
AFD min margin = minimum % margin value of all locations examined.
f2(I) OPT min margin = minimum % margin value of all locations examined.
: 3. If the AFD min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.
  (a) Within 2 hours, administratively reduce the negative AFD limit lines at each power level by:          Reduced AFD Limit = (AFDLimit from COLR) + absolute value of (NSLOPE AFD* % x AFD min margin of 4.2.2.2.c.2)
  (b) Within 2 hours, administratively reduce the positive AFD limit lines at each power level by:
Reduced AFD Limit = (AFDLimit from COLR)
-absolute value of (PSLOPE AFD* % X AFD min margin)
: 4. If the f2(I) min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.
          (a) Within 48 hours, reduce the OPT negative f 2(I) breakpoint limit by:
Reduced OPT negative f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) + absolute value of
* NSLOPEAFD and PSLOPE AFD are the amount of AFD adjustment required to compensate for each 1%
that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14.
  ** 22f(I)f(I)NSLOPE and PSLOPE are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-6 Amendment No. 21, 95, 131, 146,  206, 214 (NSLOPE % x f(I)  margin) 2**f(I)2min  Page 8 of 10 LA03M05ACTION B REQUIRED ACTION B.2 REQUIRED ACTION B.1 REQUIRED ACTION C.2 ACTION C REQUIRED ACTION B.1/B.2 REQUIRED ACTION C.1/C.2 M05LA03LA03LA03LA03LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
    (b) Within 48 hours, reduce the OPT positive f 2(I) breakpoint limit by:
Reduced OPT positive f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) absolute value of (PSLOPE** % x f(I)  margin) 2f(I)2min     
: d. Measuring QMF(X,Y,Z) according to the following schedule:
: 1. Upon achieving equilibrium conditions after exceeding by 10 percent or more of RATED THERMAL POWER, the THERMAL POWER at which F Q(X,Y,Z) was last determined,***
or        2. At least once per 31 Effective Full Power Days, whichever occurs first.
: e. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding Z),Y,BQNOM(X,  Z)Y,(X,FMQ either of the following actions specified shall be taken.     
: 1. QMF(X,Y,Z) shall be increased over that specified in 4.2.2.2.a by the appropriate factor specified in the COLR, and 4.2.2.2.c repeated, or        2. QMF(X,Y,Z)shall be evaluated according to 4.2.2.2 at or before the time when the margin is projected to result in one of the actions specified in 4.2.2.2.c.3 or 4.2.2.2.c.4.
4.2.2.3  When FQ(X,Y,Z) is measured for reasons other than meeting the requirements of Specification 4.2.2.2 an overall measured FQ(X,Y,Z) shall be obtained from a power distribution map, increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR according to Specification 3.2.2.
      ** 2f(I)NSLOPE and 2f(I)PSLOPE are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14.
  *** During power escalation at the beginning of each cycle, power level may be increase d until a power level for extended operation has been achieved and power distribution map obtained.
April 21, 1997 SEQUOYAH - UNIT 2    3/4 2-6a            Amendment No. 21, 95, 131, 214 Page 9 of 10 SR Note LA04In accordance with the Surveillance Frequency Control Program andM08thereafter M06SR 3.2.1.1 SR 3.2.1.2 SR 3.2.1.3 LA03LA02REQUIRED ACTION C.1 M08REQUIRED ACTION C.1/C.2 LA03M04SR 3.2.1.1 SR 3.2.1.2 / SR 3.2.1.3 NOTE b. SR 3.2.1.2 /  SR 3.2.1.3 NOTE a. SR 3.2.1.2/SR 3.2.1.3 NOTE M09INSERT 4 Once within 12 hours after M07A02)Z,Y,X(FCQINSERT 3 Not required to be performed until 12 hours after an equilibrium can be 3.2.1 Insert Page 3/4 2-6a CTS (Page 9 of 10)
INSERT 3 Once after each refueling prior to THERMAL POWER exceeding 75% RTP
INSERT 4  Once after each refueling prior to THERMAL POWER exceeding 75% RTP
AND Once within 12 hours after achieving equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which  )Z,Y,X(FCQ was last verified AND  At least once per 31 Effective Full Power Days
DOC M09 DOC M06 LA04In accordance with the Surveillance Frequency Control Program A01ITS ITS 3.2.1
This page intentionally deleted.
March 30, 1992 SEQUOYAH - UNIT 2    3/4 2-7            Amendment No. 131, 146 Page 10 of 10 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 1 of 9 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 4.2.2.2 evaluates )Z,Y,X(FMQto determine if F Q(X,Y,Z) is within the limits.
CTS 4.2.2.3 evaluates F Q(X,Y,Z) for reasons other than meeting the requirements of CTS 4.2.2.2 and requires the overall measured F Q(X,Y,Z) be obtained from a distribution flux map and increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR. ITS 3.2.1 ACTION A and SR 3.2.1.1 use )Z,Y,X(FCQto represent the overall measured F Q(X,Y,Z) adjusted for measurement uncertainty and manufacturing tolerances. This changes the CTS by adding a new term,)Z,Y,X(FCQ which reflects the requirements in CTS 4.2.2.3 for evaluating the steady state limit of F Q(X,Y,Z) specified in the COLR.
BAW-10163PA, "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989, requires that F Q(X,Y,Z) is compared against three limits: (1) steady state limit, (F QRTP / P)
* K(Z), (2) limiting condition LOCA limit, BQDES(X,Y,Z), and (3) Limiting condition centerline fuel melt limit, BCDES(X,Y,Z). BAW-10163PA further states that the overall measured FQ(X,Y,Z) must be adjusted for uncertainty prior to comparison to the steady state limit.
The CTS 3.2.2 Surveillance Requirements address both the steady state and the limiting conditions. CTS 4.2.2.2, in part evaluates)Z,Y,X(FMQ for both  BQDES(X,Y,Z) and BCDES(X,Y,Z) to ensure the F Q(X,Y,Z) limit is met at limiting conditions. Thus if BQDES(X,Y,Z) and BCDES(X,Y,Z) are met, the steady state limit is met  These verifications are reflected in ITS SR 3.2.1.2 and SR 3.2.1.3.
CTS 4.2.2.3 addresses evaluation of the steady state limit directly using the overall measured F Q(X,Y,Z) adjusted by the two penalty factors,)Z,Y,X(FCQ. ITS 3.2.1 uses )Z,Y,X(FCQthroughout the Specification to refer to the steady state limit. This change is designated as administrative because it does not result in technical changes to the CTS.
MORE RESTRICTIVE CHANGES M01 CTS 3.2.2 ACTION c states that with F Q(X,Y,Z) exceeding its limit "Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 2 of 9 POWER above the reduced limit required by Action a. and b., above; THERMAL POWER may then be increased provided F Q(X,Y,Z) is demonstrated through incore flux mapping to be within its limits."  However, under CTS 3.0.2, the FQ(X,Y,Z) measurement does not have to be completed, if compliance with the LCO is restored. ITS 3.2.1 ACTION A contains a Note which states, "Required Action A.5 must be completed whenever this Condition is entered."  ITS Required Action A.5 requires performance of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 prior to increasing THERMAL POWER above the limit of Required Action A.1. This changes the CTS by requiring )Z,Y,X(FCQverification to be made even if )Z,Y,X(FCQis restored to within its limit.
The purpose of CTS 3.2.2 ACTION c is to ensure that when F Q(X,Y,Z) has exceeded the limit, compensatory measures are commenced to restore core power distribution to within the limits prior to increasing THERMAL POWER. This change is acceptable, because it establishes appropriate compensatory measurements for violation of the F Q(X,Y,Z) limit. As power is reduced under ITS Required Action A.1, the margin to the F Q(X,Y,Z) limit increases. Therefore, compliance with the LCO could be restored during the power reduction. Verifying that the limit is met as power is increased ensures that the limit continues to be met and does not remain unmeasured for up to 31 EFPD. This change is designated as a more restrictive change, because it imposes requirements in addition to those in the CTS.
M02 CTS 3.2.2 ACTION states in part that when F Q(X,Y,Z) has exceeded the limit, to (1) Reduce THERMAL POWER at least 1% for each 1% F Q(X,Y,Z) exceeds the limit within 15 minutes, (2) Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours, (3) Reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours, (4) Reduce the Overpower Delta T Trip Setpoints (value of K
: 4) at least 1% (in T span) for each 1% that F Q(X,Y,Z) exceeds the limit specified in the COLR within the next 48 hours, (5) Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced limit required by Action a. and b., above; THERMAL POWER may then be increased provided F Q(X,Y,Z) is demonstrated through incore mapping to be within its limits. ITS 3.2.1 has similar Required Actions and Completion Times with the added requirement to ensure the times are met after each )Z,Y,X(FCQdetermination. This changes the CTS by requiring the Required Actions to be re-performed within a specific Completion Time after each flux map determination.
The purpose of the CTS 3.2.2 ACTIONs is to ensure that when F Q(X,Y,Z) has exceeded the limit, compensatory measures are commenced to restore core power distribution to within the limits assumed in the safety analysis. This change is acceptable because it ensures that the Required Actions for )Z,Y,X(FCQ not within limits will be re-performed after each )Z,Y,X(FCQdetermination within the prescribed Completion Time. When )Z,Y,X(FCQ is not met, the margin to the limit prescribes the amount of power reduction and setpoint reduction to be performed. Therefore, each time flux mapping is performed, the determination of margin to the limit will determine if additional power reduction or additional DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 3 of 9 setpoint reduction is required. This change is designated as more restrictive, because it applies new Completion Time requirements which do not exist in the CTS.
M03 CTS 3.2.2 does not contain an Action to follow, if the provided Actions cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour to initiate a shutdown and to be in HOT STANDBY within 7 hours. ITS 3.2.1 ACTION D, states that the plant must be in MODE 2 within 6 hours, if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shutdown and, consequently, allowing one hour less for the unit to be in MODE 2.
This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODE 1. Requiring a shutdown to MODE 2 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shutdown is not needed, because the operators have had time to prepare for the shutdown while attempting to follow the Required Actions and associated Completion Times. This change is designated as more restrictive because it allows less time to shut down than does the CTS.
M04 CTS 4.2.2.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. CTS 4.2.2.2.d.1 Note *** states that during power escalation at the beginning of each cycle, power level may be increased until a power level for extended operation has been achieved and power distribution map obtained. ITS 3.2.1 has a similar note for the beginning of each cycle, however, there is no specific allowance for changing MODES at any other time with ITS LCO 3.2.1 not met. ITS LCO 3.0.4 requires, in part, that when an LCO is not met, entry into a MODE or other specified condition in the applicability shall only be made: If part a. or part b. or part c. is met. Part c allows, when an allowance is stated in the individual value, parameter or other specification. ITS 3.2.1 Surveillance Requirements Note will provide an allowance whereby, Surveillance performance is not required until 12 hours after an equilibrium power level has been achieved, at which a power distribution map can be obtained. This changes CTS by allowing entry into the MODE of Applicability by only deferring the performance of the Surveillance Requirements instead of deferring compliance with the LCO.
The purpose of CTS 4.2.2.1 is to provide an allowance for entering the next higher MODE of applicability when any Surveillance is not met. This change is acceptable because ITS provides an allowance to enter the MODE of Applicability at any time LCO 3.2.1 is not met solely based on Surveillance performance. SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 require using the incore detector system to provide the necessary data to create a power distribution map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level (~40%-50%). The surveillances cannot be performed in MODE 2. This change is designated as more restrictive because the CTS 4.0.4 MODE DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 4 of 9 change allowance with the LCO not met is now limited to the performance of the SRs and does not include the allowance to change MODES for non-compliance with the acceptance criteria.
M05 CTS 3.2.2 provides two acceptable alternatives for the AFD min margin and f 2(I) min margin not met. CTS 4.2.2.2.c.3 states, "If the AFD min margin in 4.2.2.2.c.2 above is < 0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed." CTS 4.2.2.2.c.4 states, "If the f 2(I) min margin in 4.2.2.2.c.2 above is < 0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed." CTS 4.2.2.2.c.3.a and CTS 4.2.2.2.c.3.b have been replaced by ITS 3.2.1 Required Actions B.1 and B.2. Similarly, CTS 4.2.2.2.c.4.a and 4.2.2.2.c.4.b have been replaced with ITS 3.2.1 Required Actions C.1 and C.2. However, in both cases the option for, "the action statements for 3.2.2 shall be followed" has not been retained. This changes the CTS by removing the option to follow the action statement of CTS 3.2.2 for either
min margin (AFD or f 2(I)) not met.
The purpose of CTS 4.2.2.2.c.3 and CTS 4.2.2.2.c.4 is to provide acceptable alternatives for the required compensatory actions when either AFD min margin or f2(I) min margin is not met. The CTS surveillance requirements for either AFD min margin or f 2(I) min margin not met require either the administrative reduction in their respective setpoints or the option of entering the actions of LCO 3.2.2. The CTS Actions for 3.2.2, F Q(X,Y,Z) exceeding the limits, require in part the reduction of THERMAL POWER, reduction of AFD limit lines, and reduction
f2(I) breakpoint limits. ITS 3.2.1 has removed this option, but retains the requirement for administrative reduction in AFD limits, ITS CONDITION B, or
f2(I) breakpoint limits, ITS CONDITION C. If the ITS Required Actions to administratively reduce the respective setpoints is not performed within the allowed Completion Time, Condition D will be entered requiring the Unit to be placed in MODE 2. This change is designated as more restrictive because an acceptable alternative Required Action available in CTS is being removed.
M06 CTS 4.2.2.2.d requires F Q(X,Y,Z) to be determined to be within its limit upon achieving equilibrium conditions after exceeding by 10 percent or more of RTP, the THERMAL POWER at which F Q(X,Y,Z) was last determined, or at least once per 31 EFPD, whichever occurs first. ITS SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.1.3 collectively verify that F Q(X,Y,Z) is within its limit after each refueling prior to THERMAL POWER exceeding 75% RTP, once within 12 hours after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the THERMAL POWER at which),,(ZYXFCQand)Z,Y,X(FMQwas last verified, and in accordance with the Surveillance Frequency Control Program. This changes the CTS by adding a new Frequency (Once after each refueling prior to THERMAL POWER exceeding 75% RTP). The replacement of the words "whichever occurs first" with the word "thereafter" to the Frequency is discussed in DOC M08. Moving the "31 EFPD thereafter" Frequency to the Surveillance Frequency Control Program is discussed in DOC LA04. The addition of "once within 12 hours" is discussed in DOC M07.
DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 5 of 9  The purpose of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 is to verify that F Q(X,Y,Z) is  within the limits assumed in the safety analysis. This change is acceptable, because adopting the new Frequency of confirming ),,(ZYXFCQand)Z,Y,X(FMQare within the limits prior to exceeding 75% RTP following each core reload, will ensure that some determination of ),,(ZYXFCQand)Z,Y,X(FMQ is made at a lower power level at which adequate margin is available, before going to 100% RTP. This change is designated as more restrictive, because it applies new requirements which do not exist in the CTS.
M07 CTS 4.2.2.2.d requires F Q(X,Y,Z) to be determined to be within its limit upon achieving equilibrium conditions after exceeding by 10 percent or more of RTP, the THERMAL POWER at which F Q(X,Y,Z) was last determined, or at least once per 31 EFPD, whichever occurs first. ITS SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.1.3 collectively verify that F Q(X,Y,Z) is within its limit after each refueling prior to THERMAL POWER exceeding 75% RTP, once within 12 hours after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the THERMAL POWER at which F Q(X,Y,Z) was last verified, and in accordance with the Surveillance Frequency Control Program. This changes the CTS by modifying the existing Frequency (Upon achieving equilibrium conditions-) by adding a specific time element (Once within 12 hours after achieving equilibrium conditions) which limits the time duration allowed for completing a single performance after a 10% RTP change . The replacement of the words "whichever occurs first" with the word "thereafter" to the Frequency is discussed in DOC M08. The relocation of the "31 EFPD thereafter" Frequency to the
Surveillance Frequency Control Program is discussed in DOC LA04. The addition of new Frequency (Once after each refueling prior to THERMAL POWER exceeding 75% RTP) is discussed in DOC M06.
The purpose of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 is to verify that F Q(X,Y,Z) is  within the limits assumed in the safety analysis. This change is acceptable, because modifying the existing frequency by adding a specific time element completing a single performance after a 10% RTP change is made ensures adequate margin is available, before going to a higher power level. This change is designated as more restrictive, because it applies new requirements which do not exist in the CTS.
M08 CTS 4.2.2.2.d.1 Surveillance states "required to be performed upon achieving equilibrium conditions after exceeding by 10 percent or more of RATED THERMAL POWER, the THERMAL POWER at which F Q(X,Y,Z) was last determined, or at least once per 31 EFPD, whichever occurs first." ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 are similar, but the logical connector between the Frequencies is an "AND" not an "or". Additionally, the ITS 31 EFPD Frequency is qualified with "thereafter". This changes the CTS by (1) removing the phrase, "whichever occurs first" and replacing it with "thereafter" and (2) changing the CTS logical connector from "or" to "AND". The purpose of CTS 4.2.2.2 is to establish both when and how often )Z,Y,X(FMQis measured. The intent of the CTS Frequency logical connector "or" does not provide an exclusion to perform either the situational performance or the DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 6 of 9 repetitive performance of the test, because both are continuously applicable when )Z,Y,X(FMQis measured. Additionally, the CTS Frequency describes "when" the first performance is required (i.e. whichever occurs first) based on plant conditions. This change is acceptable because the ITS use of "AND
" will ensure both the situational and periodic performances are continuously applicable. This change is designated more restrictive because the Surveillance Requirements will be required to be performed more frequently than is required in CTS.
M09 CTS 4.2.2.3 states that when F Q(X,Y,Z) is measured for reasons other than meeting the requirements of Specification 4.2.2.2 an overall measured F Q(X,Y,Z) shall be obtained from a power distribution map, increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR according to Specification 3.2.2. Proposed ITS SR 3.2.1.1, verifies )Z,Y,X(FCQis within the steady state limits, (1) Once after each refueling prior to THERMAL POWER exceeding 75% RTP, and (2) Once within 12 hours after achieving equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which  )Z,Y,X(FCQwas last verified, and (3) In accordance with the Surveillance Frequency Control Program. This changes the CTS from a 4.2.2.3 measurement of F Q(X,Y,Z) to be within limits on a situational Frequency basis to the ITS Frequency of (1) Once after each refueling prior to THERMAL POWER exceeding 75% RTP, and (2) Once within 12 hours after achieving equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which  )Z,Y,X(FCQwas last verified, and (3) In accordance with the Surveillance Frequency Control Program. (The relocation of "31 EFPD, thereafter to the Surveillance Frequency Control program" is discussed in DOC LA04 (Refer to DOC A02 for the discussion of the addition of a new term describing the steady state limit,)Z,Y,X(FCQ). The purpose of CTS 4.2.2.3 is to evaluate F Q(X,Y,Z) during those situational conditions where core power distribution limits may exceed limits assumed in the safety analysis. BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989 requires the measured F Q(X,Y,Z) to be compared against the steady state limit (ITS SR 3.2.1.1) and the two transient limits BQDES(X,Y,Z)(ITS SR 3.2.1.2) and BCDES(X,Y,Z)(ITS SR 3.2.1.3). ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 will be performed at the same Frequencies. This change is designated as more restrictive because the situational testing Frequency of CTS 4.2.2.3 is being replaced with two new situational Frequencies and a periodic performance, once every 31 EFPD.
RELOCATED SPECIFICATIONS
None DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 7 of 9 REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.2 ACTION b requires within 48 hours when FQ(X,Y,Z) is not within limits to reduce the Overpower Delta T Trip setpoints (value of K
: 4) at least 1% (in T span) for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR. ITS LCO 3.2.1 Required Action A.3 requires within 48 hours of discovery that )Z,Y,X(FCQis not within limits, to reduce Overpower T trip setpoints at least 1% for each 1% that )Z,Y,X(FCQ exceeds the limit. This changes the CTS by moving the specific information regarding the terms, "value of K4" and "in T span," to the COLR.
The removal of these details for performing actions from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements to reduce Overpower T trip setpoints at least 1% for each 1% that )Z,Y,X(FCQexceeds the limit. Also, this change is acceptable because the removed information will be adequately controlled in the COLR requirements provided in ITS 5.6.5, "Core Operating Limits Report."  ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as transient analysis limits and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 3.2.2 ACTION c requires F Q(X,Y,Z) to be determined to be within its limit through incore mapping. CTS 4.2.2.3 requires
FQ(X,Y,Z) to be determined to be within its limit by obtaining a power distribution map and applying manufacturing tolerances and measurement uncertainty factors before comparing the results to the F Q(X,Y,Z) limit specified in the COLR. ITS 3.2.1 Required Action A.5 and ITS SR 3.2.1.1 require verification that )Z,Y,X(FCQ is within its limit. This changes the CTS by moving the manner in which the F Q(X,Y,Z) determination is performed to the Bases.
The removal of these details for performing actions from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to determine FQ(X,Y,Z) is within its limit. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 8 of 9 LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.2.2, 4.2.2.2.a, 4.2.2.2.b, 4.2.2.2.*, 4.2.2.2.**, 4.2.2.2.c.1, 4.2.2.2.c.2, 4.2.2.2.c.3.a, 4.2.2.2.c.3.b, 4.2.2.2.c.4.a, 4.2.2.2.c.4.b, 4.2.2.2.d,  and 4.2.2.3 provide details for evaluating F MQ(X,Y,Z) to determine if FQ(X,Y,Z) is within limits. ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 collectively verify that F Q(X,Y,Z) (as discussed in DOC A4) is within limits specified in the COLR. This changes the CTS by moving the details for evaluating F MQ(X,Y,Z) to determine if F Q(X,Y,Z) is within limits to the ITS Bases.
The removal of these details from the Technical Specifications and their relocation into the ITS Bases is acceptable, because the procedural steps and further details for making a determination that F Q(X,Y,Z) is within its limits is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS Surveillance Requirement to verify
FQ(X,Y,Z) is within its limits will more closely align with the LCO requirement for FQ(X,Y,Z) to be within the limits specified in the COLR. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA04 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program)  CTS 4.2.2.2 requires, in part, a determination that F Q(X,Y,Z) is within its limits at least once per 31 EFPD. ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 require a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."  This changes the CTS by moving the specified Frequencies for this SR and associated Bases to the Surveillance Frequency Control Program.
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 9 of 9 LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.2 ACTION a.2 states, in part, that when F Q(X,Y,Z) exceeds its limit, reduce the Power Range Neutron Flux - High Trip setpoints within the next 4 hours. ITS 3.2.1 Required Actions A.4 states with )Z,Y,X(FCQ not within limit, reduce the Power Range Neutron Flux - High Trip setpoints by  1% for each 1% )Z,Y,X(FCQ exceeds the limit. The ITS 3.2.1 Required Action A.4 Completion Time is "within 72 hours after each )Z,Y,X(FCQdetermination." This changes the CTS by increasing the time allowed to reduce the trip setpoints.
The purpose of CTS 3.2.2 ACTION a.2 is to lower the Power Range Neutron Flux - High Trip setpoints, which ensures continued operation is at an acceptably low power level with an adequate DNBR margin and avoids violating the )Z,Y,X(FCQ limit. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced, and considers the low probability of a DBA occurring during the allowed Completion Time. The revised
Completion Time allows the Power Range Neutron Flux - High Trip setpoints to be reduced in a controlled manner without challenging operators, technicians, or plant systems. Following a significant power reduction, a time period of 24 hours is allowed to reestablish steady state xenon concentration and power distribution and to take and analyze a flux map. If it is determined that )Z,Y,X(FCQis still not within its limit, reducing the Power Range Neutron Flux - High Trip Setpoints can be accomplished within a few hours. Furthermore, setpoint changes should only be required for extended operation in this condition, because of the risk of a plant trip during the adjustment. This change is designated as less restrictive, because additional time is allowed to lower the Power Range Neutron Flux - High Trip setpoints than was allowed in the CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-1 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 1223.2  POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)
LCO  3.2.1 B FQ(Z), as approximated by )Z(FCQ and )Z(FWQ, shall be within the limits specified in the COLR.
APPLICABILITY: MODE 1.
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME
A. ------------NOTE------------
Required Action A.
4 shall be completed whenever this Condition is entered.  ---------------------------------
)Z(FCQ not within limit.
A.1 Reduce THERMAL POWER  1% RTP for each 1%  )Z(FCQ exceeds limit. AND  A.2 Reduce Power Range Neutron Flux - High trip
setpoints  1% for each 1% )Z(FCQ exceeds limit.
AND  A.3 Reduce Overpower T trip setpoints  1% for each 1%  )Z(FCQ exceeds limit.
AND  A.4 Perform SR 3.2.1.1 and  SR 3.2.1.
: 2. 15 minutes after each )Z(FCQ determination
72 hours after each )Z(FCQ determination
72 hours after each )Z(FCQ determination
Prior to increasing THERMAL POWER
above the limit of Required Action A.1 X,Y,Z 22X,Y,Z 3.2.2 Applicabilit y ACTION a DOC L01 ACTION a.2 DOC M02 ACTION b DOC M02 ACTION c DOC M02 ),,(ZYXFCQ 111411DOC M01 4548 INSERT 1 the steady state 5 ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ, SR 3.2.1.2 3DOC M02 33333 3.2.1 Insert Page 3.2.1-1 CTS INSERT 1  CONDITION REQUIRED ACTION COMPLETION TIME AND  A.2 Reduce, by administrative means, AFD limits  1% for each 1% )Z,Y,X(FCQ exceeds limit.
2 hours after each  )Z,Y,X(FCQ determination 3ACTION a.1 DOC M02 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-2 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. ------------
NOTE------------
Required Action B.4 shall be completed whenever this Condition is entered.
  ---------------------------------
  )Z(FWQ not within limits.
B.1 Reduce AFD limits  1% for each 1%  )Z(FWQ 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. 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. 4 hours 72 hours   
72 hours   
Prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits
C. Required Action and associated Completion Time not met.
C.1 Be in MODE 2.
6 hours    4D D DOC M03 INSERT 2 3.2.1 Insert Page 3.2.1-2 CTS INSERT 2  CONDITION REQUIRED ACTION COMPLETION TIME B. AFD min margin < 0
B.1 Reduce, by administrative means, positive AFD limit lines for each power level by PSLOPE AFD for each 1%
FQ(X,Y,Z) exceeds limit.
AND  B.2 Reduce, by administrative means, negative AFD limit lines for each power level by NSLOPE AFD for each 1%
FQ(X,Y,Z) exceeds limit.
2 hours 
2 hours C. f2(I) min margin < 0
C.1 Reduce Overpower T positive f 2(I) breakpoint limit by PSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.
AND  C.2 Reduce Overpower T negative f 2(I) breakpoint limit by NSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.
48 hours
48 hours
44.2.2.2.c.3.b Note*4.2.2.2.c.3.a Note
* 4.2.2.2.c.4.b Note ** 4.2.2.2.c.4.a Note ** 4.2.2.2.c.3 4.2.2.2.c.3 4.2.2.2.c.4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-3 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE----------------------------------------------------------- During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.
-------------------------------------------------------------------------------------------------------------------------------
SURVEILLANCE FREQUENCY
SR  3.2.1.1 Verify )Z(FCQ is within limit.
Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND  Once within
[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z(FCQ was last verified
AND 
[ 31 EFPD thereafter OR In accordance with the Surveillance
Frequency Control Program
]  4.2.2.2 Note *** 4.2.2.2 4.2.2.3 
DOC M06 DOC M09 DOC A02 117884.2.2.2.d.2 4.2.2.2.d.1 DOC M07 the steady state),,(ZYXFCQ),,(ZYXFCQ4.2.2.1 DOC M04 5can be5INSERT 3 6Not required to be performed until 12 hours after 3.2.1 Insert Page 3.2.1-3 CTS INSERT 3  -----------------------------------------NOTE------------------------------------ Not required to be performed if SR 3.2.1.2 and SR 3.2.1.3 are met. --------------------------------------------------------------------------------------
64.2.2.2 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-4 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122SURVEILLANCE REQUIREMENTS  (continued)
SURVEILLANCE FREQUENCY SR  3.2.1.2
-------------------------------
NOTE------------------------------
If  measurements indicate that the
maximum over z [ )Z(FCQ / K(Z) ]    has increased since the previous evaluation of )Z(FCQ: 
: a. Increase )Z(FWQ by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR and reverify )Z(FWQ 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
[)Z(FCQ / K(Z) ]      has not increased.
    ---------------------------------------------------------------------
Verify )Z(FWQ is within limit.
Once after each refueling prior to THERMAL POWER exceed
-ing 75% RTP AND  Once within
[12] hours after achieving equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which )Z(FWQ was last verified AND  4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-5 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122SURVEILLANCE REQUIREMENTS  (continued)
SURVEILLANCE FREQUENCY
[ 31 EFPD thereafter OR  In accordance with the Surveillance Frequency Control Program ]
4INSERT 4 4
3.2.1 Insert Page 3.2.1-5a CTS INSERT 4  SURVEILLANCE FREQUENCY SR  3.2.1.2 -------------------------------NOTE------------------------------ If two measurements extrapolated to 31 EFPD  beyond the most recent measurement yield:
  )Z,Y,X(FMQ > BQNOM(X,Y,Z)    a. Increase  )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify      AFD min margin > 0; or
: b. Repeat SR 3.2.1.2 prior to the time at which the projected AFD min margin will be < 0.    ---------------------------------------------------------------------
Verify AFD min margin > 0.
Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND  Once within 12 hours after
achieving
equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which  )Z,Y,X(FMQ was last verified AND    44.2.2.2.e 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.c.1 DOC M06  4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5b CTS INSERT 4 (continued)
SURVEILLANCE FREQUENCY
[ 31 EFPD thereafter]
OR  In accordance
with the Surveillance Frequency
Control Program
]  4.2.2.2.d.2 4
3.2.1 Insert Page 3.2.1-5c CTS INSERT 4 (continued)
SURVEILLANCE FREQUENCY SR  3.2.1.3 -------------------------------NOTE------------------------------
If  two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:
  )Z,Y,X(FMQ > BQNOM(X,Y,Z)
: a. Increase  )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify f2(I) min margin > 0; or
: b. Repeat SR 3.2.1.3 prior to the time at which the projected f 2(I) min margin will be < 0.    ---------------------------------------------------------------------
Verify f 2(I) min margin > 0.
Once after each
refueling prior to THERMAL POWER exceeding
75% RTP
AND Once within 12 hours after
achieving
equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which  )Z,Y,X(FMQ was last verified
AND    4 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.e 4.2.2.2.c.1 DOC M06 4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5d CTS INSERT 4 (continued)
SURVEILLANCE FREQUENCY
    [ 31 EFPD thereafter OR  In accordance with the
Surveillance
Frequency
Control Program
] 
4.2.2.2.d.2 4
FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-1 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 1223.2  POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)
LCO  3.2.1 B FQ(Z), as approximated by )Z(FCQ and )Z(FWQ, shall be within the limits specified in the COLR.
APPLICABILITY: MODE 1.
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME
A. ------------NOTE------------
Required Action A.
4 shall be completed whenever this Condition is entered.  ---------------------------------
)Z(FCQ not within limit.
A.1 Reduce THERMAL POWER  1% RTP for each 1%  )Z(FCQ exceeds limit. AND  A.2 Reduce Power Range Neutron Flux - High trip
setpoints  1% for each 1% )Z(FCQ exceeds limit.
AND  A.3 Reduce Overpower T trip setpoints  1% for each 1%  )Z(FCQ exceeds limit.
AND  A.4 Perform SR 3.2.1.1 and  SR 3.2.1.
: 2. 15 minutes after each )Z(FCQ determination
72 hours after each )Z(FCQ determination
72 hours after each )Z(FCQ determination
Prior to increasing THERMAL POWER
above the limit of Required Action A.1 X,Y,Z 22X,Y,Z 3.2.2 Applicabilit y ACTION a DOC L01 ACTION a.2 DOC M02 ACTION b DOC M02 ACTION c DOC M02 ),,(ZYXFCQ 111411DOC M01 4548 INSERT 1 the steady state 5 ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ, SR 3.2.1.2 3DOC M02 33333 3.2.1 Insert Page 3.2.1-1 CTS INSERT 1  CONDITION REQUIRED ACTION COMPLETION TIME AND  A.2 Reduce, by administrative means, AFD limits  1% for each 1% )Z,Y,X(FCQ exceeds limit.
2 hours after each  )Z,Y,X(FCQ determination 3ACTION a.1 DOC M02 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-2 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. ------------
NOTE------------
Required Action B.4 shall be completed whenever this Condition is entered.
  ---------------------------------
  )Z(FWQ not within limits.
B.1 Reduce AFD limits  1% for each 1%  )Z(FWQ 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. 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. 4 hours 72 hours   
72 hours   
Prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits
C. Required Action and associated Completion Time not met.
C.1 Be in MODE 2.
6 hours    4D D DOC M03 INSERT 2 3.2.1 Insert Page 3.2.1-2 CTS INSERT 2  CONDITION REQUIRED ACTION COMPLETION TIME B. AFD min margin < 0
B.1 Reduce, by administrative means, positive AFD limit lines for each power level by PSLOPE AFD for each 1%
FQ(X,Y,Z) exceeds limit.
AND  B.2 Reduce, by administrative means, negative AFD limit lines for each power level by NSLOPE AFD for each 1%
FQ(X,Y,Z) exceeds limit.
2 hours 
2 hours C. f2(I) min margin < 0
C.1 Reduce Overpower T positive f 2(I) breakpoint limit by PSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.
AND  C.2 Reduce Overpower T negative f 2(I) breakpoint limit by NSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.
48 hours
48 hours
44.2.2.2.c.3.b Note*4.2.2.2.c.3.a Note
* 4.2.2.2.c.4.b Note ** 4.2.2.2.c.4.a Note ** 4.2.2.2.c.3 4.2.2.2.c.3 4.2.2.2.c.4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-3 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE----------------------------------------------------------- During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.
-------------------------------------------------------------------------------------------------------------------------------
SURVEILLANCE FREQUENCY
SR  3.2.1.1 Verify )Z(FCQ is within limit.
Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND  Once within
[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z(FCQ was last verified
AND 
[ 31 EFPD thereafter OR In accordance with the Surveillance
Frequency Control Program
]  4.2.2.2 Note *** 4.2.2.2 4.2.2.3 
DOC M06 DOC M09 DOC A02 117884.2.2.2.d.2 4.2.2.2.d.1 DOC M07 the steady state),,(ZYXFCQ),,(ZYXFCQ4.2.2.1 DOC M04 5can be5INSERT 3 6Not required to be performed until 12 hours after 3.2.1 Insert Page 3.2.1-3 CTS INSERT 3  -----------------------------------------NOTE------------------------------------ Not required to be performed if SR 3.2.1.2 and SR 3.2.1.3 are met. --------------------------------------------------------------------------------------
64.2.2.2 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-4 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122SURVEILLANCE REQUIREMENTS  (continued)
SURVEILLANCE FREQUENCY SR  3.2.1.2
-------------------------------
NOTE------------------------------
If  measurements indicate that the
maximum over z [ )Z(FCQ / K(Z) ]    has increased since the previous evaluation of )Z(FCQ: 
: a. Increase )Z(FWQ by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR and reverify )Z(FWQ 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
[)Z(FCQ / K(Z) ]      has not increased.
    ---------------------------------------------------------------------
Verify )Z(FWQ is within limit.
Once after each refueling prior to THERMAL POWER exceed
-ing 75% RTP AND  Once within
[12] hours after achieving equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which )Z(FWQ was last verified AND  4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B  WOG STS 3.2.1B-5 Rev. 4.0,  CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122SURVEILLANCE REQUIREMENTS  (continued)
SURVEILLANCE FREQUENCY
[ 31 EFPD thereafter OR  In accordance with the Surveillance Frequency Control Program ]
4INSERT 4 4
3.2.1 Insert Page 3.2.1-5a CTS INSERT 4  SURVEILLANCE FREQUENCY SR  3.2.1.2 -------------------------------NOTE------------------------------ If two measurements extrapolated to 31 EFPD  beyond the most recent measurement yield:
  )Z,Y,X(FMQ > BQNOM(X,Y,Z)    a. Increase  )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify      AFD min margin > 0; or
: b. Repeat SR 3.2.1.2 prior to the time at which the projected AFD min margin will be < 0.    ---------------------------------------------------------------------
Verify AFD min margin > 0.
Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND  Once within 12 hours after
achieving
equilibrium conditions after exceeding, by  10% RTP, the THERMAL POWER at which  )Z,Y,X(FMQ was last verified AND    44.2.2.2.e 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.c.1 DOC M06  4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5b CTS INSERT 4 (continued)
SURVEILLANCE FREQUENCY
[ 31 EFPD thereafter]
OR  In accordance
with the Surveillance Frequency
Control Program
]  4.2.2.2.d.2 4
3.2.1 Insert Page 3.2.1-5c CTS INSERT 4 (continued)
SURVEILLANCE FREQUENCY SR  3.2.1.3 -------------------------------NOTE------------------------------
If  two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:
  )Z,Y,X(FMQ > BQNOM(X,Y,Z)
: a. Increase  )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify f2(I) min margin > 0; or
: b. Repeat SR 3.2.1.3 prior to the time at which the projected f 2(I) min margin will be < 0.    ---------------------------------------------------------------------
Verify f 2(I) min margin > 0.
Once after each
refueling prior to THERMAL POWER exceeding
75% RTP
AND Once within 12 hours after
achieving
equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which  )Z,Y,X(FMQ was last verified
AND    4 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.e 4.2.2.2.c.1 DOC M06 4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5d CTS INSERT 4 (continued)
SURVEILLANCE FREQUENCY
    [ 31 EFPD thereafter OR  In accordance with the
Surveillance
Frequency
Control Program
] 
4.2.2.2.d.2 4
JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 1 of 2 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 2. The RAOC-W(Z) methodology and the Specification designator "B" are deleted because they are unnecessary. (Only one Heat Flux Hot Channel Factor Specification is used in the SQN ITS)
. This information is provided in NUREG-1431, Rev. 4 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-F XY and CAOC-W(Z) methodology Specifications (ISTS 3.2.1A and 3.2.1C) are not used and are not
shown. 3. ISTS ACTIONS do not contain a requirement to reduce the AFD limits when ACTION A is entered for )Z,Y,X(FCQnot met. CTS 3.2.2 ACTION a.1 requires a reduction of the allowable power at each point along the AFD limit lines to be reduced within 2 hours. This requirement and Completion Time are being added as Required Action A.2.
: 4. ISTS SR 3.2.1.2 and ISTS ACTION B have been deleted. CTS does not include requirements to verify )Z(FWQis within limits, or actions to take if )Z(FWQis not within limits. However, CTS does require the verification that both AFD min
margin is > 0 and f 2(I) min margin  is > 0. Additionally, the CTS specifies the actions to take if the above verifications are not met. These verifications and actions are added to ITS 3.2.1 as SR 3.2.1.2 and SR 3.2.1.3 with the associated
ACTIONS B and C. 
: 5. ISTS 3.2.1 Surveillance Requirements Note allows, 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. CTS 3.2.2 *** Note has a similar allowance. However, in both CTS and ISTS the allowance is for the first power escalation at the beginning of a new core cycle. Additionally, the CTS has SR 4.2.2.1 which provides, The provisions of Specification 4.0.4 are not applicable. This allowance enables SQN to enter the MODE of Applicability with the Surveillance not being met. ISTS does not have a similar allowance in LCO 3.2.1. Therefore, SQN is retaining the allowance to change the MODE of Applicability with the surveillance not being met by modifying the existing Surveillance Note.
: 6. ISTS 3.2.1.1 has been modified by a Note providing an allowance to not perform SR 3.2.1.1 if the Surveillance has been determined to be met based on the performance results of both SR 3.2.1.2 and SR 3.2.1.3. If both the AFD min
margin and the f 2(I) min margin are positive, then the steady state limit is met because these margins represent bounding limiting conditions. 
: 7. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 2 of 2 8. ISTS SR 3.2.1.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-1 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.1B  Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)
BASES BACKGROUND The purpose of the limits on the values of F Q(Z) is to limit the local (i.e., pellet) peak power density. The value of F Q(Z) varies along the axial height (Z) of the core.
FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density
, assuming nominal fuel pellet and fuel rod dimensions. Therefore, F Q(Z) is a measure of the peak fuel pellet power within the reactor core.
During power operation, the global power distribution is limited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO(QPTR)," which are directly and continuously measured process variables. These LCOs, along with LCO 3.1.6, "Control Bank Insertion Limits," maintain the core limits on power distributions on a continuous basis.
FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution.
FQ(Z) is measured periodically using the incore detector system. These measurements are generally taken with the core at or near equilibrium conditions.
Using the measured three dimensional power distributions, it is possible
to derive a measured value for F Q(Z). However, because this value represents an equilibrium condition, it does not include the variations in
the value of F Q(Z) which are present during nonequilibrium situations such as load following or power ascension.
To account for these possible variations, the equilibrium value of F Q(Z) is adjusted as )Z(FWQby an elevation dependent factor that accounts for the calculated worst case transient conditions.
Core monitoring and control under non-equilibrium conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion. X,Y,Z 21X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z 1111and by assembly location, X, Y INSERT 1 8
3.2.1 Insert Page B 3.2.1-1 INSERT 1  "the FQ(X,Y,Z) limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted by pre-calculated factors (MQ(X,Y,Z) and MC(X,Y,Z) respectively) to account for the calculated worst case transient conditions."
1 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-2 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES
APPLICABLE This LCO precludes core power distributions that violate the following SAFETY  fuel design criteria:
ANALYSES  a. During a large break loss of coolant accident (LOCA), the peak cladding temperature must not exceed 2200&deg;F (Ref. 1),
: b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a departure from nucleate boiling (DNB) condition,
: c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
: d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully
withdrawn (Ref. 3).
Limits on F Q(Z) ensure that the value of the initial total peaking factor assumed in the accident analyses remains valid. Other criteria must also be met (e.g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling). However, the peak cladding temperature is typically most limiting.
FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the F Q(Z) limit assumed in safety analyses for other postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents
FQ(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The Heat Flux Hot Channel Factor, F Q(Z), shall be limited by the following relationships:
FQ(Z)  (CFQ / P) K(Z)  for P > 0.5
FQ(Z)  (CFQ / 0.5) K(Z)  for P  0.5 where: CFQ is the F Q(Z) limit at RTP provided in the COLR, K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and
P = THERMAL POWER / RTP 1X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z RTPQFRTPQFFQ (X,Y,Z)X,Y,Z RTPQF 1.8 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-3 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES
LCO  (continued)
For this facility, the actual values of CFQ and K(Z) are given in the COLR;
: however, CFQ is normally a number on the order of [2.32], and K(Z) is a function that looks like the one provided in Figure B 3.2.1B-1.
For Relaxed Axial Offset Control operation, F Q(Z) is approximated by  )Z(FCQ and )Z(FWQ. Thus, both )Z(FCQ and )Z(FWQ must meet the preceding limits on F Q(Z). An )Z(FCQ evaluation requires obtaining an incore flux map in MODE
: 1. From the incore flux map results we obtain the measured value ()Z(FMQ) of FQ(Z). Then,
  )Z(FCQ = )Z(FMQ [1.0815]  where [1.0815] is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.
  )Z(FCQ is an excellent approximation for F Q(Z) when the reactor is at the steady state power at which the incore flux map was taken.
The expression for )Z(FWQ is:  )Z(FWQ= )Z(FCQW(Z)  where W(Z) is a cycle dependent function that accounts for power distribution transients encountered during normal operation. W(
Z) is included in the COLR. The
)Z(FCQ is calculated at equilibrium conditions.
The FQ(Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200&deg;F during either a large or small break LOCA.
This LCO requires operation within the bounds assumed in the safety analyses. Calculations are performed in the core design process to confirm that the core can be controlled in such a manner during operation that it can stay within the LOCA F Q(Z) limits. If )Z(FCQ cannot be maintained within the LCO limits, reduction of the core power is required
and if )Z(FWQcannot be maintained within the LCO limits, reduction of the AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.
Violating the LCO limits for F Q(Z) produces unacceptable consequences if a design basis event occurs while F Q(Z) is outside its specified limits.
RTPQFRTPQF2.62134INSERT 2 X,Y,Z )Z,Y,X(FCQX,Y,Z X,Y,Z 115SQN 3.2.1 Insert Page B 3.2.1-3a INSERT 2  Measured F Q(X,Y,Z) is compared against three limits:
* Steady state limit, (F QRTP / P)
* K(Z),
* Limiting condition LOCA limit, BQDES(X,Y,Z), and
* Limiting condition centerline fuel melt limit, BCDES(X,Y,Z).
FQ(X,Y,Z) is approximated by )Z,Y,X(FCQ for the steady state limit on F Q(X,Y,Z). An  )Z,Y,X(FCQ evaluation requires using the moveable incore detectors to obtain a power distribution map in MODE 1. From the incore flux map results we obtain the measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z). Then, )Z,Y,X(FCQ = overall measured F Q(X,Y,Z)
* 1.05
* 1.03 where, 1.05 is the measurement reliability factor that accounts for flux map measurement uncertainty (Reference 5) and 1.03 is the local engineering heat flux hot channel factor to account for fuel rod manufacturing tolerance (Reference 4).
BQDES(X,Y,Z) and BCDES(X,Y,Z) are cycle dependent design limits to ensure the
FQ(X,Y,Z) limit is met during transients. An evaluation of these limits requires obtaining an incore flux map in MODE 1. From the incore flux map results we obtain the assembly nodal measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z).  )Z,Y,X(FMQ is compared directly to the limits BQDES(X,Y,Z) and BCDES(X,Y,Z). This is appropriate since BQDES(X,Y,Z) and BCDES(X,Y,Z) have been adjusted for uncertainties.
The expression for BQDES(X,Y,Z) is: BQDES(X,Y,Z) = P d(X,Y,Z)
* MQ(X,Y,Z)
* NRF
* F1 / MRF
where:
* BQDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y at axial location Z. BQDES(X,Y,Z) ensures that the LOCA limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
* Pd(X,Y,Z) is the design power distribution for fuel assembly X,Y at axial location Z, including the operational flexibility factor;
* MQ(X,Y,Z) is the minimum available margin ratio for the LOCA limit at assembly X,Y and axial location Z;
* NRF is the nuclear reliability factor;
* F1 is the spacer grid factor;
* MRF is measurement reliability factor.
4 3.2.1 Insert Page B 3.2.1-3b INSERT 2 (continued)
The expression for BCDES(X,Y,Z) is: BCDES(X,Y,Z) = P d(X,Y,Z)
* MC(X,Y,Z)
* NRF
* F1 / MRF
where:
* BCDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y, at axial location Z. BCDES(X,Y,Z) ensures that the centerline fuel melt limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
* MC(X,Y,Z) is the minimum available margin ratio for the centerline fuel melt limit at assembly X,Y and axial location Z; The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:
)Z,Y,X(FMQ  BQNOM(X,Y,Z) where:
* BQNOM(X,Y,Z) is the nominal design peaking factor for assembly X,Y at axial location Z increased by an allowance for the expected deviation between the measured and predicted design power distribution.
The FQ(X,Y,Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200&deg;F during either a large or small break LOCA.
BQNOM (X,Y,Z), BQDES(X,Y,Z), and BCDES(X,Y,Z) Data bases are provided for the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in the COLR.
4 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-4 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES
APPLICABILITY The F Q(Z) limits must be maintained in MODE 1 to prevent core power distributions from exceeding the limits assumed in the safety analyses. 
Applicability in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require a limit on the distribution of
core power.
ACTIONS A.1 Reducing THERMAL POWER by  1% RTP for each 1% by which )Z(FCQ exceeds its limit, maintains an acceptable absolute power density.  )Z(FCQ is )Z(FMQmultiplied by a factor accounting for manufacturing tolerances and measurement uncertainties.  )Z(FMQ is the measured value of FQ(Z). The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of )Z(FCQ and would require power reductions within 15 minutes of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable power level. 
Decreases in )Z(FCQ would allow increasing the maximum allowable power level and increasing power up to this revised limit.
A.2  A reduction of the Power Range Neutron Flux - High trip setpoints by  1% for each 1% by which )Z(FCQ exceeds its limit, 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 in accordance with Required Action A.1. The maximum allowable Power Range Neutron Flux - High trip setpoints initially determined by Required Action A.
2 may be affected by subsequent determinations of )Z(FCQ and would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in )Z(FCQ would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.
X,Y,Z 15)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 5)Z,Y,X(FMQ FQ (X,Y,Z))Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ4 )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQINSERT 3 54 Move to next page after A.3 3.2.1 Insert Page B 3.2.1-4 INSERT 3  A.2  Required Action A.2 requires an administrative reduction of the AFD limits by  1% for each 1% by which )Z,Y,X(FCQ exceeds the steady state limit. The allowed Completion Time of 2 hours, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded. The maximum allowable AFD limits initially determined by Required Action A.2 may be affected by subsequent determinations of )Z,Y,X(FCQ and would require further AFD limit reductions within 2 hours of the )Z,Y,X(FCQdetermination, if necessary to comply with the decreased maximum allowable AFD limits.
Decreases in),,(ZYXFCQwould allow increasing the maximum allowable AFD limits.
5 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-5 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES  ACTIONS  (continued)
A.3 Reduction in the Overpower T trip setpoints (value of K
: 4) by  1% for each 1% by which )Z(FCQ exceeds its limit, 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 in accordance with Required Action A.1. The maximum allowable Overpower T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of )Z(FCQ and would require Overpower T trip setpoint reductions within 72 hours of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable Overpower T trip setpoints. Decreases in )Z(FCQ would allow increasing the maximum allowable Overpower T trip setpoints.
A.4  Verification that )Z(FCQ 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 F Q(Z) that can occur during normal maneuvers, )Z(FWQ, exceeds its specified limits, there exists a potential for )Z(FCQ to become excessively high if a normal operational transient occurs. Reducing the AFD by  1% for each 1% by which )Z(FWQ 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.
51555154848)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ3 , SR 3.2.1.2 INSERT 4 INSERT 6 INSERT 5 in T span5543steady state and transient 55 , SR 3.2.1.2 , SR 3.2.1.2 35 )Z,Y,X(FCQ)Z,Y,X(FCQ 3.2.1 Insert Page B 3.2.1-5a INSERT 4  Since)Z,Y,X(FCQ exceeds the steady state limit, the limiting condition operational limit (BQDES) and the limiting condition Reactor Protection System limit (BCDES) may also be exceeded. By performing SR 3.2.1.2 and SR 3.2.1.3, appropriate actions with respect to reductions in AFD limits and OPT trip setpoints will be performed, ensuring that core conditions during operational and Condition II transients are maintained within the bounds of the safety analysis.
5 3.2.1 Insert Page B 3.2.1-5b INSERT 5  B.1 and B.2 The FQ(X,Y,Z) margin supporting AFD operational limits (AFD margin) during transient operations is based on the relationship between)Z,Y,X(FMQ and the limiting condition operational limit, BQDES (X,Y,Z), as follows:
%AFD margin = %*),,(),,(1001ZYXBQDESZYXFMQ The AFD min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BQDES (X,Y,Z) and calculation of %AFD margin is not required. If the AFD margin is less than zero, then )Z,Y,X(FMQ is greater than BQDES (X,Y,Z) and the AFD limits may not be adequate to prevent exceeding the peaking criteria for a LOCA if a normal operational transient occurs. 
Required Actions B.1 and B.2 require reducing the AFD limit lines as follows. The AFD limit reduction is from the full power AFD limits. The adjusted AFD limits must be used until a new measurement shows that a smaller adjustment can be made to the AFD limits, or that no adjustment is necessary:
APL  = PAFDL - Absolute Value of (PSLOPE AFD * % AFD Margin)
ANL  = NAFDL + Absolute Value of (NSLOPE AFD * % AFD Margin)
where,
* APL is the adjusted positive AFD limit.
* ANL is the adjusted negative AFD limit.
* PAFDL is the positive AFD limit defined in the COLR.
* NAFDL is the negative AFD limit defined in the COLR.
* PSLOPEAFD is the adjustment to the positive AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
* NSLOPEAFD is the adjustment to the negative AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
* % AFD Margin is the most negative margin determined above.
Completing Required Actions B.1 and B.2 within the allowed Completion Time of 2 hours, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded.
54 3.2.1 Insert Page B 3.2.1-5c INSERT 6  C.1 and C.2
The FQ(X,Y,Z) margin supporting the Overpower T f2(I) breakpoints (f 2(I) margin) during transient operations is based on the relationship between  )Z,Y,X(FMQ and the limit, BCDES(X,Y,Z), as follows:
% f2(I) margin = %*),,(),,(1001ZYXBCDESZYXFMQ  The f2(I) min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BCDES(X,Y,Z) and calculation of % f 2(I) margin is not required. If the f 2(I) margin is less than zero, then )Z,Y,X(FMQ is greater than BCDES(X,Y,Z) and there is a potential that the f 2(I) limits are insufficient to preclude centerline fuel melt during certain transients. 
Required Actions C.1 and C.2 require reducing the f 2(I) breakpoint limits as follows. The f 2(I) breakpoint limit reduction is always from the full power f2(I) breakpoint limits. The adjusted f 2(I) breakpoint limits must be used until a new measurement show s that a smaller adjustment can be made to the f 2(I) breakpoint limits, or that no adjustment is necessary.
Posf2(I)Adjusted  = Posf2(I)Limit - Absolute Value of (PSLOPE f2(I) * % f2(I) Margin)
Negf2(I)Adjusted 
= Negf2(I)Limit + Absolute Value of (NSLOPE f2(I) * % f2(I) Margin) where:
* Posf2(I)Adjusted is the adjusted OPT positive f 2(I) breakpoint limit.
* Negf2(I)Adjusted is the adjusted OPT negative f 2(I) breakpoint limit.
* Posf2(I)Limit is the OPT positive f 2(I) breakpoint limit defined in the COLR.
* Negf2(I)Limit is the OPT negative f 2(I) breakpoint limit defined in the COLR.
* PSLOPEf2(I) is the adjustment to the positive OPT f2(I) limit required to compensate for each 1% that  )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
* NSLOPEf2(I) is the adjustment to the negative OPT f2(I) limit required to compensate for each 1% that  )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
* % f2(I) Margin is the most negative margin determined above.
54 3.2.1 Insert Page B 3.2.1-5d INSERT 6 (continued)
Completing Required Actions C.1 and C.2 is a conservative action for protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Completing Required Actions C.1 and C.2 within the allowed Completion Time of 48 hours is sufficient considering the small likelihood of a limiting transient in this time period.
54 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-6 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES ACTIONS  (continued)
The implicit assumption is that if W(
Z) values were recalculated (consistent with the reduced AFD limits), then )Z(FCQ times the recalculated W(Z) values would meet the F Q(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 and B.4.
B.2  A reduction of the Power Range Neutron Flux
-High trip setpoints by  1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.
B.3 Reduction in the Overpower T trip setpoints value of K 4 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 as a result of reducing AFD limits in accordance with Required Action B.1.
B.4  Verification that )Z(FWQ has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.1 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.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 B.1, even when Condition A is exited prior to performing Required Action B.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure F Q(Z) is properly evaluated prior to increasing THERMAL POWER.
5 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-7 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES ACTIONS  (continued)
C.1  If Required Actions A.1 through A.4 or B.1 through B.4 are not met within their associated Completion Times, the plant must be placed in a mode or condition in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours.
This allowed Completion Time is reasonable based on operating experience regarding the amount of time it takes to reach MODE 2 from full power operation in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.
2 are modified by a Note.
The Note applies REQUIREMENTS during the first power ascension after a refueling. It states that THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained. This allowance is modified, however, by one of the Frequency conditions that requires verification that )Z(FCQ and )Z(FWQ are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits.
Because )Z(FCQ and )Z(FWQ could not have previously been measured in this reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of )Z(FCQ and )Z(FWQ are made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of )Z(FCQ and )Z(FWQ following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of )Z(FCQ and )Z(FWQ. The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.
D 551X,Y,Z A.5, B.1, B.2, C.1 or C.2 )Z,Y,X(FCQ)Z,Y,X(FMQ , SR 3.2.1.2 3)Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 12 hours afterSurveillance performance  is not re quired FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-8 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES SURVEILLANCE REQUIREMENTS  (continued)
SR  3.2.1.1 Verification that )Z(FCQ is within its specified limits involves increasing)Z(FMQ to allow for manufacturing tolerance and measurement uncertainties in order to obtain )Z(FCQ. Specifically, )Z(FMQ is the measured value of F Q(Z) obtained from incore flux map results and )Z(FCQ = )Z(FMQ [1.0815] (Ref.
4).  )Z(FCQ is then compared to its specified limits.
The limit with which )Z(FCQ is compared varies inversely with power above 50% RTP and directly with a function called K(Z) provided in the COLR.
Performing this Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the )Z(FCQ limit is met when RTP is achieved, because peaking factors generally decrease as power level is increased.
If THERMAL POWER has been increased by  10% RTP since the last determination of )Z(FCQ, another evaluation of this factor is required
[12] hours after achieving equilibrium conditions at this higher power level (to ensure that )Z(FCQ values are being reduced sufficiently with power increase to stay within the LCO limits).
[ The Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup because such changes are slow and well controlled when the plant is operated in accordance with the Technical Specifications (TS).
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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] 1111267)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQDirect verification 3the overall measured F Q (X,Y,Z)INSERT 7 4
3.2.1 Insert Page B 3.2.1-8 INSERT 7  The surveillance has been modified by a Note providing an allowance to not perform SR 3.2.1.1 if the Surveillance has been determined to be met based on the performance results of both SR 3.2.1.2 and SR 3.2.1.3. If both the AFD min margin and the f 2(I) min margin are positive, then the steady state limit is met because these margins represent bounding limiting conditions.
However, if AFD min margin or f 2(I) min margin is negative then a direct evaluation of the steady state limit is required to satisfy this surveillance requirement.
4 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-9 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES
SURVEILLANCE REQUIREMENTS  (continued)
SR  3.2.1.2
The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, )Z(FCQ, by W(Z) gives the maximum F Q(Z) calculated to occur in normal operation, )Z(FWQ. The limit with which )Z(FWQ 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 30 to 75 core elevations.  )Z(FWQ evaluations are not applicable for the following axial core regions, measured in percent of core height:
: a. Lower core region, from 0 to 15% inclusive and
: b. Upper core region, from 85 to 100% inclusive.
The top and bottom 15% 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 )Z(FWQ is evaluated, an evaluation of the expression below is required to account for any increase to )Z(FMQ that may occur and cause the F Q(Z) limit to be exceeded before the next required FQ(Z) evaluation.
If the two most recent F Q(Z) evaluations show an increase in the expression maximum over z [ )Z(FCQ / K(Z) ], it is required to meet the FQ(Z) limit with the last )Z(FWQ increased by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR (Ref. 5)
and 3.2.1.3 5FQ (X,Y,Z)BQDES (X,Y,Z) and BCDES (X,Y,Z) limits INSERT 10 INSERT 8 INSERT 9 FQ (X,Y,Z))Z,Y,X(FMQ and found to be within the applicable limiting condition limits 244based on future projections 3.2.1 Insert Page B 3.2.1-9a INSERT 8  both assembly and axial location (X,Y,Z), has been included in the cycle specific limits BQDES(X,Y,Z) and BCDES(X,Y,Z) using margin factors MQ(X,Y,Z) and MC(X,Y,Z),
respectively (Reference 5).
INSERT 9  No uncertainties are applied to )Z,Y,X(FMQ because the limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted for uncertainties.
44 3.2.1 Insert Page B 3.2.1-9b INSERT 10 In addition to ensuring via surveillance that the heat flux hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Z,Y,X(FMQ for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an )Z,Y,X(FMQ > BQNOM(X,Y,Z), further consideration is required.
The implications of these extrapolations are considered separately for both the operational and RPS heat flux hot channel factor limits. If the extrapolations of )Z,Y,X(FMQ are unfavorable, additional actions must be taken. These actions are to meet the F Q(X,Y,Z) limit with the last  )Z,Y,X(FMQ increased by the appropriate factor specified in the COLR or to evaluate )Z,Y,X(FMQ prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative requirements prevent F Q(X,Y,Z) from exceeding its limit for any significant period of time without detection using the best available data.
Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.
FQ(X,Y,Z) is verified at power levels  10% RTP above the THERMAL POWER of its last verification within 12 hours after achieving equilibrium conditions to ensure that F Q(X,Y,Z) is within its limit at higher power levels. 4 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-10 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES
SURVEILLANCE REQUIREMENTS  (continued)
-----------------------------------REVIEWER'S NOTE-----------------------------------
WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control and FQ Surveillance Technical Specification," February 1994, or other appropriate plant specific methodology, is to be listed in the COLR description in the Administrative Controls Section 5.0 to address the methodology used to derive this factor.
--------------------------------------------------------------------------------------------------
or to evaluate F Q(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.
Performing the Surveillance in MODE 1 prior to exceeding 75%
RTP ensures that the F Q(Z) limit is met when RTP is achieved, because peaking factors are generally decreased as power level is increased.
FQ(Z) is verified at power levels  10% RTP above the THERMAL POWER of its last verification, [12]
hours after achieving equilibrium conditions to ensure that F Q(Z) is within its limit at higher power levels.
The Surveillance Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup. The Surveillance may be done more frequently if required by the results of F Q(Z) evaluations.
  [ The Frequency of 31 EFPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS, to preclude adverse peaking factors between 31 day surveillances.
OR  The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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]  467 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-11 Rev. 4.0, 1X,Y,Z212Revision XXX SEQUOYAH UNIT 1 BASES REFERENCES 1. 10 CFR 50.46, 1974.
: 2. Regulatory Guide 1.77, Rev. 0, May 1974.
: 3. 10 CFR 50, Appendix A, GDC 26.
: 4. WCAP-7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.
: 5. WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control (and) F Q Surveillance Technical Specification," February 1994.      4BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989.
Enclosure 2, Volume 7, Rev. 0, Page 76 of 249Fq(z)@arzrj B 3'2'1s%g 06\<FT.(.) %* Fo r c216.64633.3 50.0CORE HEIGHTI66.712100re height of 12 feetFigure B 3.2. 1B-1K(Z) , Normalized Fo(Z) as a(page 1 of 1)Function of Core Height+WOG STSB 3.2.1s12Volume 7, Rev. 0,ooDO NOT OPERATE IN THIS AREA(6.0, 1 .0):9, o.g4)(12.0,0.65)
ILLUSIGURE FORRATION ONLY.NOT USE FOROPERATION Enclosure 2,Page 76 of 249 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-1 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.1B  Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)
BASES BACKGROUND The purpose of the limits on the values of F Q(Z) is to limit the local (i.e., pellet) peak power density. The value of F Q(Z) varies along the axial height (Z) of the core.
FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density
, assuming nominal fuel pellet and fuel rod dimensions. Therefore, F Q(Z) is a measure of the peak fuel pellet power within the reactor core.
During power operation, the global power distribution is limited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO(QPTR)," which are directly and continuously measured process variables. These LCOs, along with LCO 3.1.6, "Control Bank Insertion Limits," maintain the core limits on power distributions on a continuous basis.
FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution.
FQ(Z) is measured periodically using the incore detector system. These measurements are generally taken with the core at or near equilibrium conditions.
Using the measured three dimensional power distributions, it is possible
to derive a measured value for F Q(Z). However, because this value represents an equilibrium condition, it does not include the variations in
the value of F Q(Z) which are present during nonequilibrium situations such as load following or power ascension.
To account for these possible variations, the equilibrium value of F Q(Z) is adjusted as )Z(FWQby an elevation dependent factor that accounts for the calculated worst case transient conditions.
Core monitoring and control under non-equilibrium conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion. X,Y,Z 21X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z 1111and by assembly location, X, Y INSERT 1 8
3.2.1 Insert Page B 3.2.1-1 INSERT 1  "the FQ(X,Y,Z) limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted by pre-calculated factors (MQ(X,Y,Z) and MC(X,Y,Z) respectively) to account for the calculated worst case transient conditions."
1 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-2 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES
APPLICABLE This LCO precludes core power distributions that violate the following SAFETY  fuel design criteria:
ANALYSES  a. During a large break loss of coolant accident (LOCA), the peak cladding temperature must not exceed 2200&deg;F (Ref. 1),
: b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a departure from nucleate boiling (DNB) condition,
: c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
: d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully
withdrawn (Ref. 3).
Limits on F Q(Z) ensure that the value of the initial total peaking factor assumed in the accident analyses remains valid. Other criteria must also be met (e.g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling). However, the peak cladding temperature is typically most limiting.
FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the F Q(Z) limit assumed in safety analyses for other postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents
FQ(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The Heat Flux Hot Channel Factor, F Q(Z), shall be limited by the following relationships:
FQ(Z)  (CFQ / P) K(Z)  for P > 0.5
FQ(Z)  (CFQ / 0.5) K(Z)  for P  0.5 where: CFQ is the F Q(Z) limit at RTP provided in the COLR, K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and
P = THERMAL POWER / RTP 1X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z RTPQFRTPQFFQ (X,Y,Z)X,Y,Z RTPQF1.8 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-3 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES
LCO  (continued)
For this facility, the actual values of CFQ and K(Z) are given in the COLR;
: however, CFQ is normally a number on the order of [2.32], and K(Z) is a function that looks like the one provided in Figure B 3.2.1B-1.
For Relaxed Axial Offset Control operation, F Q(Z) is approximated by  )Z(FCQ and )Z(FWQ. Thus, both )Z(FCQ and )Z(FWQ must meet the preceding limits on F Q(Z). An )Z(FCQ evaluation requires obtaining an incore flux map in MODE
: 1. From the incore flux map results we obtain the measured value ()Z(FMQ) of FQ(Z). Then,
  )Z(FCQ = )Z(FMQ [1.0815]  where [1.0815] is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.
  )Z(FCQ is an excellent approximation for F Q(Z) when the reactor is at the steady state power at which the incore flux map was taken.
The expression for )Z(FWQ is:  )Z(FWQ= )Z(FCQW(Z)  where W(Z) is a cycle dependent function that accounts for power distribution transients encountered during normal operation. W(
Z) is included in the COLR. The
)Z(FCQ is calculated at equilibrium conditions.
The FQ(Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200&deg;F during either a large or small break LOCA.
This LCO requires operation within the bounds assumed in the safety analyses. Calculations are performed in the core design process to confirm that the core can be controlled in such a manner during operation that it can stay within the LOCA F Q(Z) limits. If )Z(FCQ cannot be maintained within the LCO limits, reduction of the core power is required
and if )Z(FWQcannot be maintained within the LCO limits, reduction of the AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.
Violating the LCO limits for F Q(Z) produces unacceptable consequences if a design basis event occurs while F Q(Z) is outside its specified limits.
RTPQFRTPQF2.62134INSERT 2 X,Y,Z )Z,Y,X(FCQX,Y,Z X,Y,Z 115SQN 3.2.1 Insert Page B 3.2.1-3a INSERT 2  Measured F Q(X,Y,Z) is compared against three limits:
* Steady state limit, (F QRTP / P)
* K(Z),
* Limiting condition LOCA limit, BQDES(X,Y,Z), and
* Limiting condition centerline fuel melt limit, BCDES(X,Y,Z).
FQ(X,Y,Z) is approximated by )Z,Y,X(FCQ for the steady state limit on F Q(X,Y,Z). An  )Z,Y,X(FCQ evaluation requires using the moveable incore detectors to obtain a power distribution map in MODE 1. From the incore flux map results we obtain the measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z). Then, )Z,Y,X(FCQ = overall measured F Q(X,Y,Z)
* 1.05
* 1.03 where, 1.05 is the measurement reliability factor that accounts for flux map measurement uncertainty (Reference 5) and 1.03 is the local engineering heat flux hot channel factor to account for fuel rod manufacturing tolerance (Reference 4).
BQDES(X,Y,Z) and BCDES(X,Y,Z) are cycle dependent design limits to ensure the
FQ(X,Y,Z) limit is met during transients. An evaluation of these limits requires obtaining an incore flux map in MODE 1. From the incore flux map results we obtain the assembly nodal measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z).  )Z,Y,X(FMQ is compared directly to the limits BQDES(X,Y,Z) and BCDES(X,Y,Z). This is appropriate since BQDES(X,Y,Z) and BCDES(X,Y,Z) have been adjusted for uncertainties.
The expression for BQDES(X,Y,Z) is: BQDES(X,Y,Z) = P d(X,Y,Z)
* MQ(X,Y,Z)
* NRF
* F1 / MRF
where:
* BQDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y at axial location Z. BQDES(X,Y,Z) ensures that the LOCA limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
* Pd(X,Y,Z) is the design power distribution for fuel assembly X,Y at axial location Z, including the operational flexibility factor;
* MQ(X,Y,Z) is the minimum available margin ratio for the LOCA limit at assembly X,Y and axial location Z;
* NRF is the nuclear reliability factor;
* F1 is the spacer grid factor;
* MRF is measurement reliability factor.
4 3.2.1 Insert Page B 3.2.1-3b INSERT 2 (continued)
The expression for BCDES(X,Y,Z) is: BCDES(X,Y,Z) = P d(X,Y,Z)
* MC(X,Y,Z)
* NRF
* F1 / MRF
where:
* BCDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y, at axial location Z. BCDES(X,Y,Z) ensures that the centerline fuel melt limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
* MC(X,Y,Z) is the minimum available margin ratio for the centerline fuel melt limit at assembly X,Y and axial location Z; The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:
)Z,Y,X(FMQ  BQNOM(X,Y,Z) where:
* BQNOM(X,Y,Z) is the nominal design peaking factor for assembly X,Y at axial location Z increased by an allowance for the expected deviation between the measured and predicted design power distribution.
The FQ(X,Y,Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200&deg;F during either a large or small break LOCA.
BQNOM (X,Y,Z), BQDES(X,Y,Z), and BCDES(X,Y,Z) Data bases are provided for the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in the COLR.
4 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-4 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES
APPLICABILITY The F Q(Z) limits must be maintained in MODE 1 to prevent core power distributions from exceeding the limits assumed in the safety analyses. 
Applicability in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require a limit on the distribution of
core power.
ACTIONS A.1 Reducing THERMAL POWER by  1% RTP for each 1% by which )Z(FCQ exceeds its limit, maintains an acceptable absolute power density.  )Z(FCQ is )Z(FMQmultiplied by a factor accounting for manufacturing tolerances and measurement uncertainties.  )Z(FMQ is the measured value of FQ(Z). The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of )Z(FCQ and would require power reductions within 15 minutes of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable power level. 
Decreases in )Z(FCQ would allow increasing the maximum allowable power level and increasing power up to this revised limit.
A.2  A reduction of the Power Range Neutron Flux - High trip setpoints by  1% for each 1% by which )Z(FCQ exceeds its limit, 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 in accordance with Required Action A.1. The maximum allowable Power Range Neutron Flux - High trip setpoints initially determined by Required Action A.
2 may be affected by subsequent determinations of )Z(FCQ and would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in )Z(FCQ would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.
X,Y,Z 15)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 5)Z,Y,X(FMQ FQ (X,Y,Z))Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ4 )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQINSERT 3 54 Move to next page after A.3 3.2.1 Insert Page B 3.2.1-4 INSERT 3  A.2  Required Action A.2 requires an administrative reduction of the AFD limits by  1% for each 1% by which )Z,Y,X(FCQ exceeds the steady state limit. The allowed Completion Time of 2 hours, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded. The maximum allowable AFD limits initially determined by Required Action A.2 may be affected by subsequent determinations of )Z,Y,X(FCQ and would require further AFD limit reductions within 2 hours of the )Z,Y,X(FCQdetermination, if necessary to comply with the decreased maximum allowable AFD limits.
Decreases in),,(ZYXFCQwould allow increasing the maximum allowable AFD limits.
5 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-5 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES  ACTIONS  (continued)
A.3 Reduction in the Overpower T trip setpoints (value of K
: 4) by  1% for each 1% by which )Z(FCQ exceeds its limit, 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 in accordance with Required Action A.1. The maximum allowable Overpower T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of )Z(FCQ and would require Overpower T trip setpoint reductions within 72 hours of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable Overpower T trip setpoints. Decreases in )Z(FCQ would allow increasing the maximum allowable Overpower T trip setpoints.
A.4  Verification that )Z(FCQ 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 F Q(Z) that can occur during normal maneuvers, )Z(FWQ, exceeds its specified limits, there exists a potential for )Z(FCQ to become excessively high if a normal operational transient occurs. Reducing the AFD by  1% for each 1% by which )Z(FWQ 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.
51555154848)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ3 , SR 3.2.1.2 INSERT 4 INSERT 6 INSERT 5 in T span5543steady state and transient 55 , SR 3.2.1.2 , SR 3.2.1.2 35 )Z,Y,X(FCQ)Z,Y,X(FCQ 3.2.1 Insert Page B 3.2.1-5a INSERT 4  Since)Z,Y,X(FCQ exceeds the steady state limit, the limiting condition operational limit (BQDES) and the limiting condition Reactor Protection System limit (BCDES) may also be exceeded. By performing SR 3.2.1.2 and SR 3.2.1.3, appropriate actions with respect to reductions in AFD limits and OPT trip setpoints will be performed, ensuring that core conditions during operational and Condition II transients are maintained within the bounds of the safety analysis.
5 3.2.1 Insert Page B 3.2.1-5b INSERT 5  B.1 and B.2 The FQ(X,Y,Z) margin supporting AFD operational limits (AFD margin) during transient operations is based on the relationship between)Z,Y,X(FMQ and the limiting condition operational limit, BQDES (X,Y,Z), as follows:
%AFD margin = %*),,(),,(1001ZYXBQDESZYXFMQ The AFD min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BQDES (X,Y,Z) and calculation of %AFD margin is not required. If the AFD margin is less than zero, then )Z,Y,X(FMQ is greater than BQDES (X,Y,Z) and the AFD limits may not be adequate to prevent exceeding the peaking criteria for a LOCA if a normal operational transient occurs. 
Required Actions B.1 and B.2 require reducing the AFD limit lines as follows. The AFD limit reduction is from the full power AFD limits. The adjusted AFD limits must be used until a new measurement shows that a smaller adjustment can be made to the AFD limits, or that no adjustment is necessary:
APL  = PAFDL - Absolute Value of (PSLOPE AFD * % AFD Margin)
ANL  = NAFDL + Absolute Value of (NSLOPE AFD * % AFD Margin)
where,
* APL is the adjusted positive AFD limit.
* ANL is the adjusted negative AFD limit.
* PAFDL is the positive AFD limit defined in the COLR.
* NAFDL is the negative AFD limit defined in the COLR.
* PSLOPEAFD is the adjustment to the positive AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
* NSLOPEAFD is the adjustment to the negative AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
* % AFD Margin is the most negative margin determined above.
Completing Required Actions B.1 and B.2 within the allowed Completion Time of 2 hours, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded.
54 3.2.1 Insert Page B 3.2.1-5c INSERT 6  C.1 and C.2
The FQ(X,Y,Z) margin supporting the Overpower T f2(I) breakpoints (f 2(I) margin) during transient operations is based on the relationship between  )Z,Y,X(FMQ and the limit, BCDES(X,Y,Z), as follows:
% f2(I) margin = %*),,(),,(1001ZYXBCDESZYXFMQ  The f2(I) min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BCDES(X,Y,Z) and calculation of % f 2(I) margin is not required. If the f 2(I) margin is less than zero, then )Z,Y,X(FMQ is greater than BCDES(X,Y,Z) and there is a potential that the f 2(I) limits are insufficient to preclude centerline fuel melt during certain transients. 
Required Actions C.1 and C.2 require reducing the f 2(I) breakpoint limits as follows. The f 2(I) breakpoint limit reduction is always from the full power f2(I) breakpoint limits. The adjusted f 2(I) breakpoint limits must be used until a new measurement show s that a smaller adjustment can be made to the f 2(I) breakpoint limits, or that no adjustment is necessary.
Posf2(I)Adjusted  = Posf2(I)Limit - Absolute Value of (PSLOPE f2(I) * % f2(I) Margin)
Negf2(I)Adjusted 
= Negf2(I)Limit + Absolute Value of (NSLOPE f2(I) * % f2(I) Margin) where:
* Posf2(I)Adjusted is the adjusted OPT positive f 2(I) breakpoint limit.
* Negf2(I)Adjusted is the adjusted OPT negative f 2(I) breakpoint limit.
* Posf2(I)Limit is the OPT positive f 2(I) breakpoint limit defined in the COLR.
* Negf2(I)Limit is the OPT negative f 2(I) breakpoint limit defined in the COLR.
* PSLOPEf2(I) is the adjustment to the positive OPT f2(I) limit required to compensate for each 1% that  )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
* NSLOPEf2(I) is the adjustment to the negative OPT f2(I) limit required to compensate for each 1% that  )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
* % f2(I) Margin is the most negative margin determined above.
54 3.2.1 Insert Page B 3.2.1-5d INSERT 6 (continued)
Completing Required Actions C.1 and C.2 is a conservative action for protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Completing Required Actions C.1 and C.2 within the allowed Completion Time of 48 hours is sufficient considering the small likelihood of a limiting transient in this time period.
54 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-6 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES ACTIONS  (continued)
The implicit assumption is that if W(
Z) values were recalculated (consistent with the reduced AFD limits), then )Z(FCQ times the recalculated W(Z) values would meet the F Q(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 and B.4.
B.2  A reduction of the Power Range Neutron Flux
-High trip setpoints by  1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.
B.3 Reduction in the Overpower T trip setpoints value of K 4 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 as a result of reducing AFD limits in accordance with Required Action B.1.
B.4  Verification that )Z(FWQ has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.1 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.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 B.1, even when Condition A is exited prior to performing Required Action B.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure F Q(Z) is properly evaluated prior to increasing THERMAL POWER.
5 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-7 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES ACTIONS  (continued)
C.1  If Required Actions A.1 through A.4 or B.1 through B.4 are not met within their associated Completion Times, the plant must be placed in a mode or condition in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours.
This allowed Completion Time is reasonable based on operating experience regarding the amount of time it takes to reach MODE 2 from full power operation in an orderly manner and without challenging plant systems.
SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.
2 are modified by a Note.
The Note applies REQUIREMENTS during the first power ascension after a refueling. It states that THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained. This allowance is modified, however, by one of the Frequency conditions that requires verification that )Z(FCQ and )Z(FWQ are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits.
Because )Z(FCQ and )Z(FWQ could not have previously been measured in this reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of )Z(FCQ and )Z(FWQ are made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of )Z(FCQ and )Z(FWQ following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of )Z(FCQ and )Z(FWQ. The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.
D 551X,Y,Z A.5, B.1, B.2, C.1 or C.2 )Z,Y,X(FCQ)Z,Y,X(FMQ , SR 3.2.1.2 3)Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 12 hours afterSurveillance performance  is not re quired FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-8 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES SURVEILLANCE REQUIREMENTS  (continued)
SR  3.2.1.1 Verification that )Z(FCQ is within its specified limits involves increasing)Z(FMQ to allow for manufacturing tolerance and measurement uncertainties in order to obtain )Z(FCQ. Specifically, )Z(FMQ is the measured value of F Q(Z) obtained from incore flux map results and )Z(FCQ = )Z(FMQ [1.0815] (Ref.
4).  )Z(FCQ is then compared to its specified limits.
The limit with which )Z(FCQ is compared varies inversely with power above 50% RTP and directly with a function called K(Z) provided in the COLR.
Performing this Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the )Z(FCQ limit is met when RTP is achieved, because peaking factors generally decrease as power level is increased.
If THERMAL POWER has been increased by  10% RTP since the last determination of )Z(FCQ, another evaluation of this factor is required
[12] hours after achieving equilibrium conditions at this higher power level (to ensure that )Z(FCQ values are being reduced sufficiently with power increase to stay within the LCO limits).
[ The Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup because such changes are slow and well controlled when the plant is operated in accordance with the Technical Specifications (TS).
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
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] 1111267)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQDirect verification 3the overall measured F Q (X,Y,Z)INSERT 7 4
3.2.1 Insert Page B 3.2.1-8 INSERT 7  The surveillance has been modified by a Note providing an allowance to not perform SR 3.2.1.1 if the Surveillance has been determined to be met based on the performance results of both SR 3.2.1.2 and SR 3.2.1.3. If both the AFD min margin and the f 2(I) min margin are positive, then the steady state limit is met because these margins represent bounding limiting conditions.
However, if AFD min margin or f 2(I) min margin is negative then a direct evaluation of the steady state limit is required to satisfy this surveillance requirement.
4 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-9 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES
SURVEILLANCE REQUIREMENTS  (continued)
SR  3.2.1.2
The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, )Z(FCQ, by W(Z) gives the maximum F Q(Z) calculated to occur in normal operation, )Z(FWQ. The limit with which )Z(FWQ 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 30 to 75 core elevations.  )Z(FWQ evaluations are not applicable for the following axial core regions, measured in percent of core height:
: a. Lower core region, from 0 to 15% inclusive and
: b. Upper core region, from 85 to 100% inclusive.
The top and bottom 15% 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 )Z(FWQ is evaluated, an evaluation of the expression below is required to account for any increase to )Z(FMQ that may occur and cause the F Q(Z) limit to be exceeded before the next required FQ(Z) evaluation.
If the two most recent F Q(Z) evaluations show an increase in the expression maximum over z [ )Z(FCQ / K(Z) ], it is required to meet the FQ(Z) limit with the last )Z(FWQ increased by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR (Ref. 5)
and 3.2.1.3 5FQ (X,Y,Z)BQDES (X,Y,Z) and BCDES (X,Y,Z) limits INSERT 10 INSERT 8 INSERT 9 FQ (X,Y,Z))Z,Y,X(FMQ and found to be within the applicable limiting condition limits 244based on future projections 3.2.1 Insert Page B 3.2.1-9a INSERT 8  both assembly and axial location (X,Y,Z), has been included in the cycle specific limits BQDES(X,Y,Z) and BCDES(X,Y,Z) using margin factors MQ(X,Y,Z) and MC(X,Y,Z),
respectively (Reference 5).
INSERT 9  No uncertainties are applied to )Z,Y,X(FMQ because the limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted for uncertainties.
44 3.2.1 Insert Page B 3.2.1-9b INSERT 10 In addition to ensuring via surveillance that the heat flux hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Z,Y,X(FMQ for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an )Z,Y,X(FMQ > BQNOM(X,Y,Z), further consideration is required.
The implications of these extrapolations are considered separately for both the operational and RPS heat flux hot channel factor limits. If the extrapolations of )Z,Y,X(FMQ are unfavorable, additional actions must be taken. These actions are to meet the F Q(X,Y,Z) limit with the last  )Z,Y,X(FMQ increased by the appropriate factor specified in the COLR or to evaluate )Z,Y,X(FMQ prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative requirements prevent F Q(X,Y,Z) from exceeding its limit for any significant period of time without detection using the best available data.
Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.
FQ(X,Y,Z) is verified at power levels  10% RTP above the THERMAL POWER of its last verification within 12 hours after achieving equilibrium conditions to ensure that F Q(X,Y,Z) is within its limit at higher power levels. 4 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-10 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES
SURVEILLANCE REQUIREMENTS  (continued)
-----------------------------------REVIEWER'S NOTE-----------------------------------
WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control and FQ Surveillance Technical Specification," February 1994, or other appropriate plant specific methodology, is to be listed in the COLR description in the Administrative Controls Section 5.0 to address the methodology used to derive this factor.
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or to evaluate F Q(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.
Performing the Surveillance in MODE 1 prior to exceeding 75%
RTP ensures that the F Q(Z) limit is met when RTP is achieved, because peaking factors are generally decreased as power level is increased.
FQ(Z) is verified at power levels  10% RTP above the THERMAL POWER of its last verification, [12]
hours after achieving equilibrium conditions to ensure that F Q(Z) is within its limit at higher power levels.
The Surveillance Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup. The Surveillance may be done more frequently if required by the results of F Q(Z) evaluations.
  [ The Frequency of 31 EFPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS, to preclude adverse peaking factors between 31 day surveillances.
OR  The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]  467 FQ(Z) (RAOC-W(Z) Methodology)
B 3.2.1B    WOG STS B 3.2.1B-11 Rev. 4.0, 1X,Y,Z212Revision XXX SEQUOYAH UNIT 2 BASES REFERENCES 1. 10 CFR 50.46, 1974.
: 2. Regulatory Guide 1.77, Rev. 0, May 1974.
: 3. 10 CFR 50, Appendix A, GDC 26.
: 4. WCAP-7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.
: 5. WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control (and) F Q Surveillance Technical Specification," February 1994.      4BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989.
Enclosure 2, Volume 7, Rev. 0, Page 99 of 249Fo(z)@EvaJ B 3'218%\t 0.6\<FT.(-) To*For c216.64633.3 50.0CORE HEIGHTI66 .712100re height of 12 feetFigure B 3.2. 1B-1K(Z) - Normalized Fo(Z) as a(page 1 of 1)Function of Core HeightWOGTSTSB 3.2.1912Volume 7, Rev. 0,,'ooDO NOT OPERATE IN THIS AREA(6.0, 1 .0).8,0.94)(12.0,0.65)
ILLUSIGURE FORRATION ONLY.NOT USE FOROPERATION Enclosure 2,Page 99 of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, BASES, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 2. The RAOC-W(Z) methodology and the Specification designator "B" are deleted because they are unnecessary. (Only one Heat Flux Hot Channel Factor Specification is used in the SQN ITS.
) This information is provided in NUREG-1431, Rev. 4 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-F XY and CAOC-W(Z) methodology Specification Bases (ISTS B 3.2.1A and B 3.2.1C) are not used and are not shown.
: 3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.
: 4. The ISTS Bases for LCO 3.2.1, has been updated to reflect the methodology identified in BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989.
: 5. Changes have been made to be consistent with changes made to the Specification.
: 6. ISTS SR 3.2.1.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies for ITS SR 3.2.1.1 under the Surveillance Frequency Control Program.
: 7. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
: 8. Editorial changes made to enhance clarity/consistency.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))
Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 2 ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS 3/4.2.3  NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)    LIMITING CONDITION FOR OPERATION 3.2.3  FH(X,Y) shall be maintained within the limits specified in the COLR.
APPLICABILITY
:  MODE 1
ACTION:  With FH(X,Y) exceeding the limit specified in the COLR:
: a. Within 2 hours either:
: 1. Restore FH(X,Y) to within the limit specified in the COLR, or
: 2. Reduce the allowable THERMAL POWER from RATED THERMAL POWER at least RRH*% for each 1% that FH(X,Y) exceeds the limit, and
: b. Within the next 4 hours either:
: 1. Restore FH(X,Y) to within the limit specified in the COLR, or
: 2. Reduce the Power Range Neutron Flux-High Trip Setpoint in Table 2.2-1 at least RRH
*% for each 1% that FH(X,Y) exceeds that limit, and
: c. Within 24 hours of initially being outside the limit specified in the COLR, either:
: 1. Restore FH(X,Y) to within the limit specified in the COLR, or
: 2. Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next 2 hours.
_______________________
* RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-10 Amendment No. 19, 138, 155, 223 LCO 3.2.2 Applicabilit y ACTION A Required Action A.2 LA01Required Action A.3 ACTION A ACTION A Required Action A.1 Page 1 of 8 Add proposed ACTION A Note M01LA01LA01LA02L0172M02Add proposed ACTION C A02A02A02ACTION C L026 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS
ACTION:  (Continued)
: d. Within 48 hours of initially being outside the limit specified in the COLR, reduce the Overtemperature Delta T K1 term in Table 2.2
-1 by at least TRH
** for each 1% that FH(X,Y) exceeds the limit, and
: e. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced THERMAL POWER limit required by ACTION a.2 and/or b. and/or c. and/or d., above:  subsequent POWER OPERATION may proceed provided that FH(X,Y) is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the following THERMAL POWER levels:
: 1. A nominal 50% of RATED THERMAL POWER,
: 2. A nominal 75% of RATED THERMAL POWER, and
: 3. Within 24 hours of attaining greater than or equal to 95% of RATED THERMAL POWER.
___________________________
** TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-11 Amendment No. 138, 223 Required Action A.4 Required Action A.5 Completion Time A.5 LA03Page 2 of 8 Add proposed Required Action A.5 Note LA02LA03A03 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable.
4.2.3.2 HMF(X,Y) shall be evaluated to determine if FH(X,Y) is within its limit by:
: a. Using the movable incore detectors to obtain a power distribution map HMF(X,Y)* at any THERMAL POWER greater than 5% of RATED THERMAL POWER.
: b. Satisfying the following relationship:
FHRM(X,Y)  BHNOM(X,Y)
Where:
And BHNOM(X,Y)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.
MAPM is the maximum Allowable Peak** obtained from the measured power distribution.
AXIAL(X,Y) is the axial shape for FH(X,Y). 
: c. If the above relationship is not satisfied, then
: 1. For the location, calculate the % margin to the maximum allowable design as follows:
100% x Y)BRDES(X,Y)(X,HRF  1  = I)Margin(
f %M1 where BHDES (X,Y) and BRDES (X,Y)** represent the maximum allowable design peaking factors which insure that the licensing criteria will be preserved for operation within the LCO limits, and include allowances for calculational and measurement uncertaintie
: s. _________________________
* No additional uncertainties are required in the following equations for HMF(X,Y) and F)HRM(X,Y), because the limits include uncertainties.
  ** BHNOM(X,Y), MAP M, BHDES(X,Y), and BRDES(X,Y) data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-11a Amendment No. 223 FHR(X,Y) = F(X,Y)MAP / AXIAL(X,Y)
MHMM  % F Margin = 1 FHR(X,Y)BHDES(X,Y)  x 100%HM M03LA04Page 3 of 8 SR 3.2.2.1 SR 3.2.2.2 SR NOTE LA04SR 3.2.2.2 SR 3.2.2.1 LA04 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS
: 2. Find the minimum margin of all locations examined in 4.2.3.2.c.1 above.
FH min margin = minimum % margin value of all locations examined
f1(I) min margin = minimum % margin value of all locations examined
: 3. If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH
*% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the Action statements for 3.2.3 apply.
: 4. If the f 1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours reduce the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH
**% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the action statements for 3.2.3 apply.
: d. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding
FHRM(X,Y) > BHNOM(X,Y)
either of the following actions shall be taken:
: 1. HMF(X,Y) shall be increased over that specified in 4.2.3.2.a by the appropriate factor specified in the COLR, and 4.2.3.2.c.1 repeated, or
: 2. HMF(X,Y) shall be evaluated according to 4.2.3.2 at or before the time when the margin is projected to result in the action specified in 4.2.3.2.c.3 or 4.2.3.2.c.4.
4.2.3.3  Y)(X,FMH shall be determined to be within its limit by using the incore detectors to obtain a power distribution map
:  a. Prior to operation above 75% of RATED THERMAL POWER after each fuel loading, and
: b. At least once per 31 EFPD.
____________________________
* RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
** TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-11b Amendment No. 223 LA01SR 3.2.2.1 SR 3.2.2.2 Page 4 of 8 A04thereafter LA05In accordance with the Surveillance Frequency Control Program LA04ACTION A  ACTION B SR 3.2.2.1/SR 3.2.2.2 NOTE SR 3.2.2.1/SR 3.2.2.2 NOTE a. SR 3.2.2.1/SR 3.2.2.2 NOTE b. SR 3.2.2.1 SR 3.2.2.2 LA02M04M04LA03LA01LA03 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS 3/4.2.3  NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  LIMITING CONDITION FOR OPERATION 3.2.3  FH(X,Y) shall be maintained within the limits specified in the COLR.
APPLICABILITY
:  MODE 1 ACTION:  With FH(X,Y) exceeding the limit specified in the COLR:
: a. Within 2 hours either:
: 1. Restore FH(X,Y) to within the limit specified in the COLR, or
: 2. Reduce the allowable THERMAL POWER from RATED THERMAL POWER at least RRH
*% for each 1% that FH(X,Y) exceeds the limit, and      b. Within the next 4 hours either:      1. Restore FH(X,Y) to within the limit specified in the COLR, or
: 2. Reduce the Power Range Neutron Flux-High Trip Setpoint in Table 2.2-1 at least RRH
*% for each 1% that FH(X,Y) exceeds that limit, and   
: c. Within 24 hours of initially being outside the limit specified in the COLR, either:
: 1. Restore FH(X,Y) to within the limit specified in the COLR, or
: 2. Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next 2 hours.
* RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 2    3/4 2-8        Amendment No. 21, 130, 146, 214 LCO 3.2.2 Applicabilit y ACTION A Required Action A.2 LA01Required Action A.3 ACTION A ACTION A Required Action A.1 Page 5 of 8 Add proposed ACTION A Note M01LA01LA01LA02L0172M02Add proposed ACTION C A02A02A02ACTION C L026 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS ACTION:  (Continued)
: d. Within 48 hours of initially being outside the limit specified in the COLR, reduce the Overtemperature Delta T K1 term in Table 2.2
-1 by at least TRH
** for each 1% that FH(X,Y) exceeds the limit, and
: e. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced THERMAL POWER limit required by ACTION a.2 and/or b. and/or c. and/or d., above;  subsequent POWER OPERATION may proceed provided that FH(X,Y) is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the following THERMAL POWER levels:
: 1. A nominal 50% of RATED THERMAL POWER,
: 2. A nominal 75% of RATED THERMAL POWER, and
: 3. Within 24 hours of attaining greater than or equal to 95% of RATED THERMAL POWER. 
      ** TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-9 Amendment No. 130, 214 Required Action A.4 Required Action A.5 Completion Time A.5 LA03Page 6 of 8 LA03LA02A03Add proposed Required Action A.5 Note A01ITS 3.2.2 ITS  POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable.
4.2.3.2 HMF(X,Y) shall be evaluated to determine if FH(X,Y) is within its limit by:   
: a. Using the movable incore detectors to obtain a power distribution map HMF(X,Y)* at any THERMAL POWER greater than 5% of RATED THERMAL POWER.
: b. Satisfying the following relationship:
FHRM(X,Y)  BHNOM (X,Y)
Where:
And BHNOM (X,Y)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.
MAPM is the maximum Allowable Peak** obtained from the measured power distribution.
AXIAL (X,Y) is the axial shape for FH(X,Y).   
: c. If the above relationship is not satisfied, then   
: 1. For the location, calculate the % margin to the maximum allowable design as follows:
where BHDES(X,Y) and BRDES(X,Y)** represent the maximum allowable design peaking factors which insure that the licensing criteria will be preserved for operation within the LCO limits, and include allowances for calculational and measurement uncertainties.
* No additional uncertainties are required in the following equations for HMF(X,Y)1 and FHRM(X,Y), because the limits include uncertainties.
    ** BHNOM (X,Y), MAP M, BHDES (X,Y), and BRDES (X,Y) data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 2    3/4 2-9a          Amendment No. 214 Y)AXIAL(X, /
MAPY)(X,F = Y)(X,HRFMMHM      100% x Y)BRDES(X,Y)(X,HRF  1  = I)Margin(
f %M1    100% x  BHDES(X,Y)
(X,Y)HRF  1 =  Margin F %MH M03Page 7 of 8 SR 3.2.2.1 SR 3.2.2.2 SR 3.2.2.2 SR 3.2.2.1 SR NOTE LA04LA04LA04 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS
: 2. Find the minimum margin of all locations examined in 4.2.3.2.c.1 above.
FH min margin = minimum % margin value of all locations examined
f1(I) min margin = minimum % margin value of all locations examined
: 3. If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH
*% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the Action statements for 3.2.3 apply.
: 4. If the f1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours reduce the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH
**% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the action statements for 3.2.3 apply.
: d. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding FHRM (X,Y) > BHNOM (X,Y)      either of the following actions shall be taken:
: 1. Y)(X,FMH shall be increased over that specified in 4.2.3.2.a by the appropriate factor specified in the COLR, and 4.2.3.2.c.1 repeated, or      2. HMF(X,Y) shall be evaluated according to 4.2.3.2 at or before the time when the margin is projected to result in the action specified in 4.2.3.2.c.3 or 4.2.3.2.c.4. 4.2.3.3  HMF(X,Y) shall be determined to be within its limit by using the incore detectors to obtain a power distribution map
:      a. Prior to operation above 75% of RATED THERMAL POWER after each fuel loading, and      b. At least once per 31 EFPD.
* RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
    ** TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
April 21, 1997 SEQUOYAH - UNIT 2    3/4 2-9b          Amendment No. 214
LA01SR 3.2.2.1 SR 3.2.2.2 Page 8 of 8 LA04M04LA02LA05In accordance with the Surveillance Frequency Control Program A04thereafter SR 3.2.2.1 SR 3.2.2.2 ACTION A ACTION B SR 3.2.2.1/SR 3.2.2.2 NOTE SR 3.2.2.1/SR 3.2.2.2 NOTE a. SR 3.2.2.1/SR 3.2.2.2 NOTE b M04LA03LA01LA03 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 1 of 8 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.3 ACTION a.1, b.1 and c.1 require the restoration of FH(X,Y) to within the limit specified in the COLR. ISTS LCO 3.0.2 Bases states that correction of the entered Condition is an action that may always be considered upon entering ACTIONS and that the restoration of compliance with the LCO is always an option. This changes the CTS by not specifically stating that restoration of FH(X,Y) is required.
This change is acceptable because the technical requirements have not changed. ISTS LCO 3.0.2 Bases states that correction of the entered Condition is an action that may always be considered upon entering ACTIONS and that the restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. In this specific application, Required Action A.1.1 is not the only ACTION and a power reduction should be the focus
for restoration of FH(X,Y) to within the limits. This change is designated as administrative, because it does not result in technical changes to the CTS.
A03 CTS 3.2.3 ACTION e states in part that with FH(X,Y) exceeding its limit, FH(X,Y) must be demonstrated to be within its limit prior to exceeding 50% RTP and 75%
RTP, and within 24 hours of attaining or exceeding 95% RTP. ITS 3.2.2 Required Action A.5 contains the same requirements. However, ITS 3.2.2 Required Action A.5 is modified by a Note which states "THERMAL POWER does not have to be reduced to comply with this Required Action."  This modifies the CTS by adding a Note stating that THERMAL POWER does not have to be reduced to comply with the Required Action.
This change is acceptable, because the requirements have not changed. The Note is included in the ITS to make clear that THERMAL POWER does not have to be reduced to perform the Required Action. For example, if FH(X,Y) exceeds its limit and, per ITS Required Action A.1, THERMAL POWER is reduced to 60%
RTP, THERMAL POWER does not have to be reduced to less than 50% RTP to
verify FH(X,Y) is within its limit to comply with ITS Required Action A.5.
However, FH(X,Y) must still be measured prior to exceeding 75% RTP and within 24 hours of attaining or exceeding 95% RTP. The Note is needed because the ITS contains a Note in ITS 3.2.2 ACTION A that states "Required Actions A.3 and A.5 must be completed whenever Condition A is entered."  The ITS 3.2.2 ACTION A Note does not exist in the CTS and could be construed as DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 2 of 8 requiring THERMAL POWER to be reduced to comply with Required Action A.5.  (Addition of the ACTION A Note is discussed in DOC M01.)  As a result, the Required Action A.5 Note makes the ITS and CTS actions consistent. This change is designated as administrative, because it does not result in technical changes to the CTS.
A04 CTS 4.2.3.3 requires Y)(X,FMHto be determined prior to operation above 75% of RTP after each fuel loading, and at least once per 31 EFPD. ITS SR 3.2.2.1 and SR 3.2.2.2 Frequency is once after each refueling prior to THERMAL POWER exceeding 75% RTP AND 31 EFPD thereafter. This changes the CTS by  adding the word "thereafter" to the Frequency. The removal of the "31 EFPD thereafter" Frequency to the Surveillance Frequency Control Program is discussed in DOC LA05.
CTS 4.2.3.3 is required to be performed prior to operation above 75% RTP after each fuel loading and once per 31 EFPD. Also, although this Frequency is removed to the Surveillance Frequency Control Program, the addition of the word "thereafter" in ITS SR 3.2.2.1 and SR 3.2.2.2 ensures that the 31 EFPD Frequency starts after the first performance of the SR, which is required prior to exceeding 75% RTP after each fuel loading. Therefore, the addition of the word "thereafter" is considered acceptable because the use of thereafter is essentially the same as the CTS Frequency. This change is designated as administrative, because it does not result in technical changes to the CTS.
MORE RESTRICTIVE CHANGES M01 CTS 3.2.3 ACTION e states that with FH(X,Y) exceeding its limit "subsequent POWER OPERATION may proceed provided that FH(X,Y) is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the
following THERMAL POWER levels: 1. A nominal 50% of RATED THERMAL POWER, 2. A nominal 75% of RATED THERMAL POWER, and 3. Within 24 hours of attaining greater than or equal to 95% of RATED THERMAL POWER." However, under CTS 3.0.2, these measurements do not have to be completed, if compliance with the LCO is restored. ITS 3.2.2 ACTION A contains a Note which states, "Required Actions A.3 and A.5 must be completed whenever Condition A is entered."  ITS 3.2.2 Required Action A.3 requires verification that FH min margin is >0 24 hours after entry into Condition A. Required Action A.5 requires verification that FH min margin is >0 prior to THERMAL POWER exceeding 50% RTP and 75% RTP, and within 24 hours after THERMAL POWER is greater than or equal to 95% RTP. This changes the CTS by requiring
the verification that FH min margin is >0 to be made even if FH(X,Y) is restored to within its limit.
This change is acceptable, because it establishes appropriate compensatory measurements for violation of the FH(X,Y) limit. As power is reduced under ITS 3.2.2 Required Action A.1, the margin to the FH(X,Y) limit increases. Therefore, compliance with the LCO could be restored during the power reduction. Verifying that the limit is met as power is increased ensures that the limit continues to be met and does not remain unmeasured for up to 31 EFPD. This change is DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 3 of 8 designated as a more restrictive change because it imposes requirements in addition to those in the CTS.
M02 CTS 3.2.3 does not contain an Action to follow if  ACTIONS a, b, d, and e cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour to initiate a shutdown and to be in HOT STANDBY within 7 hours. ITS 3.2.2 ACTION C, states that the plant must be in MODE 2 within 6 hours, if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shut down and, consequently, allowing one hour less for the unit to be in MODE 2.
The purpose of CTS 3.0.3 is to delineate the ACTION to be taken for circumstances not directly provided fo r in the ACTION statement and whose occurrences would violate the intent of the Specification. This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODE 1. Requiring a shut down to MODE 2 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shut down is not needed, because the operators have had time to prepare for the shut down while attempting to follow the Required Actions and associated Completion Times. This change is designated as more restrictive because it allows less time to shut down than does the CTS.
M03 CTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable provides an allowance for entering the next higher MODE of Applicability when the LCO is not met. ITS 3.2.2 has no specific allowance for changing MODES at any time with ITS LCO 3.2.2 not met. ITS LCO 3.0.4 requires in part that, When an LCO is not met, entry into a MODE or other specified Condition in the Applicability shall only be made: If either part a. or part b. or part c. is met. Part c provides the following allowance, When an allowance is stated in the individual value, parameter or other specification. ITS 3.2.2 Surveillance Requirements Note will be added to provide the following allowance, Not required to be performed until 12 hours after an equilibrium power level has been achieved, at which a power distribution map can be obtained. This changes CTS by allowing entry into the MODE of Applicability by only deferring the performance of the Surveillance Requirements instead of deferring compliance with the LCO.
The purpose of CTS 4.2.3.1 is to provide an exception to SR 4.0.4. SR 4.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This change is acceptable because ITS provides an allowance to enter the MODE of Applicability at any time ITS LCO 3.2.2 is not met solely based on surveillance performance. SR 3.2.2.1 and SR 3.2.2.2 require using the incore detector system to provide the necessary data to create a power distribut ion map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level (~40%-50%). The surveillances cannot be performed in MODE 2. This change is designated as more restrictive because the CTS 4.0.4 MODE change allowance for not met is now limited to DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 4 of 8 the performance of the SRs and does not include the allowance to change MODES with the acceptance criteria not met.
M04 CTS 3.2.3 provides two acceptable alternatives for the FH min margin and f 1(I) min margin not met. CTS 4.2.3.2.c.3 states, If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH*% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the Action statements for 3.2.3 apply. CTS 4.2.3.2.c.4 states,  If the f 1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours reduce the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH**% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the action statements for 3.2.3 apply. CTS 4.2.3.2.c.3 has been replaced by ITS 3.2.2 Required Actions A.1. Similarly, CTS 4.2.3.2.c.4 has been replaced with ITS 3.2.2 Required Actions B.1. However, in both cases the option for,  otherwise, the action statements for 3.2.3 apply  has not been retained. This changes the CTS by removing the option to follow the action statement of CTS 3.2.3 for either min margin (FH or f1(I)) not met.
The purpose of CTS 4.2.3.2.c.3 and CTS 4.2.3.2.c.4 is to provide acceptable alternatives for the required compensatory actions when either FH min margin or f1(I) min margin is not met. The CTS surveillance requirements for FH min margin not met requires the reduction of ALLOWABLE THERMAL POWER from RTP by RRH*% x most negative margin from 4.2.3.2.c.2. This requirement is being retained as ITS 3.2.2 Required Action A.1. The CTS surveillance
requirements for f 1(I) min margin not met requires the reduction of the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH**% x most negative margin from 4.2.3.2.c.2. This requirement is being retained as ITS 3.2.2 Required Action B.1. If the ITS Required Actions are not performed within the allowed Completion Time, Condition C will be entered requiring the Unit to be placed in MODE 2. This change is designated as more restrictive because an acceptable alternative Required Action available in CTS is being removed.
RELOCATED SPECIFICATIONS
None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.3 provides actions to take within 2 hours when FH(X,Y) is not within limits, and states to reduce the allowable THERMAL POWER and within 4 hours reduce the Power Range Neutron Flux-High Trip Setpoint at least RRH*% for each 1% that FH(X,Y) exceeds the limit provided in the COLR. Similarly, CTS 4.2.3.2.c.3 requires in part to reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH*% x most negative margin from 4.2.3.2.c.2. CTS NOTE
* provides the definition of RRH as the amount of power reduction required to compensate for each 1% that FH(X,Y)
DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 5 of 8 exceeds the limit provided in the COLR per Specification 6.9.1.14. ITS 3.2.2 Required Action A.1 requires within 2 hours of discovery that FH min margin is not within limits, to reduce THERMAL POWER from RTP, and ITS 3.2.2 Required Action A.2 requires within 72 hours to reduce the Power Range
Neutron Flux-High Trip Setpoint by  RRH% multiplied times the FH min margin. This changes the CTS by relocating the definition of RRH to the COLR.
The removal of these details from the Technical Specifications and its relocation into the COLR is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements to reduce THERMAL POWER from RTP and reduce the Power Range Neutron Flux-High Trip Setpoint by  RRH% for each 1% that FH(X,Y) exceeds its limit. The definition of RRH is already located in the COLR. Also, this change is acceptable because the removed information will be adequately controlled in the COLR requirements provided in ITS 5.6.5, "Core Operating Limits Report."  ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such transient analysis limits and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)
CTS 3.2.3 ACTIONS c.2 and e require FH(X,Y) to be determined to be within its limit through incore flux mapping. Additionally, CTS 4.2.3.3 requires HMF(X,Y)to be determined to be within its limit by using the incore detectors to obtain a power distribution map. ITS SR 3.2.2.1 and SR 3.2.2.2 collectively verifiy that FH(X,Y) is within its limit. This changes the CTS by moving the manner in which the FH(X,Y) determination is performed to the Bases.
The removal of these details for performing actions and a Surveillance Requirement from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the
requirement to determine FH(X,Y) is within its limit. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.3 Action d requires within 48 hours of FH(X,Y) being outside its limits, to reduce the Overtemperature Delta T K 1 term in Table 2.2-1 by at least TRH** for each 1% that FH(X,Y) exceeds the limit. Similarly, CTS 4.2.3.2.c.4 requires in part to reduce Overtemperature Delta T K1 term in DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 6 of 8 Table 2.2-1 by at least TRH** x most negative margin from 4.2.3.2.c.2. CTS Note ** provides a definition for TRH as the amount of Overtemperature Delta T K1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR. ITS 3.2.2 Required Action A.4 states when FH min margin is < 0, reduce the OTT setpoint by  TRH multiplied times the f 1(I) min margin. This changes the CTS by moving the details of the specific variable
within OTT to be reduced, the location of the K 1 terms, and the definition of TRH to the COLR.
The removal of these details from the Technical Specifications and their relocation into the COLR is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to reduce the OTT setpoint by  TRH multiplied times the f 1(I) min margin. The specific variable within OTT to be reduced, the location of the K 1 terms, and definition of TRH are already located in the COLR. Also, this change is acceptable because the removed information will be adequately controlled in the COLR requirements provided in ITS 5.6.5, "Core Operating Limits Report."  ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such transient analysis limits and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA04 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.3.2.a, 4.2.3.2.b, 4.2.3.2.c.1, and 4.2.3.2.c.2, provide details for evaluating F MH(X,Y) to determine if FH(X,Y) is within limits. ITS SR 3.2.2.1 and SR 3.2.2.2 collectively verify that FH(X,Y) is within limits specified in the COLR. This changes the CTS by moving the details for
evaluating F MH(X,Y) to determine if FH(X,Y) is within limits to the TS Bases.
The removal of these details from the Technical Specifications and their relocation into the TS Bases is acceptable, because the procedural steps and further details for making a determination that FH(X,Y) is within its limits is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to
determine FH(X,Y) is within its limits specified in the COLR. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.
LA05 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program)  CTS 4.2.3.3 requires, in part, a determination that FH(X,Y) is within its limits at least once per 31 EFPD. ITS SR 3.2.2.1 and SR 3.2.2.2 collectively require a similar Surveillance and specify the periodic Frequency as, "In DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 7 of 8 accordance with the Surveillance Frequency Control Program."  This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION b states, in part, that when FH(X,Y) exceeds its limit, reduce the Power Range Neutron Flux
- High Trip setpoints by at least RRH*% for each 1% FH(X,Y) exceeds that limit within the next 4 hours. ITS 3.2.2 Required Actions A.2 states with FH(X,Y) not within limit, reduce the Power Range Neutron Flux - High trip setpoints by at least RRH% multiplied times the FH min margin within 72 hours. This changes the CTS by increasing the time allowed to reduce the trip setpoints.
The purpose of CTS 3.2.3 ACTION b is to lower the Power Range Neutron Flux - High Trip setpoints, which ensures continued operation is at an acceptably low power level with an adequate DNBR margin and avoids violating the FH(X,Y) limit. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced, and considers the low probability of a DBA occurring during the allowed Completion Time. The revised Completion Time allows the Power Range Neutron Flux - High Trip setpoints to be reduced in a controlled manner without challenging operators, technicians, or plant systems. Following a significant power reduction, a time period of 24 hours is allowed to reestablish steady state xenon concentration and power distribution and to take and analyze a flux map. If it is determined that FH(X,Y) is still not within its limit, reducing the Power Range Neutron Flux - High Trip Setpoints can be accomplished within a few hours. Furthermore, setpoint changes should only be required for extended operation in this condition, because of the risk of a plant trip during the adjustment. This change is designated as less restrictive, because additional time is allowed to lower the Power Range Neutron Flux - High Trip setpoints than
was allowed in the CTS.
DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)  Sequoyah Unit 1 and Unit 2 Page 8 of 8 L02  (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION c.2 states, "Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next two
hours."  ITS 3.2.2 ACTION C states, "Required Action and associated Completion Time not met." Required Action C.1 states, "Be in MODE 2" within a Completion Time of "6 hours." This changes the CTS by increasing the time allowed to exit the MODE of Applicability when the Required Actions or associated Completion Times are not met.
The purpose of CTS 3.2.3 ACTION c.2 is to, within 24 hours, either verify FH(X,Y) is restored within limits for the reduced power level or within the next 2 hours, enter MODE 2. Under similar conditions, ITS will require the plant to be placed in a MODE in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced. This change is designated as less restrictive, because additional time is allowed to exit the LCO than was allowed in the CTS.
.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
NHF 3.2.2  WOG STS 3.2.2-1 Rev. 4.0,  CTS FH(X,Y)SEQUOYAH UNIT 1 Amendment xxx 113.2  POWER DISTRIBUTION LIMITS 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (
NHF)  LCO  3.2.2 NHF shall be within the limits specified in the COLR.
APPLICABILITY: MODE 1. 
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME
A. ------------NOTE------------  Required Actions A.
2 and A.3 must be completed whenever Condition A is entered.  ---------------------------------
NHFnot within limit.
A.1.1 Restore NHF to within limit
.
OR  A.1.2.1 Reduce THERMAL POWER to < 50% RTP.
AND  A.1.2.2 Reduce Power Range Neutron Flux - High trip
setpoints to  55% RTP. AND  A.2 Perform SR 3.2.2.1
AND 4 hours 
4 hours 72 hours
24 hours FH(X,Y)FH(X,Y) INSERT 1 INSERT 333.2.3 Applicabilit y DOC M01 
ACTION a.2 SR 4.2.3.2.c.3 ACTION b.2 ACTION c.2 112435653INSERT 2 FH min margin < 0 2 5 3 SR 4.2.3.2.c.3 222allowable 3.2.2 Insert Page 3.2.2-1 CTS INSERT 1  from RTP by  RRH% multiplied times the FH min margin.
INSERT 2  by  RRH% multiplied times the FH min margin.
INSERT 3 A.4 Reduce Overtemperature T trip setpoint by  TRH multiplied times the FH min margin.
AND 48 hours ACTION d  355ACTION a.2 4.2.3.2.c.3 ACTION b.2 NHF 3.2.2  WOG STS 3.2.2-2 Rev. 4.0,  CTS FH(X,Y)SEQUOYAH UNIT 1 Amendment xxx 11ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A.3 --------------NOTE--------------  THERMAL POWER does not have to be reduced to comply with this Required Action.  -------------------------------------
Perform SR 3.2.2.1.
Prior to THERMAL
POWER exceeding 50% RTP AND Prior to THERMAL
POWER exceeding 75% RTP AND 24 hours after
THERMAL POWER reaching  95% RTP B. Required Action and associated Completion Time not met.
B.1 Be in MODE 2.
6 hours    5ACTION e DOC A03 ACTION e.1 ACTION e.2 ACTION e.3 ACTION c.2 DOC M02 3C CINSERT 4 66 3.2.2 Insert Page 3.2.2-2 CTS INSERT 4    CONDITION REQUIRED ACTION COMPLETION TIME
B. f1(I) min margin < 0.
B.1 Reduce Overtemperature T trip setpoint by  TRH multiplied times the f 1(I) min margin. 
48 hours
4.2.3.2.c.4 6
NHF 3.2.2  WOG STS 3.2.2-3 Rev. 4.0,  CTS FH(X,Y)SEQUOYAH UNIT 1 Amendment xxx 11SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
SR  3.2.2.1 Verify NHF is within limits specified in the COLR.
Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND  [ 31 EFPD thereafter OR In accordance
with the
Surveillance Frequency Control Program
]    8INSERT 7INSERT 587INSERT 64.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 899FH min margin > 0 3.2.2 Insert Page 3.2.2-3a CTS INSERT 5  ------------------------------------------------------------NOTE----------------------------------------------------------- Not required to be performed until 12 hours after an equilibrium power level has been achieved, at which a power distribution map can be obtained.
-------------------------------------------------------------------------------------------------------------------------------
74.2.3.1 3.2.2 Insert Page 3.2.2-3b CTS INSERT 6     
-------------------------------NOTE------------------------------
If two measurements extrapolated to 31 EFPD  beyond the most recent measurement yield:
FHRM(X,Y) > BHNOM(X,Y)    a. Increase HMF(X,Y) by the appropriate factor  specified in the COLR and reverify FH min margin > 0; or
: b. Repeat SR 3.2.2.1 prior to the time at which the projected FH min margin will be < 0.    ---------------------------------------------------------------------
4.2.3.2.d 4.2.3.2.d.1 4.2.3.2.d.2 3.2.2 Insert Page 3.2.2-3c CTS INSERT 7  SURVEILLANCE FREQUENCY SR  3.2.2.2 -------------------------------NOTE------------------------------
If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:
FHRM(X,Y) > BHNOM(X,Y)        a. Increase HMF(X,Y) by the appropriate factor specified in the COLR and reverify      f1 (I) min margin > 0; or
: b. Repeat SR 3.2.2.2 prior to the time at which    the projected f 1 (I) min margin will be < 0.
  ---------------------------------------------------------------------
Verify f 1(I) min margin > 0.
Once after each
refueling prior to THERMAL POWER exceeding 75% RTP AND In accordance
with the Surveillance Frequency Control Program 
84.2.3.2.d 4.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 4.2.3.2.d.1 4.2.3.2.d.2 NHF 3.2.2  WOG STS 3.2.2-1 Rev. 4.0,  CTS FH(X,Y)SEQUOYAH UNIT 2 Amendment xxx 113.2  POWER DISTRIBUTION LIMITS 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (
NHF)  LCO  3.2.2 NHF shall be within the limits specified in the COLR.
APPLICABILITY: MODE 1. 
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME
A. ------------NOTE------------  Required Actions A.
2 and A.3 must be completed whenever Condition A is entered.  ---------------------------------
NHFnot within limit.
A.1.1 Restore NHF to within limit
.
OR  A.1.2.1 Reduce THERMAL POWER to < 50% RTP.
AND  A.1.2.2 Reduce Power Range Neutron Flux - High trip
setpoints to  55% RTP. AND  A.2 Perform SR 3.2.2.1
AND 4 hours 
4 hours 72 hours
24 hours FH(X,Y)FH(X,Y) INSERT 1 INSERT 333.2.3 Applicabilit y DOC M01 
ACTION a.2 SR 4.2.3.2.c.3 ACTION b.2 ACTION c.2 112435653INSERT 2 FH min margin < 0 2 5 3 SR 4.2.3.2.c.3 222allowable 3.2.2 Insert Page 3.2.2-1 CTS INSERT 1  from RTP by  RRH% multiplied times the FH min margin.
INSERT 2  by  RRH% multiplied times the FH min margin.
INSERT 3 A.4 Reduce Overtemperature T trip setpoint by  TRH multiplied times the FH min margin.
AND 48 hours ACTION d  355ACTION a.2 4.2.3.2.c.3 ACTION b.2 NHF 3.2.2  WOG STS 3.2.2-2 Rev. 4.0,  CTS FH(X,Y)SEQUOYAH UNIT 2 Amendment xxx 11ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A.3 --------------NOTE--------------  THERMAL POWER does not have to be reduced to comply with this Required Action.  -------------------------------------
Perform SR 3.2.2.1.
Prior to THERMAL
POWER exceeding 50% RTP AND Prior to THERMAL
POWER exceeding 75% RTP AND 24 hours after
THERMAL POWER reaching  95% RTP B. Required Action and associated Completion Time not met.
B.1 Be in MODE 2.
6 hours    5ACTION e DOC A03 ACTION e.1 ACTION e.2 ACTION e.3 ACTION c.2 DOC M02 3C CINSERT 4 66 3.2.2 Insert Page 3.2.2-2 CTS INSERT 4    CONDITION REQUIRED ACTION COMPLETION TIME
B. f1(I) min margin < 0.
B.1 Reduce Overtemperature T trip setpoint by  TRH multiplied times the f 1(I) min margin. 
48 hours
4.2.3.2.c.4 6
NHF 3.2.2  WOG STS 3.2.2-3 Rev. 4.0,  CTS FH(X,Y)SEQUOYAH UNIT 2 Amendment xxx 11SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
SR  3.2.2.1 Verify NHF is within limits specified in the COLR.
Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND  [ 31 EFPD thereafter OR In accordance
with the
Surveillance Frequency Control Program
]    8INSERT 7INSERT 587INSERT 64.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 899FH min margin > 0 3.2.2 Insert Page 3.2.2-3a CTS INSERT 5  ------------------------------------------------------------NOTE----------------------------------------------------------- Not required to be performed until 12 hours after an equilibrium power level has been achieved, at which a power distribution map can be obtained.
-------------------------------------------------------------------------------------------------------------------------------
74.2.3.1 3.2.2 Insert Page 3.2.2-3b CTS INSERT 6     
-------------------------------NOTE------------------------------
If two measurements extrapolated to 31 EFPD  beyond the most recent measurement yield:
FHRM(X,Y) > BHNOM(X,Y)    a. Increase HMF(X,Y) by the appropriate factor  specified in the COLR and reverify FH min margin > 0; or
: b. Repeat SR 3.2.2.1 prior to the time at which the projected FH min margin will be < 0.    ---------------------------------------------------------------------
4.2.3.2.d 4.2.3.2.d.1 4.2.3.2.d.2 3.2.2 Insert Page 3.2.2-3c CTS INSERT 7  SURVEILLANCE FREQUENCY SR  3.2.2.2 -------------------------------NOTE------------------------------
If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:
FHRM(X,Y) > BHNOM(X,Y)        a. Increase HMF(X,Y) by the appropriate factor specified in the COLR and reverify      f1 (I) min margin > 0; or
: b. Repeat SR 3.2.2.2 prior to the time at which    the projected f 1 (I) min margin will be < 0.
  ---------------------------------------------------------------------
Verify f 1(I) min margin > 0.
Once after each
refueling prior to THERMAL POWER exceeding 75% RTP AND In accordance
with the Surveillance Frequency Control Program 
84.2.3.2.d 4.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 4.2.3.2.d.1 4.2.3.2.d.2 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))  Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 2. ISTS LCO 3.2.2 Required Action A.1.1 states, restore NHFto within limit. ITS 3.2.2 will not retain the specific requirement to restore. LCO 3.0.2 Bases states that correction of the entered Condition is an action that may always be considered upon entering ACTIONS. This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. In this specific application, Required Action A.1.1 is not the only ACTION and a power reduction should be the focus for restoration of FH(X,Y)to within the limits. Subsequent Required Actions have been renumbered o reflect this deletion.
: 3. Required Action A.4 is added to the ITS. CTS 3.2.3 ACTION d requires reduction of the OTT setpoint when FH(X,Y) exceeds the limit in the COLR. Subsequent Required Actions have been renumbered o reflect this deletion.
: 4. The Completion Times for reducing THERMAL POWER upon discovery that FH(X,Y) has exceeded its limit are shortened from 4 hours to 2 hours consistent with the current licensing basis.
: 5. The amount that THERMAL POWER and the Power Range Neutron Flux - High Trip setpoints are reduced after FH(X,Y) has exceeded its limit are changed to reflect the values in the current licensing basis.
: 6. ITS Conditions A and B have been changed to reflect the CTS ACTIONs for both FH and/or f1(I) min margins not met. 
: 7. ISTS LCO 3.2.2 does not contain a specific provision for changing MODES if LCO 3.2.2 is not met, other than the generic use of LCO 3.0.4. CTS SR 4.2.3.1
states, The provisions of Specification 4.0.4 are not applicable. This allowance enables SQN to enter the MODE of Applicability with the Surveillance not met or performed. SQN is retaining the allowance to change the MODE of Applicability with the Surveillance not performed by adding a Surveillance Note to retain the allowance.
: 8. ISTS SR 3.2.2.1 and SR 3.2.2.2 have been changed to reflect the CTS evaluation of FH min margin > 0 and f 1(I) min margin > 0.
: 9. ISTS SR 3.2.2.1 (and proposed ITS SR 3.2.2.2) provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
HNF B 3.2.2 
WOG STS B 3.2.2-1 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.2  Nuclear Enthalpy Rise Hot Channel Factor (
HNF  )
BASES  BACKGROUND The purpose of this LCO is to establish limits on the power density at any point in the core so that the fuel design criteria are not exceeded and the accident analysis assumptions remain valid. The design limits on local (pellet) and integrated fuel rod peak power density are expressed in terms of hot channel factors. Control of the core power distribution with respect to these factors ensures that local conditions in the fuel rods and coolant channels do not challenge core integrity at any location during either normal operation or a postulated accident analyzed in the safety analyses.
HNF is defined as the ratio of the integral of the linear power along the fuel rod with the highest integrated power to the average integrated fuel rod power. Therefore, HNF is a measure of the maximum total power produced in a fuel rod.
HNF is sensitive to fuel loading patterns, bank insertion, and fuel burnup.
HNF typically increases with control bank insertion and typically decreases with fuel burnup.
HNF is not directly measurable but is inferred from a power distribution map obtained with the movable incore detector system. Specifically, the results of the three dimensional power distribution map are analyzed by a computer to determine HNF. This factor is calculated at least every 31 EFPD. However, during power operation, the global power distribution is monitored by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," which address directly and continuously measured process variables.
The COLR provides peaking factor limits that ensure that the design basis
value of the departure from nucleate boiling (DNB) is met for normal operation, operational transients, and any transient condition arising from events of moderate frequency. The DNB design basis precludes DNB and is met by limiting the minimum local DNB heat flux ratio to [1.3] using the [W3] CHF correlation. All DNB limited transient events are assumed to begin with an HNF value that satisfies the LCO requirements.
Operation outside the LCO limits may produce unacceptable consequences if a DNB limiting event occurs. The DNB design basis ensures that there is no overheating of the fuel that results in possible cladding perforation with the release of fission products to the reactor coolant.
FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y)1111FH(X,Y)the design limit value usin g an NRC approved critical heat flux 1INSERT 1 2
B 3.2.2 Insert Page B 3.2.2-1a INSERT 1  An FH(X,Y) evaluation requires obtaining an incore flux map in MODE 1. The incore flux map results provide the measured value ()Y,X(FMH of FH(X,Y) for each assembly location (X,Y). The FH ratio (FDHR) is used in order to determine the FH limit for the measured and design power distributions. Then,
FHRM(X,Y) = )Y,X(AXIAL/MAP)Y,X(FMMMH where MMAP is the maximum allowable peak from the COLR for the measured assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties, and )Y,X(AXIAL M is the measured ratio of the peak-to-average axial power at assembly location (X,Y).
BHDES(X,Y) is a cycle dependent design limit to preserve Departure from Nucleate Boiling(DNB) assumed for initial conditions at the time of limiting transients such as a Loss of Flow Accident (LOFA). BRDES(X,Y) is a cycle dependent design limit to preserve reactor protection system safety limits for DNB requirements.
The expression for BHDES(X,Y) is:
BHDES(X,Y) = FHRd(X,Y)
* MH(X,Y) where: FHRd(X,Y) = )Y,X(AXIAL/MAP)Y,X(FdddH
* dMAP is the maximum allowable peak from the COLR for the design assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties, 
* )Y,X(AXIAL d is the design ratio of the peak-to-average axial power at assembly location (X,Y), 
* )Y,X(FdH is the design FH assembly location (X, Y), and
* MH(X,Y) is the minimum available margin ratio for initial condition DNB at the limiting conditions at assembly location (X,Y).
2 B 3.2.2 Insert Page B 3.2.2-1b INSERT 1 (continued)
The expression for BRDES(X,Y) is:
BRDES(X,Y) = FHRd(X,Y)
* MH s(X,Y) where: MH s(X,Y) is the minimum available margin ratio for steady state DNB at the limiting conditions at assembly location (X,Y).
The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:
FHRM(X,Y)  BHNOM(X,Y)
where:  BHNOM(X,Y) is the nominal design radial peaking factor for an assembly at core location (X,Y) increased by an allowance for the expected deviation between the measured and predicted design power distribution.
2 HNF B 3.2.2 
WOG STS B 3.2.2-2 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES  APPLICABLE Limits on HNF preclude core power distributions that exceed the following SAFETY  fuel design limits: ANALYSES 
: a. There must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hottest fuel rod in the core does not experience a DNB condition,
: b. During a large break loss of coolant accident (LOCA), peak cladding temperature (PCT) must not exceed 2200&deg;F,
: c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm
[Ref. 1], and  d. Fuel design limits required by GDC 26 (Ref. 2) for the condition when control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn.
For transients that may be DNB limited, the Reactor Coolant System flow and HNF are the core parameters of most importance. The limits on HNF ensure that the DNB design basis is met for normal operation, operational transients, and any transients arising from events of moderate frequency. The DNB design basis is met by limiting the minimum DNBR to the 95/95 DNB criterion of [1.3] using the [W3
] CHF correlation. This value provides a high degree of assurance that the hottest fuel rod in the core does not experience a DNB.
The allowable HNF limit increase s with decreasing power level. This functionality in HNF is included in the analyses that provide the Reactor Core Safety Limits (SLs) of SL 2.1.1. Therefore, any DNB events in which the calculation of the core limits is modeled implicitly use this variable value of HNF in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial HNF as a function of power level defined by the COLR limit equation.
The LOCA safety analysis indirectly models HNF as an input parameter.
The Nuclear Heat Flux Hot Channel Factor (F Q(Z)) and the axial peaking factors are inserted directly into the LOCA safety analyses that verify the acceptability of the resulting peak cladding temperature
[Ref. 3].
The fuel is protected in part by Technical Specifications, which ensure that the initial conditions assumed in the safety and accident analyses remain valid. The following LCOs ensure this:  LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, "QUADRANT POWER TILT RATIO FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y) FH(X,Y)1113X,Y, local DNB heat flux ratio to the desi gn limit value usin g an NRC approved critical heat flux 1limits, FH min margin and f1(I) min margin,
)(8) ( 83 HNF B 3.2.2 
WOG STS B 3.2.2-3 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES
APPLICABLE SAFETY ANALYSES  (continued)
(QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor )F(HN," and LCO 3.2.1, "Heat Flux Hot Channel Factor (F Q(Z))."  HNF and FQ(Z) are measured periodically using the movable incore detector system. Measurements are generally taken with the core at, or near, steady state conditions. Core monitoring and control under transient conditions (Condition 1 events) are accomplished by operating the core within the limits of the LCOs on AFD, QPTR, and Bank Insertion
Limits.
HNF satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO HNF shall be maintained within the limits of the relationship provided in the COLR.
The HNF limit identifies the coolant flow channel with the maximum enthalpy rise. This channel has the least heat removal capability and thus the highest probability for a DNB.
The limiting value of HNF, described by the equation contained in the COLR, is the design radial peaking factor used in the unit safety analyses.
A power multiplication factor in this equation includes an additional margin for higher radial peaking from reduced thermal feedback and greater control rod insertion at low power levels. The limiting value of is HNF allowed to increase 0.3% for every 1%
RTP reduction in THERMAL POWER. APPLICABILITY The HNF limits must be maintained in MODE 1 to preclude core power distributions from exceeding the fuel design limits for DNBR and PCT.
Applicability in other modes is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the coolant to require a limit on the distribution of core power. Specifically, the design bases events that are sensitive to HNF in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict HNF in these modes.
FH(X,Y) FH(X,Y) FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y)1211X, Y, ZX, Y, ZINSERT 2 indirectly B 3.2.2 Insert Page B 3.2.2-3 INSERT 2  The LCO states that FH(X,Y) shall be less than the limits provided in the COLR. This LCO relationship must be satisfied even if the core is operating at limiting conditions. This requires adjustment to the measured
FH(X,Y) to account for limiting conditions and the differences between design and measured conditions. The adjustments are accounted for by
comparing FHRM(X,Y) to the limits BHDES(X,Y) and BRDES(X,Y). Therefore, if the FH min margin is >0 and f 1(I) min margin >0 the LCO is satisfied.
2 HNF B 3.2.2 
WOG STS B 3.2.2-4 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES
ACTIONS A.1.1  With HNF exceeding its limit, the unit is allowed 4 hours to restore HNF to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring HNF within its power dependent limit. When the HNF limit is exceeded, the DNBR limit is not likely violated in steady state operation, because events that could significantly perturb the HNF value (e.g., static control rod misalignment) are considered in the safety analyses. However, the DNBR limit may be violated if a DNB limiting event occurs. Thus, the allowed Completion Time of 4 hours provides an acceptable time to restore HNF to within its limits without allowing the plant to remain in an unacceptable condition for an extend ed period of time.
Condition A is modified by a Note that requires that Required Actions A.
2 and A.3 must be completed whenever Condition A is entered.
Thus, if power is not reduced because this Required Action is completed within the 4 hour time period, Required Action A.2 nevertheless requires another measurement and calculation of HNF within 24 hours in accordance with SR 3.2.2.1.
However, if power is reduced below 50% RTP, Required Action A.
3 requires that another determination of HNF must be done prior to exceeding 50% RTP, prior to exceeding 75% RTP, and within 24 hours after reaching or exceeding 95% RTP. In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours. 
A.1.2.1 and A.1.2.2  If the value of HNF is not restored to within its specified limit either by adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in accordance with Required Action A.1
.2.1 and reduce the Power Range Neutron Flux - High to  55% RTP in accordance with Required Action A.
1.2.2. Reducing RTP to < 50% RTP increases the DNB margin and does not likely cause the DNBR limit to be violated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptable low power level with adequate DNBR
margin. The allowed Completion Time of 4 hours for Required Action A.1
.2.1 is consistent with those allowed for in Required Action A.1.1 and provides an acceptable time to reach the required power level from full power operation without allowing the plant to remain in an unacceptable condition for an extended period of time.
The Completion Times of 4 hours for Required Actions A.1.1 and A.1.2.1 are not additive
. FH min margin 445 5 41FH min marginINSERT 5 INSERT 6 INSERT 7 2 41335allowableINSERT 3 2verified3 INSERT 4 B 3.2.2 Insert Page B 3.2.2-4a INSERT 3  The % FH margin is based on the relationship between  FHRM(X,Y)  and the limit, BHDES (X,Y), as follows:
100% x  Y)BHDES(X,Y)(X,HRF  1 =Margin F %MH If the reactor core is operating as designed, then FHRM(X,Y) is less than BHDES (X,Y) and calculation of %FH margin is not required. If the
%FH margin is less than zero, then FHRM(X,Y) is greater than BHDES (X, Y) and the FH(X,Y) limits may not be adequate to prevent exceeding the initial DNB conditions assumed for transients such as a LOFA. BHDES (X,Y) represents the maximum allowable design radial peaking factors which ensures that the initial conditions DNB will be preserved for operation within the LCO limits, and includes allowances for calculational and measurement uncertainties. The FH min margin is the minimum for all core locations examined.
INSERT 4  If FH min margin < 0 is restored to within limits prior to completion of the THERMAL POWER reduction in Required Action A.1, compliance of Required Actions A.3 and A.5 must be met.
24 B 3.2.2 Insert Page B 3.2.2-4b INSERT 5  from RTP by at least RRH % (where RRH = Thermal power reduction required to compensate for each 1% that  FH(X,Y) exceeds its limit)  multiplied times the FH min margin
INSERT 6 trip setpoints, as specified in TS Table 3.3.1-1 by  RRH% multiplied times the FH min margin INSERT 7 by at least RRH% multiplied times the FH min margin 444 HNF B 3.2.2 
WOG STS B 3.2.2-5 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES ACTIONS  (continued)
The allowed Completion Time of 72 hours to reset the trip setpoints per
Required Action A.
1.2.2 recognizes that, once power is reduced, the safety analysis assumptions are satisfied and there is no urgent need to reduce the trip setpoints. This is a sensitive operation that may inadvertently trip the Reactor Protection System.
A.2 Once the power level has been reduced to < 50% RTP per Required Action A.1
.2.1, an incore flux map (SR 3.2.2.1) must be obtained and the measured value of HNF verified not to exceed the allowed limit at the lower power level. The unit is provided 20 additional hours to perform this task over and above the 4 hours allowed by either Action A.1.1 or Action A.1
.2.1. The Completion Time of 24 hours is acceptable because of the increase in the DNB margin, which is obtained at lower power levels, and the low probability of having a DNB limiting event within this 24 hour period. Additionally, operating experience has indicated that this Completion Time is sufficient to obtain the incore flux map, perform the required calculations, and evaluate HNF. A.3  Verification that HNF is within its specified limits after an out of limit occurrence ensures that the cause that led to the HNF exceeding its limit is corrected, and that subsequent operation proceeds within the LCO limit. This Action demonstrates that the HNF limit is within the LCO limits prior to exceeding 50% RTP, again prior to exceeding 75% RTP, and within 24 hours after THERMAL POWER is  95% RTP.
This Required Action is modified by a Note that states that THERMAL POWER does not have to be reduced prior to performing this Action.
B.1  When Required Actions A.1
.1 through A.
3 cannot be completed within their required Completion Times, the plant must be placed in a mode in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.
FH min margin is verified > 0 FHmin margin FHmin margin is > 0 FH min margin FH min margin 1114INSERT 8 4322 2 INSERT 945 45, and B.1, 4C 2allowable 3 >0INSERT 10 B 3.2.2 Insert Page B 3.2.2-5a INSERT 8  by at least RRH% multiplied times the FH min margin INSERT 9  A.4  If the value of FHRM(X,Y) is not restored to within its specified limit, Overtemperarture T K1 (OTT K1) term is required to be reduced by at least TRH multiplied times the FH min margin. The value of TRH is provided in the COLR. Completing Required Action A.4 ensures protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Also, completing Required Action A.4 within the allowed Completion Time of 48 hours is sufficient considering the small likelihood of a limiting transient in this time period.
44 B 3.2.2 Insert Page B 3.2.2-5b INSERT 10 B.1  The %f1(I) margin is based on the relationship between FHRM(X,Y)  and the limit, BRDES (X,Y), as follows:
% f(I)Margin =  1 FHR(X,Y)BRDES(X,Y) x 100%1M If the reactor core is operating as designed, then FHRM(X,Y) is less than BRDES (X,Y) and calculation of %f 1(I) margin is not required. If the
%f1(I) margin is less than zero, then FHRM(X,Y) is greater than    BRDES (X, Y) and the OTT setpoint limits may not be adequate to prevent exceeding DNB requirements.
BRDES (X,Y) represents the maximum allowable design radial peaking factors which ensure that the steady state DNBR limit will be preserved for operation within the LCO limits, including allowances for calculational
and measurement uncertainties Required Action B.1 requires the reduction of the OTT K1 term by at least TRH multiplied by the f 1(I) min margin. TRH is the amount of OTT K1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR. Completing Required Action B.1 within the allowed Completion Time of 48 hours, restricts FH(X,Y) such that even if a transient occurred, DNB requirements are met. The f 1(I) min margin is the minimum % of f 1(I) margin for all core locations examined.
2 HNF B 3.2.2 
WOG STS B 3.2.2-6 Rev. 4.0,  FH(X,Y)1SEQUOYAH UNIT 1 Revision XXX 1BASES
SURVEILLANCE SR  3.2.2.1 REQUIREMENTS The value of HNF is determined by using the movable incore detector system to obtain a flux distribution map. A data reduction computer program then calculates the maximum value of HNF from the measured flux distributions. The measured value of HNF must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the HNF limit. After each refueling, HNF must be determined in MODE 1 prior to exceeding 75%
RTP. This requirement ensures that HNF limits are met at the beginning of each fuel cycle.
  [ The 31 EFPD Frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup. Accordingly, this Frequency is short enough that the HNF limit cannot be exceeded for any significant period of o peration.
OR  The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]
REFERENCES 1. Regulatory Guide 1.77, Rev.
[0], May 1974.
: 2. 10 CFR 50, Appendix A, GDC 26.
: 3. 10 CFR 50.46.
1INSERT 12 4467INSERT 11 B 3.2.2 Insert Page B 3.2.2-6a INSERT 11 SR 3.2.2.1 and SR 3.2.2.2 are modified by a Note. It states that, "Not required to be performed until 12 hours after an equilibrium power level has been achieved at which a power distribution map can be obtained."
SR 3.2.2.1 and SR 3.2.2.2 require using the incore detector system to provide the necessary data to create a power distribution map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level. These surveillances could not be satisfactorily performed if the requirement for performance of the Surveillances was included in MODE 2 prior to entering MODE 1.
In a reload core,HMF(X,Y)could not have previously been measured, therefore, there is a Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of HMF(X,Y) is made at a lower power level at which adequate margin is available before going to 100% RTP.
4 B 3.2.2 Insert Page B 3.2.2-6b INSERT 12 SR  3.2.2.1 and SR 3.2.2.2
In addition to ensuring via Surveillance that the nuclear enthalpy rise hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Y,X(FMH for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an FHRM(X,Y) > BHNOM(X,Y), further consideration is required.
The implications of these extrapolations are considered separately for BHDES(X,Y) and BRDES(X,Y) limits. If the extrapolations of )Y,X(FMH  are unfavorable, additional actions must be taken. These actions are to meet the FH(X,Y) limit with the last HMF(X,Y) increased by the appropriate factor specified in the COLR or to evaluateHMF(X,Y) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These al ternative requirements attempt to prevent FH(X,Y) from exceeding its limit for any significant period of time without detection using the best available data. 
Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.
4 HNF B 3.2.2 
WOG STS B 3.2.2-1 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.2  Nuclear Enthalpy Rise Hot Channel Factor (
HNF  )
BASES  BACKGROUND The purpose of this LCO is to establish limits on the power density at any point in the core so that the fuel design criteria are not exceeded and the accident analysis assumptions remain valid. The design limits on local (pellet) and integrated fuel rod peak power density are expressed in terms of hot channel factors. Control of the core power distribution with respect to these factors ensures that local conditions in the fuel rods and coolant channels do not challenge core integrity at any location during either normal operation or a postulated accident analyzed in the safety analyses.
HNF is defined as the ratio of the integral of the linear power along the fuel rod with the highest integrated power to the average integrated fuel rod power. Therefore, HNF is a measure of the maximum total power produced in a fuel rod.
HNF is sensitive to fuel loading patterns, bank insertion, and fuel burnup.
HNF typically increases with control bank insertion and typically decreases with fuel burnup.
HNF is not directly measurable but is inferred from a power distribution map obtained with the movable incore detector system. Specifically, the results of the three dimensional power distribution map are analyzed by a computer to determine HNF. This factor is calculated at least every 31 EFPD. However, during power operation, the global power distribution is monitored by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," which address directly and continuously measured process variables.
The COLR provides peaking factor limits that ensure that the design basis
value of the departure from nucleate boiling (DNB) is met for normal operation, operational transients, and any transient condition arising from events of moderate frequency. The DNB design basis precludes DNB and is met by limiting the minimum local DNB heat flux ratio to [1.3] using the [W3] CHF correlation. All DNB limited transient events are assumed to begin with an HNF value that satisfies the LCO requirements.
Operation outside the LCO limits may produce unacceptable consequences if a DNB limiting event occurs. The DNB design basis ensures that there is no overheating of the fuel that results in possible cladding perforation with the release of fission products to the reactor coolant.
FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y)1111FH(X,Y)the design limit value usin g an NRC approved critical heat flux 1INSERT 1 2
B 3.2.2 Insert Page B 3.2.2-1a INSERT 1  An FH(X,Y) evaluation requires obtaining an incore flux map in MODE 1. The incore flux map results provide the measured value ()Y,X(FMH of FH(X,Y) for each assembly location (X,Y). The FH ratio (FDHR) is used in order to determine the FH limit for the measured and design power distributions. Then,
FHRM(X,Y) = )Y,X(AXIAL/MAP)Y,X(FMMMH where MMAP is the maximum allowable peak from the COLR for the measured assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties, and )Y,X(AXIAL M is the measured ratio of the peak-to-average axial power at assembly location (X,Y).
BHDES(X,Y) is a cycle dependent design limit to preserve Departure from Nucleate Boiling(DNB) assumed for initial conditions at the time of limiting transients such as a Loss of Flow Accident (LOFA). BRDES(X,Y) is a cycle dependent design limit to preserve reactor protection system safety limits for DNB requirements.
The expression for BHDES(X,Y) is:
BHDES(X,Y) = FHRd(X,Y)
* MH(X,Y) where: FHRd(X,Y) = )Y,X(AXIAL/MAP)Y,X(FdddH
* dMAP is the maximum allowable peak from the COLR for the design assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties, 
* )Y,X(AXIAL d is the design ratio of the peak-to-average axial power at assembly location (X,Y), 
* )Y,X(FdH is the design FH assembly location (X, Y), and
* MH(X,Y) is the minimum available margin ratio for initial condition DNB at the limiting conditions at assembly location (X,Y).
2 B 3.2.2 Insert Page B 3.2.2-1b INSERT 1 (continued)
The expression for BRDES(X,Y) is:
BRDES(X,Y) = FHRd(X,Y)
* MH s(X,Y) where: MH s(X,Y) is the minimum available margin ratio for steady state DNB at the limiting conditions at assembly location (X,Y).
The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:
FHRM(X,Y)  BHNOM(X,Y)
where:  BHNOM(X,Y) is the nominal design radial peaking factor for an assembly at core location (X,Y) increased by an allowance for the expected deviation between the measured and predicted design power distribution.
2 HNF B 3.2.2 
WOG STS B 3.2.2-2 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES  APPLICABLE Limits on HNF preclude core power distributions that exceed the following SAFETY  fuel design limits: ANALYSES 
: a. There must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hottest fuel rod in the core does not experience a DNB condition,
: b. During a large break loss of coolant accident (LOCA), peak cladding temperature (PCT) must not exceed 2200&deg;F,
: c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm
[Ref. 1], and  d. Fuel design limits required by GDC 26 (Ref. 2) for the condition when control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn.
For transients that may be DNB limited, the Reactor Coolant System flow and HNF are the core parameters of most importance. The limits on HNF ensure that the DNB design basis is met for normal operation, operational transients, and any transients arising from events of moderate frequency. The DNB design basis is met by limiting the minimum DNBR to the 95/95 DNB criterion of [1.3] using the [W3
] CHF correlation. This value provides a high degree of assurance that the hottest fuel rod in the core does not experience a DNB.
The allowable HNF limit increase s with decreasing power level. This functionality in HNF is included in the analyses that provide the Reactor Core Safety Limits (SLs) of SL 2.1.1. Therefore, any DNB events in which the calculation of the core limits is modeled implicitly use this variable value of HNF in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial HNF as a function of power level defined by the COLR limit equation.
The LOCA safety analysis indirectly models HNF as an input parameter.
The Nuclear Heat Flux Hot Channel Factor (F Q(Z)) and the axial peaking factors are inserted directly into the LOCA safety analyses that verify the acceptability of the resulting peak cladding temperature
[Ref. 3].
The fuel is protected in part by Technical Specifications, which ensure that the initial conditions assumed in the safety and accident analyses remain valid. The following LCOs ensure this:  LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, "QUADRANT POWER TILT RATIO FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y) FH(X,Y)1113X,Y, local DNB heat flux ratio to the desi gn limit value usin g an NRC approved critical heat flux 1limits, FH min margin and f1(I) min margin,
)(8) ( 83 HNF B 3.2.2 
WOG STS B 3.2.2-3 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES
APPLICABLE SAFETY ANALYSES  (continued)
(QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor )F(HN," and LCO 3.2.1, "Heat Flux Hot Channel Factor (F Q(Z))."  HNF and FQ(Z) are measured periodically using the movable incore detector system. Measurements are generally taken with the core at, or near, steady state conditions. Core monitoring and control under transient conditions (Condition 1 events) are accomplished by operating the core within the limits of the LCOs on AFD, QPTR, and Bank Insertion
Limits.
HNF satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO HNF shall be maintained within the limits of the relationship provided in the COLR.
The HNF limit identifies the coolant flow channel with the maximum enthalpy rise. This channel has the least heat removal capability and thus the highest probability for a DNB.
The limiting value of HNF, described by the equation contained in the COLR, is the design radial peaking factor used in the unit safety analyses.
A power multiplication factor in this equation includes an additional margin for higher radial peaking from reduced thermal feedback and greater control rod insertion at low power levels. The limiting value of is HNF allowed to increase 0.3% for every 1%
RTP reduction in THERMAL POWER. APPLICABILITY The HNF limits must be maintained in MODE 1 to preclude core power distributions from exceeding the fuel design limits for DNBR and PCT.
Applicability in other modes is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the coolant to require a limit on the distribution of core power. Specifically, the design bases events that are sensitive to HNF in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict HNF in these modes.
FH(X,Y) FH(X,Y) FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y)1211X, Y, ZX, Y, ZINSERT 2 indirectly B 3.2.2 Insert Page B 3.2.2-3 INSERT 2  The LCO states that FH(X,Y) shall be less than the limits provided in the COLR. This LCO relationship must be satisfied even if the core is operating at limiting conditions. This requires adjustment to the measured
FH(X,Y) to account for limiting conditions and the differences between design and measured conditions. The adjustments are accounted for by
comparing FHRM(X,Y) to the limits BHDES(X,Y) and BRDES(X,Y). Therefore, if the FH min margin is >0 and f 1(I) min margin >0 the LCO is satisfied.
2 HNF B 3.2.2 
WOG STS B 3.2.2-4 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES
ACTIONS A.1.1  With HNF exceeding its limit, the unit is allowed 4 hours to restore HNF to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring HNF within its power dependent limit. When the HNF limit is exceeded, the DNBR limit is not likely violated in steady state operation, because events that could significantly perturb the HNF value (e.g., static control rod misalignment) are considered in the safety analyses. However, the DNBR limit may be violated if a DNB limiting event occurs. Thus, the allowed Completion Time of 4 hours provides an acceptable time to restore HNF to within its limits without allowing the plant to remain in an unacceptable condition for an extend ed period of time.
Condition A is modified by a Note that requires that Required Actions A.
2 and A.3 must be completed whenever Condition A is entered.
Thus, if power is not reduced because this Required Action is completed within the 4 hour time period, Required Action A.2 nevertheless requires another measurement and calculation of HNF within 24 hours in accordance with SR 3.2.2.1.
However, if power is reduced below 50% RTP, Required Action A.
3 requires that another determination of HNF must be done prior to exceeding 50% RTP, prior to exceeding 75% RTP, and within 24 hours after reaching or exceeding 95% RTP. In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours. 
A.1.2.1 and A.1.2.2  If the value of HNF is not restored to within its specified limit either by adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in accordance with Required Action A.1
.2.1 and reduce the Power Range Neutron Flux - High to  55% RTP in accordance with Required Action A.
1.2.2. Reducing RTP to < 50% RTP increases the DNB margin and does not likely cause the DNBR limit to be violated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptable low power level with adequate DNBR
margin. The allowed Completion Time of 4 hours for Required Action A.1
.2.1 is consistent with those allowed for in Required Action A.1.1 and provides an acceptable time to reach the required power level from full power operation without allowing the plant to remain in an unacceptable condition for an extended period of time.
The Completion Times of 4 hours for Required Actions A.1.1 and A.1.2.1 are not additive
. FH min margin 445 5 41FH min marginINSERT 5 INSERT 6 INSERT 7 2 41335allowableINSERT 3 2verified3 INSERT 4 B 3.2.2 Insert Page B 3.2.2-4a INSERT 3  The % FH margin is based on the relationship between  FHRM(X,Y)  and the limit, BHDES (X,Y), as follows:
100% x  Y)BHDES(X,Y)(X,HRF  1 =Margin F %MH If the reactor core is operating as designed, then FHRM(X,Y) is less than BHDES (X,Y) and calculation of %FH margin is not required. If the
%FH margin is less than zero, then FHRM(X,Y) is greater than BHDES (X, Y) and the FH(X,Y) limits may not be adequate to prevent exceeding the initial DNB conditions assumed for transients such as a LOFA. BHDES (X,Y) represents the maximum allowable design radial peaking factors which ensures that the initial conditions DNB will be preserved for operation within the LCO limits, and includes allowances for calculational and measurement uncertainties. The FH min margin is the minimum for all core locations examined.
INSERT 4  If FH min margin < 0 is restored to within limits prior to completion of the THERMAL POWER reduction in Required Action A.1, compliance of Required Actions A.3 and A.5 must be met.
24 B 3.2.2 Insert Page B 3.2.2-4b INSERT 5  from RTP by at least RRH % (where RRH = Thermal power reduction required to compensate for each 1% that  FH(X,Y) exceeds its limit)  multiplied times the FH min margin
INSERT 6 trip setpoints, as specified in TS Table 3.3.1-1 by  RRH% multiplied times the FH min margin INSERT 7 by at least RRH% multiplied times the FH min margin 444 HNF B 3.2.2 
WOG STS B 3.2.2-5 Rev. 4.0,  FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES ACTIONS  (continued)
The allowed Completion Time of 72 hours to reset the trip setpoints per
Required Action A.
1.2.2 recognizes that, once power is reduced, the safety analysis assumptions are satisfied and there is no urgent need to reduce the trip setpoints. This is a sensitive operation that may inadvertently trip the Reactor Protection System.
A.2 Once the power level has been reduced to < 50% RTP per Required Action A.1
.2.1, an incore flux map (SR 3.2.2.1) must be obtained and the measured value of HNF verified not to exceed the allowed limit at the lower power level. The unit is provided 20 additional hours to perform this task over and above the 4 hours allowed by either Action A.1.1 or Action A.1
.2.1. The Completion Time of 24 hours is acceptable because of the increase in the DNB margin, which is obtained at lower power levels, and the low probability of having a DNB limiting event within this 24 hour period. Additionally, operating experience has indicated that this Completion Time is sufficient to obtain the incore flux map, perform the required calculations, and evaluate HNF. A.3  Verification that HNF is within its specified limits after an out of limit occurrence ensures that the cause that led to the HNF exceeding its limit is corrected, and that subsequent operation proceeds within the LCO limit. This Action demonstrates that the HNF limit is within the LCO limits prior to exceeding 50% RTP, again prior to exceeding 75% RTP, and within 24 hours after THERMAL POWER is  95% RTP.
This Required Action is modified by a Note that states that THERMAL POWER does not have to be reduced prior to performing this Action.
B.1  When Required Actions A.1
.1 through A.
3 cannot be completed within their required Completion Times, the plant must be placed in a mode in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours. The allowed Completion Time of 6 hours is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.
FH min margin is verified > 0 FHmin margin FHmin margin is > 0 FH min margin FH min margin 1114INSERT 8 4322 2 INSERT 945 45, and B.1, 4C 2allowable 3 >0INSERT 10 B 3.2.2 Insert Page B 3.2.2-5a INSERT 8  by at least RRH% multiplied times the FH min margin INSERT 9  A.4  If the value of FHRM(X,Y) is not restored to within its specified limit, Overtemperarture T K1 (OTT K1) term is required to be reduced by at least TRH multiplied times the FH min margin. The value of TRH is provided in the COLR. Completing Required Action A.4 ensures protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Also, completing Required Action A.4 within the allowed Completion Time of 48 hours is sufficient considering the small likelihood of a limiting transient in this time period.
44 B 3.2.2 Insert Page B 3.2.2-5b INSERT 10 B.1  The %f1(I) margin is based on the relationship between FHRM(X,Y)  and the limit, BRDES (X,Y), as follows:
% f(I)Margin =  1 FHR(X,Y)BRDES(X,Y) x 100%1M If the reactor core is operating as designed, then FHRM(X,Y) is less than BRDES (X,Y) and calculation of %f 1(I) margin is not required. If the
%f1(I) margin is less than zero, then FHRM(X,Y) is greater than    BRDES (X, Y) and the OTT setpoint limits may not be adequate to prevent exceeding DNB requirements.
BRDES (X,Y) represents the maximum allowable design radial peaking factors which ensure that the steady state DNBR limit will be preserved for operation within the LCO limits, including allowances for calculational
and measurement uncertainties Required Action B.1 requires the reduction of the OTT K1 term by at least TRH multiplied by the f 1(I) min margin. TRH is the amount of OTT K1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR. Completing Required Action B.1 within the allowed Completion Time of 48 hours, restricts FH(X,Y) such that even if a transient occurred, DNB requirements are met. The f 1(I) min margin is the minimum % of f 1(I) margin for all core locations examined.
2 HNF B 3.2.2 
WOG STS B 3.2.2-6 Rev. 4.0,  FH(X,Y)1SEQUOYAH UNIT 2 Revision XXX 1BASES
SURVEILLANCE SR  3.2.2.1 REQUIREMENTS The value of HNF is determined by using the movable incore detector system to obtain a flux distribution map. A data reduction computer program then calculates the maximum value of HNF from the measured flux distributions. The measured value of HNF must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the HNF limit. After each refueling, HNF must be determined in MODE 1 prior to exceeding 75%
RTP. This requirement ensures that HNF limits are met at the beginning of each fuel cycle.
  [ The 31 EFPD Frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup. Accordingly, this Frequency is short enough that the HNF limit cannot be exceeded for any significant period of o peration.
OR  The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]
REFERENCES 1. Regulatory Guide 1.77, Rev.
[0], May 1974.
: 2. 10 CFR 50, Appendix A, GDC 26.
: 3. 10 CFR 50.46.
1INSERT 12 4467INSERT 11 B 3.2.2 Insert Page B 3.2.2-6a INSERT 11 SR 3.2.2.1 and SR 3.2.2.2 are modified by a Note. It states that, "Not required to be performed until 12 hours after an equilibrium power level has been achieved at which a power distribution map can be obtained."
SR 3.2.2.1 and SR 3.2.2.2 require using the incore detector system to provide the necessary data to create a power distribution map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level. These surveillances could not be satisfactorily performed if the requirement for performance of the Surveillances was included in MODE 2 prior to entering MODE 1.
In a reload core,HMF(X,Y)could not have previously been measured, therefore, there is a Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of HMF(X,Y) is made at a lower power level at which adequate margin is available before going to 100% RTP.
4 B 3.2.2 Insert Page B 3.2.2-6b INSERT 12 SR  3.2.2.1 and SR 3.2.2.2
In addition to ensuring via Surveillance that the nuclear enthalpy rise hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Y,X(FMH for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an FHRM(X,Y) > BHNOM(X,Y), further consideration is required.
The implications of these extrapolations are considered separately for BHDES(X,Y) and BRDES(X,Y) limits. If the extrapolations of )Y,X(FMH  are unfavorable, additional actions must be taken. These actions are to meet the FH(X,Y) limit with the last HMF(X,Y) increased by the appropriate factor specified in the COLR or to evaluateHMF(X,Y) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These al ternative requirements attempt to prevent FH(X,Y) from exceeding its limit for any significant period of time without detection using the best available data. 
Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.
4 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, BASES, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))  Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 2. The ISTS 3.2.2 LCO and Action A Bases have been modified to add details associated with the relationship between FHRM(X,Y) and BHDES(X,Y) in accordance with NRC Safety Evaluation dated April 27, 1997 (ML013320456).
: 3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.
: 4. Changes have been made to be consistent with changes made to the Specification.
: 5. The ISTS 3.2.2 Bases for A.1.1, 2nd paragraph, contains in part, "Required Action A.2 nevertheless requires another measurement and calculation of HNF within 24 hours in accordance with SR 3.2.2.1." The last paragraph contains a similar statement, " In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours." SQN is deleting the redundant statement in last paragraph.
: 6. ISTS SR 3.2.2.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies for ITS SR 3.2.2.1 under the Surveillance Frequency Control Program.
: 7. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
: 8. Editorial change made for clarification.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))  Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 3 ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.2.3 3/4.2  POWER DISTRIBUTION LIMITS 3/4.2.1  AXIAL FLUX DIFFERENCE (AFD)
LIMITING CONDITION FOR OPERATION
3.2.1  The indicated AXIAL FLUX DIFFERENCE (
AFD) shall be maintained within the limits specified in the COLR. 
APPLICABILITY
:  MODE 1 above 50% RATED THERMAL POWER
* ACTION:  a. With the indicated AXIAL FLUX DIFFERENCE outside of the limits specified in the COLR;    1. Either restore the indicated AFD to within the limits within 15 minutes, or
: 2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 30 minutes and reduce the Power Range Neutron Flux
-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours. b. THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR. 
    *See Special Test Exception 3.10.2 October 4, 1995 SEQUOYAH - UNIT 1 3/4 2-1 Amendment No. 19, 155, 213 Page 1 of 6 LCO 3.2.3 Applicabilit y L01L02A04A02M01 in % flux difference units A03A03ACTION A A02A02 A01ITS ITS 3.2.3 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.1.1  The indicated AXIAL FLUX DIFFERENCE shall be determined to be within its limits during POWER OPERATION above 50% of RATED THERMAL POWER by: 
: a. Monitoring the indicated AFD for each OPERABLE excore channel at least once per 7 days when the AFD Monitor Alarm is OPERABLE
. 
: b. Monitoring and logging the indicated AXIAL FLUX DIFFERENCE for each OPERABLE excore channel at least once per hour for the first 24 hours and at least once per 30 minutes thereafter, when the AXIAL FLUX DIFFERENCE Monitor Alarm is inoperable. The logged values of the indicated AXIAL FLUX DIFFERENCE shall be assumed to exist during the interval preceding each logging. 
4.2.1.2  The indicated AFD shall be considered outside of its limits when at least 2 OPERABLE excore channels are indicating the AFD to be outside the limits. 
December 2, 1986 SEQUOYAH - UNIT 1    3/4 2-2            Amendment No. 51 SR 3.2.3.1 LCO 3.2.3 Note L03Page 2 of 6 LA01In accordance with the Surveillance Frequency Control Program A02A02A02 A01ITS ITS 3.2.3 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
This page left blank intentionally. 
December 23, 1982 SEQUOYAH - UNIT 1    3/4 2-3    Amendment No. 19 Page 3 of 6 A01ITS ITS 3.2.3 3/4.2  POWER DISTRIBUTION LIMITS 
3/4.2.1  AXIAL FLUX DIFFERENCE (AFD)
LIMITING CONDITION FOR OPERATION 3.2.1  The indicated AXIAL FLUX DIFFERENCE (
AFD) shall be maintained within the limits specified in the COLR. 
APPLICABILITY
:  MODE 1 above 50% of RATED THERMAL POWER
*.
ACTION:    a. With the indicated AXIAL FLUX DIFFERENCE outside of the limits specified in the COLR;      1. Either restore the indicated AFD to within the limits within 15 minutes, or
: 2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 30 minutes and reduce the Power Range Neutron Flux
-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours.
: b. THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR. 
      *See Special Test Exception 3.10.2
October 4, 1995 SEQUOYAH - UNIT 2    3/4 2-1      Amendment Nos. 21, 146, 203 Page 4 of 6 LCO 3.2.3 Applicabilit y ACTION A L01L02A04M01 in % flux difference units A03A03A02A02 A01ITS ITS 3.2.3 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.1.1  The indicated AXIAL FLUX DIFFERENCE shall be determined to be within its limits during POWER OPERATION above 50% of RATED THERMAL POWER by: 
: a. Monitoring the indicated AFD for each OPERABLE excore channel at least once per 7 days when the AFD Monitor Alarm is OPERABLE, and
: b. Monitoring and logging the indicated AXIAL FLUX DIFFERENCE for each OPERABLE excore channel at least once per hour for the first 24 hours and at least once per 30 minutes thereafter, when the AXIAL FLUX DIFFERENCE Monitor Alarm is inoperable. The logged values of the indicated AXIAL FLUX DIFFERENCE shall be assumed to exist during the interval preceding each logging. 
4.2.1.2  The indicated AFD shall be considered outside of its limits when at least 2 OPERABLE excore channels are indicating the AFD to be outside the limits.
December 2, 1986 SEQUOYAH - UNIT 2    3/4 2-2            Amendment No. 43
Page 5 of 6 SR 3.2.3.1 LCO 3.2.3 Note L03LA01In accordance with the Surveillance Frequency Control Program A02A02A02 A01ITS ITS 3.2.3
This page intentionally deleted
March 30, 1992 SEQUOYAH - UNIT 2    3/4 2-3            Amendment Nos. 21, 146
Page 6 of 6 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and Unit 2 Page 1 of 4 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal.
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.1 states "The indicated AXIAL FLUX DIFFERENCE (AFD) shall be maintained within the limits specified in the COLR." CTS 3.2.1 ACTION a provides ACTIONs to take when the indicated AFD is outside the limits. CTS 4.2.1.1 requires a determination that the indicated AFD is within limits. CTS 4.2.1.2 states that the indicated AFD shall be considered outside the limits when at least 2 OPERABLE excore channels are indicating the AFD to be outside the limits. ITS LCO 3.2.3 states "The AFD in % flux difference units shall be maintained within the limits specified in the COLR." ITS LCO 3.2.3 is modified by a Note specifying when AFD is considered to be outside the limits. ITS SR 3.2.3.1 requires verification that AFD is within limits. This changes the CTS by deleting "indicated and adding "% flux difference units" to the LCO statement.
The purpose of CTS 3.2.1 is to ensure the AFD remains within the limits specified in the COLR. AFD is the difference in normalized flux signals between the top and bottom excore detectors, therefore, this is a presentation change.
This change is designated as administrative because it does not result in a technical change to the CTS.
A03 CTS 3.2.1 Applicability contains a footnote (footnote *) which states "See Special Test Exception 3.10.2."  ITS 3.2.3 Applicability does not contain this footnote. This changes the CTS by not including Footnote*.
The purpose of Footnote
* is to alert the Technical Specification user that a Special Test Exception exists that may modify the Applicability of this Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative because it does not result in a technical change to the CTS.
A04 CTS 3.2.1 ACTION b states "THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR."  ITS 3.2.3 does not contain a similar requirement. This changes the CTS by eliminating a prohibition contained in the CTS.
This change is acceptable because the requirements have not changed. CTS 3.0.4 and ITS 3.0.4 prohibit entering the MODE of Applicability of a Technical Specification unless the requirements of the LCO are met. CTS 3.2.1 and ITS 3.2.3 are applicable in MODE 1 with THERMAL POWER > 50% RTP (CTS) and  50 RTP (ITS). Therefore, both the CTS and ITS prohibit exceeding DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and Unit 2 Page 2 of 4 50% RTP without the LCO requirements being met. CTS 3.2.1 ACTION b is duplicative of CTS 3.0.4 and ITS 3.0.4 and its elimination does not make a technical change to the Specification. This change is designated as an administrative change because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES
M01 CTS 3.2.1 is applicable in MODE 1 with THERMAL POWER > 50% RTP. ITS 3.2.3 is applicable in MODE 1 with THERMAL POWER  50% RTP. This changes the CTS by requiring LCO 3.2.3 to be met when THERMAL POWER is equal to 50 % RTP.
The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR. When AFD is not within limits, CTS 3.2.1 ACTION a.2, requires reducing THERMAL POWER to less than 50% RTP. This change is acceptable because it aligns the Applicability to the Required Actions. The CTS and ITS Required Action is to reduce THERMAL POWER to less than 50% RTP. When the THERMAL POWER is reduced to this value, it places the core in a condition outside of the Applicability of the LCO. Therefore, changing the Applicability from in MODE 1 with THERMAL POWER > 50% RTP to MODE 1 with THERMAL POWER  50% RTP has no affect on the LCO. This change is designated as more restrictive because it provides additional requirements to the Applicability.
RELOCATED SPECIFICATIONS
None
REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program)  CTS 4.2.1.1.a requires monitoring the indicated AFD for each OPERABLE excore channel at least once per 7days. ITS SR 3.2.3.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program."  This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program.
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and Unit 2 Page 3 of 4 Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES
L01 (Category 4 - Relaxation of Required Action)  CTS 3.2.1 ACTION a.1 requires with the AXIAL FLUX DIFFERENCE (AFD) outside of the limits, to restore the indicated AFD to within the limits within 15 minutes. ITS 3.2.3 does not include a Required Action to restore the indicated AFD to within the limits within 15 minutes. This changes the CTS by not including a specific requirement to restore the AFD to within limits.
The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR. This change is acceptable because the requirement to restore the AFD to within limits has not changed. ITS 3.2.3 allows a Completion Time of 30 minutes to reduce THERMAL POWER to < 50% RTP. During the time that power is being reduced, AFD can be restored to within limits. Per ITS LCO 3.0.2, if the LCO is met prior to expiration of the Completion Time, completion of the Required Actions is not required. This allowance also is provided in CTS 3.0.2.
Therefore, restoration of AFD is always an option and a specific ACTION is not required. This change is designated as less restrictive because additional
Completion Time is provided that was not provided in the CTS.
L02 (Category 4 - Relaxation of Required Action)  CTS 3.2.1 ACTION a.2 states that with the indicated AFD outside of the limits specified in the COLR, reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours. ITS 3.2.3 ACTION A only requires THERMAL POWER to be reduced to less than 50% RTP. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux - High trip setpoints to  55 % of RTP within the next 4 hours.
The purpose of CTS 3.2.1 ACTION a.2 is to reduce THERMAL POWER to the point at which the LCO is met if AFD is not restored within its limit. With the AFD meeting the Technical Specification requirements, further actions are not required to ensure that the assumptions of the safety analyses are met.
Increases in THERMAL POWER are governed by ITS LCO 3.0.4, which requires the LCO to be met prior to entering a MODE or other specified condition in which the LCO applies. Therefore, power increases are prohibited while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L03 (Category 7 - Relaxation of Surveillance Frequency)
CTS 4.2.1.1.a requires the monitoring of the indicated AFD for each OPERABLE excore channel at least once per 7 days when the AFD Monitor Alarm is OPERABLE. CTS 4.2.1.1.b DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and Unit 2 Page 4 of 4 requires the monitoring and logging of the indicated AFD for each OPERABLE excore channel at least once per hour for the first 24 hours and at least once per 30 minutes thereafter, when the AFD Monitor Alarm is inoperable. The logged values of the indicated AFD shall be assumed to exist during the interval preceding each logging. This changes the CTS by eliminating all AFD Surveillance Frequencies based on the OPERABILITY of the AFD Monitor Alarm.
The purpose of ITS 3.2.3 is to ensure that AFD is within its limit. This change is acceptable because the remaining Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of monitoring AFD when the AFD Monitor Alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that AFD is outside of its limit. The AFD Monitor Alarm is for indication only. Its use is not credited in any safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
AFD (RAOC Methodology) 3.2.3B  Westinghouse STS 3.2.3B-1 Rev. 4.0  Amendment XXX SEQUOYAH UNIT 1 11CTS 23.2  POWER DISTRIBUTION LIMITS
3.2.3B AXIAL FLUX DIFFERENCE (AFD)
(Relaxed Axial Offset Control (RAOC)
Methodology)
LCO  3.2.3 B The AFD in % flux difference units shall be maintained within the limits specified in the COLR.
--------------------------------------------NOTE---------------------------------------------
The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits.  --------------------------------------------------------------------------------------------------
APPLICABILITY: MODE 1 with THERMAL POWER  50% RTP.
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME
A. AFD not within limits.
A.1 Reduce THERMAL POWER to < 50% RTP.
30 minutes
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR  3.2.3.1 Verify AFD within limits for each OPERABLE excore channel.
[ 7 days  OR  In accordance
with the
Surveillance Frequency Control Program
]    1333.2.1 Applicabilit y ACTION A.2 4.2.1.2 4.2.1.1.a 1
AFD (RAOC Methodology) 3.2.3B  Westinghouse STS 3.2.3B-1 Rev. 4.0  Amendment XXX SEQUOYAH UNIT 2 11CTS 23.2  POWER DISTRIBUTION LIMITS
3.2.3B AXIAL FLUX DIFFERENCE (AFD)
(Relaxed Axial Offset Control (RAOC)
Methodology)
LCO  3.2.3 B The AFD in % flux difference units shall be maintained within the limits specified in the COLR.
--------------------------------------------NOTE---------------------------------------------
The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits.  --------------------------------------------------------------------------------------------------
APPLICABILITY: MODE 1 with THERMAL POWER  50% RTP.
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME
A. AFD not within limits.
A.1 Reduce THERMAL POWER to < 50% RTP.
30 minutes
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR  3.2.3.1 Verify AFD within limits for each OPERABLE excore channel.
[ 7 days  OR  In accordance
with the
Surveillance Frequency Control Program
]    1333.2.1 Applicabilit y ACTION A.2 4.2.1.2 4.2.1.1.a 1
JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one AFD Specification is used in the Sequoyah Nuclear (SQN) Plant ITS.)  This information is provided in NUREG-1431, Rev. 4.0, to assist in indentifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Constant Axial Offset Control (CAOC) methodology Specification (ISTS 3.2.3A) is not used and is not shown. 
: 2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 3. ISTS SR 3.2.3.1 provides two options for controlling the Frequency of the Surveillance Requirement. SQN is proposing to control the Surveillance Frequency under the Surveillance Frequency Control Program.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-1 Rev. 4.0  211SEQUOYAH UNIT 1 Revision XXX B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.3B  AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC Methodology)
BASES
BACKGROUND The purpose of this LCO is to establish limits on the values of the AFD in order to limit the amount of axial power distribution skewing to either the top or bottom of the core. By limiting the amount of power distribution skewing, core peaking factors are consistent with the assumptions used in the safety analyses. Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in axial power distribution control.
RAOC is a calculational procedure that defines the allowed operational space of the AFD versus THERMAL POWER.
The AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of the AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidate the conclusions of the accident and transient analyses with regard to fuel cladding integrity.
The AFD is monitored on an automatic basis using the unit process computer, which has an AFD monitor alarm. The computer determines the 1 minute average of each of the OPERABLE excore detector outputs
and provides an alarm message immediately if the AFD for two or more OPERABLE excore channels is outside its specified limits.
Although the RAOC defines limits that must be met to satisfy safety analyses, typically an operating scheme, Constant Axial Offset Control (CAOC), is used to control axial power distribution in day to day operation (Ref. 1). CAOC requires that the AFD be controlled within a narrow tolerance band around a burnup dependent target to minimize the variation of axial peaking factors and axial xenon distribution during unit maneuvers.
The CAOC operating space is typically smaller and lies within the RAOC operating space. Control within the CAOC operating space constrains the variation of axial xenon distributions and axial power distributions. RAOC calculations assume a wide range of xenon distributions and then confirm that the resulting power distributions satisfy the requirements of the accident analyses.
1111 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-2 Rev. 4.0  211SEQUOYAH UNIT 1 Revision XXX BASES
APPLICABLE The AFD is a measure of the axial power distribution skewing to either the SAFETY  top or bottom half of the core. The AFD is sensitive to many core related ANALYSES parameters such as control bank positions, core power level, axial burnup, axial xenon distribution, and, to a lesser extent, reactor coolant temperature and boron concentration.
The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements.
The RAOC methodology (Ref.
: 2) establishes a xenon distribution library with tentatively wide AFD limits. One dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requi rements.
The limits on the AFD ensure that the Heat Flux Hot Channel Factor
(FQ(Z)) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents.
The most important Condition 4 event is the LOCA. The most important Condition 3 event is the loss of flow accident. The most i mportant Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents.
Condition 2 accidents simulated to begin from within the AFD limits are used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.
The limits on the AFD satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The shape of the power profile in the axial (i.e., the vertical) direction is largely under the control of the operator through the manual operation of the control banks or automatic motion of control banks. The automatic motion of the control banks is in response to temperature deviations resulting from manual operation of the Chemical and Volume Control System to change boron concentration or from power level changes.
Signals are available to the operator from the Nuclear Instrumentation System (NIS) excore neutron detectors (Ref.
3). Separate signals are taken from the top and bottom detectors. The AFD is defined as the difference in normalized flux signals between the top and bottom excore detectors in each detector well. For convenience, this flux difference is
converted to provide flux difference units expressed as a percentage and labeled as % flux or %I. 1 and 212X, Y, 22s 6, 6 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-3 Rev. 4.0  211SEQUOYAH UNIT 1 Revision XXX BASES LCO  (continued)
The AFD limits are provided in the COLR.
Figure B 3.2.3B-1 shows typical RAOC AFD limits. The AFD limits for RAOC do not depend on the target flux difference. However, the target flux difference may be used to minimize changes in the axial power distribution.
Violating this LCO on the AFD could produce unacceptable consequences if a Condition 2, 3, or 4 event occurs while the AFD is outside its specified limits.
APPLICABILITY The AFD requirements are applicable in MODE 1 greater than or equal to 50% RTP when the combination of THERMAL POWER and core peaking factors are of primary importance in safety analysis.
For AFD limits developed using RAOC methodology, the value of the AFD does not affect the limiting accident consequences with THERMAL POWER < 50% RTP and for lower operating power MODES.
ACTIONS A.1 As an alternative to restoring the AFD to within its specified limits, Required Action A.1 requires a THERMAL POWER reduction to
< 50% RTP. This places the core in a condition for which the value of the AFD is not important in the applicable safety analyses. A Completion Time of 30 minutes is reasonable, based on operating experience, to reach 50% RTP without challenging plant systems.
SURVEILLANCE SR  3.2.3.1 REQUIREMENTS This Surveillance verifies that the AFD, as indicated by the NIS excore channel, is within its specified limits. 
[ The Surveillance Frequency of 7 days is adequate considering that the AFD is monitored by a computer and any deviation from requirements is alarmed. OR  The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]  INSERT 1151343 B 3.2.3 Insert Page B 3.2.3-3 INSERT 1  The AFD limits resulting from analysis of core power distributions relative to the initial condition peaking limits comprise a power-dependant envelope of acceptable AFD values. During steady-state operation, the core normally is controlled to a target AFD within a narrow (approximately +/- 5% AFD) band. However, the limiting AFD values may be somewhat greater than the extremes of the normal operating band.
1 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-4 Rev. 4.0  1Revision XXX 1SEQUOYAH UNIT 1 2BASES
REFERENCES 1.
WCAP-8403 (nonproprietary), "Power Distribution Control and Load Following Procedures," Westinghouse Electric Corporation, September 1974. 
: 2. R. W. Miller et al., "Relaxation of Constant Axial Offset Control:  F Q Surveillance Technical Specification," WCAP
-10217(NP), June 1983. 
: 3. FSAR, Chapter
[15]. 
UFSAR, Section 4.3.2.BAW 10163P-A, Core Operating Limit Methodology for Westinghouse-Designed PWRs, June 1989.
222 Encfosure 2, Volume 7, Rev. 0, Page 195 of 249d,l!=oo-J=d,Lt.l-rFoL&JFd,Fc)o\o100BO604020AFD lffB 3.2.38 ,1 \-/5040-50-30_ L0-20AXIAL FLUXDr FFERENCE
(%)20Figure B 3.2.38-1 (page 1 of 1)AXIAL FLUX DIFFERENCE Acceptable Operation Limits as a Funct'i on of RATED THERMAL P0WERB 3.2.3s-5Volume 7, Rev. 0,@Rev,t4,O t?U(-15,100)
(6, too)PTABLEUNACCE PTABLEOPERATION
-31 ,50PTABL20,50)THIS FIGURI LLUSTRATDO NOTIS FOREnclosure 2,Page 195 of 249 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-1 Rev. 4.0  211SEQUOYAH UNIT 2 Revision XXX B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.3B  AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC Methodology)
BASES
BACKGROUND The purpose of this LCO is to establish limits on the values of the AFD in order to limit the amount of axial power distribution skewing to either the top or bottom of the core. By limiting the amount of power distribution skewing, core peaking factors are consistent with the assumptions used in the safety analyses. Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in axial power distribution control.
RAOC is a calculational procedure that defines the allowed operational space of the AFD versus THERMAL POWER.
The AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of the AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidate the conclusions of the accident and transient analyses with regard to fuel cladding integrity.
The AFD is monitored on an automatic basis using the unit process computer, which has an AFD monitor alarm. The computer determines the 1 minute average of each of the OPERABLE excore detector outputs
and provides an alarm message immediately if the AFD for two or more OPERABLE excore channels is outside its specified limits.
Although the RAOC defines limits that must be met to satisfy safety analyses, typically an operating scheme, Constant Axial Offset Control (CAOC), is used to control axial power distribution in day to day operation (Ref. 1). CAOC requires that the AFD be controlled within a narrow tolerance band around a burnup dependent target to minimize the variation of axial peaking factors and axial xenon distribution during unit maneuvers.
The CAOC operating space is typically smaller and lies within the RAOC operating space. Control within the CAOC operating space constrains the variation of axial xenon distributions and axial power distributions. RAOC calculations assume a wide range of xenon distributions and then confirm that the resulting power distributions satisfy the requirements of the accident analyses.
1111 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-2 Rev. 4.0  211SEQUOYAH UNIT 2 Revision XXX BASES
APPLICABLE The AFD is a measure of the axial power distribution skewing to either the SAFETY  top or bottom half of the core. The AFD is sensitive to many core related ANALYSES parameters such as control bank positions, core power level, axial burnup, axial xenon distribution, and, to a lesser extent, reactor coolant temperature and boron concentration.
The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements.
The RAOC methodology (Ref.
: 2) establishes a xenon distribution library with tentatively wide AFD limits. One dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requi rements.
The limits on the AFD ensure that the Heat Flux Hot Channel Factor
(FQ(Z)) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents.
The most important Condition 4 event is the LOCA. The most important Condition 3 event is the loss of flow accident. The most i mportant Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents.
Condition 2 accidents simulated to begin from within the AFD limits are used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.
The limits on the AFD satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The shape of the power profile in the axial (i.e., the vertical) direction is largely under the control of the operator through the manual operation of the control banks or automatic motion of control banks. The automatic motion of the control banks is in response to temperature deviations resulting from manual operation of the Chemical and Volume Control System to change boron concentration or from power level changes.
Signals are available to the operator from the Nuclear Instrumentation System (NIS) excore neutron detectors (Ref.
3). Separate signals are taken from the top and bottom detectors. The AFD is defined as the difference in normalized flux signals between the top and bottom excore detectors in each detector well. For convenience, this flux difference is
converted to provide flux difference units expressed as a percentage and labeled as % flux or %I. 1 and 212X, Y, 22s 6, 6 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-3 Rev. 4.0  211SEQUOYAH UNIT 2 Revision XXX BASES LCO  (continued)
The AFD limits are provided in the COLR.
Figure B 3.2.3B-1 shows typical RAOC AFD limits. The AFD limits for RAOC do not depend on the target flux difference. However, the target flux difference may be used to minimize changes in the axial power distribution.
Violating this LCO on the AFD could produce unacceptable consequences if a Condition 2, 3, or 4 event occurs while the AFD is outside its specified limits.
APPLICABILITY The AFD requirements are applicable in MODE 1 greater than or equal to 50% RTP when the combination of THERMAL POWER and core peaking factors are of primary importance in safety analysis.
For AFD limits developed using RAOC methodology, the value of the AFD does not affect the limiting accident consequences with THERMAL POWER < 50% RTP and for lower operating power MODES.
ACTIONS A.1 As an alternative to restoring the AFD to within its specified limits, Required Action A.1 requires a THERMAL POWER reduction to
< 50% RTP. This places the core in a condition for which the value of the AFD is not important in the applicable safety analyses. A Completion Time of 30 minutes is reasonable, based on operating experience, to reach 50% RTP without challenging plant systems.
SURVEILLANCE SR  3.2.3.1 REQUIREMENTS This Surveillance verifies that the AFD, as indicated by the NIS excore channel, is within its specified limits. 
[ The Surveillance Frequency of 7 days is adequate considering that the AFD is monitored by a computer and any deviation from requirements is alarmed. OR  The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]  INSERT 1151343 B 3.2.3 Insert Page B 3.2.3-3 INSERT 1  The AFD limits resulting from analysis of core power distributions relative to the initial condition peaking limits comprise a power-dependant envelope of acceptable AFD values. During steady-state operation, the core normally is controlled to a target AFD within a narrow (approximately +/- 5% AFD) band. However, the limiting AFD values may be somewhat greater than the extremes of the normal operating band.
1 AFD (RAOC Methodology)
B 3.2.3B    Westinghouse STS B 3.2.3B-4 Rev. 4.0  1Revision XXX 1SEQUOYAH UNIT 2 2BASES
REFERENCES 1.
WCAP-8403 (nonproprietary), "Power Distribution Control and Load Following Procedures," Westinghouse Electric Corporation, September 1974. 
: 2. R. W. Miller et al., "Relaxation of Constant Axial Offset Control:  F Q Surveillance Technical Specification," WCAP
-10217(NP), June 1983. 
: 3. FSAR, Chapter
[15]. 
UFSAR, Section 4.3.2.BAW 10163P-A, Core Operating Limit Methodology for Westinghouse-Designed PWRs, June 1989.
222
(-15,100)
(6,100)PTABLEUNACCEPTABLE OPERAT ION-31 ,50PTABL20,50)THIS FIGURI LL USTRAT DO NOTIS FOREnclosure 2, Volume 7, Rev. 0, Page 201 of 249Eu-l=Oo-J=d.lrl-Fol-lJFd,q-oo\o100806040AFD -[ nl83-2-3ts-J\r50-50-30_ L0-20AXIAL FLUXDTFFERENCE
(%)40F'i gure B 3.2.38-1 (page 1 of 1)AXIAL FLUX DIFFERENCE Acceptabl e Operati on Li mi tsas a Functi on of RATED THERMAL P0II'IERB 3.2.38-5Volume 7, Rev. 0, Page 201ooSEQUOYAH UNIT 2Enclosure 2,of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one AFD Specification is used in the Sequoyah Nuclear (SQN) Plant ITS.)  This information is provided in NUREG-1431, Rev. 4.0, to assist in indentifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Constant Axial Offset Control (CAOC) methodology Specification (ISTS B 3.2.3A) is not used and is not shown. 
: 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 3. ISTS SR 3.2.3.1 Bases provides two options for controlling the Frequency of Surveillance Requirement. SQN is proposing to control the Surveillance Frequency under the Surveillance Frequency Control Program. Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.
: 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
: 5. ISTS 3.2.3 Bases contains Figure B 3.2.3B-1. This Figure is located in the Sequoyah Nuclear Plant (SQN) COLR. Therefore, this figure is not included in the Bases for ITS 3.2.3.
: 6. Editorial changes made to enhance clarity/consistency.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.
ATTACHMENT 4 ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS 3/4.2.4  QUADRANT POWER TILT RATIO LIMITING CONDITION FOR OPERATION 3.2.4  The QUADRANT POWER TILT RATIO shall not exceed 1.02.
APPLICABILITY:  MODE 1 above 50% of RATED THERMAL POWER
* ACTION: 
: a. With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09:   
: 1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until:
a) Either the QUADRANT POWER TILT RATIO is reduced to within its limit, or    b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.           
: 2. Within 2 hours:
a) Either reduce the QUADRANT POWER TILT RATIO to within its limit
, or b) Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux
-High Trip Setpoints within the next 4 hours
.   
: 3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours
. 
: 4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL power may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified acceptable at 95% or greater RATED THERMAL POWER.
__________________
*See Special Test Exception 3.10.2. 
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-12 Amendment No. 138, 223 be A02A03L0112 hours A04not within limit A05A05L03L02LCO 3.2.4 Applicabilit y ACTION A, ACTION B ACTION A ACTION B ACTION A A03Add proposed Required Actions A.3, A.4, A.5, and A.6 and proposed ACTION B Page 1 of 6 or equal to A06after each QPTR determination M01 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS ACTION:  (Continued)
: b. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to misalignment of either a shutdown or control rod
:   
: 1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until:
a) Either the QUADRANT POWER TILT RATIO is reduced to within its limit, or    b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER. 
: 2. Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 within 30 minutes. 3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 2 hours after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours and reduce the Power Range Neutron Flux-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours
. 4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified acceptable at 95% or greater RATED THERMAL POWER.
: c. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod
: 
: 1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until:
a) Either the QUADRANT POWER TILT RATIO is reduced to within its limit, or    b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER. 
April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-13 Amendment No. 138, 223 A05L0112 hours A04not within limit L03A0412 hoursnot within limit L01L042 hours A05ACTION A, ACTION B ACTION A ACTION B ACTION A, ACTION B ACTION A ACTION B ACTION A Page 2 of 6 or equal to A06or equal to A06 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS ACTION:  (Continued)
: 2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 2 hours and reduce the Power Range Neutron Flux
-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours. 3. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for l2 hours or until verified at 95% or greater RATED THERMAL POWER.
: d. With the indicated QUADRANT POWER TILT RATIO not confirmed as required by Surveillance Requirement 4.2.4.2, reduce THERMAL POWER to less than 75 percent RATED THERMAL POWER within 6 hours.
: e. With the QUADRANT POWER TILT RATIO not monitored as required by Surveillance Requirement 4.2.4.1, reduce THERMAL POWER to less than 50 percent of RATED THERMAL POWER within the next 6 hours.
SURVEILLANCE REQUIREMENTS 4.2.4.1  The QUADRANT POWER TILT RATIO shall be determined to be within the limit above 50% of RATED THERMAL POWER by: 
: a. Calculating the ratio at least once per 7 days when the alarm is OPERABLE.   
: b. Calculating the ratio at least once per 12 hours during steady state operation when the alarm is inoperable
.
4.2.4.2  The QUADRANT POWER TILT RATIO shall be determined to be within the limit when above 75 percent of RATED THERMAL POWER with one Power Range Channel inoperable by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained from the 4 pairs of symmetric thimble locations or from performance of a full core map, is consistent with the indicated QUADRANT POWER TILT RATIO at least once per 12 hours.   
April 11, 2005 SEQUOYAH - UNIT 1 3/4 2-14 Amendment Nos. 135, 138, 301 L03L05L05L06Add proposed SR 3.2.4.1 Notes 1 and 2 LA01LA01LA02SR 3.2.4.1 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program L07Add proposed SR 3.2.4.2 Note SR 3.2.4.2 SR 3.2.4.2  Note SR 3.2.4.2 L08Page 3 of 6 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS 3/4.2.4  QUADRANT POWER TILT RATIO    LIMITING CONDITION FOR OPERATION 3.2.4  The QUADRANT POWER TILT RATIO shall not exceed 1.02.
APPLICABILITY:  MODE 1 above 50% of RATED THERMAL POWER
* ACTION:    a. With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09:       
: 1. Calculate the QUARANT POWER TILT RATIO at least once per hour until either:
a) The QUADRANT POWER TILT RATIO is reduced to within its limit, or          b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.          2. Within 2 hours either:          a) Reduce the QUADRANT POWER TILT RATIO to within its limit
, or        b) Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux
-High Trip Setpoints within the next 4 hours.       
: 3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours.     
: 4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL power may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified acceptable at 95% or greater RATED THERMAL POWER.
* See Special Test Exception 3.10.2. 
April 21, 1997 SEQUOYAH - UNIT 2    3/4 2-10            Amendment No. 130, 214 be A02A03L0112 hoursA04A05L03LCO 3.2.4 Applicabilit y ACTION A, ACTION B ACTION A ACTION B ACTION A A03Add proposed Required Actions A.3, A.4, A.5, and A.6 and proposed ACTION B L02A05Page 4 of 6 or equal to A06not within limit after each QPTR determination M01 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS
ACTION: (Continued)   
: b. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to misalignment of either a shutdown or control rod:       
: 1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until either:          a) The QUADRANT POWER TILT RATIO is reduced to within its limit, or          b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.       
: 2. Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 within
30 minutes.          3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 2 hours after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours and reduce the Power Range Neutron Flux-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours.          4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified acceptable at 95% or greater RATED THERMAL POWER. 
: c. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod
:       
: 1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until either:          a) The QUADRANT POWER TILT RATIO is reduced to within its limit, or          b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER. 
April 21, 1997 SEQUOYAH - UNIT 2    3/4 2-11            Amendment No. 130, 214 A05L0112 hours A04not within limit L03A0412 hoursnot within limit L01A05ACTION A, ACTION B ACTION A ACTION B ACTION A, ACTION B ACTION A ACTION B ACTION A L042 hours Page 5 of 6 or equal to A06or equal to A06 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS
ACTION:  (Continued)   
: 2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 2 hours and reduce the Power Range Neutron Flux
-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours. 
: 3. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified at 95% or greater RATED THERMAL POWER. 
: d. With the indicated QUADRANT POWER TILT RATIO not confirmed as required by Surveillance Requirement 4.2.4.2, reduce TH ERMAL POWER to less than 75 percent RATED THERMAL POWER within 6 hours.      e. With the QUADRANT POWER TILT RATIO not monitored as required by Surveillance Requirement 4.2.4.1, reduce THERMAL POWER to less than 50 percent of RATED THERMAL POWER within the next 6 hours.        SURVEILLANCE REQUIREMENTS 4.2.4.1  The QUADRANT POWER TILT RATIO shall be determined to be within the limit above 50% of RATED THERMAL POWER by: 
: a. Calculating the ratio at least once per 7 days when the alarm is OPERABLE.   
: b. Calculating the ratio at least once per 12 hours during steady state operation when the alarm is inoperable.
4.2.4.2  The QUADRANT POWER TILT RATIO shall be determined to be within the limit when above 75 percent of RATED THERMAL POWER with one Power Range channel inoperable by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained from 4 pairs of symmetric thimble locations or from performance of a full core map, is consistent with the indicated QUADRANT POWER TILT RATIO at least once per 12 hours.   
April 11, 2005 SEQUOYAH - UNIT 2 3/4 2-12 Amendment No. 122, 130, 290 L03L05L05L06Add proposed SR 3.2.4.1 Notes 1 and 2 LA01LA01LA02SR 3.2.4.1 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program L07Add proposed SR 3.2.4.2 Note SR 3.2.4.2 SR 3.2.4.2 NoteSR 3.2.4.2 L08Page 6 of 6 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 1 of 9 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this
submittal.
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.4 states "The QUADRANT POWER TILT RATIO shall not exceed 1.02."  ITS LCO 3.2.4 states "The QPTR shall be  1.02. This changes the CTS by requiring the QPTR to be less than or equal to 1.02.
This change is acceptable because nothing has changed. This is a presentation change for clarity. Stating that the QPTR shall be less than or equal to 1.02 is clearer than stating that it shall not exceed. This change is designated as an administrative change because it does not result in a technical change to the CTS.
A03 CTS 3.2.4 Applicability contains a footnote (footnote *) that states "See Special Test Exceptions 3.10.2."  ITS 3.2.4 Applicability does not contain this footnote.
This changes the CTS by not including the footnote reference.
The purpose of CTS 3.2.4 footnote
* is to alert the user that a Special Test Exception exists which may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as an administrative change since it does not result in a technical change to the CTS.
A04 CTS 3.2.4 ACTION a states "With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09."  CTS 3.2.4 ACTION b states "With the QUADRANT POWER TILT RATIO determined to exceed 1.09 resulting from misalignment of either a shutdown or control rod."  CTS 3.2.4 ACTION c states "With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod."  ITS 3.2.4 ACTION A states "QPTR not within limit."  This changes the CTS by specifying that action must be taken when the QPTR is not within limits.  (See DOCS L02, L03, and L04 for changes to the compensatory
measures.)
The purpose of CTS 3.2.4 is to provide compensatory actions when the QPTR exceeds 1.02. ITS 3.2.4 continues to provide compensatory actions when the QPTR exceeds 1.02. This change is a presentation change. This change is designated as an administrative change since it does not result in technical changes to the CTS.
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 2 of 9 A05 CTS 3.2.4 ACTION a.1.a) states that with QPTR greater than 1.02 and less than or equal to 1.09, calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RTP. CTS 3.2.4 ACTION a.2.a) states within 2 hours, either QUADRANT POWER TILT RATIO is reduced to within its limit or reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours. CTS 3.2.4 ACTION b.1.a) states that with QPTR greater than 1.09 due to misalignment of either a shutdown or control rod, calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within its limit or THEMAL POWER is reduced to less than 50% of RTP. CTS 3.2.4 ACTION c.1.a) states that with QPTR greater than 1.09 due to causes other than the misalignment of either a shutdown or control rod, calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RTP. ITS 3.2.4 does not contain a Required Action stating QPTR must be reduced to within its limit. This changes the CTS by not specifically stating that the restoration of QUADRANT POWER TILT RATIO is required.
This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as an administrative change since it does not result in technical changes to the CTS.
A06 CTS 3.2.4 LCO APPLICABLITY is MODE 1 above 50% RTP. CTS 3.2.4 ACTION  a.1.b, ACTION b.1.b and ACTION c.1.b state, in part, to calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within limit, or THERMAL POWER is reduced to less than 50% of RTP. ITS 3.2.4 LCO APPLICABILITY is MODE 1 with THERMAL POWER >50% RTP. ITS 3.2.4 CONDITION B states that when the Required Action and associated Completion Time are not met to reduce THERMAL POWER to  50% RTP. This changes the CTS requirement of reducing power and exiting the MODE of APPLICABILITY  to a value of < 50%
RTP and allow stopping at a value of 50% RTP.
This change is acceptable because the technical requirements have not changed. LCO 3.0.2 states that that when a Required Action to restore variables within limits is not met, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. In this case, both CTS and ITS require a reduction of power to exit the MODE of APPLICABILITY when compliance with the LCO is not met within the prescribed amount of time. Once the MODE of APPLICABILITY for LCO 3.2.4 is exited(>50%), the new power level(50%) is no longer controlled by this specification. This change is designated as an administrative change since it does not result in technical changes to CTS LCO 3.2.4.
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 3 of 9 MORE RESTRICTIVE CHANGES M01 CTS 3.2.4 ACTION a.2.b states in part, within 2 hours, reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02. ITS 3.2.4 Required Action
A.1 has a similar requirement to reduce THERMAL POWER  3% from RTP for each 1% of QPTR > 1.02. The Completion Time for ITS 3.2.4 Required Action A.1 is 2 hours after each QPTR determination. This changes the CTS by specifically requiring a power reduction, if applicable, after each QPTR
determination.
The purpose CTS 3.2.4 ACTION a.2.b is to commence a power level reduction to ensure that core power distributions that violate fuel design criteria are minimized. The maximum allowable power level initially determined by ITS 3.2.4 Required Action A.1 may be affected by subsequent determinations of QPTR.
However, any increases in QPTR would require additional power reductions within 2 hours of each QPTR determination, if necessary to comply with the decreased maximum allowable power level. This change is designated as more restrictive because it adds required actions to the CTS.
RELOCATED SPECIFICATIONS
None 
REMOVED DETAIL CHANGES
LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program)  CTS 4.2.4.1 states, in part, the QPTR shall be determined at least once per 7 days by calculating the ratio. CTS 4.2.4.2 states, in part, the QPTR shall be determined, at least once per 12 hours, by using the movable incore detectors. ITS SR 3.2.4.1 and SR 3.2.4.2 require similar Surveillances and specify the periodic Frequencies as, "In accordance with the Surveillance Frequency Control Program."  This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program.
The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 4 of 9 associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)  CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained from the 4 pairs of
symmetric thimble locations or from performance of a full core map, is consistent with the indicated QUADRANT POWER TILT RATIO. ITS SR 3.2.4.2 requires verifying QPTR is within limit using the movable incore detectors. This changes the CTS by moving the procedural details for meeting the Surveillance to the Bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide protection of public health and safety. The ITS still retains the requirement that the QPTR is verified to be within the limits using the movable incore detectors. The details relating to system design do not need to appear in the specification in order for the requirement to apply. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LESS RESTRICTIVE CHANGES
L01 (Category 3 - Relaxation of Completion Time)  CTS 3.2.4 ACTIONS a.1, b.1, and c.1 require calculating the QPTR at least once per hour. ITS 3.2.4 ACTION A (Required Action A.2 and associated Completion Time) require, in part, that when the QPTR is not within limit to determine QPTR once per 12 hours. This changes the CTS by requiring the determination of QPTR to be done once per 12 hours instead of once per hour.
The purpose of CTS 3.2.4 ACTIONS a.1, b.1, and c.1 is to verify QPTR until it is brought to within limit or reactor power has been lowered to less than or equal to 50% RTP. This action is taken because with the QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters
such as F Q (X, Y, Z) and FH (X,Y) may not be within their limits. In addition to ITS 3.2.4 Required Action A.2 Completion Time the other Required Actions and associated Completion Times of Condition A are consistent with safe operation, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. In addition to reducing reactor power by greater than or equal to 3% for each 1% QPTR exceeds 1.02, ITS 3.2.4 requires a determination of QPTR once per 12 hours. Additionally, ITS 3.2.4 requires DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 5 of 9 measurement of F Q (X, Y, Z) and FH (X,Y) within 24 hours and every 7 days thereafter to verify that those parameters are within limit. Furthermore, ITS 3.2.4 requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, ITS 3.2.4 allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures the core is operated within the safety analyses. This change is designated as less restrictive because less stringent Completion Times are being applied in the ITS than were applied in
the CTS.
L02 (Category 4 - Relaxation of Required Action)  CTS 3.2.4 ACTION a.2.b) requires that when QPTR is in excess of 1.02 but less than or equal to 1.09, to reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours. ITS 3.2.4 Required Action A.1 includes the requirement to reduce the THERMAL POWER, but does not include a requirement to reduce the Power Range Neutron Flux-High Trip Setpoints. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux-High Trip Setpoints.
The purpose of CTS 3.2.4 ACTION a.2.b) is to reduce THERMAL POWER to increase the margin to the core power distribution limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. With THERMAL POWER reduced by 3% from RTP for each 1% QPTR is greater than 1.02, further actions are not required to ensure that THERMAL POWER is not increased. Power increases are administratively prohibited by the Technical Specification while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L03 (Category 4 - Relaxation of Required Action)  CTS 3.2.4 ACTION a.3 states "Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours."  CTS 3.2.4 ACTION b.3 and b.4 contain the same compensatory actions as CTS ACTION a.3 but requires the QPTR to be within limits within 2 hours. CTS 3.2.4 ACTIONS a.4, b.4, and c.3 state "Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL power may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours or until verified acceptable at 95% or greater RATED THERMAL POWER."
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 6 of 9 ITS 3.2.4 Required Action A.3 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.1.3, SR 3.2.2.1, SR 3.2.2.2 within 24 hours after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 and once per 7 days thereafter. ITS 3.2.4 Required Action A.4 requires reevaluation of the safety analyses and confirmation that the results remain valid for duration of operation under this condition prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.5 requires normalization of excore detectors to restore QPTR to within limit prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.6 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.1.3, SR 3.2.2.1, SR 3.2.2.2 within 24 hours after achieving equilibrium conditions at RTP not to exceed 48 hours after increasing THERMAL POWER above the limit of Required Action A.1. Additionally, ITS 3.2.4 Required Action A.5 contains two Notes and ITS 3.2.4 Required Action A.6 contains one Note. ITS 3.2.4 Required Action A.5 Note 1 states "Perform Required Action A.5 only after Required Action A.4 is completed."  ITS 3.2.4 Required Action A.5 Note 2 states "Required Action A.6 shall be completed whenever Required Action A.5 is performed."  ITS 3.2.4 Required Action A.6 Note states "Perform Required Action A.6 only after Required Action A.5 is completed."  Furthermore, ITS 3.2.4 ACTION B states that with a Required Action and associated Completion Time (of
Condition A) not met, reduce THERMAL POWER to  50% RTP within 4 hours. This changes the CTS by eliminating requirements to be  50% RTP within a specified time of exceeding the LCO and substituting compensatory measures in ITS 3.2.4 ACTION A, which if not met, results in a reduction in power per ITS 3.2.4 ACTION B.
The purpose of the CTS actions is to lower reactor power to less than 50% when QPTR is not within its limit and cannot be restored to within its limit within a reasonable time period. In addition, the Power Range Neutron Flux-High Trip setpoints are reduced to  55% to ensure that reactor power is not inadvertently increased without QPTR within its limit. This action is taken because with QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters such as F Q (X, Y, Z) and FH (X,Y) may not be within their limits. A QPTR not within limit may not be an unacceptable condition if the critical core parameters such as F Q (X, Y, Z) and FH (X,Y) are within their limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. ITS 3.2.4 requires measurement of FQ (X, Y, Z) and FH (X,Y) within 24 hours and every 7 days thereafter to verify that those parameters are within limit. In addition, ITS 3.2.4 requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, ITS 3.2.4 allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures the core is operated within the safety analyses. This change is designated as less restrictive because less DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 7 of 9 stringent Required Actions are being applied in the ITS than were applied in the CTS.
L04 (Category 3 - Relaxation of Completion Time)  CTS 3.2.4 ACTION b.2, applies when QPTR is greater than 1.09 due to misalignment of either a shutdown or control rod, requires a THERMAL POWER reduction from RATED THERMAL POWER for each 1% of indicated QPTR in excess of 1.02 within 30 minutes. ITS 3.2.4 Required Action A.1 requires a THERMAL POWER reduction of 3%
from RTP for each 1% QPTR exceeds 1.02 within 2 hours. This changes the CTS by allowing 2 hours to perform the required power reduction.
The purpose of CTS 3.2.4 is to provide appropriate compensatory actions for QPTR greater than that assumed in the safety analyses. This change is acceptable because the completion Time is consistent with safe operation under the specified Condition, considering other indications available to the operator, a reasonable time for restoring compliance with the LCO, and the low probability of a DBA occurring during the restoration period. Under the ITS, a QPTR of 1.09 would require THERMAL POWER to be reduced to  79% RTP. This will provide sufficient thermal margin to account for the radial power distribution. In addition, the 2 hour time limit is consistent with the CTS time allowed when QPTR is
> 1.02 but  1.09. This change is designated as less restrictive because additional time is allowed to decrease power than was allowed in the CTS.
L05 (Category 4 - Relaxation of Required Action)  CTS 3.2.4 ACTION d states "With the indicated QUADRANT POWER TILT RATIO not confirmed as required by Surveillance Requirement 4.2.4.2, reduce THERMAL POWER to less than 75
percent RATED THERMAL POWER within 6 hours."  CTS 3.2.4 ACTION e states "With the QUADRANT POWER TILT RATIO not monitored as required by Surveillance Requirement 4.2.4.1, reduce THERMAL POWER to less than 50 percent of RATED THERMAL POWER within the next 6 hours."  ITS 3.2.4 does not contain these ACTIONS. This changes the CTS by not requiring RTP to be reduced to less than 75 percent, within 6 hours, when the QPTR is not confirmed and not requiring RTP to be reduced to less than 50 percent, within 6 hours, when the QPTR is not monitored.
The purpose of CTS 3.2.4 ACTIONs d and e is to provide compensatory actions to take when Surveillance 4.2.4.1 has not been met or Surveillance 4.2.4.2 have not been performed. ITS 3.2.4 does not contain these ACTIONS since ITS SR 3.0.1 and SR 3.0.3 provide guidance on missed and not performed Surveillances. ITS SR 3.0.1 states, in part, that failure to meet a Surveillance is a failure to meet the LCO. Therefore, the compensatory actions for ITS LCO 3.2.4 would be entered. Additionally, ITS SR 3.0.1 states, in part, that failure to perform a Surveillance shall be failure to meet the LCO, but allows an exception as provided in SR 3.0.3. ITS SR 3.0.3 allows a delayed entry into the LCO to perform the Surveillance. If the Surveillance is not performed in this time period, then the LCO must be declared not met and the compensatory actions for ITS LCO 3.2.4 entered. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 8 of 9 L06 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.2.4.1.a states, in part, that the QPTR shall be determined to be within the limit by calculating the ratio at least once per 7 days. ITS SR 3.2.4.1 requires the same determination, but includes two Notes. ITS SR 3.2.4.1 Note 1 states when the input from one Power Range Neutron Flux channel is inoperable, the remaining three power range channels can be used for calculating QPTR as long as THERMAL POWER is less than or equal to 75% RTP. ITS SR 3.2.4.1 Note 2 states that SR 3.2.4.2 may be performed in lieu of this Surveillance. This changes the CTS by allowing use of three Power Range Neutron Flux channels for calculating the QPTR and by allowing the movable incore detectors to be used to determine QPTR instead of the excore detectors.
The purpose of CTS 4.2.4.1.a is to periodically verify that QPTR is within limit. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are sufficient for verification that the parameters meet the LCO. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. With only one Power Range Neutron Flux channel inoperable, QPTR can still be verified by calculation as long as three Power Range Neutron Flux channels are OPERABLE and THERMAL POWER is less than or equal to 75% RTP. The movable incore detector system provides a more accurate indication of QPTR than the excore detectors. In fact, the movable incore detector system is used to calibrate the excore detectors. Therefore, allowing the use of the movable incore detector system or excore detector is appropriate. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
L07 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.2.4.1.a states that the QPTR shall be determined to be within the limit by calculating the ratio at least once per 7 days when the alarm is OPERABLE.
CTS 4.2.4.1.b states that the QPTR shall be determined to be within the limit by calculating the ratio at least once per 12 hours during steady state operation when the alarm is inoperable. ITS SR 3.2.4.1 requires verification that the QPTR is within limits every 7 days. This changes the CTS by eliminating the requirement to verify the QPTR more frequently when the QPTR alarm is inoperable.
The purpose of CTS 4.2.4.1.a and 4.2.4.1.b is to periodically verify that the QPTR is within limit. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the frequency of QPTR verification when the QPTR alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that the QPTR is outside its limit. The QPTR alarm is for indication only. It use is not credited in any of the safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
L08 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.2.4.2  states, in part, that the QPTR shall be determined to be within the limit when above 75 percent of RATED THERMAL POWER with one Power Range Channel inoperable by using the movable incore detectors. ITS DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 9 of 9 SR 3.2.4.2 requires determination of the QPTR by use of the movable incore detectors. Additionally, ITS SR 3.2.4.2 contains a Note which states "Not required to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER
> 75% RTP."  This changes the CTS by not requiring the Surveillance to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable.
The purpose of CTS 4.2.4.2 is to verify that the QPTR is within limit using the movable incore detectors. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. Therefore, the movable incore detector system provides a more accurate indication of QPTR than the excore detectors. The ITS SR 3.2.4.2 allowance, for not requiring performance of the Surveillance for 12 hours after input when one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER > 75% RTP, is required to allow time for the movable incore detectors to perform the initial measurement of the QPTR before the Surveillance is declared not met. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
QPTR 3.2.4  Westinghouse STS 3.2.4-1 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 1 23.2  POWER DISTRIBUTION LIMITS
3.2.4 QUADRANT POWER TILT RATIO (QPTR)
LCO  3.2.4  The QPTR shall be  1.02. 
APPLICABILITY: MODE 1 with THERMAL POWER > 50% RTP.
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME A. QPTR not within limit.
A.1 Reduce THERMAL POWER  3% from RTP for each 1% of QPTR > 1.00. AND  A.2 Determine QPTR.
AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1. 
AND 2 hours after each QPTR determination
Once per 12 hours
24 hours after achieving equilibrium conditions from a
THERMAL POWER reduction per
Required Action A.1
AND  Once per 7 days
thereafter 3.2.4 Applicabilit y ACTION a, ACTION b, ACTION c DOC M01 121.02SR 3.2.1.3,  SR 3.2.2.1 and SR 3.2.2.2.
DOC L03 QPTR 3.2.4  Westinghouse STS 3.2.4-2 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 1 2ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A.4  Reevaluate safety analyses and confirm results remain valid for duration of operation under this condition.
AND A.5 -------------NOTES-------------  1. Perform Required Action A.5 only after
Required Action A.4 is
completed.
: 2. Required Action A.6 shall be completed whenever Required
Action A.5 is performed.  -------------------------------------
Normalize excore detectors to restore QPTR to within limit.
AND  A.6 ---------------NOTE--------------
Perform Required Action A.6 only after Required Action A.5 is completed.  -------------------------------------
Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.
Prior to increasing
THERMAL POWER
above the limit of Required Action A.1
Prior to increasing
THERMAL POWER
above the limit of
Required Action A.1
Within 24 hours after achieving equilibrium conditions at RTP not to exceed 48 hours after increasing THERMAL
POWER above the limit
of Required Action A.1 DOC L03 1SR 3.2.1.3,  SR 3.2.2.1 and SR 3.2.2.2.
DOC L03 DOC L03 QPTR 3.2.4  Westinghouse STS 3.2.4-3 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 1 2ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.
B.1 Reduce THERMAL POWER to  50% RTP.
4 hours 
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
SR  3.2.4.1 ------------------------------NOTES-----------------------------
: 1. With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channels can be used for calculating QPTR.
: 2. SR 3.2.4.2 may be performed in lieu of this Surveillance.  ---------------------------------------------------------------------
Verify QPTR is within limit by calculation.
  [ 7 days  OR In accordance
with the Surveillance Frequency
Control Program
]  ACTION a, ACTION b, ACTION c 4.2.4.1 DOC L06 33 QPTR 3.2.4  Westinghouse STS 3.2.4-4 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 1 2SURVEILLANCE REQUIREMENTS  (continued)
SURVEILLANCE FREQUENCY SR  3.2.4.2 -------------------------------NOTE------------------------------
Not required to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER
> 75% RTP.  ---------------------------------------------------------------------
Verify QPTR is within limit using the movable incore detectors.
[ 12 hours  OR In accordance
with the
Surveillance
Frequency Control Program
]    334.2.4.2, DOC L08 QPTR 3.2.4  Westinghouse STS 3.2.4-1 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 2 23.2  POWER DISTRIBUTION LIMITS
3.2.4 QUADRANT POWER TILT RATIO (QPTR)
LCO  3.2.4  The QPTR shall be  1.02. 
APPLICABILITY: MODE 1 with THERMAL POWER > 50% RTP.
ACTIONS  CONDITION REQUIRED ACTION COMPLETION TIME A. QPTR not within limit.
A.1 Reduce THERMAL POWER  3% from RTP for each 1% of QPTR > 1.00. AND  A.2 Determine QPTR.
AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1. 
AND 2 hours after each QPTR determination
Once per 12 hours
24 hours after achieving equilibrium conditions from a
THERMAL POWER reduction per
Required Action A.1
AND  Once per 7 days
thereafter 3.2.4 Applicabilit y ACTION a, ACTION b, ACTION c DOC M01 121.02SR 3.2.1.3,  SR 3.2.2.1 and SR 3.2.2.2.
DOC L03 QPTR 3.2.4  Westinghouse STS 3.2.4-2 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 2 2ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME A.4  Reevaluate safety analyses and confirm results remain valid for duration of operation under this condition.
AND A.5 -------------NOTES-------------  1. Perform Required Action A.5 only after
Required Action A.4 is
completed.
: 2. Required Action A.6 shall be completed whenever Required
Action A.5 is performed.  -------------------------------------
Normalize excore detectors to restore QPTR to within limit.
AND  A.6 ---------------NOTE--------------
Perform Required Action A.6 only after Required Action A.5 is completed.  -------------------------------------
Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.
Prior to increasing
THERMAL POWER
above the limit of Required Action A.1
Prior to increasing
THERMAL POWER
above the limit of
Required Action A.1
Within 24 hours after achieving equilibrium conditions at RTP not to exceed 48 hours after increasing THERMAL
POWER above the limit
of Required Action A.1 DOC L03 1SR 3.2.1.3,  SR 3.2.2.1 and SR 3.2.2.2.
DOC L03 DOC L03 QPTR 3.2.4  Westinghouse STS 3.2.4-3 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 2 2ACTIONS  (continued)
CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.
B.1 Reduce THERMAL POWER to  50% RTP.
4 hours 
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY
SR  3.2.4.1 ------------------------------NOTES-----------------------------
: 1. With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channels can be used for calculating QPTR.
: 2. SR 3.2.4.2 may be performed in lieu of this Surveillance.  ---------------------------------------------------------------------
Verify QPTR is within limit by calculation.
  [ 7 days  OR In accordance
with the Surveillance Frequency
Control Program
]  ACTION a, ACTION b, ACTION c 4.2.4.1 DOC L06 33 QPTR 3.2.4  Westinghouse STS 3.2.4-4 Rev. 4.0  CTS Amendment XXX SEQUOYAH UNIT 2 2SURVEILLANCE REQUIREMENTS  (continued)
SURVEILLANCE FREQUENCY SR  3.2.4.2 -------------------------------NOTE------------------------------
Not required to be performed until 12 hours after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER
> 75% RTP.  ---------------------------------------------------------------------
Verify QPTR is within limit using the movable incore detectors.
[ 12 hours  OR In accordance
with the
Surveillance
Frequency Control Program
]    334.2.4.2, DOC L08 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made to be consistent with changes made to Specification 3.2.1 and 3.2.2. 2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
: 3. ISTS SR 3.2.4.1 and SR 3.2.4.2 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
QPTR B 3.2.4    Westinghouse STS B 3.2.4-1 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 1 B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.4  QUADRANT POWER TILT RATIO (QPTR)
BASES BACKGROUND The QPTR limit ensures that the gross radial power distribution remains consistent with the design values used in the safety analyses. Precise radial power distribution measurements are made during startup testing, after refueling, and periodically during power operation.
The power density at any point in the core must be limited so that the fuel design criteria are maintained. Together, LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, and LCO 3.1.6, "Control Rod Insertion Limits," provide limits on process variables that characterize and control the three dimensional power distribution of the reactor core. Control of these variables ensures that the core operates within the fuel design criteria and that the power distribution remains within the bounds used in
the safety analyses.
APPLICABLE  This LCO precludes core power distributions that violate the following fuel  SAFETY  design criteria:
ANALYSES  a. During a large break loss of coolant accident, the peak cladding temperature must not exceed 2200&deg;F (Ref. 1),
: b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 departure from nucleate boiling (DNB) criterion) that the hot fuel rod in the core does not experience a DNB condition,
: c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
: d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (Ref. 3).
The LCO limits on the AFD, the QPTR, the Heat Flux Hot Channel Factor (FQ(Z)), the Nuclear Enthalpy Rise Hot Channel Factor
)F(HN, and control bank insertion are established to preclude core power distributions that exceed the safety analyses limits.
The QPTR limits ensure that HNF and FQ(Z) remain below their limiting values by preventing an undetected change in the gross radial power distribution. X, Y, (FH(X, Y)) X, Y, FH(X, Y) 111 QPTR B 3.2.4    Westinghouse STS B 3.2.4-2 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 1 BASES
APPLICABLE SAFETY ANALYSES  (continued)
In MODE 1, the HNF and FQ(Z) limits must be maintained to preclude core power distributions from exceeding design limits assumed in the safety analyses.
The QPTR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The QPTR limit of 1.02, at which corrective action is required, provides a margin of protection for both the DNB ratio and linear heat generation rate contributing to excessive power peaks resulting from X-Y plane power tilts. A limiting QPTR of 1.02 can be tolerated before the margin for uncertainty in F Q(Z) and )F(HN is possibly challenged.
APPLICABILITY The QPTR limit must be maintained in MODE 1 with THERMAL POWER > 50% RTP to prevent core power distributions from exceeding the design limits. Applicability in MODE 1  50% RTP and in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require the implementation of a QPTR limit on the distribution of core power. The QPTR limit in these conditions is, therefore, not important. Note that the HNF and FQ(Z) LCOs still apply, but allow progressively higher peaking factors at 50% RTP or lower.
ACTIONS A.1 With the QPTR exceeding its limit, a power level reduction of 3% RTP for each 1% by which the QPTR exceeds 1.00 is a conservative tradeoff of total core power with peak linear power. The Completion Time of 2 hours allows sufficient time to identify the cause and correct the tilt. Note that the power reduction itself may cause a change in the tilted condition.
The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of QPTR.
Increases in QPTR would require power reduction within 2 hours of QPTR determination, if necessary to comply with the decreased maximum allowable power level. Decreases in QPTR would allow increasing the maximum allowable power level and increasing power up to this revised limit.
X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111.021 QPTR B 3.2.4    Westinghouse STS B 3.2.4-3 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 1 BASES
ACTIONS  (continued)
A.2 After completion of Required Action A.1, the QPTR alarm may still be in its alarmed state. As such, any additional changes in the QPTR are detected by requiring a check of the QPTR once per 12 hours thereafter.
A 12 hour Completion Time is sufficient because any additional change in QPTR would be relatively slow.
A.3  The peaking factors F Q(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are of primary importance in ensuring that the power distribution remains consistent with the initial conditions used in the safety analyses. Performing SRs on HNF and FQ(Z) within the Completion Time of 24 hours after achieving equilibrium conditions from a Thermal Power reduction per Required Action A.1 ensures that these primary indicators of power distribution are within their respective limits. Equilibrium conditions are achieved when the core is sufficiently stable at intended operating conditions to support flux mapping. A Completion Time of 24 hours after achieving equilibrium conditions from Thermal Power reduction per Required Action A.1 takes into consideration the rate at which peaking factors are likely to change, and the time required to stabilize the plant and perform a flux map. If these peaking factors are not within their limits, the Required Actions of these Surveillances provide an appropriate response for the abnormal condition. If the QPTR remains above its specified limit, the peaking factor surveillances are required each 7 days thereafter to evaluate HNF and FQ(Z) with changes in power distribution. Relatively small changes are expected due to either burnup and xenon redistribution or correction of the cause for exceeding the
QPTR limit.
A.4  Although HNF and FQ(Z) are of primary importance as initial conditions in the safety analyses, other changes in the power distribution may occur as the QPTR limit is exceeded and may have an impact on the validity of the safety analysis. A change in the power distribution can affect such reactor parameters as bank worths and peaking factors for rod  X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111 the applicable LCOs 3 QPTR B 3.2.4    Westinghouse STS B 3.2.4-4 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 1 BASES
ACTIONS  (continued)
malfunction accidents. When the QPTR exceeds its limit, it does not necessarily mean a safety concern exists. It does mean that there is an indication of a change in the gross radial power distribution that requires an investigation and evaluation that is accomplished by examining the incore power distribution. Specifically, the core peaking factors and the quadrant tilt must be evaluated because they are the factors that best characterize the core power distribution. This re-evaluation is required to ensure that, before increasing THERMAL POWER to above the limit of Required Action A.1, the reactor core conditions are consistent with the assumptions in the safety analyses.
A.5 If the QPTR has exceeded the 1.02 limit and a re-evaluation of the safety analysis is completed and shows that safety requirements are met, the
excore detectors are normalized to restore QPTR to within limits prior to increasing THERMAL POWER to above the limit of Required Action A.1.
Normalization is accomplished in such a manner that the indicated QPTR following normalization is near 1.00. This is done to detect any subsequent significant changes in QPTR.
Required Action A.5 is modified by two Notes. Note 1 states that the QPTR is not restored to within limits until after the re-evaluation of the safety analysis has determined that core conditions at RTP are within the safety analysis assumptions (i.e., Required Action A.4). Note 2 states that if Required Action A.5 is performed, then Required Action A.6 shall be performed. Required Action A.5 normalizes the excore detectors to restore QPTR to within limits, which restores compliance with LCO 3.2.4. Thus, Note 2 prevents exiting the Actions prior to completing flux mapping to verify peaking factors, per Required Action A.6. These Notes are intended to prevent any ambiguity about the required sequence of actions.
A.6 Once the flux tilt is restored to within limits (i.e., Required Action A.5 is performed), it is acceptable to return to full power operation. However, as an added check that the core power distribution is consistent with the safety analysis assumptions, Required Action A.6 requires verification 11.02is still exceedingshall be shall not be by excore detector normalization 266 QPTR B 3.2.4    Westinghouse STS B 3.2.4-5 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 1 BASES
ACTIONS  (continued) that FQ(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are within their specified limits within 24 hours of achieving equilibrium conditions at RTP. As an added precaution, if the core power does not reach equilibrium conditions at RTP within 24 hours, but is increased slowly, then the peaking factor surveillances must be performed within 48 hours after increasing THERMAL POWER abov e the limit of Required Action A.1. These Completion Times are intended to allow adequate time to increase THERMAL POWER to above the limit of Required Action A.1, while not permitting the core to remain with unconfirmed power distributions for extended periods of time.
Required Action A.6 is modified by a Note that states that the peaking factor surveillances may only be done after the excore detectors have been normalized to restore QPTR to within limits (i.e., Required Action A.5). The intent of this Note is to have the peaking factor surveillances performed at operating power levels, which can only be accomplished after the excore detectors are normalized to restore QPTR to within limits and the core returned to power.
B.1 If Required Actions A.1 through A.6 are not completed within their associated Completion Times, the unit must be brought to a MODE or condition in which the requirements do not apply. To achieve this status, THERMAL POWER must be reduced to
< 50% RTP within 4 hours. The allowed Completion Time of 4 hours is reasonable, based on operating experience regarding the amount of time required to reach the reduced power level without challenging plant systems.
SURVEILLANCE SR  3.2.4.1 REQUIREMENTS SR 3.2.4.1 is modified by two Notes. Note 1 allows QPTR to be calculated with three power range channels if THERMAL POWER is 75% RTP and the input from one Power Range Neutron Flux channel is inoperable. Note 2 allows performance of SR 3.2.4.2 in lieu of
SR 3.2.4.1.
This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits. 
[ The Frequency of 7 days takes into account other information and alarms available to the operator in the control room.
41X, Y, FH(X, Y) 1 QPTR B 3.2.4    Westinghouse STS B 3.2.4-6 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 1 BASES SURVEILLANCE REQUIREMENTS  (continued)
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]  For those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.
SR  3.2.4.2 This Surveillance is modified by a Note, which states that it is not required until 12 hours after the input from one or more Power Range Neutron Flux channels are inoperable and the THERMAL POWER is > 75% RTP.
With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased. 
[ Performing SR 3.2.4.2 at a Frequency of 12 hours provides an accurate alternative means for ensuring that any tilt remains within its limits.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]
4544544QPTR6 QPTR B 3.2.4    Westinghouse STS B 3.2.4-7 Rev. 4.0  2Revision XXXSEQUOYAH UNIT 1 BASES SURVEILLANCE REQUIREMENTS  (continued)
For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and four loop cores
.
The symmetric thimble flux map can be used to generate symmetric thimble "tilt."  This can be compared to a reference symmetric thimble tilt, from the most recent full core flux map, to generate an incore QPTR. Therefore, incore monitoring of QPTR can be used to confirm that QPTR
is within limits.
With one NIS channel inoperable, the indicated tilt may be changed from the value indicated with all four channels OPERABLE. To confirm that no change in tilt has actually occurred, which might cause the QPTR limit to be exceeded, the incore result may be compared against previous flux maps either using the symmetric thimbles as described above or a complete flux map. Nominally, quadrant tilt from the Surveillance should be within 2% of the tilt shown by the most recent flux map data.
REFERENCES 1. 10 CFR 50.46.
: 2. Regulatory Guide 1.77, Rev
[0], May 1974.
: 3. 10 CFR 50, Appendix A, GDC 26.
22 QPTR B 3.2.4    Westinghouse STS B 3.2.4-1 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 2 B 3.2  POWER DISTRIBUTION LIMITS
B 3.2.4  QUADRANT POWER TILT RATIO (QPTR)
BASES BACKGROUND The QPTR limit ensures that the gross radial power distribution remains consistent with the design values used in the safety analyses. Precise radial power distribution measurements are made during startup testing, after refueling, and periodically during power operation.
The power density at any point in the core must be limited so that the fuel design criteria are maintained. Together, LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, and LCO 3.1.6, "Control Rod Insertion Limits," provide limits on process variables that characterize and control the three dimensional power distribution of the reactor core. Control of these variables ensures that the core operates within the fuel design criteria and that the power distribution remains within the bounds used in
the safety analyses.
APPLICABLE  This LCO precludes core power distributions that violate the following fuel  SAFETY  design criteria:
ANALYSES  a. During a large break loss of coolant accident, the peak cladding temperature must not exceed 2200&deg;F (Ref. 1),
: b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 departure from nucleate boiling (DNB) criterion) that the hot fuel rod in the core does not experience a DNB condition,
: c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
: d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (Ref. 3).
The LCO limits on the AFD, the QPTR, the Heat Flux Hot Channel Factor (FQ(Z)), the Nuclear Enthalpy Rise Hot Channel Factor
)F(HN, and control bank insertion are established to preclude core power distributions that exceed the safety analyses limits.
The QPTR limits ensure that HNF and FQ(Z) remain below their limiting values by preventing an undetected change in the gross radial power distribution. X, Y, (FH(X, Y)) X, Y, FH(X, Y) 111 QPTR B 3.2.4    Westinghouse STS B 3.2.4-2 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 2 BASES
APPLICABLE SAFETY ANALYSES  (continued)
In MODE 1, the HNF and FQ(Z) limits must be maintained to preclude core power distributions from exceeding design limits assumed in the safety analyses.
The QPTR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).
LCO The QPTR limit of 1.02, at which corrective action is required, provides a margin of protection for both the DNB ratio and linear heat generation rate contributing to excessive power peaks resulting from X-Y plane power tilts. A limiting QPTR of 1.02 can be tolerated before the margin for uncertainty in F Q(Z) and )F(HN is possibly challenged.
APPLICABILITY The QPTR limit must be maintained in MODE 1 with THERMAL POWER > 50% RTP to prevent core power distributions from exceeding the design limits. Applicability in MODE 1  50% RTP and in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require the implementation of a QPTR limit on the distribution of core power. The QPTR limit in these conditions is, therefore, not important. Note that the HNF and FQ(Z) LCOs still apply, but allow progressively higher peaking factors at 50% RTP or lower.
ACTIONS A.1 With the QPTR exceeding its limit, a power level reduction of 3% RTP for each 1% by which the QPTR exceeds 1.00 is a conservative tradeoff of total core power with peak linear power. The Completion Time of 2 hours allows sufficient time to identify the cause and correct the tilt. Note that the power reduction itself may cause a change in the tilted condition.
The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of QPTR.
Increases in QPTR would require power reduction within 2 hours of QPTR determination, if necessary to comply with the decreased maximum allowable power level. Decreases in QPTR would allow increasing the maximum allowable power level and increasing power up to this revised limit.
X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111.021 QPTR B 3.2.4    Westinghouse STS B 3.2.4-3 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 2 BASES
ACTIONS  (continued)
A.2 After completion of Required Action A.1, the QPTR alarm may still be in its alarmed state. As such, any additional changes in the QPTR are detected by requiring a check of the QPTR once per 12 hours thereafter.
A 12 hour Completion Time is sufficient because any additional change in QPTR would be relatively slow.
A.3  The peaking factors F Q(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are of primary importance in ensuring that the power distribution remains consistent with the initial conditions used in the safety analyses. Performing SRs on HNF and FQ(Z) within the Completion Time of 24 hours after achieving equilibrium conditions from a Thermal Power reduction per Required Action A.1 ensures that these primary indicators of power distribution are within their respective limits. Equilibrium conditions are achieved when the core is sufficiently stable at intended operating conditions to support flux mapping. A Completion Time of 24 hours after achieving equilibrium conditions from Thermal Power reduction per Required Action A.1 takes into consideration the rate at which peaking factors are likely to change, and the time required to stabilize the plant and perform a flux map. If these peaking factors are not within their limits, the Required Actions of these Surveillances provide an appropriate response for the abnormal condition. If the QPTR remains above its specified limit, the peaking factor surveillances are required each 7 days thereafter to evaluate HNF and FQ(Z) with changes in power distribution. Relatively small changes are expected due to either burnup and xenon redistribution or correction of the cause for exceeding the
QPTR limit.
A.4  Although HNF and FQ(Z) are of primary importance as initial conditions in the safety analyses, other changes in the power distribution may occur as the QPTR limit is exceeded and may have an impact on the validity of the safety analysis. A change in the power distribution can affect such reactor parameters as bank worths and peaking factors for rod  X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111 the applicable LCOs 3 QPTR B 3.2.4    Westinghouse STS B 3.2.4-4 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 2 BASES
ACTIONS  (continued)
malfunction accidents. When the QPTR exceeds its limit, it does not necessarily mean a safety concern exists. It does mean that there is an indication of a change in the gross radial power distribution that requires an investigation and evaluation that is accomplished by examining the incore power distribution. Specifically, the core peaking factors and the quadrant tilt must be evaluated because they are the factors that best characterize the core power distribution. This re-evaluation is required to ensure that, before increasing THERMAL POWER to above the limit of Required Action A.1, the reactor core conditions are consistent with the assumptions in the safety analyses.
A.5 If the QPTR has exceeded the 1.02 limit and a re-evaluation of the safety analysis is completed and shows that safety requirements are met, the
excore detectors are normalized to restore QPTR to within limits prior to increasing THERMAL POWER to above the limit of Required Action A.1.
Normalization is accomplished in such a manner that the indicated QPTR following normalization is near 1.00. This is done to detect any subsequent significant changes in QPTR.
Required Action A.5 is modified by two Notes. Note 1 states that the QPTR is not restored to within limits until after the re-evaluation of the safety analysis has determined that core conditions at RTP are within the safety analysis assumptions (i.e., Required Action A.4). Note 2 states that if Required Action A.5 is performed, then Required Action A.6 shall be performed. Required Action A.5 normalizes the excore detectors to restore QPTR to within limits, which restores compliance with LCO 3.2.4. Thus, Note 2 prevents exiting the Actions prior to completing flux mapping to verify peaking factors, per Required Action A.6. These Notes are intended to prevent any ambiguity about the required sequence of actions.
A.6 Once the flux tilt is restored to within limits (i.e., Required Action A.5 is performed), it is acceptable to return to full power operation. However, as an added check that the core power distribution is consistent with the safety analysis assumptions, Required Action A.6 requires verification 11.02is still exceedingshall be shall not be by excore detector normalization 266 QPTR B 3.2.4    Westinghouse STS B 3.2.4-5 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 2 BASES
ACTIONS  (continued) that FQ(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are within their specified limits within 24 hours of achieving equilibrium conditions at RTP. As an added precaution, if the core power does not reach equilibrium conditions at RTP within 24 hours, but is increased slowly, then the peaking factor surveillances must be performed within 48 hours after increasing THERMAL POWER abov e the limit of Required Action A.1. These Completion Times are intended to allow adequate time to increase THERMAL POWER to above the limit of Required Action A.1, while not permitting the core to remain with unconfirmed power distributions for extended periods of time.
Required Action A.6 is modified by a Note that states that the peaking factor surveillances may only be done after the excore detectors have been normalized to restore QPTR to within limits (i.e., Required Action A.5). The intent of this Note is to have the peaking factor surveillances performed at operating power levels, which can only be accomplished after the excore detectors are normalized to restore QPTR to within limits and the core returned to power.
B.1 If Required Actions A.1 through A.6 are not completed within their associated Completion Times, the unit must be brought to a MODE or condition in which the requirements do not apply. To achieve this status, THERMAL POWER must be reduced to
< 50% RTP within 4 hours. The allowed Completion Time of 4 hours is reasonable, based on operating experience regarding the amount of time required to reach the reduced power level without challenging plant systems.
SURVEILLANCE SR  3.2.4.1 REQUIREMENTS SR 3.2.4.1 is modified by two Notes. Note 1 allows QPTR to be calculated with three power range channels if THERMAL POWER is 75% RTP and the input from one Power Range Neutron Flux channel is inoperable. Note 2 allows performance of SR 3.2.4.2 in lieu of
SR 3.2.4.1.
This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits. 
[ The Frequency of 7 days takes into account other information and alarms available to the operator in the control room.
41X, Y, FH(X, Y) 1 QPTR B 3.2.4    Westinghouse STS B 3.2.4-6 Rev. 4.0  2Revision XXX SEQUOYAH UNIT 2 BASES SURVEILLANCE REQUIREMENTS  (continued)
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]  For those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.
SR  3.2.4.2 This Surveillance is modified by a Note, which states that it is not required until 12 hours after the input from one or more Power Range Neutron Flux channels are inoperable and the THERMAL POWER is > 75% RTP.
With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased. 
[ Performing SR 3.2.4.2 at a Frequency of 12 hours provides an accurate alternative means for ensuring that any tilt remains within its limits.
OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.
-----------------------------------REVIEWER'S NOTE-----------------------------------
Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.
------------------------------------------------------------------------------------------------
]
4544544QPTR6 QPTR B 3.2.4    Westinghouse STS B 3.2.4-7 Rev. 4.0  2Revision XXXSEQUOYAH UNIT 2 BASES SURVEILLANCE REQUIREMENTS  (continued)
For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and four loop cores
.
The symmetric thimble flux map can be used to generate symmetric thimble "tilt."  This can be compared to a reference symmetric thimble tilt, from the most recent full core flux map, to generate an incore QPTR. Therefore, incore monitoring of QPTR can be used to confirm that QPTR
is within limits.
With one NIS channel inoperable, the indicated tilt may be changed from the value indicated with all four channels OPERABLE. To confirm that no change in tilt has actually occurred, which might cause the QPTR limit to be exceeded, the incore result may be compared against previous flux maps either using the symmetric thimbles as described above or a complete flux map. Nominally, quadrant tilt from the Surveillance should be within 2% of the tilt shown by the most recent flux map data.
REFERENCES 1. 10 CFR 50.46.
: 2. Regulatory Guide 1.77, Rev
[0], May 1974.
: 3. 10 CFR 50, Appendix A, GDC 26.
22 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT RATIO (QPTR)
Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made to be consistent with changes made to the Specification.
: 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description. 
: 3. ISTS 3.2.4 Bases Required Action A.3 refers to the Required Actions of the referenced Surveillances. There are no Required Actions in the ITS 3.2.1 or ITS 3.2.2 Surveillances. This reference has been corrected to refer to the Required Actions of the applicable LCOs.
: 4. ISTS SR 3.2.4.1 and SR 3.2.4.2 Bases provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.
Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.
: 5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
: 6. Typographical/grammatical error corrected.
Specific No Significant Haza rds Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.}}

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ENCLOSURE 2 VOLUME 7

SEQUOYAH NUCLEAR PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION

ITS SECTION 3.2 POWER DISTRIBUTION LIMITS

Revision 0

LIST OF ATTACHMENTS

1. ITS 3.2.1, - Heat Flux Hot Channel Factor (F Q(X,Y, Z)) 2. ITS 3.2.2, - Nuclear Enthalpy Rise Hot Channel Factor (FH(X, Y)) 3. ITS 3.2.3 - Axial Flux Difference (AFD) 4. ITS 3.2.4 - Quadrant Power Tilt Ratio (QPTR)

ATTACHMENT 1 ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (F Q(X,Y,Z))

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS 3/4.2.2 HEAT FLUX HOT CHANNEL FACTOR-F Q(X,Y,Z) LIMITING CONDITION FOR OPERATION 3.2.2 FQ(X,Y,Z) shall be maintained within the acceptable limits specified in the COLR:

APPLICABILITY

MODE 1

ACTION:

With FQ(X,Y,Z) exceeding its limit:

a. Reduce THERMAL POWER at least 1% for each 1%

FQ(X,Y,Z) exceeds the limit within 15 minutes, and similarly reduce the following:

1. Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and
2. The Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. b. POWER OPERATION may proceed for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Subsequent POWER OPERATION may proceed provided the Overpower Delta T Trip Setpoints (value of K
4) have been reduced at least 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR.
c. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced limit required by Action
a. and b., above; THERMAL POWER may then be increased provided FQ(X,Y,Z) is demonstrated through incore mapping to be within its limits.

SURVEILLANCE REQUIREMENTS 4.2.2.1 The provisions of Specification 4.0.4 are not applicable.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-5 Amendment No. 19, 95, 140, 155, 223 Page 1 of 10 LCO 3.2.1 Applicabilit y ACTION A Required Action A.4 Add proposed ACTION A Note M01Required Action A.1 Required Action A.3 Required Action A.5 LA01LA02Add proposed ACTION D M03Required Action A.2 SR NOTE M04M02after each F Q(X,Y,Z) determination )Z,Y,X(FCQsteady state A02A02)Z,Y,X(FCQL0172 M02after each F Q(X,Y,Z) determination A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued) 4.2.2.2 QMF(X,Y,Z) shall be evaluated to determine if F Q(X,Y,Z) is within its limit by:

a. Using the moveable incore detectors to obtain a power distribution map (

QMF(X,Y,Z)*) at any THERMAL POWER greater than 5% of RATED THERMAL POWER.

b. Satisfying the following relationship:

(QMF(X,Y,Z) BQNOM(X,Y,Z) where BQNOM (X,Y,Z)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.

The BQNOM (X,Y,Z) factors are not applicable in the following core plane regions as measured in percent of core height from the bottom of the fuel:

1. Lower core region from 0 to 15%, inclusive.
2. Upper core region from 85 to 100%, inclusive.
c. If the above relationship is not satisfied, then
1. For that location, calculate the % margin to the maximum allowable design as follows:

where BQDES(X,Y,Z)** and BCDES(X,Y,Z)** represent the maximum allowable design peaking factors which insure that the licensing criteria will be preserved for operation within Limiting Condition for Operation limits, and include allowances for the calculational and measurement uncertainties.

  • No additional uncertainties are required in the following equations for QMF(X,Y,Z), because the limits include uncertainties.
    • BQNOM (X,Y,Z), BQDES(X,Y,Z), and BCDES(X,Y,Z) Data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-6 Amendment Nos. 19, 95, 140, 155, 223

% AFD Margin = 1 -

F(X,Y,Z)BQDES(X,Y,Z) x 100%QM  % f(I) Margin = 1 -

F(X,Y,Z)BCDES(X,Y,Z) x 100%2QM SR 3.2.1.2 SR 3.2.1.3 Page 2 of 10 LA03SR 3.2.1.2 SR 3.2.1.3 LA03LA03LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

2. Find the minimum margin of all locations examined in 4.2.2.2.c.1 above.

AFD min margin = minimum % margin value of all locations examined.

f2(I) OPT min margin = minimum % margin value of all locations examined.

3. If the AFD min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.

(a) Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, administratively reduce the negative AFD limit lines at each power level by:

Reduced AFD Limit = (AFDLimit from COLR) + absolute value of (NSLOPE AFD* % x AFD min margin of 4.2.2.2.c.2)

(b) Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, administratively reduce the positive AFD limit lines at each power level by:

Reduced AFD Limit = (AFDLimit from COLR) absolute value of (PSLOPE AFD* % X AFD min margin)

4. If the f 2(I) min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.

(a) Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the OPT negative f 2(I) breakpoint limit by:

Reduced OPT negative f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) + absolute value of

  • NSLOPE AFD and PSLOPE AFD are the amount of AFD adjustment required to compensate for each 1% that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14
    • PSLOPE and NSLOPEI)(fI)(f22 are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-7 Amendment No. 19, 95, 140, 155, 216, 223 margin) min I)(

f x % NSLOPE(2)I(f**2 LA03Page 3 of 10 ACTION B REQUIRED ACTION B.2 REQUIRED ACTION B.1 REQUIRED ACTION C.2 ACTION C REQUIRED ACTION B.1/B.2 REQUIRED ACTION C.1/C.2 LA03LA03LA03LA03M05M05LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

(b) Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the OPT positive f 2(I) breakpoint limit by:

Reduced OPT positive f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) absolute value of margin) min I)(

f x % **PSLOPE(2I)(f2 d. Measuring QMF(X,Y,Z) according to the following schedule:

1. Upon achieving equilibrium conditions after exceeding by 10 percent or more of RATED THERMAL POWER, the THERMAL POWER at which F Q(X,Y,Z) was last determined,***

or 2. At least once per 31 Effective Full Power Days, whichever occurs first.

e. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding QMF(X,Y,Z) BQNOM(X,Y,Z), either of the following actions specified shall be taken. 1. QMF(X,Y,Z) shall be increased over that specified in 4.2.2.2.a by the appropriate factor specified in the COLR, and 4.2.2.2.c repeated, or
2. QMF(X,Y,Z) shall be evaluated according to 4.2.2.2 at or before the time when the margin is projected to result in one of the actions specified in 4.2.2.2.c.3 or 4.2.2.2.c.4.

4.2.2.3 When FQ(X,Y,Z) is measured for reasons other than meeting the requirements of Specification 4.2.2.2 an overall measured FQ(X,Y,Z) shall be obtained from a power distribution map, increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR according to Specification 3.2.2.

___________________________

    • PSLOPE and NSLOPEI)(fI)(f22 are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14 *** During power escalation at the beginning of each cycle, power level may be increased until a power level for extended operation has been achieved and power distribution map obtained.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-8 Amendment No. 19, 140, 223 Page 4 of 10 M08thereafter LA04In accordance with the Surveillance Frequency Control ProgramSR Note INSERT 1 andM06SR 3.2.1.1 SR 3.2.1.2 SR 3.2.1.3 LA02LA03REQUIRED ACTION C.1 SR 3.2.1.2/SR 3.2.1.3 NOTE SR 3.2.1.2 / SR 3.2.1.3

NOTE a. SR 3.2.1.2 /

SR 3.2.1.3

NOTE b. SR 3.2.1.1 LA03REQUIRED ACTION C.1/C.2 M08M04M07M09INSERT 2 Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after A02)Z,Y,X(FCQNot required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium can be 3.2.1 Insert Page 3/4 2-8 CTS (Page 4 of 10)

INSERT 1 Once after each refueling prior to THERMAL POWER exceeding 75% RTP

INSERT 2 Once after each refueling prior to THERMAL POWER exceeding 75% RTP

AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FCQ was last verified AND At least once per 31 Effective Full Power Days

DOC M09 DOC M06 LA04In accordance with the Surveillance Frequency Control Program A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS

This page intentionally deleted.

October 23, 1991 SEQUOYAH - UNIT 1 3/4 2-9 Amendment No. 12, 140, 155 Page 5 of 10 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS 3/4.2.2 HEAT FLUX HOT CHANNEL FACTOR- F Q(X,Y,Z) LIMITING CONDITION FOR OPERATION 3.2.2 FQ(X,Y,Z) shall be maintained within the acceptable limits specified in the COLR.

APPLICABILITY

MODE 1 ACTION:

With FQ(X,Y,Z) exceeding its limit:

a. Reduce THERMAL POWER at least 1% for each 1%

FQ(X,Y,Z) exceeds the limit within 15 minutes, and similarly reduce the following:

1. Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and
2. The Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
b. POWER OPERATION may proceed for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Subsequent POWER OPERATION may proceed provided the Overpower Delta T Trip Setpoints (value of K
4) have been reduced at least 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR.
c. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced limit required by Action
a. and b., above; THERMAL POWER may then be increased provided FQ(X,Y,Z) is demonstrated through incore mapping to be within its limits.

SURVEILLANCE REQUIREMENTS 4.2.2.1 The provisions of Specification 4.0.4 are not applicable.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-4 Amendment Nos. 21, 95, 131, 146, 214 LCO 3.2.1 Applicabilit y ACTION A Required Action A.4 Required Action A.1 Required Action A.3 Required Action A.5 LA01Page 6 of 10 M01Add proposed ACTION D M03Required Action A.2 SR NOTE M04M02after each F Q(X,Y,Z) determination A02)Z,Y,X(FCQAdd proposed ACTION A Notesteady state A02)Z,Y,X(FCQLA02M02after each F Q(X,Y,Z) determination L0172 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued) 4.2.2.2 Z)Y,(X,FMQ shall be evaluated to determine if F Q(X,Y,Z) is within its limit by:

a. Using the moveable incore detectors to obtain a power distribution map (

QMF(X,Y,Z)*) at any THERMAL POWER greater than 5% of RATED THERMAL POWER.

b. Satisfying the following relationship:

QMF(X,Y,Z) BQNOM(X,Y,Z) where BQNOM (X,Y,Z)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.

The BQNOM (X,Y,Z) factors are not applicable in the following core plane regions as measured in percent of core height from the bottom of the fuel:

1. Lower core region from 0 to 15%, inclusive.
2. Upper core region from 85 to 100%, inclusive.
c. If the above relationship is not satisfied, then 1. For that location, calculate the % margin to the maximum allowable design as follows:

where BQDES (X,Y,Z)** and BCDES(X,Y,Z)** represent the maximum allowable design peaking factors which insure that the licensing criteria w ill be preserved for operation within Limiting Condition for Operation limits, and include allowances for the calculational and measurement uncertainties.

  • No additional uncertainties are required in the following equations for QMF(X,Y,Z), because the limits include uncertainties.
    • BQNOM (X,Y,Z), BQDES (X,Y,Z), and BCDES (X,Y,Z) Data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-5 Amendment No. 21, 95, 131, 146, 214

% AFD Margin = 1 -

F(X,Y,Z)BQDES(X,Y,Z) x 100%QM % f(I) Margin = 1 -

F(X,Y,Z)BCDES(X,Y,Z) x 100%2QMPage 7 of 10 LA03SR 3.2.1.2 SR 3.2.1.3 LA03SR 3.2.1.2 SR 3.2.1.3 LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

2. Find the minimum margin of all locations examined in 4.2.2.2.c.1 above.

AFD min margin = minimum % margin value of all locations examined.

f2(I) OPT min margin = minimum % margin value of all locations examined.

3. If the AFD min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.

(a) Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, administratively reduce the negative AFD limit lines at each power level by: Reduced AFD Limit = (AFDLimit from COLR) + absolute value of (NSLOPE AFD* % x AFD min margin of 4.2.2.2.c.2)

(b) Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, administratively reduce the positive AFD limit lines at each power level by:

Reduced AFD Limit = (AFDLimit from COLR)

-absolute value of (PSLOPE AFD* % X AFD min margin)

4. If the f2(I) min margin in 4.2.2.2.c.2 above is <0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed.

(a) Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the OPT negative f 2(I) breakpoint limit by:

Reduced OPT negative f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) + absolute value of

  • NSLOPEAFD and PSLOPE AFD are the amount of AFD adjustment required to compensate for each 1%

that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14.

    • 22f(I)f(I)NSLOPE and PSLOPE are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-6 Amendment No. 21, 95, 131, 146, 206, 214 (NSLOPE % x f(I) margin) 2**f(I)2min Page 8 of 10 LA03M05ACTION B REQUIRED ACTION B.2 REQUIRED ACTION B.1 REQUIRED ACTION C.2 ACTION C REQUIRED ACTION B.1/B.2 REQUIRED ACTION C.1/C.2 M05LA03LA03LA03LA03LA03 A01ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

(b) Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, reduce the OPT positive f 2(I) breakpoint limit by:

Reduced OPT positive f 2(I) breakpoint limit = (f 2(I) limit of Table 2.2-1) absolute value of (PSLOPE** % x f(I) margin) 2f(I)2min

d. Measuring QMF(X,Y,Z) according to the following schedule:
1. Upon achieving equilibrium conditions after exceeding by 10 percent or more of RATED THERMAL POWER, the THERMAL POWER at which F Q(X,Y,Z) was last determined,***

or 2. At least once per 31 Effective Full Power Days, whichever occurs first.

e. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding Z),Y,BQNOM(X, Z)Y,(X,FMQ either of the following actions specified shall be taken.
1. QMF(X,Y,Z) shall be increased over that specified in 4.2.2.2.a by the appropriate factor specified in the COLR, and 4.2.2.2.c repeated, or 2. QMF(X,Y,Z)shall be evaluated according to 4.2.2.2 at or before the time when the margin is projected to result in one of the actions specified in 4.2.2.2.c.3 or 4.2.2.2.c.4.

4.2.2.3 When FQ(X,Y,Z) is measured for reasons other than meeting the requirements of Specification 4.2.2.2 an overall measured FQ(X,Y,Z) shall be obtained from a power distribution map, increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR according to Specification 3.2.2.

    • 2f(I)NSLOPE and 2f(I)PSLOPE are the amounts of the OPT f2(I) limit adjustment required to compensate for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14.
      • During power escalation at the beginning of each cycle, power level may be increase d until a power level for extended operation has been achieved and power distribution map obtained.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-6a Amendment No. 21, 95, 131, 214 Page 9 of 10 SR Note LA04In accordance with the Surveillance Frequency Control Program andM08thereafter M06SR 3.2.1.1 SR 3.2.1.2 SR 3.2.1.3 LA03LA02REQUIRED ACTION C.1 M08REQUIRED ACTION C.1/C.2 LA03M04SR 3.2.1.1 SR 3.2.1.2 / SR 3.2.1.3 NOTE b. SR 3.2.1.2 / SR 3.2.1.3 NOTE a. SR 3.2.1.2/SR 3.2.1.3 NOTE M09INSERT 4 Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after M07A02)Z,Y,X(FCQINSERT 3 Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium can be 3.2.1 Insert Page 3/4 2-6a CTS (Page 9 of 10)

INSERT 3 Once after each refueling prior to THERMAL POWER exceeding 75% RTP

INSERT 4 Once after each refueling prior to THERMAL POWER exceeding 75% RTP

AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FCQ was last verified AND At least once per 31 Effective Full Power Days

DOC M09 DOC M06 LA04In accordance with the Surveillance Frequency Control Program A01ITS ITS 3.2.1

This page intentionally deleted.

March 30, 1992 SEQUOYAH - UNIT 2 3/4 2-7 Amendment No. 131, 146 Page 10 of 10 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 1 of 9 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 4.2.2.2 evaluates )Z,Y,X(FMQto determine if F Q(X,Y,Z) is within the limits.

CTS 4.2.2.3 evaluates F Q(X,Y,Z) for reasons other than meeting the requirements of CTS 4.2.2.2 and requires the overall measured F Q(X,Y,Z) be obtained from a distribution flux map and increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR. ITS 3.2.1 ACTION A and SR 3.2.1.1 use )Z,Y,X(FCQto represent the overall measured F Q(X,Y,Z) adjusted for measurement uncertainty and manufacturing tolerances. This changes the CTS by adding a new term,)Z,Y,X(FCQ which reflects the requirements in CTS 4.2.2.3 for evaluating the steady state limit of F Q(X,Y,Z) specified in the COLR.

BAW-10163PA, "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989, requires that F Q(X,Y,Z) is compared against three limits: (1) steady state limit, (F QRTP / P)

  • K(Z), (2) limiting condition LOCA limit, BQDES(X,Y,Z), and (3) Limiting condition centerline fuel melt limit, BCDES(X,Y,Z). BAW-10163PA further states that the overall measured FQ(X,Y,Z) must be adjusted for uncertainty prior to comparison to the steady state limit.

The CTS 3.2.2 Surveillance Requirements address both the steady state and the limiting conditions. CTS 4.2.2.2, in part evaluates)Z,Y,X(FMQ for both BQDES(X,Y,Z) and BCDES(X,Y,Z) to ensure the F Q(X,Y,Z) limit is met at limiting conditions. Thus if BQDES(X,Y,Z) and BCDES(X,Y,Z) are met, the steady state limit is met These verifications are reflected in ITS SR 3.2.1.2 and SR 3.2.1.3.

CTS 4.2.2.3 addresses evaluation of the steady state limit directly using the overall measured F Q(X,Y,Z) adjusted by the two penalty factors,)Z,Y,X(FCQ. ITS 3.2.1 uses )Z,Y,X(FCQthroughout the Specification to refer to the steady state limit. This change is designated as administrative because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.2.2 ACTION c states that with F Q(X,Y,Z) exceeding its limit "Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 2 of 9 POWER above the reduced limit required by Action a. and b., above; THERMAL POWER may then be increased provided F Q(X,Y,Z) is demonstrated through incore flux mapping to be within its limits." However, under CTS 3.0.2, the FQ(X,Y,Z) measurement does not have to be completed, if compliance with the LCO is restored. ITS 3.2.1 ACTION A contains a Note which states, "Required Action A.5 must be completed whenever this Condition is entered." ITS Required Action A.5 requires performance of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 prior to increasing THERMAL POWER above the limit of Required Action A.1. This changes the CTS by requiring )Z,Y,X(FCQverification to be made even if )Z,Y,X(FCQis restored to within its limit.

The purpose of CTS 3.2.2 ACTION c is to ensure that when F Q(X,Y,Z) has exceeded the limit, compensatory measures are commenced to restore core power distribution to within the limits prior to increasing THERMAL POWER. This change is acceptable, because it establishes appropriate compensatory measurements for violation of the F Q(X,Y,Z) limit. As power is reduced under ITS Required Action A.1, the margin to the F Q(X,Y,Z) limit increases. Therefore, compliance with the LCO could be restored during the power reduction. Verifying that the limit is met as power is increased ensures that the limit continues to be met and does not remain unmeasured for up to 31 EFPD. This change is designated as a more restrictive change, because it imposes requirements in addition to those in the CTS.

M02 CTS 3.2.2 ACTION states in part that when F Q(X,Y,Z) has exceeded the limit, to (1) Reduce THERMAL POWER at least 1% for each 1% F Q(X,Y,Z) exceeds the limit within 15 minutes, (2) Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, (3) Reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, (4) Reduce the Overpower Delta T Trip Setpoints (value of K

4) at least 1% (in T span) for each 1% that F Q(X,Y,Z) exceeds the limit specified in the COLR within the next 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, (5) Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced limit required by Action a. and b., above; THERMAL POWER may then be increased provided F Q(X,Y,Z) is demonstrated through incore mapping to be within its limits. ITS 3.2.1 has similar Required Actions and Completion Times with the added requirement to ensure the times are met after each )Z,Y,X(FCQdetermination. This changes the CTS by requiring the Required Actions to be re-performed within a specific Completion Time after each flux map determination.

The purpose of the CTS 3.2.2 ACTIONs is to ensure that when F Q(X,Y,Z) has exceeded the limit, compensatory measures are commenced to restore core power distribution to within the limits assumed in the safety analysis. This change is acceptable because it ensures that the Required Actions for )Z,Y,X(FCQ not within limits will be re-performed after each )Z,Y,X(FCQdetermination within the prescribed Completion Time. When )Z,Y,X(FCQ is not met, the margin to the limit prescribes the amount of power reduction and setpoint reduction to be performed. Therefore, each time flux mapping is performed, the determination of margin to the limit will determine if additional power reduction or additional DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 3 of 9 setpoint reduction is required. This change is designated as more restrictive, because it applies new Completion Time requirements which do not exist in the CTS.

M03 CTS 3.2.2 does not contain an Action to follow, if the provided Actions cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ITS 3.2.1 ACTION D, states that the plant must be in MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shutdown and, consequently, allowing one hour less for the unit to be in MODE 2.

This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODE 1. Requiring a shutdown to MODE 2 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shutdown is not needed, because the operators have had time to prepare for the shutdown while attempting to follow the Required Actions and associated Completion Times. This change is designated as more restrictive because it allows less time to shut down than does the CTS.

M04 CTS 4.2.2.1 states that the provisions of Specification 4.0.4 are not applicable, and thereby provides an allowance for entering the next higher MODE of Applicability when the Surveillance is not met. CTS 4.2.2.2.d.1 Note *** states that during power escalation at the beginning of each cycle, power level may be increased until a power level for extended operation has been achieved and power distribution map obtained. ITS 3.2.1 has a similar note for the beginning of each cycle, however, there is no specific allowance for changing MODES at any other time with ITS LCO 3.2.1 not met. ITS LCO 3.0.4 requires, in part, that when an LCO is not met, entry into a MODE or other specified condition in the applicability shall only be made: If part a. or part b. or part c. is met. Part c allows, when an allowance is stated in the individual value, parameter or other specification. ITS 3.2.1 Surveillance Requirements Note will provide an allowance whereby, Surveillance performance is not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium power level has been achieved, at which a power distribution map can be obtained. This changes CTS by allowing entry into the MODE of Applicability by only deferring the performance of the Surveillance Requirements instead of deferring compliance with the LCO.

The purpose of CTS 4.2.2.1 is to provide an allowance for entering the next higher MODE of applicability when any Surveillance is not met. This change is acceptable because ITS provides an allowance to enter the MODE of Applicability at any time LCO 3.2.1 is not met solely based on Surveillance performance. SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 require using the incore detector system to provide the necessary data to create a power distribution map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level (~40%-50%). The surveillances cannot be performed in MODE 2. This change is designated as more restrictive because the CTS 4.0.4 MODE DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 4 of 9 change allowance with the LCO not met is now limited to the performance of the SRs and does not include the allowance to change MODES for non-compliance with the acceptance criteria.

M05 CTS 3.2.2 provides two acceptable alternatives for the AFD min margin and f 2(I) min margin not met. CTS 4.2.2.2.c.3 states, "If the AFD min margin in 4.2.2.2.c.2 above is < 0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed." CTS 4.2.2.2.c.4 states, "If the f 2(I) min margin in 4.2.2.2.c.2 above is < 0, either the following actions shall be taken, or the action statements for 3.2.2 shall be followed." CTS 4.2.2.2.c.3.a and CTS 4.2.2.2.c.3.b have been replaced by ITS 3.2.1 Required Actions B.1 and B.2. Similarly, CTS 4.2.2.2.c.4.a and 4.2.2.2.c.4.b have been replaced with ITS 3.2.1 Required Actions C.1 and C.2. However, in both cases the option for, "the action statements for 3.2.2 shall be followed" has not been retained. This changes the CTS by removing the option to follow the action statement of CTS 3.2.2 for either

min margin (AFD or f 2(I)) not met.

The purpose of CTS 4.2.2.2.c.3 and CTS 4.2.2.2.c.4 is to provide acceptable alternatives for the required compensatory actions when either AFD min margin or f2(I) min margin is not met. The CTS surveillance requirements for either AFD min margin or f 2(I) min margin not met require either the administrative reduction in their respective setpoints or the option of entering the actions of LCO 3.2.2. The CTS Actions for 3.2.2, F Q(X,Y,Z) exceeding the limits, require in part the reduction of THERMAL POWER, reduction of AFD limit lines, and reduction

f2(I) breakpoint limits. ITS 3.2.1 has removed this option, but retains the requirement for administrative reduction in AFD limits, ITS CONDITION B, or

f2(I) breakpoint limits, ITS CONDITION C. If the ITS Required Actions to administratively reduce the respective setpoints is not performed within the allowed Completion Time, Condition D will be entered requiring the Unit to be placed in MODE 2. This change is designated as more restrictive because an acceptable alternative Required Action available in CTS is being removed.

M06 CTS 4.2.2.2.d requires F Q(X,Y,Z) to be determined to be within its limit upon achieving equilibrium conditions after exceeding by 10 percent or more of RTP, the THERMAL POWER at which F Q(X,Y,Z) was last determined, or at least once per 31 EFPD, whichever occurs first. ITS SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.1.3 collectively verify that F Q(X,Y,Z) is within its limit after each refueling prior to THERMAL POWER exceeding 75% RTP, once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the THERMAL POWER at which),,(ZYXFCQand)Z,Y,X(FMQwas last verified, and in accordance with the Surveillance Frequency Control Program. This changes the CTS by adding a new Frequency (Once after each refueling prior to THERMAL POWER exceeding 75% RTP). The replacement of the words "whichever occurs first" with the word "thereafter" to the Frequency is discussed in DOC M08. Moving the "31 EFPD thereafter" Frequency to the Surveillance Frequency Control Program is discussed in DOC LA04. The addition of "once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />" is discussed in DOC M07.

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 5 of 9 The purpose of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 is to verify that F Q(X,Y,Z) is within the limits assumed in the safety analysis. This change is acceptable, because adopting the new Frequency of confirming ),,(ZYXFCQand)Z,Y,X(FMQare within the limits prior to exceeding 75% RTP following each core reload, will ensure that some determination of ),,(ZYXFCQand)Z,Y,X(FMQ is made at a lower power level at which adequate margin is available, before going to 100% RTP. This change is designated as more restrictive, because it applies new requirements which do not exist in the CTS.

M07 CTS 4.2.2.2.d requires F Q(X,Y,Z) to be determined to be within its limit upon achieving equilibrium conditions after exceeding by 10 percent or more of RTP, the THERMAL POWER at which F Q(X,Y,Z) was last determined, or at least once per 31 EFPD, whichever occurs first. ITS SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.1.3 collectively verify that F Q(X,Y,Z) is within its limit after each refueling prior to THERMAL POWER exceeding 75% RTP, once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the THERMAL POWER at which F Q(X,Y,Z) was last verified, and in accordance with the Surveillance Frequency Control Program. This changes the CTS by modifying the existing Frequency (Upon achieving equilibrium conditions-) by adding a specific time element (Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions) which limits the time duration allowed for completing a single performance after a 10% RTP change . The replacement of the words "whichever occurs first" with the word "thereafter" to the Frequency is discussed in DOC M08. The relocation of the "31 EFPD thereafter" Frequency to the

Surveillance Frequency Control Program is discussed in DOC LA04. The addition of new Frequency (Once after each refueling prior to THERMAL POWER exceeding 75% RTP) is discussed in DOC M06.

The purpose of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 is to verify that F Q(X,Y,Z) is within the limits assumed in the safety analysis. This change is acceptable, because modifying the existing frequency by adding a specific time element completing a single performance after a 10% RTP change is made ensures adequate margin is available, before going to a higher power level. This change is designated as more restrictive, because it applies new requirements which do not exist in the CTS.

M08 CTS 4.2.2.2.d.1 Surveillance states "required to be performed upon achieving equilibrium conditions after exceeding by 10 percent or more of RATED THERMAL POWER, the THERMAL POWER at which F Q(X,Y,Z) was last determined, or at least once per 31 EFPD, whichever occurs first." ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 are similar, but the logical connector between the Frequencies is an "AND" not an "or". Additionally, the ITS 31 EFPD Frequency is qualified with "thereafter". This changes the CTS by (1) removing the phrase, "whichever occurs first" and replacing it with "thereafter" and (2) changing the CTS logical connector from "or" to "AND". The purpose of CTS 4.2.2.2 is to establish both when and how often )Z,Y,X(FMQis measured. The intent of the CTS Frequency logical connector "or" does not provide an exclusion to perform either the situational performance or the DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 6 of 9 repetitive performance of the test, because both are continuously applicable when )Z,Y,X(FMQis measured. Additionally, the CTS Frequency describes "when" the first performance is required (i.e. whichever occurs first) based on plant conditions. This change is acceptable because the ITS use of "AND

" will ensure both the situational and periodic performances are continuously applicable. This change is designated more restrictive because the Surveillance Requirements will be required to be performed more frequently than is required in CTS.

M09 CTS 4.2.2.3 states that when F Q(X,Y,Z) is measured for reasons other than meeting the requirements of Specification 4.2.2.2 an overall measured F Q(X,Y,Z) shall be obtained from a power distribution map, increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the F Q(X,Y,Z) limit specified in the COLR according to Specification 3.2.2. Proposed ITS SR 3.2.1.1, verifies )Z,Y,X(FCQis within the steady state limits, (1) Once after each refueling prior to THERMAL POWER exceeding 75% RTP, and (2) Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FCQwas last verified, and (3) In accordance with the Surveillance Frequency Control Program. This changes the CTS from a 4.2.2.3 measurement of F Q(X,Y,Z) to be within limits on a situational Frequency basis to the ITS Frequency of (1) Once after each refueling prior to THERMAL POWER exceeding 75% RTP, and (2) Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FCQwas last verified, and (3) In accordance with the Surveillance Frequency Control Program. (The relocation of "31 EFPD, thereafter to the Surveillance Frequency Control program" is discussed in DOC LA04 (Refer to DOC A02 for the discussion of the addition of a new term describing the steady state limit,)Z,Y,X(FCQ). The purpose of CTS 4.2.2.3 is to evaluate F Q(X,Y,Z) during those situational conditions where core power distribution limits may exceed limits assumed in the safety analysis. BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989 requires the measured F Q(X,Y,Z) to be compared against the steady state limit (ITS SR 3.2.1.1) and the two transient limits BQDES(X,Y,Z)(ITS SR 3.2.1.2) and BCDES(X,Y,Z)(ITS SR 3.2.1.3). ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 will be performed at the same Frequencies. This change is designated as more restrictive because the situational testing Frequency of CTS 4.2.2.3 is being replaced with two new situational Frequencies and a periodic performance, once every 31 EFPD.

RELOCATED SPECIFICATIONS

None DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 7 of 9 REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.2 ACTION b requires within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when FQ(X,Y,Z) is not within limits to reduce the Overpower Delta T Trip setpoints (value of K

4) at least 1% (in T span) for each 1% that F Q(X,Y,Z) exceeds the limit provided in the COLR. ITS LCO 3.2.1 Required Action A.3 requires within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of discovery that )Z,Y,X(FCQis not within limits, to reduce Overpower T trip setpoints at least 1% for each 1% that )Z,Y,X(FCQ exceeds the limit. This changes the CTS by moving the specific information regarding the terms, "value of K4" and "in T span," to the COLR.

The removal of these details for performing actions from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements to reduce Overpower T trip setpoints at least 1% for each 1% that )Z,Y,X(FCQexceeds the limit. Also, this change is acceptable because the removed information will be adequately controlled in the COLR requirements provided in ITS 5.6.5, "Core Operating Limits Report." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such as transient analysis limits and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)

CTS 3.2.2 ACTION c requires F Q(X,Y,Z) to be determined to be within its limit through incore mapping. CTS 4.2.2.3 requires

FQ(X,Y,Z) to be determined to be within its limit by obtaining a power distribution map and applying manufacturing tolerances and measurement uncertainty factors before comparing the results to the F Q(X,Y,Z) limit specified in the COLR. ITS 3.2.1 Required Action A.5 and ITS SR 3.2.1.1 require verification that )Z,Y,X(FCQ is within its limit. This changes the CTS by moving the manner in which the F Q(X,Y,Z) determination is performed to the Bases.

The removal of these details for performing actions from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to determine FQ(X,Y,Z) is within its limit. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 8 of 9 LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.2.2, 4.2.2.2.a, 4.2.2.2.b, 4.2.2.2.*, 4.2.2.2.**, 4.2.2.2.c.1, 4.2.2.2.c.2, 4.2.2.2.c.3.a, 4.2.2.2.c.3.b, 4.2.2.2.c.4.a, 4.2.2.2.c.4.b, 4.2.2.2.d, and 4.2.2.3 provide details for evaluating F MQ(X,Y,Z) to determine if FQ(X,Y,Z) is within limits. ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 collectively verify that F Q(X,Y,Z) (as discussed in DOC A4) is within limits specified in the COLR. This changes the CTS by moving the details for evaluating F MQ(X,Y,Z) to determine if F Q(X,Y,Z) is within limits to the ITS Bases.

The removal of these details from the Technical Specifications and their relocation into the ITS Bases is acceptable, because the procedural steps and further details for making a determination that F Q(X,Y,Z) is within its limits is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS Surveillance Requirement to verify

FQ(X,Y,Z) is within its limits will more closely align with the LCO requirement for FQ(X,Y,Z) to be within the limits specified in the COLR. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA04 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.2.2.2 requires, in part, a determination that F Q(X,Y,Z) is within its limits at least once per 31 EFPD. ITS SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 require a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for this SR and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 9 of 9 LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.2 ACTION a.2 states, in part, that when F Q(X,Y,Z) exceeds its limit, reduce the Power Range Neutron Flux - High Trip setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.1 Required Actions A.4 states with )Z,Y,X(FCQ not within limit, reduce the Power Range Neutron Flux - High Trip setpoints by 1% for each 1% )Z,Y,X(FCQ exceeds the limit. The ITS 3.2.1 Required Action A.4 Completion Time is "within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each )Z,Y,X(FCQdetermination." This changes the CTS by increasing the time allowed to reduce the trip setpoints.

The purpose of CTS 3.2.2 ACTION a.2 is to lower the Power Range Neutron Flux - High Trip setpoints, which ensures continued operation is at an acceptably low power level with an adequate DNBR margin and avoids violating the )Z,Y,X(FCQ limit. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced, and considers the low probability of a DBA occurring during the allowed Completion Time. The revised

Completion Time allows the Power Range Neutron Flux - High Trip setpoints to be reduced in a controlled manner without challenging operators, technicians, or plant systems. Following a significant power reduction, a time period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to reestablish steady state xenon concentration and power distribution and to take and analyze a flux map. If it is determined that )Z,Y,X(FCQis still not within its limit, reducing the Power Range Neutron Flux - High Trip Setpoints can be accomplished within a few hours. Furthermore, setpoint changes should only be required for extended operation in this condition, because of the risk of a plant trip during the adjustment. This change is designated as less restrictive, because additional time is allowed to lower the Power Range Neutron Flux - High Trip setpoints than was allowed in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-1 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 1223.2 POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)

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

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------

Required Action A.

4 shall be completed whenever this Condition is entered. ---------------------------------

)Z(FCQ not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% )Z(FCQ exceeds limit. AND A.2 Reduce Power Range Neutron Flux - High trip

setpoints 1% for each 1% )Z(FCQ exceeds limit.

AND A.3 Reduce Overpower T trip setpoints 1% for each 1% )Z(FCQ exceeds limit.

AND A.4 Perform SR 3.2.1.1 and SR 3.2.1.

2. 15 minutes after each )Z(FCQ determination

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each )Z(FCQ determination

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each )Z(FCQ determination

Prior to increasing THERMAL POWER

above the limit of Required Action A.1 X,Y,Z 22X,Y,Z 3.2.2 Applicabilit y ACTION a DOC L01 ACTION a.2 DOC M02 ACTION b DOC M02 ACTION c DOC M02 ),,(ZYXFCQ 111411DOC M01 4548 INSERT 1 the steady state 5 ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ, SR 3.2.1.2 3DOC M02 33333 3.2.1 Insert Page 3.2.1-1 CTS INSERT 1 CONDITION REQUIRED ACTION COMPLETION TIME AND A.2 Reduce, by administrative means, AFD limits 1% for each 1% )Z,Y,X(FCQ exceeds limit.

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after each )Z,Y,X(FCQ determination 3ACTION a.1 DOC M02 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-2 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ------------

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

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

)Z(FWQ not within limits.

B.1 Reduce AFD limits 1% for each 1% )Z(FWQ 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. 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. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

Prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits

C. Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 4D D DOC M03 INSERT 2 3.2.1 Insert Page 3.2.1-2 CTS INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME B. AFD min margin < 0

B.1 Reduce, by administrative means, positive AFD limit lines for each power level by PSLOPE AFD for each 1%

FQ(X,Y,Z) exceeds limit.

AND B.2 Reduce, by administrative means, negative AFD limit lines for each power level by NSLOPE AFD for each 1%

FQ(X,Y,Z) exceeds limit.

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> C. f2(I) min margin < 0

C.1 Reduce Overpower T positive f 2(I) breakpoint limit by PSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.

AND C.2 Reduce Overpower T negative f 2(I) breakpoint limit by NSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

44.2.2.2.c.3.b Note*4.2.2.2.c.3.a Note

  • 4.2.2.2.c.4.b Note ** 4.2.2.2.c.4.a Note ** 4.2.2.2.c.3 4.2.2.2.c.3 4.2.2.2.c.4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-3 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE----------------------------------------------------------- During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.

SURVEILLANCE FREQUENCY

SR 3.2.1.1 Verify )Z(FCQ is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within

[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z(FCQ was last verified

AND

[ 31 EFPD thereafter OR In accordance with the Surveillance

Frequency Control Program

] 4.2.2.2 Note *** 4.2.2.2 4.2.2.3

DOC M06 DOC M09 DOC A02 117884.2.2.2.d.2 4.2.2.2.d.1 DOC M07 the steady state),,(ZYXFCQ),,(ZYXFCQ4.2.2.1 DOC M04 5can be5INSERT 3 6Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 3.2.1 Insert Page 3.2.1-3 CTS INSERT 3 -----------------------------------------NOTE------------------------------------ Not required to be performed if SR 3.2.1.2 and SR 3.2.1.3 are met. --------------------------------------------------------------------------------------

64.2.2.2 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-4 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2

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

If measurements indicate that the

maximum over z [ )Z(FCQ / K(Z) ] has increased since the previous evaluation of )Z(FCQ:

a. Increase )Z(FWQ by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR and reverify )Z(FWQ 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

[)Z(FCQ / K(Z) ] has not increased.

Verify )Z(FWQ is within limit.

Once after each refueling prior to THERMAL POWER exceed

-ing 75% RTP AND Once within

[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z(FWQ was last verified AND 4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-5 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 1 Amendment xxx 122SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD thereafter OR In accordance with the Surveillance Frequency Control Program ]

4INSERT 4 4

3.2.1 Insert Page 3.2.1-5a CTS INSERT 4 SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------ If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

)Z,Y,X(FMQ > BQNOM(X,Y,Z) a. Increase )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify AFD min margin > 0; or

b. Repeat SR 3.2.1.2 prior to the time at which the projected AFD min margin will be < 0. ---------------------------------------------------------------------

Verify AFD min margin > 0.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

achieving

equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FMQ was last verified AND 44.2.2.2.e 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.c.1 DOC M06 4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5b CTS INSERT 4 (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD thereafter]

OR In accordance

with the Surveillance Frequency

Control Program

] 4.2.2.2.d.2 4

3.2.1 Insert Page 3.2.1-5c CTS INSERT 4 (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.3 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

)Z,Y,X(FMQ > BQNOM(X,Y,Z)

a. Increase )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify f2(I) min margin > 0; or
b. Repeat SR 3.2.1.3 prior to the time at which the projected f 2(I) min margin will be < 0. ---------------------------------------------------------------------

Verify f 2(I) min margin > 0.

Once after each

refueling prior to THERMAL POWER exceeding

75% RTP

AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

achieving

equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FMQ was last verified

AND 4 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.e 4.2.2.2.c.1 DOC M06 4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5d CTS INSERT 4 (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD thereafter OR In accordance with the

Surveillance

Frequency

Control Program

]

4.2.2.2.d.2 4

FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-1 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 1223.2 POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)

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

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------

Required Action A.

4 shall be completed whenever this Condition is entered. ---------------------------------

)Z(FCQ not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% )Z(FCQ exceeds limit. AND A.2 Reduce Power Range Neutron Flux - High trip

setpoints 1% for each 1% )Z(FCQ exceeds limit.

AND A.3 Reduce Overpower T trip setpoints 1% for each 1% )Z(FCQ exceeds limit.

AND A.4 Perform SR 3.2.1.1 and SR 3.2.1.

2. 15 minutes after each )Z(FCQ determination

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each )Z(FCQ determination

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each )Z(FCQ determination

Prior to increasing THERMAL POWER

above the limit of Required Action A.1 X,Y,Z 22X,Y,Z 3.2.2 Applicabilit y ACTION a DOC L01 ACTION a.2 DOC M02 ACTION b DOC M02 ACTION c DOC M02 ),,(ZYXFCQ 111411DOC M01 4548 INSERT 1 the steady state 5 ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ),,(ZYXFCQ, SR 3.2.1.2 3DOC M02 33333 3.2.1 Insert Page 3.2.1-1 CTS INSERT 1 CONDITION REQUIRED ACTION COMPLETION TIME AND A.2 Reduce, by administrative means, AFD limits 1% for each 1% )Z,Y,X(FCQ exceeds limit.

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after each )Z,Y,X(FCQ determination 3ACTION a.1 DOC M02 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-2 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ------------

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

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

)Z(FWQ not within limits.

B.1 Reduce AFD limits 1% for each 1% )Z(FWQ 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. 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. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />

Prior to increasing THERMAL POWER above the maximum allowable power of the AFD limits

C. Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 4D D DOC M03 INSERT 2 3.2.1 Insert Page 3.2.1-2 CTS INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME B. AFD min margin < 0

B.1 Reduce, by administrative means, positive AFD limit lines for each power level by PSLOPE AFD for each 1%

FQ(X,Y,Z) exceeds limit.

AND B.2 Reduce, by administrative means, negative AFD limit lines for each power level by NSLOPE AFD for each 1%

FQ(X,Y,Z) exceeds limit.

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> C. f2(I) min margin < 0

C.1 Reduce Overpower T positive f 2(I) breakpoint limit by PSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.

AND C.2 Reduce Overpower T negative f 2(I) breakpoint limit by NSLOPE f2(I) for each 1% F Q(X,Y,Z) exceeds limit.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

44.2.2.2.c.3.b Note*4.2.2.2.c.3.a Note

  • 4.2.2.2.c.4.b Note ** 4.2.2.2.c.4.a Note ** 4.2.2.2.c.3 4.2.2.2.c.3 4.2.2.2.c.4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-3 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122SURVEILLANCE REQUIREMENTS ------------------------------------------------------------NOTE----------------------------------------------------------- During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.

SURVEILLANCE FREQUENCY

SR 3.2.1.1 Verify )Z(FCQ is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within

[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z(FCQ was last verified

AND

[ 31 EFPD thereafter OR In accordance with the Surveillance

Frequency Control Program

] 4.2.2.2 Note *** 4.2.2.2 4.2.2.3

DOC M06 DOC M09 DOC A02 117884.2.2.2.d.2 4.2.2.2.d.1 DOC M07 the steady state),,(ZYXFCQ),,(ZYXFCQ4.2.2.1 DOC M04 5can be5INSERT 3 6Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after 3.2.1 Insert Page 3.2.1-3 CTS INSERT 3 -----------------------------------------NOTE------------------------------------ Not required to be performed if SR 3.2.1.2 and SR 3.2.1.3 are met. --------------------------------------------------------------------------------------

64.2.2.2 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-4 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2

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

If measurements indicate that the

maximum over z [ )Z(FCQ / K(Z) ] has increased since the previous evaluation of )Z(FCQ:

a. Increase )Z(FWQ by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR and reverify )Z(FWQ 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

[)Z(FCQ / K(Z) ] has not increased.

Verify )Z(FWQ is within limit.

Once after each refueling prior to THERMAL POWER exceed

-ing 75% RTP AND Once within

[12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z(FWQ was last verified AND 4 FQ(Z) (RAOC-W(Z) Methodology) 3.2.1B WOG STS 3.2.1B-5 Rev. 4.0, CTS X,Y,Z 1SEQUOYAH UNIT 2 Amendment xxx 122SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD thereafter OR In accordance with the Surveillance Frequency Control Program ]

4INSERT 4 4

3.2.1 Insert Page 3.2.1-5a CTS INSERT 4 SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------ If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

)Z,Y,X(FMQ > BQNOM(X,Y,Z) a. Increase )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify AFD min margin > 0; or

b. Repeat SR 3.2.1.2 prior to the time at which the projected AFD min margin will be < 0. ---------------------------------------------------------------------

Verify AFD min margin > 0.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

achieving

equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FMQ was last verified AND 44.2.2.2.e 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.c.1 DOC M06 4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5b CTS INSERT 4 (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD thereafter]

OR In accordance

with the Surveillance Frequency

Control Program

] 4.2.2.2.d.2 4

3.2.1 Insert Page 3.2.1-5c CTS INSERT 4 (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.3 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

)Z,Y,X(FMQ > BQNOM(X,Y,Z)

a. Increase )Z,Y,X(FMQ by the appropriate factor specified in the COLR and reverify f2(I) min margin > 0; or
b. Repeat SR 3.2.1.3 prior to the time at which the projected f 2(I) min margin will be < 0. ---------------------------------------------------------------------

Verify f 2(I) min margin > 0.

Once after each

refueling prior to THERMAL POWER exceeding

75% RTP

AND Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after

achieving

equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which )Z,Y,X(FMQ was last verified

AND 4 4.2.2.2.e.1 4.2.2.2.e.2 4.2.2.2.e 4.2.2.2.c.1 DOC M06 4.2.2.2.d.1 DOC M07 3.2.1 Insert Page 3.2.1-5d CTS INSERT 4 (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD thereafter OR In accordance with the

Surveillance

Frequency

Control Program

]

4.2.2.2.d.2 4

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 1 of 2 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The RAOC-W(Z) methodology and the Specification designator "B" are deleted because they are unnecessary. (Only one Heat Flux Hot Channel Factor Specification is used in the SQN ITS)

. This information is provided in NUREG-1431, Rev. 4 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-F XY and CAOC-W(Z) methodology Specifications (ISTS 3.2.1A and 3.2.1C) are not used and are not

shown. 3. ISTS ACTIONS do not contain a requirement to reduce the AFD limits when ACTION A is entered for )Z,Y,X(FCQnot met. CTS 3.2.2 ACTION a.1 requires a reduction of the allowable power at each point along the AFD limit lines to be reduced within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This requirement and Completion Time are being added as Required Action A.2.

4. ISTS SR 3.2.1.2 and ISTS ACTION B have been deleted. CTS does not include requirements to verify )Z(FWQis within limits, or actions to take if )Z(FWQis not within limits. However, CTS does require the verification that both AFD min

margin is > 0 and f 2(I) min margin is > 0. Additionally, the CTS specifies the actions to take if the above verifications are not met. These verifications and actions are added to ITS 3.2.1 as SR 3.2.1.2 and SR 3.2.1.3 with the associated

ACTIONS B and C.

5. ISTS 3.2.1 Surveillance Requirements Note allows, 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. CTS 3.2.2 *** Note has a similar allowance. However, in both CTS and ISTS the allowance is for the first power escalation at the beginning of a new core cycle. Additionally, the CTS has SR 4.2.2.1 which provides, The provisions of Specification 4.0.4 are not applicable. This allowance enables SQN to enter the MODE of Applicability with the Surveillance not being met. ISTS does not have a similar allowance in LCO 3.2.1. Therefore, SQN is retaining the allowance to change the MODE of Applicability with the surveillance not being met by modifying the existing Surveillance Note.
6. ISTS 3.2.1.1 has been modified by a Note providing an allowance to not perform SR 3.2.1.1 if the Surveillance has been determined to be met based on the performance results of both SR 3.2.1.2 and SR 3.2.1.3. If both the AFD min

margin and the f 2(I) min margin are positive, then the steady state limit is met because these margins represent bounding limiting conditions.

7. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 2 of 2 8. ISTS SR 3.2.1.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-1 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.1B Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)

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

FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density

, assuming nominal fuel pellet and fuel rod dimensions. Therefore, F Q(Z) is a measure of the peak fuel pellet power within the reactor core.

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

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

FQ(Z) is measured periodically using the incore detector system. These measurements are generally taken with the core at or near equilibrium conditions.

Using the measured three dimensional power distributions, it is possible

to derive a measured value for F Q(Z). However, because this value represents an equilibrium condition, it does not include the variations in

the value of F Q(Z) which are present during nonequilibrium situations such as load following or power ascension.

To account for these possible variations, the equilibrium value of F Q(Z) is adjusted as )Z(FWQby an elevation dependent factor that accounts for the calculated worst case transient conditions.

Core monitoring and control under non-equilibrium conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion. X,Y,Z 21X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z 1111and by assembly location, X, Y INSERT 1 8

3.2.1 Insert Page B 3.2.1-1 INSERT 1 "the FQ(X,Y,Z) limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted by pre-calculated factors (MQ(X,Y,Z) and MC(X,Y,Z) respectively) to account for the calculated worst case transient conditions."

1 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-2 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES

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

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

b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a departure from nucleate boiling (DNB) condition,
c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully

withdrawn (Ref. 3).

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

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

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

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

FQ(Z) (CFQ / P) K(Z) for P > 0.5

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

P = THERMAL POWER / RTP 1X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z RTPQFRTPQFFQ (X,Y,Z)X,Y,Z RTPQF 1.8 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-3 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES

LCO (continued)

For this facility, the actual values of CFQ and K(Z) are given in the COLR;

however, CFQ is normally a number on the order of [2.32], and K(Z) is a function that looks like the one provided in Figure B 3.2.1B-1.

For Relaxed Axial Offset Control operation, F Q(Z) is approximated by )Z(FCQ and )Z(FWQ. Thus, both )Z(FCQ and )Z(FWQ must meet the preceding limits on F Q(Z). An )Z(FCQ evaluation requires obtaining an incore flux map in MODE

1. From the incore flux map results we obtain the measured value ()Z(FMQ) of FQ(Z). Then,

)Z(FCQ = )Z(FMQ [1.0815] where [1.0815] is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.

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

The expression for )Z(FWQ is: )Z(FWQ= )Z(FCQW(Z) where W(Z) is a cycle dependent function that accounts for power distribution transients encountered during normal operation. W(

Z) is included in the COLR. The

)Z(FCQ is calculated at equilibrium conditions.

The FQ(Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA.

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

and if )Z(FWQcannot be maintained within the LCO limits, reduction of the AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.

Violating the LCO limits for F Q(Z) produces unacceptable consequences if a design basis event occurs while F Q(Z) is outside its specified limits.

RTPQFRTPQF2.62134INSERT 2 X,Y,Z )Z,Y,X(FCQX,Y,Z X,Y,Z 115SQN 3.2.1 Insert Page B 3.2.1-3a INSERT 2 Measured F Q(X,Y,Z) is compared against three limits:

  • Steady state limit, (F QRTP / P)
  • K(Z),
  • Limiting condition LOCA limit, BQDES(X,Y,Z), and
  • Limiting condition centerline fuel melt limit, BCDES(X,Y,Z).

FQ(X,Y,Z) is approximated by )Z,Y,X(FCQ for the steady state limit on F Q(X,Y,Z). An )Z,Y,X(FCQ evaluation requires using the moveable incore detectors to obtain a power distribution map in MODE 1. From the incore flux map results we obtain the measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z). Then, )Z,Y,X(FCQ = overall measured F Q(X,Y,Z)

  • 1.05
  • 1.03 where, 1.05 is the measurement reliability factor that accounts for flux map measurement uncertainty (Reference 5) and 1.03 is the local engineering heat flux hot channel factor to account for fuel rod manufacturing tolerance (Reference 4).

BQDES(X,Y,Z) and BCDES(X,Y,Z) are cycle dependent design limits to ensure the

FQ(X,Y,Z) limit is met during transients. An evaluation of these limits requires obtaining an incore flux map in MODE 1. From the incore flux map results we obtain the assembly nodal measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z). )Z,Y,X(FMQ is compared directly to the limits BQDES(X,Y,Z) and BCDES(X,Y,Z). This is appropriate since BQDES(X,Y,Z) and BCDES(X,Y,Z) have been adjusted for uncertainties.

The expression for BQDES(X,Y,Z) is: BQDES(X,Y,Z) = P d(X,Y,Z)

  • MQ(X,Y,Z)
  • NRF
  • F1 / MRF

where:

  • BQDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y at axial location Z. BQDES(X,Y,Z) ensures that the LOCA limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
  • Pd(X,Y,Z) is the design power distribution for fuel assembly X,Y at axial location Z, including the operational flexibility factor;
  • MQ(X,Y,Z) is the minimum available margin ratio for the LOCA limit at assembly X,Y and axial location Z;
  • NRF is the nuclear reliability factor;
  • F1 is the spacer grid factor;
  • MRF is measurement reliability factor.

4 3.2.1 Insert Page B 3.2.1-3b INSERT 2 (continued)

The expression for BCDES(X,Y,Z) is: BCDES(X,Y,Z) = P d(X,Y,Z)

  • MC(X,Y,Z)
  • NRF
  • F1 / MRF

where:

  • BCDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y, at axial location Z. BCDES(X,Y,Z) ensures that the centerline fuel melt limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
  • MC(X,Y,Z) is the minimum available margin ratio for the centerline fuel melt limit at assembly X,Y and axial location Z; The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:

)Z,Y,X(FMQ BQNOM(X,Y,Z) where:

  • BQNOM(X,Y,Z) is the nominal design peaking factor for assembly X,Y at axial location Z increased by an allowance for the expected deviation between the measured and predicted design power distribution.

The FQ(X,Y,Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA.

BQNOM (X,Y,Z), BQDES(X,Y,Z), and BCDES(X,Y,Z) Data bases are provided for the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in the COLR.

4 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-4 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES

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

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

core power.

ACTIONS A.1 Reducing THERMAL POWER by 1% RTP for each 1% by which )Z(FCQ exceeds its limit, maintains an acceptable absolute power density. )Z(FCQ is )Z(FMQmultiplied by a factor accounting for manufacturing tolerances and measurement uncertainties. )Z(FMQ is the measured value of FQ(Z). The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of )Z(FCQ and would require power reductions within 15 minutes of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable power level.

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

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

2 may be affected by subsequent determinations of )Z(FCQ and would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in )Z(FCQ would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

X,Y,Z 15)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 5)Z,Y,X(FMQ FQ (X,Y,Z))Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ4 )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQINSERT 3 54 Move to next page after A.3 3.2.1 Insert Page B 3.2.1-4 INSERT 3 A.2 Required Action A.2 requires an administrative reduction of the AFD limits by 1% for each 1% by which )Z,Y,X(FCQ exceeds the steady state limit. The allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded. The maximum allowable AFD limits initially determined by Required Action A.2 may be affected by subsequent determinations of )Z,Y,X(FCQ and would require further AFD limit reductions within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the )Z,Y,X(FCQdetermination, if necessary to comply with the decreased maximum allowable AFD limits.

Decreases in),,(ZYXFCQwould allow increasing the maximum allowable AFD limits.

5 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-5 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES ACTIONS (continued)

A.3 Reduction in the Overpower T trip setpoints (value of K

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

A.4 Verification that )Z(FCQ 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 F Q(Z) that can occur during normal maneuvers, )Z(FWQ, exceeds its specified limits, there exists a potential for )Z(FCQ to become excessively high if a normal operational transient occurs. Reducing the AFD by 1% for each 1% by which )Z(FWQ exceeds its limit within the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded.

51555154848)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ3 , SR 3.2.1.2 INSERT 4 INSERT 6 INSERT 5 in T span5543steady state and transient 55 , SR 3.2.1.2 , SR 3.2.1.2 35 )Z,Y,X(FCQ)Z,Y,X(FCQ 3.2.1 Insert Page B 3.2.1-5a INSERT 4 Since)Z,Y,X(FCQ exceeds the steady state limit, the limiting condition operational limit (BQDES) and the limiting condition Reactor Protection System limit (BCDES) may also be exceeded. By performing SR 3.2.1.2 and SR 3.2.1.3, appropriate actions with respect to reductions in AFD limits and OPT trip setpoints will be performed, ensuring that core conditions during operational and Condition II transients are maintained within the bounds of the safety analysis.

5 3.2.1 Insert Page B 3.2.1-5b INSERT 5 B.1 and B.2 The FQ(X,Y,Z) margin supporting AFD operational limits (AFD margin) during transient operations is based on the relationship between)Z,Y,X(FMQ and the limiting condition operational limit, BQDES (X,Y,Z), as follows:

%AFD margin = %*),,(),,(1001ZYXBQDESZYXFMQ The AFD min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BQDES (X,Y,Z) and calculation of %AFD margin is not required. If the AFD margin is less than zero, then )Z,Y,X(FMQ is greater than BQDES (X,Y,Z) and the AFD limits may not be adequate to prevent exceeding the peaking criteria for a LOCA if a normal operational transient occurs.

Required Actions B.1 and B.2 require reducing the AFD limit lines as follows. The AFD limit reduction is from the full power AFD limits. The adjusted AFD limits must be used until a new measurement shows that a smaller adjustment can be made to the AFD limits, or that no adjustment is necessary:

APL = PAFDL - Absolute Value of (PSLOPE AFD * % AFD Margin)

ANL = NAFDL + Absolute Value of (NSLOPE AFD * % AFD Margin)

where,

  • APL is the adjusted positive AFD limit.
  • ANL is the adjusted negative AFD limit.
  • PAFDL is the positive AFD limit defined in the COLR.
  • NAFDL is the negative AFD limit defined in the COLR.
  • PSLOPEAFD is the adjustment to the positive AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
  • NSLOPEAFD is the adjustment to the negative AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
  • % AFD Margin is the most negative margin determined above.

Completing Required Actions B.1 and B.2 within the allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded.

54 3.2.1 Insert Page B 3.2.1-5c INSERT 6 C.1 and C.2

The FQ(X,Y,Z) margin supporting the Overpower T f2(I) breakpoints (f 2(I) margin) during transient operations is based on the relationship between )Z,Y,X(FMQ and the limit, BCDES(X,Y,Z), as follows:

% f2(I) margin = %*),,(),,(1001ZYXBCDESZYXFMQ The f2(I) min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BCDES(X,Y,Z) and calculation of % f 2(I) margin is not required. If the f 2(I) margin is less than zero, then )Z,Y,X(FMQ is greater than BCDES(X,Y,Z) and there is a potential that the f 2(I) limits are insufficient to preclude centerline fuel melt during certain transients.

Required Actions C.1 and C.2 require reducing the f 2(I) breakpoint limits as follows. The f 2(I) breakpoint limit reduction is always from the full power f2(I) breakpoint limits. The adjusted f 2(I) breakpoint limits must be used until a new measurement show s that a smaller adjustment can be made to the f 2(I) breakpoint limits, or that no adjustment is necessary.

Posf2(I)Adjusted = Posf2(I)Limit - Absolute Value of (PSLOPE f2(I) * % f2(I) Margin)

Negf2(I)Adjusted

= Negf2(I)Limit + Absolute Value of (NSLOPE f2(I) * % f2(I) Margin) where:

  • Posf2(I)Adjusted is the adjusted OPT positive f 2(I) breakpoint limit.
  • Negf2(I)Adjusted is the adjusted OPT negative f 2(I) breakpoint limit.
  • Posf2(I)Limit is the OPT positive f 2(I) breakpoint limit defined in the COLR.
  • Negf2(I)Limit is the OPT negative f 2(I) breakpoint limit defined in the COLR.
  • PSLOPEf2(I) is the adjustment to the positive OPT f2(I) limit required to compensate for each 1% that )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
  • NSLOPEf2(I) is the adjustment to the negative OPT f2(I) limit required to compensate for each 1% that )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
  • % f2(I) Margin is the most negative margin determined above.

54 3.2.1 Insert Page B 3.2.1-5d INSERT 6 (continued)

Completing Required Actions C.1 and C.2 is a conservative action for protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Completing Required Actions C.1 and C.2 within the allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is sufficient considering the small likelihood of a limiting transient in this time period.

54 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-6 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES ACTIONS (continued)

The implicit assumption is that if W(

Z) values were recalculated (consistent with the reduced AFD limits), then )Z(FCQ times the recalculated W(Z) values would meet the F Q(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 and B.4.

B.2 A reduction of the Power Range Neutron Flux

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

B.3 Reduction in the Overpower T trip setpoints value of K 4 by 1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.4 Verification that )Z(FWQ has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.1 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.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 B.1, even when Condition A is exited prior to performing Required Action B.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure F Q(Z) is properly evaluated prior to increasing THERMAL POWER.

5 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-7 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES ACTIONS (continued)

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

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

SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.

2 are modified by a Note.

The Note applies REQUIREMENTS during the first power ascension after a refueling. It states that THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained. This allowance is modified, however, by one of the Frequency conditions that requires verification that )Z(FCQ and )Z(FWQ are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits.

Because )Z(FCQ and )Z(FWQ could not have previously been measured in this reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of )Z(FCQ and )Z(FWQ are made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of )Z(FCQ and )Z(FWQ following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of )Z(FCQ and )Z(FWQ. The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.

D 551X,Y,Z A.5, B.1, B.2, C.1 or C.2 )Z,Y,X(FCQ)Z,Y,X(FMQ , SR 3.2.1.2 3)Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> afterSurveillance performance is not re quired FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-8 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.1 Verification that )Z(FCQ is within its specified limits involves increasing)Z(FMQ to allow for manufacturing tolerance and measurement uncertainties in order to obtain )Z(FCQ. Specifically, )Z(FMQ is the measured value of F Q(Z) obtained from incore flux map results and )Z(FCQ = )Z(FMQ [1.0815] (Ref.

4). )Z(FCQ is then compared to its specified limits.

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

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

If THERMAL POWER has been increased by 10% RTP since the last determination of )Z(FCQ, another evaluation of this factor is required

[12] hours after achieving equilibrium conditions at this higher power level (to ensure that )Z(FCQ values are being reduced sufficiently with power increase to stay within the LCO limits).

[ The Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup because such changes are slow and well controlled when the plant is operated in accordance with the Technical Specifications (TS).

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] 1111267)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQDirect verification 3the overall measured F Q (X,Y,Z)INSERT 7 4

3.2.1 Insert Page B 3.2.1-8 INSERT 7 The surveillance has been modified by a Note providing an allowance to not perform SR 3.2.1.1 if the Surveillance has been determined to be met based on the performance results of both SR 3.2.1.2 and SR 3.2.1.3. If both the AFD min margin and the f 2(I) min margin are positive, then the steady state limit is met because these margins represent bounding limiting conditions.

However, if AFD min margin or f 2(I) min margin is negative then a direct evaluation of the steady state limit is required to satisfy this surveillance requirement.

4 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-9 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.2

The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, )Z(FCQ, by W(Z) gives the maximum F Q(Z) calculated to occur in normal operation, )Z(FWQ. The limit with which )Z(FWQ 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 30 to 75 core elevations. )Z(FWQ evaluations are not applicable for the following axial core regions, measured in percent of core height:

a. Lower core region, from 0 to 15% inclusive and
b. Upper core region, from 85 to 100% inclusive.

The top and bottom 15% 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 )Z(FWQ is evaluated, an evaluation of the expression below is required to account for any increase to )Z(FMQ that may occur and cause the F Q(Z) limit to be exceeded before the next required FQ(Z) evaluation.

If the two most recent F Q(Z) evaluations show an increase in the expression maximum over z [ )Z(FCQ / K(Z) ], it is required to meet the FQ(Z) limit with the last )Z(FWQ increased by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR (Ref. 5)

and 3.2.1.3 5FQ (X,Y,Z)BQDES (X,Y,Z) and BCDES (X,Y,Z) limits INSERT 10 INSERT 8 INSERT 9 FQ (X,Y,Z))Z,Y,X(FMQ and found to be within the applicable limiting condition limits 244based on future projections 3.2.1 Insert Page B 3.2.1-9a INSERT 8 both assembly and axial location (X,Y,Z), has been included in the cycle specific limits BQDES(X,Y,Z) and BCDES(X,Y,Z) using margin factors MQ(X,Y,Z) and MC(X,Y,Z),

respectively (Reference 5).

INSERT 9 No uncertainties are applied to )Z,Y,X(FMQ because the limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted for uncertainties.

44 3.2.1 Insert Page B 3.2.1-9b INSERT 10 In addition to ensuring via surveillance that the heat flux hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Z,Y,X(FMQ for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an )Z,Y,X(FMQ > BQNOM(X,Y,Z), further consideration is required.

The implications of these extrapolations are considered separately for both the operational and RPS heat flux hot channel factor limits. If the extrapolations of )Z,Y,X(FMQ are unfavorable, additional actions must be taken. These actions are to meet the F Q(X,Y,Z) limit with the last )Z,Y,X(FMQ increased by the appropriate factor specified in the COLR or to evaluate )Z,Y,X(FMQ prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative requirements prevent F Q(X,Y,Z) from exceeding its limit for any significant period of time without detection using the best available data.

Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.

FQ(X,Y,Z) is verified at power levels 10% RTP above the THERMAL POWER of its last verification within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions to ensure that F Q(X,Y,Z) is within its limit at higher power levels. 4 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-10 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 1 Revision XXX 12BASES

SURVEILLANCE REQUIREMENTS (continued)

REVIEWER'S NOTE-----------------------------------

WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control and FQ Surveillance Technical Specification," February 1994, or other appropriate plant specific methodology, is to be listed in the COLR description in the Administrative Controls Section 5.0 to address the methodology used to derive this factor.

or to evaluate F Q(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.

Performing the Surveillance in MODE 1 prior to exceeding 75%

RTP ensures that the F Q(Z) limit is met when RTP is achieved, because peaking factors are generally decreased as power level is increased.

FQ(Z) is verified at power levels 10% RTP above the THERMAL POWER of its last verification, [12]

hours after achieving equilibrium conditions to ensure that F Q(Z) is within its limit at higher power levels.

The Surveillance Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup. The Surveillance may be done more frequently if required by the results of F Q(Z) evaluations.

[ The Frequency of 31 EFPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS, to preclude adverse peaking factors between 31 day surveillances.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] 467 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-11 Rev. 4.0, 1X,Y,Z212Revision XXX SEQUOYAH UNIT 1 BASES REFERENCES 1. 10 CFR 50.46, 1974.

2. Regulatory Guide 1.77, Rev. 0, May 1974.
3. 10 CFR 50, Appendix A, GDC 26.
4. WCAP-7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.
5. WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control (and) F Q Surveillance Technical Specification," February 1994. 4BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989.

Enclosure 2, Volume 7, Rev. 0, Page 76 of 249Fq(z)@arzrj B 3'2'1s%g 06\<FT.(.) %* Fo r c216.64633.3 50.0CORE HEIGHTI66.712100re height of 12 feetFigure B 3.2. 1B-1K(Z) , Normalized Fo(Z) as a(page 1 of 1)Function of Core Height+WOG STSB 3.2.1s12Volume 7, Rev. 0,ooDO NOT OPERATE IN THIS AREA(6.0, 1 .0):9, o.g4)(12.0,0.65)

ILLUSIGURE FORRATION ONLY.NOT USE FOROPERATION Enclosure 2,Page 76 of 249 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-1 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.1B Heat Flux Hot Channel Factor (F Q(Z) (RAOC-W(Z) Methodology)

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

FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density

, assuming nominal fuel pellet and fuel rod dimensions. Therefore, F Q(Z) is a measure of the peak fuel pellet power within the reactor core.

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

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

FQ(Z) is measured periodically using the incore detector system. These measurements are generally taken with the core at or near equilibrium conditions.

Using the measured three dimensional power distributions, it is possible

to derive a measured value for F Q(Z). However, because this value represents an equilibrium condition, it does not include the variations in

the value of F Q(Z) which are present during nonequilibrium situations such as load following or power ascension.

To account for these possible variations, the equilibrium value of F Q(Z) is adjusted as )Z(FWQby an elevation dependent factor that accounts for the calculated worst case transient conditions.

Core monitoring and control under non-equilibrium conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion. X,Y,Z 21X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z 1111and by assembly location, X, Y INSERT 1 8

3.2.1 Insert Page B 3.2.1-1 INSERT 1 "the FQ(X,Y,Z) limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted by pre-calculated factors (MQ(X,Y,Z) and MC(X,Y,Z) respectively) to account for the calculated worst case transient conditions."

1 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-2 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES

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

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

b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a departure from nucleate boiling (DNB) condition,
c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully

withdrawn (Ref. 3).

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

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

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

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

FQ(Z) (CFQ / P) K(Z) for P > 0.5

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

P = THERMAL POWER / RTP 1X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z X,Y,Z RTPQFRTPQFFQ (X,Y,Z)X,Y,Z RTPQF1.8 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-3 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES

LCO (continued)

For this facility, the actual values of CFQ and K(Z) are given in the COLR;

however, CFQ is normally a number on the order of [2.32], and K(Z) is a function that looks like the one provided in Figure B 3.2.1B-1.

For Relaxed Axial Offset Control operation, F Q(Z) is approximated by )Z(FCQ and )Z(FWQ. Thus, both )Z(FCQ and )Z(FWQ must meet the preceding limits on F Q(Z). An )Z(FCQ evaluation requires obtaining an incore flux map in MODE

1. From the incore flux map results we obtain the measured value ()Z(FMQ) of FQ(Z). Then,

)Z(FCQ = )Z(FMQ [1.0815] where [1.0815] is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainty.

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

The expression for )Z(FWQ is: )Z(FWQ= )Z(FCQW(Z) where W(Z) is a cycle dependent function that accounts for power distribution transients encountered during normal operation. W(

Z) is included in the COLR. The

)Z(FCQ is calculated at equilibrium conditions.

The FQ(Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA.

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

and if )Z(FWQcannot be maintained within the LCO limits, reduction of the AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.

Violating the LCO limits for F Q(Z) produces unacceptable consequences if a design basis event occurs while F Q(Z) is outside its specified limits.

RTPQFRTPQF2.62134INSERT 2 X,Y,Z )Z,Y,X(FCQX,Y,Z X,Y,Z 115SQN 3.2.1 Insert Page B 3.2.1-3a INSERT 2 Measured F Q(X,Y,Z) is compared against three limits:

  • Steady state limit, (F QRTP / P)
  • K(Z),
  • Limiting condition LOCA limit, BQDES(X,Y,Z), and
  • Limiting condition centerline fuel melt limit, BCDES(X,Y,Z).

FQ(X,Y,Z) is approximated by )Z,Y,X(FCQ for the steady state limit on F Q(X,Y,Z). An )Z,Y,X(FCQ evaluation requires using the moveable incore detectors to obtain a power distribution map in MODE 1. From the incore flux map results we obtain the measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z). Then, )Z,Y,X(FCQ = overall measured F Q(X,Y,Z)

  • 1.05
  • 1.03 where, 1.05 is the measurement reliability factor that accounts for flux map measurement uncertainty (Reference 5) and 1.03 is the local engineering heat flux hot channel factor to account for fuel rod manufacturing tolerance (Reference 4).

BQDES(X,Y,Z) and BCDES(X,Y,Z) are cycle dependent design limits to ensure the

FQ(X,Y,Z) limit is met during transients. An evaluation of these limits requires obtaining an incore flux map in MODE 1. From the incore flux map results we obtain the assembly nodal measured value ()Z,Y,X(FMQ) of FQ(X,Y,Z). )Z,Y,X(FMQ is compared directly to the limits BQDES(X,Y,Z) and BCDES(X,Y,Z). This is appropriate since BQDES(X,Y,Z) and BCDES(X,Y,Z) have been adjusted for uncertainties.

The expression for BQDES(X,Y,Z) is: BQDES(X,Y,Z) = P d(X,Y,Z)

  • MQ(X,Y,Z)
  • NRF
  • F1 / MRF

where:

  • BQDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y at axial location Z. BQDES(X,Y,Z) ensures that the LOCA limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
  • Pd(X,Y,Z) is the design power distribution for fuel assembly X,Y at axial location Z, including the operational flexibility factor;
  • MQ(X,Y,Z) is the minimum available margin ratio for the LOCA limit at assembly X,Y and axial location Z;
  • NRF is the nuclear reliability factor;
  • F1 is the spacer grid factor;
  • MRF is measurement reliability factor.

4 3.2.1 Insert Page B 3.2.1-3b INSERT 2 (continued)

The expression for BCDES(X,Y,Z) is: BCDES(X,Y,Z) = P d(X,Y,Z)

  • MC(X,Y,Z)
  • NRF
  • F1 / MRF

where:

  • BCDES(X,Y,Z) is the cycle dependent maximum allowable design peaking factor for fuel assembly X,Y, at axial location Z. BCDES(X,Y,Z) ensures that the centerline fuel melt limit will be preserved for operation within the LCO limits, including allowances for calculational and measurement uncertainties;
  • MC(X,Y,Z) is the minimum available margin ratio for the centerline fuel melt limit at assembly X,Y and axial location Z; The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:

)Z,Y,X(FMQ BQNOM(X,Y,Z) where:

  • BQNOM(X,Y,Z) is the nominal design peaking factor for assembly X,Y at axial location Z increased by an allowance for the expected deviation between the measured and predicted design power distribution.

The FQ(X,Y,Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA.

BQNOM (X,Y,Z), BQDES(X,Y,Z), and BCDES(X,Y,Z) Data bases are provided for the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in the COLR.

4 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-4 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES

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

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

core power.

ACTIONS A.1 Reducing THERMAL POWER by 1% RTP for each 1% by which )Z(FCQ exceeds its limit, maintains an acceptable absolute power density. )Z(FCQ is )Z(FMQmultiplied by a factor accounting for manufacturing tolerances and measurement uncertainties. )Z(FMQ is the measured value of FQ(Z). The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of )Z(FCQ and would require power reductions within 15 minutes of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable power level.

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

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

2 may be affected by subsequent determinations of )Z(FCQ and would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the )Z(FCQ determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in )Z(FCQ would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

X,Y,Z 15)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 5)Z,Y,X(FMQ FQ (X,Y,Z))Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ4 )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQINSERT 3 54 Move to next page after A.3 3.2.1 Insert Page B 3.2.1-4 INSERT 3 A.2 Required Action A.2 requires an administrative reduction of the AFD limits by 1% for each 1% by which )Z,Y,X(FCQ exceeds the steady state limit. The allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded. The maximum allowable AFD limits initially determined by Required Action A.2 may be affected by subsequent determinations of )Z,Y,X(FCQ and would require further AFD limit reductions within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the )Z,Y,X(FCQdetermination, if necessary to comply with the decreased maximum allowable AFD limits.

Decreases in),,(ZYXFCQwould allow increasing the maximum allowable AFD limits.

5 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-5 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES ACTIONS (continued)

A.3 Reduction in the Overpower T trip setpoints (value of K

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

A.4 Verification that )Z(FCQ 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 F Q(Z) that can occur during normal maneuvers, )Z(FWQ, exceeds its specified limits, there exists a potential for )Z(FCQ to become excessively high if a normal operational transient occurs. Reducing the AFD by 1% for each 1% by which )Z(FWQ exceeds its limit within the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factors are not exceeded.

51555154848)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ3 , SR 3.2.1.2 INSERT 4 INSERT 6 INSERT 5 in T span5543steady state and transient 55 , SR 3.2.1.2 , SR 3.2.1.2 35 )Z,Y,X(FCQ)Z,Y,X(FCQ 3.2.1 Insert Page B 3.2.1-5a INSERT 4 Since)Z,Y,X(FCQ exceeds the steady state limit, the limiting condition operational limit (BQDES) and the limiting condition Reactor Protection System limit (BCDES) may also be exceeded. By performing SR 3.2.1.2 and SR 3.2.1.3, appropriate actions with respect to reductions in AFD limits and OPT trip setpoints will be performed, ensuring that core conditions during operational and Condition II transients are maintained within the bounds of the safety analysis.

5 3.2.1 Insert Page B 3.2.1-5b INSERT 5 B.1 and B.2 The FQ(X,Y,Z) margin supporting AFD operational limits (AFD margin) during transient operations is based on the relationship between)Z,Y,X(FMQ and the limiting condition operational limit, BQDES (X,Y,Z), as follows:

%AFD margin = %*),,(),,(1001ZYXBQDESZYXFMQ The AFD min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BQDES (X,Y,Z) and calculation of %AFD margin is not required. If the AFD margin is less than zero, then )Z,Y,X(FMQ is greater than BQDES (X,Y,Z) and the AFD limits may not be adequate to prevent exceeding the peaking criteria for a LOCA if a normal operational transient occurs.

Required Actions B.1 and B.2 require reducing the AFD limit lines as follows. The AFD limit reduction is from the full power AFD limits. The adjusted AFD limits must be used until a new measurement shows that a smaller adjustment can be made to the AFD limits, or that no adjustment is necessary:

APL = PAFDL - Absolute Value of (PSLOPE AFD * % AFD Margin)

ANL = NAFDL + Absolute Value of (NSLOPE AFD * % AFD Margin)

where,

  • APL is the adjusted positive AFD limit.
  • ANL is the adjusted negative AFD limit.
  • PAFDL is the positive AFD limit defined in the COLR.
  • NAFDL is the negative AFD limit defined in the COLR.
  • PSLOPEAFD is the adjustment to the positive AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
  • NSLOPEAFD is the adjustment to the negative AFD limit required to compensate for each 1% that)Z,Y,X(FMQ exceeds BQDES (X,Y,Z) as defined in the COLR.
  • % AFD Margin is the most negative margin determined above.

Completing Required Actions B.1 and B.2 within the allowed Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded.

54 3.2.1 Insert Page B 3.2.1-5c INSERT 6 C.1 and C.2

The FQ(X,Y,Z) margin supporting the Overpower T f2(I) breakpoints (f 2(I) margin) during transient operations is based on the relationship between )Z,Y,X(FMQ and the limit, BCDES(X,Y,Z), as follows:

% f2(I) margin = %*),,(),,(1001ZYXBCDESZYXFMQ The f2(I) min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then )Z,Y,X(FMQ is less than BCDES(X,Y,Z) and calculation of % f 2(I) margin is not required. If the f 2(I) margin is less than zero, then )Z,Y,X(FMQ is greater than BCDES(X,Y,Z) and there is a potential that the f 2(I) limits are insufficient to preclude centerline fuel melt during certain transients.

Required Actions C.1 and C.2 require reducing the f 2(I) breakpoint limits as follows. The f 2(I) breakpoint limit reduction is always from the full power f2(I) breakpoint limits. The adjusted f 2(I) breakpoint limits must be used until a new measurement show s that a smaller adjustment can be made to the f 2(I) breakpoint limits, or that no adjustment is necessary.

Posf2(I)Adjusted = Posf2(I)Limit - Absolute Value of (PSLOPE f2(I) * % f2(I) Margin)

Negf2(I)Adjusted

= Negf2(I)Limit + Absolute Value of (NSLOPE f2(I) * % f2(I) Margin) where:

  • Posf2(I)Adjusted is the adjusted OPT positive f 2(I) breakpoint limit.
  • Negf2(I)Adjusted is the adjusted OPT negative f 2(I) breakpoint limit.
  • Posf2(I)Limit is the OPT positive f 2(I) breakpoint limit defined in the COLR.
  • Negf2(I)Limit is the OPT negative f 2(I) breakpoint limit defined in the COLR.
  • PSLOPEf2(I) is the adjustment to the positive OPT f2(I) limit required to compensate for each 1% that )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
  • NSLOPEf2(I) is the adjustment to the negative OPT f2(I) limit required to compensate for each 1% that )Z,Y,X(FMQ exceeds BCDES(X,Y,Z) as defined in the COLR.
  • % f2(I) Margin is the most negative margin determined above.

54 3.2.1 Insert Page B 3.2.1-5d INSERT 6 (continued)

Completing Required Actions C.1 and C.2 is a conservative action for protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Completing Required Actions C.1 and C.2 within the allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is sufficient considering the small likelihood of a limiting transient in this time period.

54 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-6 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES ACTIONS (continued)

The implicit assumption is that if W(

Z) values were recalculated (consistent with the reduced AFD limits), then )Z(FCQ times the recalculated W(Z) values would meet the F Q(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 and B.4.

B.2 A reduction of the Power Range Neutron Flux

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

B.3 Reduction in the Overpower T trip setpoints value of K 4 by 1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.4 Verification that )Z(FWQ has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.1 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.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 B.1, even when Condition A is exited prior to performing Required Action B.4. Performance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure F Q(Z) is properly evaluated prior to increasing THERMAL POWER.

5 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-7 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES ACTIONS (continued)

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

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

SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.

2 are modified by a Note.

The Note applies REQUIREMENTS during the first power ascension after a refueling. It states that THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained. This allowance is modified, however, by one of the Frequency conditions that requires verification that )Z(FCQ and )Z(FWQ are within their specified limits after a power rise of more than 10% RTP over the THERMAL POWER at which they were last verified to be within specified limits.

Because )Z(FCQ and )Z(FWQ could not have previously been measured in this reload core, there is a second Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of )Z(FCQ and )Z(FWQ are made at a lower power level at which adequate margin is available before going to 100% RTP. Also, this Frequency condition, together with the Frequency condition requiring verification of )Z(FCQ and )Z(FWQ following a power increase of more than 10%, ensures that they are verified as soon as RTP (or any other level for extended operation) is achieved. In the absence of these Frequency conditions, it is possible to increase power to RTP and operate for 31 days without verification of )Z(FCQ and )Z(FWQ. The Frequency condition is not intended to require verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.

D 551X,Y,Z A.5, B.1, B.2, C.1 or C.2 )Z,Y,X(FCQ)Z,Y,X(FMQ , SR 3.2.1.2 3)Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FMQ )Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FMQ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> afterSurveillance performance is not re quired FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-8 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.1 Verification that )Z(FCQ is within its specified limits involves increasing)Z(FMQ to allow for manufacturing tolerance and measurement uncertainties in order to obtain )Z(FCQ. Specifically, )Z(FMQ is the measured value of F Q(Z) obtained from incore flux map results and )Z(FCQ = )Z(FMQ [1.0815] (Ref.

4). )Z(FCQ is then compared to its specified limits.

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

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

If THERMAL POWER has been increased by 10% RTP since the last determination of )Z(FCQ, another evaluation of this factor is required

[12] hours after achieving equilibrium conditions at this higher power level (to ensure that )Z(FCQ values are being reduced sufficiently with power increase to stay within the LCO limits).

[ The Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup because such changes are slow and well controlled when the plant is operated in accordance with the Technical Specifications (TS).

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] 1111267)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQ)Z,Y,X(FCQDirect verification 3the overall measured F Q (X,Y,Z)INSERT 7 4

3.2.1 Insert Page B 3.2.1-8 INSERT 7 The surveillance has been modified by a Note providing an allowance to not perform SR 3.2.1.1 if the Surveillance has been determined to be met based on the performance results of both SR 3.2.1.2 and SR 3.2.1.3. If both the AFD min margin and the f 2(I) min margin are positive, then the steady state limit is met because these margins represent bounding limiting conditions.

However, if AFD min margin or f 2(I) min margin is negative then a direct evaluation of the steady state limit is required to satisfy this surveillance requirement.

4 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-9 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES

SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.2

The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps are taken in steady state conditions, the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers in normal operation. The maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, )Z(FCQ, by W(Z) gives the maximum F Q(Z) calculated to occur in normal operation, )Z(FWQ. The limit with which )Z(FWQ 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 30 to 75 core elevations. )Z(FWQ evaluations are not applicable for the following axial core regions, measured in percent of core height:

a. Lower core region, from 0 to 15% inclusive and
b. Upper core region, from 85 to 100% inclusive.

The top and bottom 15% 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 )Z(FWQ is evaluated, an evaluation of the expression below is required to account for any increase to )Z(FMQ that may occur and cause the F Q(Z) limit to be exceeded before the next required FQ(Z) evaluation.

If the two most recent F Q(Z) evaluations show an increase in the expression maximum over z [ )Z(FCQ / K(Z) ], it is required to meet the FQ(Z) limit with the last )Z(FWQ increased by the greater of a factor of [1.02] or by an appropriate factor specified in the COLR (Ref. 5)

and 3.2.1.3 5FQ (X,Y,Z)BQDES (X,Y,Z) and BCDES (X,Y,Z) limits INSERT 10 INSERT 8 INSERT 9 FQ (X,Y,Z))Z,Y,X(FMQ and found to be within the applicable limiting condition limits 244based on future projections 3.2.1 Insert Page B 3.2.1-9a INSERT 8 both assembly and axial location (X,Y,Z), has been included in the cycle specific limits BQDES(X,Y,Z) and BCDES(X,Y,Z) using margin factors MQ(X,Y,Z) and MC(X,Y,Z),

respectively (Reference 5).

INSERT 9 No uncertainties are applied to )Z,Y,X(FMQ because the limits, BQDES(X,Y,Z) and BCDES(X,Y,Z), have been adjusted for uncertainties.

44 3.2.1 Insert Page B 3.2.1-9b INSERT 10 In addition to ensuring via surveillance that the heat flux hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Z,Y,X(FMQ for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an )Z,Y,X(FMQ > BQNOM(X,Y,Z), further consideration is required.

The implications of these extrapolations are considered separately for both the operational and RPS heat flux hot channel factor limits. If the extrapolations of )Z,Y,X(FMQ are unfavorable, additional actions must be taken. These actions are to meet the F Q(X,Y,Z) limit with the last )Z,Y,X(FMQ increased by the appropriate factor specified in the COLR or to evaluate )Z,Y,X(FMQ prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative requirements prevent F Q(X,Y,Z) from exceeding its limit for any significant period of time without detection using the best available data.

Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.

FQ(X,Y,Z) is verified at power levels 10% RTP above the THERMAL POWER of its last verification within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after achieving equilibrium conditions to ensure that F Q(X,Y,Z) is within its limit at higher power levels. 4 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-10 Rev. 4.0, 1X,Y,Z2SEQUOYAH UNIT 2 Revision XXX 12BASES

SURVEILLANCE REQUIREMENTS (continued)

REVIEWER'S NOTE-----------------------------------

WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control and FQ Surveillance Technical Specification," February 1994, or other appropriate plant specific methodology, is to be listed in the COLR description in the Administrative Controls Section 5.0 to address the methodology used to derive this factor.

or to evaluate F Q(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection.

Performing the Surveillance in MODE 1 prior to exceeding 75%

RTP ensures that the F Q(Z) limit is met when RTP is achieved, because peaking factors are generally decreased as power level is increased.

FQ(Z) is verified at power levels 10% RTP above the THERMAL POWER of its last verification, [12]

hours after achieving equilibrium conditions to ensure that F Q(Z) is within its limit at higher power levels.

The Surveillance Frequency of 31 EFPD is adequate to monitor the change of power distribution with core burnup. The Surveillance may be done more frequently if required by the results of F Q(Z) evaluations.

[ The Frequency of 31 EFPD is adequate to monitor the change of power distribution because such a change is sufficiently slow, when the plant is operated in accordance with the TS, to preclude adverse peaking factors between 31 day surveillances.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] 467 FQ(Z) (RAOC-W(Z) Methodology)

B 3.2.1B WOG STS B 3.2.1B-11 Rev. 4.0, 1X,Y,Z212Revision XXX SEQUOYAH UNIT 2 BASES REFERENCES 1. 10 CFR 50.46, 1974.

2. Regulatory Guide 1.77, Rev. 0, May 1974.
3. 10 CFR 50, Appendix A, GDC 26.
4. WCAP-7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.
5. WCAP-10216-P-A, Rev. 1A, "Relaxation of Constant Axial Offset Control (and) F Q Surveillance Technical Specification," February 1994. 4BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989.

Enclosure 2, Volume 7, Rev. 0, Page 99 of 249Fo(z)@EvaJ B 3'218%\t 0.6\<FT.(-) To*For c216.64633.3 50.0CORE HEIGHTI66 .712100re height of 12 feetFigure B 3.2. 1B-1K(Z) - Normalized Fo(Z) as a(page 1 of 1)Function of Core HeightWOGTSTSB 3.2.1912Volume 7, Rev. 0,,'ooDO NOT OPERATE IN THIS AREA(6.0, 1 .0).8,0.94)(12.0,0.65)

ILLUSIGURE FORRATION ONLY.NOT USE FOROPERATION Enclosure 2,Page 99 of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, BASES, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The RAOC-W(Z) methodology and the Specification designator "B" are deleted because they are unnecessary. (Only one Heat Flux Hot Channel Factor Specification is used in the SQN ITS.

) This information is provided in NUREG-1431, Rev. 4 to assist in identifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the CAOC-F XY and CAOC-W(Z) methodology Specification Bases (ISTS B 3.2.1A and B 3.2.1C) are not used and are not shown.

3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.
4. The ISTS Bases for LCO 3.2.1, has been updated to reflect the methodology identified in BAW-10163PA "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989.
5. Changes have been made to be consistent with changes made to the Specification.
6. ISTS SR 3.2.1.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies for ITS SR 3.2.1.1 under the Surveillance Frequency Control Program.
7. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
8. Editorial changes made to enhance clarity/consistency.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 2 ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS 3/4.2.3 NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) LIMITING CONDITION FOR OPERATION 3.2.3 FH(X,Y) shall be maintained within the limits specified in the COLR.

APPLICABILITY

MODE 1

ACTION: With FH(X,Y) exceeding the limit specified in the COLR:

a. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either:
1. Restore FH(X,Y) to within the limit specified in the COLR, or
2. Reduce the allowable THERMAL POWER from RATED THERMAL POWER at least RRH*% for each 1% that FH(X,Y) exceeds the limit, and
b. Within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:
1. Restore FH(X,Y) to within the limit specified in the COLR, or
2. Reduce the Power Range Neutron Flux-High Trip Setpoint in Table 2.2-1 at least RRH
  • % for each 1% that FH(X,Y) exceeds that limit, and
c. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of initially being outside the limit specified in the COLR, either:
1. Restore FH(X,Y) to within the limit specified in the COLR, or
2. Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

_______________________

  • RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-10 Amendment No. 19, 138, 155, 223 LCO 3.2.2 Applicabilit y ACTION A Required Action A.2 LA01Required Action A.3 ACTION A ACTION A Required Action A.1 Page 1 of 8 Add proposed ACTION A Note M01LA01LA01LA02L0172M02Add proposed ACTION C A02A02A02ACTION C L026 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS

ACTION: (Continued)

d. Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of initially being outside the limit specified in the COLR, reduce the Overtemperature Delta T K1 term in Table 2.2

-1 by at least TRH

    • for each 1% that FH(X,Y) exceeds the limit, and
e. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced THERMAL POWER limit required by ACTION a.2 and/or b. and/or c. and/or d., above: subsequent POWER OPERATION may proceed provided that FH(X,Y) is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the following THERMAL POWER levels:
1. A nominal 50% of RATED THERMAL POWER,
2. A nominal 75% of RATED THERMAL POWER, and
3. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 95% of RATED THERMAL POWER.

___________________________

    • TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-11 Amendment No. 138, 223 Required Action A.4 Required Action A.5 Completion Time A.5 LA03Page 2 of 8 Add proposed Required Action A.5 Note LA02LA03A03 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable.

4.2.3.2 HMF(X,Y) shall be evaluated to determine if FH(X,Y) is within its limit by:

a. Using the movable incore detectors to obtain a power distribution map HMF(X,Y)* at any THERMAL POWER greater than 5% of RATED THERMAL POWER.
b. Satisfying the following relationship:

FHRM(X,Y) BHNOM(X,Y)

Where:

And BHNOM(X,Y)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.

MAPM is the maximum Allowable Peak** obtained from the measured power distribution.

AXIAL(X,Y) is the axial shape for FH(X,Y).

c. If the above relationship is not satisfied, then
1. For the location, calculate the % margin to the maximum allowable design as follows:

100% x Y)BRDES(X,Y)(X,HRF 1 = I)Margin(

f %M1 where BHDES (X,Y) and BRDES (X,Y)** represent the maximum allowable design peaking factors which insure that the licensing criteria will be preserved for operation within the LCO limits, and include allowances for calculational and measurement uncertaintie

s. _________________________
  • No additional uncertainties are required in the following equations for HMF(X,Y) and F)HRM(X,Y), because the limits include uncertainties.
    • BHNOM(X,Y), MAP M, BHDES(X,Y), and BRDES(X,Y) data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-11a Amendment No. 223 FHR(X,Y) = F(X,Y)MAP / AXIAL(X,Y)

MHMM  % F Margin = 1 FHR(X,Y)BHDES(X,Y) x 100%HM M03LA04Page 3 of 8 SR 3.2.2.1 SR 3.2.2.2 SR NOTE LA04SR 3.2.2.2 SR 3.2.2.1 LA04 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS

2. Find the minimum margin of all locations examined in 4.2.3.2.c.1 above.

FH min margin = minimum % margin value of all locations examined

f1(I) min margin = minimum % margin value of all locations examined

3. If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH
  • % x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the Action statements for 3.2.3 apply.
4. If the f 1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH
    • % x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the action statements for 3.2.3 apply.
d. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding

FHRM(X,Y) > BHNOM(X,Y)

either of the following actions shall be taken:

1. HMF(X,Y) shall be increased over that specified in 4.2.3.2.a by the appropriate factor specified in the COLR, and 4.2.3.2.c.1 repeated, or
2. HMF(X,Y) shall be evaluated according to 4.2.3.2 at or before the time when the margin is projected to result in the action specified in 4.2.3.2.c.3 or 4.2.3.2.c.4.

4.2.3.3 Y)(X,FMH shall be determined to be within its limit by using the incore detectors to obtain a power distribution map

a. Prior to operation above 75% of RATED THERMAL POWER after each fuel loading, and
b. At least once per 31 EFPD.

____________________________

  • RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
    • TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-11b Amendment No. 223 LA01SR 3.2.2.1 SR 3.2.2.2 Page 4 of 8 A04thereafter LA05In accordance with the Surveillance Frequency Control Program LA04ACTION A ACTION B SR 3.2.2.1/SR 3.2.2.2 NOTE SR 3.2.2.1/SR 3.2.2.2 NOTE a. SR 3.2.2.1/SR 3.2.2.2 NOTE b. SR 3.2.2.1 SR 3.2.2.2 LA02M04M04LA03LA01LA03 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS 3/4.2.3 NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) LIMITING CONDITION FOR OPERATION 3.2.3 FH(X,Y) shall be maintained within the limits specified in the COLR.

APPLICABILITY

MODE 1 ACTION: With FH(X,Y) exceeding the limit specified in the COLR:
a. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either:
1. Restore FH(X,Y) to within the limit specified in the COLR, or
2. Reduce the allowable THERMAL POWER from RATED THERMAL POWER at least RRH
  • % for each 1% that FH(X,Y) exceeds the limit, and b. Within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either: 1. Restore FH(X,Y) to within the limit specified in the COLR, or
2. Reduce the Power Range Neutron Flux-High Trip Setpoint in Table 2.2-1 at least RRH
  • % for each 1% that FH(X,Y) exceeds that limit, and
c. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of initially being outside the limit specified in the COLR, either:
1. Restore FH(X,Y) to within the limit specified in the COLR, or
2. Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
  • RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-8 Amendment No. 21, 130, 146, 214 LCO 3.2.2 Applicabilit y ACTION A Required Action A.2 LA01Required Action A.3 ACTION A ACTION A Required Action A.1 Page 5 of 8 Add proposed ACTION A Note M01LA01LA01LA02L0172M02Add proposed ACTION C A02A02A02ACTION C L026 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS ACTION: (Continued)

d. Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of initially being outside the limit specified in the COLR, reduce the Overtemperature Delta T K1 term in Table 2.2

-1 by at least TRH

    • for each 1% that FH(X,Y) exceeds the limit, and
e. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced THERMAL POWER limit required by ACTION a.2 and/or b. and/or c. and/or d., above; subsequent POWER OPERATION may proceed provided that FH(X,Y) is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the following THERMAL POWER levels:
1. A nominal 50% of RATED THERMAL POWER,
2. A nominal 75% of RATED THERMAL POWER, and
3. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 95% of RATED THERMAL POWER.
    • TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-9 Amendment No. 130, 214 Required Action A.4 Required Action A.5 Completion Time A.5 LA03Page 6 of 8 LA03LA02A03Add proposed Required Action A.5 Note A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable.

4.2.3.2 HMF(X,Y) shall be evaluated to determine if FH(X,Y) is within its limit by:

a. Using the movable incore detectors to obtain a power distribution map HMF(X,Y)* at any THERMAL POWER greater than 5% of RATED THERMAL POWER.
b. Satisfying the following relationship:

FHRM(X,Y) BHNOM (X,Y)

Where:

And BHNOM (X,Y)** represents the nominal design increased by an allowance for the expected deviation between the nominal design and the measurement.

MAPM is the maximum Allowable Peak** obtained from the measured power distribution.

AXIAL (X,Y) is the axial shape for FH(X,Y).

c. If the above relationship is not satisfied, then
1. For the location, calculate the % margin to the maximum allowable design as follows:

where BHDES(X,Y) and BRDES(X,Y)** represent the maximum allowable design peaking factors which insure that the licensing criteria will be preserved for operation within the LCO limits, and include allowances for calculational and measurement uncertainties.

  • No additional uncertainties are required in the following equations for HMF(X,Y)1 and FHRM(X,Y), because the limits include uncertainties.
    • BHNOM (X,Y), MAP M, BHDES (X,Y), and BRDES (X,Y) data bases are provided for input to the plant power distribution analysis computer codes on a cycle specific basis and are determined using the methodology for core limit generation described in the references in Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-9a Amendment No. 214 Y)AXIAL(X, /

MAPY)(X,F = Y)(X,HRFMMHM 100% x Y)BRDES(X,Y)(X,HRF 1 = I)Margin(

f %M1 100% x BHDES(X,Y)

(X,Y)HRF 1 = Margin F %MH M03Page 7 of 8 SR 3.2.2.1 SR 3.2.2.2 SR 3.2.2.2 SR 3.2.2.1 SR NOTE LA04LA04LA04 A01ITS 3.2.2 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS

2. Find the minimum margin of all locations examined in 4.2.3.2.c.1 above.

FH min margin = minimum % margin value of all locations examined

f1(I) min margin = minimum % margin value of all locations examined

3. If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH
  • % x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the Action statements for 3.2.3 apply.
4. If the f1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH
    • % x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the action statements for 3.2.3 apply.
d. With two measurements extrapolated to 31 EFPD beyond the most recent measurement yielding FHRM (X,Y) > BHNOM (X,Y) either of the following actions shall be taken:
1. Y)(X,FMH shall be increased over that specified in 4.2.3.2.a by the appropriate factor specified in the COLR, and 4.2.3.2.c.1 repeated, or 2. HMF(X,Y) shall be evaluated according to 4.2.3.2 at or before the time when the margin is projected to result in the action specified in 4.2.3.2.c.3 or 4.2.3.2.c.4. 4.2.3.3 HMF(X,Y) shall be determined to be within its limit by using the incore detectors to obtain a power distribution map
a. Prior to operation above 75% of RATED THERMAL POWER after each fuel loading, and b. At least once per 31 EFPD.
  • RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.
    • TRH is the amount of Overtemperature Delta T K 1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR per Specification 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-9b Amendment No. 214

LA01SR 3.2.2.1 SR 3.2.2.2 Page 8 of 8 LA04M04LA02LA05In accordance with the Surveillance Frequency Control Program A04thereafter SR 3.2.2.1 SR 3.2.2.2 ACTION A ACTION B SR 3.2.2.1/SR 3.2.2.2 NOTE SR 3.2.2.1/SR 3.2.2.2 NOTE a. SR 3.2.2.1/SR 3.2.2.2 NOTE b M04LA03LA01LA03 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 1 of 8 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.2.3 ACTION a.1, b.1 and c.1 require the restoration of FH(X,Y) to within the limit specified in the COLR. ISTS LCO 3.0.2 Bases states that correction of the entered Condition is an action that may always be considered upon entering ACTIONS and that the restoration of compliance with the LCO is always an option. This changes the CTS by not specifically stating that restoration of FH(X,Y) is required.

This change is acceptable because the technical requirements have not changed. ISTS LCO 3.0.2 Bases states that correction of the entered Condition is an action that may always be considered upon entering ACTIONS and that the restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. In this specific application, Required Action A.1.1 is not the only ACTION and a power reduction should be the focus

for restoration of FH(X,Y) to within the limits. This change is designated as administrative, because it does not result in technical changes to the CTS.

A03 CTS 3.2.3 ACTION e states in part that with FH(X,Y) exceeding its limit, FH(X,Y) must be demonstrated to be within its limit prior to exceeding 50% RTP and 75%

RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining or exceeding 95% RTP. ITS 3.2.2 Required Action A.5 contains the same requirements. However, ITS 3.2.2 Required Action A.5 is modified by a Note which states "THERMAL POWER does not have to be reduced to comply with this Required Action." This modifies the CTS by adding a Note stating that THERMAL POWER does not have to be reduced to comply with the Required Action.

This change is acceptable, because the requirements have not changed. The Note is included in the ITS to make clear that THERMAL POWER does not have to be reduced to perform the Required Action. For example, if FH(X,Y) exceeds its limit and, per ITS Required Action A.1, THERMAL POWER is reduced to 60%

RTP, THERMAL POWER does not have to be reduced to less than 50% RTP to

verify FH(X,Y) is within its limit to comply with ITS Required Action A.5.

However, FH(X,Y) must still be measured prior to exceeding 75% RTP and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining or exceeding 95% RTP. The Note is needed because the ITS contains a Note in ITS 3.2.2 ACTION A that states "Required Actions A.3 and A.5 must be completed whenever Condition A is entered." The ITS 3.2.2 ACTION A Note does not exist in the CTS and could be construed as DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 2 of 8 requiring THERMAL POWER to be reduced to comply with Required Action A.5. (Addition of the ACTION A Note is discussed in DOC M01.) As a result, the Required Action A.5 Note makes the ITS and CTS actions consistent. This change is designated as administrative, because it does not result in technical changes to the CTS.

A04 CTS 4.2.3.3 requires Y)(X,FMHto be determined prior to operation above 75% of RTP after each fuel loading, and at least once per 31 EFPD. ITS SR 3.2.2.1 and SR 3.2.2.2 Frequency is once after each refueling prior to THERMAL POWER exceeding 75% RTP AND 31 EFPD thereafter. This changes the CTS by adding the word "thereafter" to the Frequency. The removal of the "31 EFPD thereafter" Frequency to the Surveillance Frequency Control Program is discussed in DOC LA05.

CTS 4.2.3.3 is required to be performed prior to operation above 75% RTP after each fuel loading and once per 31 EFPD. Also, although this Frequency is removed to the Surveillance Frequency Control Program, the addition of the word "thereafter" in ITS SR 3.2.2.1 and SR 3.2.2.2 ensures that the 31 EFPD Frequency starts after the first performance of the SR, which is required prior to exceeding 75% RTP after each fuel loading. Therefore, the addition of the word "thereafter" is considered acceptable because the use of thereafter is essentially the same as the CTS Frequency. This change is designated as administrative, because it does not result in technical changes to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.2.3 ACTION e states that with FH(X,Y) exceeding its limit "subsequent POWER OPERATION may proceed provided that FH(X,Y) is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the

following THERMAL POWER levels: 1. A nominal 50% of RATED THERMAL POWER, 2. A nominal 75% of RATED THERMAL POWER, and 3. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 95% of RATED THERMAL POWER." However, under CTS 3.0.2, these measurements do not have to be completed, if compliance with the LCO is restored. ITS 3.2.2 ACTION A contains a Note which states, "Required Actions A.3 and A.5 must be completed whenever Condition A is entered." ITS 3.2.2 Required Action A.3 requires verification that FH min margin is >0 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after entry into Condition A. Required Action A.5 requires verification that FH min margin is >0 prior to THERMAL POWER exceeding 50% RTP and 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is greater than or equal to 95% RTP. This changes the CTS by requiring

the verification that FH min margin is >0 to be made even if FH(X,Y) is restored to within its limit.

This change is acceptable, because it establishes appropriate compensatory measurements for violation of the FH(X,Y) limit. As power is reduced under ITS 3.2.2 Required Action A.1, the margin to the FH(X,Y) limit increases. Therefore, compliance with the LCO could be restored during the power reduction. Verifying that the limit is met as power is increased ensures that the limit continues to be met and does not remain unmeasured for up to 31 EFPD. This change is DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 3 of 8 designated as a more restrictive change because it imposes requirements in addition to those in the CTS.

M02 CTS 3.2.3 does not contain an Action to follow if ACTIONS a, b, d, and e cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ITS 3.2.2 ACTION C, states that the plant must be in MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shut down and, consequently, allowing one hour less for the unit to be in MODE 2.

The purpose of CTS 3.0.3 is to delineate the ACTION to be taken for circumstances not directly provided fo r in the ACTION statement and whose occurrences would violate the intent of the Specification. This change is acceptable because it provides an appropriate compensatory measure for the described conditions. If any Required Action and associated Completion Time cannot be met, the unit must be placed in a MODE in which the LCO does not apply. The LCO is applicable in MODE 1. Requiring a shut down to MODE 2 is appropriate in this condition. The one hour allowed by CTS 3.0.3 to prepare for a shut down is not needed, because the operators have had time to prepare for the shut down while attempting to follow the Required Actions and associated Completion Times. This change is designated as more restrictive because it allows less time to shut down than does the CTS.

M03 CTS 4.2.3.1 The provisions of Specification 4.0.4 are not applicable provides an allowance for entering the next higher MODE of Applicability when the LCO is not met. ITS 3.2.2 has no specific allowance for changing MODES at any time with ITS LCO 3.2.2 not met. ITS LCO 3.0.4 requires in part that, When an LCO is not met, entry into a MODE or other specified Condition in the Applicability shall only be made: If either part a. or part b. or part c. is met. Part c provides the following allowance, When an allowance is stated in the individual value, parameter or other specification. ITS 3.2.2 Surveillance Requirements Note will be added to provide the following allowance, Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium power level has been achieved, at which a power distribution map can be obtained. This changes CTS by allowing entry into the MODE of Applicability by only deferring the performance of the Surveillance Requirements instead of deferring compliance with the LCO.

The purpose of CTS 4.2.3.1 is to provide an exception to SR 4.0.4. SR 4.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability. This change is acceptable because ITS provides an allowance to enter the MODE of Applicability at any time ITS LCO 3.2.2 is not met solely based on surveillance performance. SR 3.2.2.1 and SR 3.2.2.2 require using the incore detector system to provide the necessary data to create a power distribut ion map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level (~40%-50%). The surveillances cannot be performed in MODE 2. This change is designated as more restrictive because the CTS 4.0.4 MODE change allowance for not met is now limited to DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 4 of 8 the performance of the SRs and does not include the allowance to change MODES with the acceptance criteria not met.

M04 CTS 3.2.3 provides two acceptable alternatives for the FH min margin and f 1(I) min margin not met. CTS 4.2.3.2.c.3 states, If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH*% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the Action statements for 3.2.3 apply. CTS 4.2.3.2.c.4 states, If the f 1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> reduce the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH**% x most negative margin from 4.2.3.2.c.2 and maintain the requirements of Specification 3.2.3; otherwise the action statements for 3.2.3 apply. CTS 4.2.3.2.c.3 has been replaced by ITS 3.2.2 Required Actions A.1. Similarly, CTS 4.2.3.2.c.4 has been replaced with ITS 3.2.2 Required Actions B.1. However, in both cases the option for, otherwise, the action statements for 3.2.3 apply has not been retained. This changes the CTS by removing the option to follow the action statement of CTS 3.2.3 for either min margin (FH or f1(I)) not met.

The purpose of CTS 4.2.3.2.c.3 and CTS 4.2.3.2.c.4 is to provide acceptable alternatives for the required compensatory actions when either FH min margin or f1(I) min margin is not met. The CTS surveillance requirements for FH min margin not met requires the reduction of ALLOWABLE THERMAL POWER from RTP by RRH*% x most negative margin from 4.2.3.2.c.2. This requirement is being retained as ITS 3.2.2 Required Action A.1. The CTS surveillance

requirements for f 1(I) min margin not met requires the reduction of the Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH**% x most negative margin from 4.2.3.2.c.2. This requirement is being retained as ITS 3.2.2 Required Action B.1. If the ITS Required Actions are not performed within the allowed Completion Time, Condition C will be entered requiring the Unit to be placed in MODE 2. This change is designated as more restrictive because an acceptable alternative Required Action available in CTS is being removed.

RELOCATED SPECIFICATIONS

None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.3 provides actions to take within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> when FH(X,Y) is not within limits, and states to reduce the allowable THERMAL POWER and within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> reduce the Power Range Neutron Flux-High Trip Setpoint at least RRH*% for each 1% that FH(X,Y) exceeds the limit provided in the COLR. Similarly, CTS 4.2.3.2.c.3 requires in part to reduce the allowable THERMAL POWER from RATED THERMAL POWER by RRH*% x most negative margin from 4.2.3.2.c.2. CTS NOTE

  • provides the definition of RRH as the amount of power reduction required to compensate for each 1% that FH(X,Y)

DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 5 of 8 exceeds the limit provided in the COLR per Specification 6.9.1.14. ITS 3.2.2 Required Action A.1 requires within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of discovery that FH min margin is not within limits, to reduce THERMAL POWER from RTP, and ITS 3.2.2 Required Action A.2 requires within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to reduce the Power Range

Neutron Flux-High Trip Setpoint by RRH% multiplied times the FH min margin. This changes the CTS by relocating the definition of RRH to the COLR.

The removal of these details from the Technical Specifications and its relocation into the COLR is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirements to reduce THERMAL POWER from RTP and reduce the Power Range Neutron Flux-High Trip Setpoint by RRH% for each 1% that FH(X,Y) exceeds its limit. The definition of RRH is already located in the COLR. Also, this change is acceptable because the removed information will be adequately controlled in the COLR requirements provided in ITS 5.6.5, "Core Operating Limits Report." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such transient analysis limits and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements)

CTS 3.2.3 ACTIONS c.2 and e require FH(X,Y) to be determined to be within its limit through incore flux mapping. Additionally, CTS 4.2.3.3 requires HMF(X,Y)to be determined to be within its limit by using the incore detectors to obtain a power distribution map. ITS SR 3.2.2.1 and SR 3.2.2.2 collectively verifiy that FH(X,Y) is within its limit. This changes the CTS by moving the manner in which the FH(X,Y) determination is performed to the Bases.

The removal of these details for performing actions and a Surveillance Requirement from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the

requirement to determine FH(X,Y) is within its limit. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.3 Action d requires within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of FH(X,Y) being outside its limits, to reduce the Overtemperature Delta T K 1 term in Table 2.2-1 by at least TRH** for each 1% that FH(X,Y) exceeds the limit. Similarly, CTS 4.2.3.2.c.4 requires in part to reduce Overtemperature Delta T K1 term in DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 6 of 8 Table 2.2-1 by at least TRH** x most negative margin from 4.2.3.2.c.2. CTS Note ** provides a definition for TRH as the amount of Overtemperature Delta T K1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR. ITS 3.2.2 Required Action A.4 states when FH min margin is < 0, reduce the OTT setpoint by TRH multiplied times the f 1(I) min margin. This changes the CTS by moving the details of the specific variable

within OTT to be reduced, the location of the K 1 terms, and the definition of TRH to the COLR.

The removal of these details from the Technical Specifications and their relocation into the COLR is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to reduce the OTT setpoint by TRH multiplied times the f 1(I) min margin. The specific variable within OTT to be reduced, the location of the K 1 terms, and definition of TRH are already located in the COLR. Also, this change is acceptable because the removed information will be adequately controlled in the COLR requirements provided in ITS 5.6.5, "Core Operating Limits Report." ITS 5.6.5 ensures that the applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems limits, and nuclear limits such transient analysis limits and accident analysis limits) of the safety analyses are met. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA04 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.3.2.a, 4.2.3.2.b, 4.2.3.2.c.1, and 4.2.3.2.c.2, provide details for evaluating F MH(X,Y) to determine if FH(X,Y) is within limits. ITS SR 3.2.2.1 and SR 3.2.2.2 collectively verify that FH(X,Y) is within limits specified in the COLR. This changes the CTS by moving the details for

evaluating F MH(X,Y) to determine if FH(X,Y) is within limits to the TS Bases.

The removal of these details from the Technical Specifications and their relocation into the TS Bases is acceptable, because the procedural steps and further details for making a determination that FH(X,Y) is within its limits is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The ITS still retains the requirement to

determine FH(X,Y) is within its limits specified in the COLR. Also, this change is acceptable, because these types of procedural details will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change, because procedural details for meeting Technical Specification requirements are being removed from the Technical Specifications.

LA05 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.2.3.3 requires, in part, a determination that FH(X,Y) is within its limits at least once per 31 EFPD. ITS SR 3.2.2.1 and SR 3.2.2.2 collectively require a similar Surveillance and specify the periodic Frequency as, "In DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 7 of 8 accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION b states, in part, that when FH(X,Y) exceeds its limit, reduce the Power Range Neutron Flux

- High Trip setpoints by at least RRH*% for each 1% FH(X,Y) exceeds that limit within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.2 Required Actions A.2 states with FH(X,Y) not within limit, reduce the Power Range Neutron Flux - High trip setpoints by at least RRH% multiplied times the FH min margin within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by increasing the time allowed to reduce the trip setpoints.

The purpose of CTS 3.2.3 ACTION b is to lower the Power Range Neutron Flux - High Trip setpoints, which ensures continued operation is at an acceptably low power level with an adequate DNBR margin and avoids violating the FH(X,Y) limit. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced, and considers the low probability of a DBA occurring during the allowed Completion Time. The revised Completion Time allows the Power Range Neutron Flux - High Trip setpoints to be reduced in a controlled manner without challenging operators, technicians, or plant systems. Following a significant power reduction, a time period of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is allowed to reestablish steady state xenon concentration and power distribution and to take and analyze a flux map. If it is determined that FH(X,Y) is still not within its limit, reducing the Power Range Neutron Flux - High Trip Setpoints can be accomplished within a few hours. Furthermore, setpoint changes should only be required for extended operation in this condition, because of the risk of a plant trip during the adjustment. This change is designated as less restrictive, because additional time is allowed to lower the Power Range Neutron Flux - High Trip setpoints than

was allowed in the CTS.

DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) Sequoyah Unit 1 and Unit 2 Page 8 of 8 L02 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION c.2 states, "Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next two

hours." ITS 3.2.2 ACTION C states, "Required Action and associated Completion Time not met." Required Action C.1 states, "Be in MODE 2" within a Completion Time of "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." This changes the CTS by increasing the time allowed to exit the MODE of Applicability when the Required Actions or associated Completion Times are not met.

The purpose of CTS 3.2.3 ACTION c.2 is to, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, either verify FH(X,Y) is restored within limits for the reduced power level or within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, enter MODE 2. Under similar conditions, ITS will require the plant to be placed in a MODE in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced. This change is designated as less restrictive, because additional time is allowed to exit the LCO than was allowed in the CTS.

.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

NHF 3.2.2 WOG STS 3.2.2-1 Rev. 4.0, CTS FH(X,Y)SEQUOYAH UNIT 1 Amendment xxx 113.2 POWER DISTRIBUTION LIMITS 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (

NHF) LCO 3.2.2 NHF shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------ Required Actions A.

2 and A.3 must be completed whenever Condition A is entered. ---------------------------------

NHFnot within limit.

A.1.1 Restore NHF to within limit

.

OR A.1.2.1 Reduce THERMAL POWER to < 50% RTP.

AND A.1.2.2 Reduce Power Range Neutron Flux - High trip

setpoints to 55% RTP. AND A.2 Perform SR 3.2.2.1

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

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FH(X,Y)FH(X,Y) INSERT 1 INSERT 333.2.3 Applicabilit y DOC M01

ACTION a.2 SR 4.2.3.2.c.3 ACTION b.2 ACTION c.2 112435653INSERT 2 FH min margin < 0 2 5 3 SR 4.2.3.2.c.3 222allowable 3.2.2 Insert Page 3.2.2-1 CTS INSERT 1 from RTP by RRH% multiplied times the FH min margin.

INSERT 2 by RRH% multiplied times the FH min margin.

INSERT 3 A.4 Reduce Overtemperature T trip setpoint by TRH multiplied times the FH min margin.

AND 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ACTION d 355ACTION a.2 4.2.3.2.c.3 ACTION b.2 NHF 3.2.2 WOG STS 3.2.2-2 Rev. 4.0, CTS FH(X,Y)SEQUOYAH UNIT 1 Amendment xxx 11ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 --------------NOTE-------------- THERMAL POWER does not have to be reduced to comply with this Required Action. -------------------------------------

Perform SR 3.2.2.1.

Prior to THERMAL

POWER exceeding 50% RTP AND Prior to THERMAL

POWER exceeding 75% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after

THERMAL POWER reaching 95% RTP B. Required Action and associated Completion Time not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 5ACTION e DOC A03 ACTION e.1 ACTION e.2 ACTION e.3 ACTION c.2 DOC M02 3C CINSERT 4 66 3.2.2 Insert Page 3.2.2-2 CTS INSERT 4 CONDITION REQUIRED ACTION COMPLETION TIME

B. f1(I) min margin < 0.

B.1 Reduce Overtemperature T trip setpoint by TRH multiplied times the f 1(I) min margin.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

4.2.3.2.c.4 6

NHF 3.2.2 WOG STS 3.2.2-3 Rev. 4.0, CTS FH(X,Y)SEQUOYAH UNIT 1 Amendment xxx 11SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.2.2.1 Verify NHF is within limits specified in the COLR.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND [ 31 EFPD thereafter OR In accordance

with the

Surveillance Frequency Control Program

] 8INSERT 7INSERT 587INSERT 64.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 899FH min margin > 0 3.2.2 Insert Page 3.2.2-3a CTS INSERT 5 ------------------------------------------------------------NOTE----------------------------------------------------------- Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium power level has been achieved, at which a power distribution map can be obtained.

74.2.3.1 3.2.2 Insert Page 3.2.2-3b CTS INSERT 6

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

If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) a. Increase HMF(X,Y) by the appropriate factor specified in the COLR and reverify FH min margin > 0; or

b. Repeat SR 3.2.2.1 prior to the time at which the projected FH min margin will be < 0. ---------------------------------------------------------------------

4.2.3.2.d 4.2.3.2.d.1 4.2.3.2.d.2 3.2.2 Insert Page 3.2.2-3c CTS INSERT 7 SURVEILLANCE FREQUENCY SR 3.2.2.2 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) a. Increase HMF(X,Y) by the appropriate factor specified in the COLR and reverify f1 (I) min margin > 0; or

b. Repeat SR 3.2.2.2 prior to the time at which the projected f 1 (I) min margin will be < 0.

Verify f 1(I) min margin > 0.

Once after each

refueling prior to THERMAL POWER exceeding 75% RTP AND In accordance

with the Surveillance Frequency Control Program

84.2.3.2.d 4.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 4.2.3.2.d.1 4.2.3.2.d.2 NHF 3.2.2 WOG STS 3.2.2-1 Rev. 4.0, CTS FH(X,Y)SEQUOYAH UNIT 2 Amendment xxx 113.2 POWER DISTRIBUTION LIMITS 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (

NHF) LCO 3.2.2 NHF shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. ------------NOTE------------ Required Actions A.

2 and A.3 must be completed whenever Condition A is entered. ---------------------------------

NHFnot within limit.

A.1.1 Restore NHF to within limit

.

OR A.1.2.1 Reduce THERMAL POWER to < 50% RTP.

AND A.1.2.2 Reduce Power Range Neutron Flux - High trip

setpoints to 55% RTP. AND A.2 Perform SR 3.2.2.1

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

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 72 hours

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> FH(X,Y)FH(X,Y) INSERT 1 INSERT 333.2.3 Applicabilit y DOC M01

ACTION a.2 SR 4.2.3.2.c.3 ACTION b.2 ACTION c.2 112435653INSERT 2 FH min margin < 0 2 5 3 SR 4.2.3.2.c.3 222allowable 3.2.2 Insert Page 3.2.2-1 CTS INSERT 1 from RTP by RRH% multiplied times the FH min margin.

INSERT 2 by RRH% multiplied times the FH min margin.

INSERT 3 A.4 Reduce Overtemperature T trip setpoint by TRH multiplied times the FH min margin.

AND 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> ACTION d 355ACTION a.2 4.2.3.2.c.3 ACTION b.2 NHF 3.2.2 WOG STS 3.2.2-2 Rev. 4.0, CTS FH(X,Y)SEQUOYAH UNIT 2 Amendment xxx 11ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 --------------NOTE-------------- THERMAL POWER does not have to be reduced to comply with this Required Action. -------------------------------------

Perform SR 3.2.2.1.

Prior to THERMAL

POWER exceeding 50% RTP AND Prior to THERMAL

POWER exceeding 75% RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after

THERMAL POWER reaching 95% RTP B. Required Action and associated Completion Time not met.

B.1 Be in MODE 2.

6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 5ACTION e DOC A03 ACTION e.1 ACTION e.2 ACTION e.3 ACTION c.2 DOC M02 3C CINSERT 4 66 3.2.2 Insert Page 3.2.2-2 CTS INSERT 4 CONDITION REQUIRED ACTION COMPLETION TIME

B. f1(I) min margin < 0.

B.1 Reduce Overtemperature T trip setpoint by TRH multiplied times the f 1(I) min margin.

48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />

4.2.3.2.c.4 6

NHF 3.2.2 WOG STS 3.2.2-3 Rev. 4.0, CTS FH(X,Y)SEQUOYAH UNIT 2 Amendment xxx 11SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.2.2.1 Verify NHF is within limits specified in the COLR.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND [ 31 EFPD thereafter OR In accordance

with the

Surveillance Frequency Control Program

] 8INSERT 7INSERT 587INSERT 64.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 899FH min margin > 0 3.2.2 Insert Page 3.2.2-3a CTS INSERT 5 ------------------------------------------------------------NOTE----------------------------------------------------------- Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium power level has been achieved, at which a power distribution map can be obtained.

74.2.3.1 3.2.2 Insert Page 3.2.2-3b CTS INSERT 6

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

If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) a. Increase HMF(X,Y) by the appropriate factor specified in the COLR and reverify FH min margin > 0; or

b. Repeat SR 3.2.2.1 prior to the time at which the projected FH min margin will be < 0. ---------------------------------------------------------------------

4.2.3.2.d 4.2.3.2.d.1 4.2.3.2.d.2 3.2.2 Insert Page 3.2.2-3c CTS INSERT 7 SURVEILLANCE FREQUENCY SR 3.2.2.2 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) a. Increase HMF(X,Y) by the appropriate factor specified in the COLR and reverify f1 (I) min margin > 0; or

b. Repeat SR 3.2.2.2 prior to the time at which the projected f 1 (I) min margin will be < 0.

Verify f 1(I) min margin > 0.

Once after each

refueling prior to THERMAL POWER exceeding 75% RTP AND In accordance

with the Surveillance Frequency Control Program

84.2.3.2.d 4.2.3.2.c.1 4.2.3.3.a 4.2.3.3.b 4.2.3.2.d.1 4.2.3.2.d.2 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y)) Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. ISTS LCO 3.2.2 Required Action A.1.1 states, restore NHFto within limit. ITS 3.2.2 will not retain the specific requirement to restore. LCO 3.0.2 Bases states that correction of the entered Condition is an action that may always be considered upon entering ACTIONS. This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. In this specific application, Required Action A.1.1 is not the only ACTION and a power reduction should be the focus for restoration of FH(X,Y)to within the limits. Subsequent Required Actions have been renumbered o reflect this deletion.
3. Required Action A.4 is added to the ITS. CTS 3.2.3 ACTION d requires reduction of the OTT setpoint when FH(X,Y) exceeds the limit in the COLR. Subsequent Required Actions have been renumbered o reflect this deletion.
4. The Completion Times for reducing THERMAL POWER upon discovery that FH(X,Y) has exceeded its limit are shortened from 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> consistent with the current licensing basis.
5. The amount that THERMAL POWER and the Power Range Neutron Flux - High Trip setpoints are reduced after FH(X,Y) has exceeded its limit are changed to reflect the values in the current licensing basis.
6. ITS Conditions A and B have been changed to reflect the CTS ACTIONs for both FH and/or f1(I) min margins not met.
7. ISTS LCO 3.2.2 does not contain a specific provision for changing MODES if LCO 3.2.2 is not met, other than the generic use of LCO 3.0.4. CTS SR 4.2.3.1

states, The provisions of Specification 4.0.4 are not applicable. This allowance enables SQN to enter the MODE of Applicability with the Surveillance not met or performed. SQN is retaining the allowance to change the MODE of Applicability with the Surveillance not performed by adding a Surveillance Note to retain the allowance.

8. ISTS SR 3.2.2.1 and SR 3.2.2.2 have been changed to reflect the CTS evaluation of FH min margin > 0 and f 1(I) min margin > 0.
9. ISTS SR 3.2.2.1 (and proposed ITS SR 3.2.2.2) provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

HNF B 3.2.2

WOG STS B 3.2.2-1 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (

HNF )

BASES BACKGROUND The purpose of this LCO is to establish limits on the power density at any point in the core so that the fuel design criteria are not exceeded and the accident analysis assumptions remain valid. The design limits on local (pellet) and integrated fuel rod peak power density are expressed in terms of hot channel factors. Control of the core power distribution with respect to these factors ensures that local conditions in the fuel rods and coolant channels do not challenge core integrity at any location during either normal operation or a postulated accident analyzed in the safety analyses.

HNF is defined as the ratio of the integral of the linear power along the fuel rod with the highest integrated power to the average integrated fuel rod power. Therefore, HNF is a measure of the maximum total power produced in a fuel rod.

HNF is sensitive to fuel loading patterns, bank insertion, and fuel burnup.

HNF typically increases with control bank insertion and typically decreases with fuel burnup.

HNF is not directly measurable but is inferred from a power distribution map obtained with the movable incore detector system. Specifically, the results of the three dimensional power distribution map are analyzed by a computer to determine HNF. This factor is calculated at least every 31 EFPD. However, during power operation, the global power distribution is monitored by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," which address directly and continuously measured process variables.

The COLR provides peaking factor limits that ensure that the design basis

value of the departure from nucleate boiling (DNB) is met for normal operation, operational transients, and any transient condition arising from events of moderate frequency. The DNB design basis precludes DNB and is met by limiting the minimum local DNB heat flux ratio to [1.3] using the [W3] CHF correlation. All DNB limited transient events are assumed to begin with an HNF value that satisfies the LCO requirements.

Operation outside the LCO limits may produce unacceptable consequences if a DNB limiting event occurs. The DNB design basis ensures that there is no overheating of the fuel that results in possible cladding perforation with the release of fission products to the reactor coolant.

FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y)1111FH(X,Y)the design limit value usin g an NRC approved critical heat flux 1INSERT 1 2

B 3.2.2 Insert Page B 3.2.2-1a INSERT 1 An FH(X,Y) evaluation requires obtaining an incore flux map in MODE 1. The incore flux map results provide the measured value ()Y,X(FMH of FH(X,Y) for each assembly location (X,Y). The FH ratio (FDHR) is used in order to determine the FH limit for the measured and design power distributions. Then,

FHRM(X,Y) = )Y,X(AXIAL/MAP)Y,X(FMMMH where MMAP is the maximum allowable peak from the COLR for the measured assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties, and )Y,X(AXIAL M is the measured ratio of the peak-to-average axial power at assembly location (X,Y).

BHDES(X,Y) is a cycle dependent design limit to preserve Departure from Nucleate Boiling(DNB) assumed for initial conditions at the time of limiting transients such as a Loss of Flow Accident (LOFA). BRDES(X,Y) is a cycle dependent design limit to preserve reactor protection system safety limits for DNB requirements.

The expression for BHDES(X,Y) is:

BHDES(X,Y) = FHRd(X,Y)

  • MH(X,Y) where: FHRd(X,Y) = )Y,X(AXIAL/MAP)Y,X(FdddH
  • dMAP is the maximum allowable peak from the COLR for the design assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties,
  • )Y,X(AXIAL d is the design ratio of the peak-to-average axial power at assembly location (X,Y),
  • )Y,X(FdH is the design FH assembly location (X, Y), and
  • MH(X,Y) is the minimum available margin ratio for initial condition DNB at the limiting conditions at assembly location (X,Y).

2 B 3.2.2 Insert Page B 3.2.2-1b INSERT 1 (continued)

The expression for BRDES(X,Y) is:

BRDES(X,Y) = FHRd(X,Y)

  • MH s(X,Y) where: MH s(X,Y) is the minimum available margin ratio for steady state DNB at the limiting conditions at assembly location (X,Y).

The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:

FHRM(X,Y) BHNOM(X,Y)

where: BHNOM(X,Y) is the nominal design radial peaking factor for an assembly at core location (X,Y) increased by an allowance for the expected deviation between the measured and predicted design power distribution.

2 HNF B 3.2.2

WOG STS B 3.2.2-2 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES APPLICABLE Limits on HNF preclude core power distributions that exceed the following SAFETY fuel design limits: ANALYSES

a. There must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hottest fuel rod in the core does not experience a DNB condition,
b. During a large break loss of coolant accident (LOCA), peak cladding temperature (PCT) must not exceed 2200°F,
c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm

[Ref. 1], and d. Fuel design limits required by GDC 26 (Ref. 2) for the condition when control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn.

For transients that may be DNB limited, the Reactor Coolant System flow and HNF are the core parameters of most importance. The limits on HNF ensure that the DNB design basis is met for normal operation, operational transients, and any transients arising from events of moderate frequency. The DNB design basis is met by limiting the minimum DNBR to the 95/95 DNB criterion of [1.3] using the [W3

] CHF correlation. This value provides a high degree of assurance that the hottest fuel rod in the core does not experience a DNB.

The allowable HNF limit increase s with decreasing power level. This functionality in HNF is included in the analyses that provide the Reactor Core Safety Limits (SLs) of SL 2.1.1. Therefore, any DNB events in which the calculation of the core limits is modeled implicitly use this variable value of HNF in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial HNF as a function of power level defined by the COLR limit equation.

The LOCA safety analysis indirectly models HNF as an input parameter.

The Nuclear Heat Flux Hot Channel Factor (F Q(Z)) and the axial peaking factors are inserted directly into the LOCA safety analyses that verify the acceptability of the resulting peak cladding temperature

[Ref. 3].

The fuel is protected in part by Technical Specifications, which ensure that the initial conditions assumed in the safety and accident analyses remain valid. The following LCOs ensure this: LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, "QUADRANT POWER TILT RATIO FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y) FH(X,Y)1113X,Y, local DNB heat flux ratio to the desi gn limit value usin g an NRC approved critical heat flux 1limits, FH min margin and f1(I) min margin,

)(8) ( 83 HNF B 3.2.2

WOG STS B 3.2.2-3 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES

APPLICABLE SAFETY ANALYSES (continued)

(QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor )F(HN," and LCO 3.2.1, "Heat Flux Hot Channel Factor (F Q(Z))." HNF and FQ(Z) are measured periodically using the movable incore detector system. Measurements are generally taken with the core at, or near, steady state conditions. Core monitoring and control under transient conditions (Condition 1 events) are accomplished by operating the core within the limits of the LCOs on AFD, QPTR, and Bank Insertion

Limits.

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

LCO HNF shall be maintained within the limits of the relationship provided in the COLR.

The HNF limit identifies the coolant flow channel with the maximum enthalpy rise. This channel has the least heat removal capability and thus the highest probability for a DNB.

The limiting value of HNF, described by the equation contained in the COLR, is the design radial peaking factor used in the unit safety analyses.

A power multiplication factor in this equation includes an additional margin for higher radial peaking from reduced thermal feedback and greater control rod insertion at low power levels. The limiting value of is HNF allowed to increase 0.3% for every 1%

RTP reduction in THERMAL POWER. APPLICABILITY The HNF limits must be maintained in MODE 1 to preclude core power distributions from exceeding the fuel design limits for DNBR and PCT.

Applicability in other modes is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the coolant to require a limit on the distribution of core power. Specifically, the design bases events that are sensitive to HNF in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict HNF in these modes.

FH(X,Y) FH(X,Y) FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y)1211X, Y, ZX, Y, ZINSERT 2 indirectly B 3.2.2 Insert Page B 3.2.2-3 INSERT 2 The LCO states that FH(X,Y) shall be less than the limits provided in the COLR. This LCO relationship must be satisfied even if the core is operating at limiting conditions. This requires adjustment to the measured

FH(X,Y) to account for limiting conditions and the differences between design and measured conditions. The adjustments are accounted for by

comparing FHRM(X,Y) to the limits BHDES(X,Y) and BRDES(X,Y). Therefore, if the FH min margin is >0 and f 1(I) min margin >0 the LCO is satisfied.

2 HNF B 3.2.2

WOG STS B 3.2.2-4 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES

ACTIONS A.1.1 With HNF exceeding its limit, the unit is allowed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore HNF to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring HNF within its power dependent limit. When the HNF limit is exceeded, the DNBR limit is not likely violated in steady state operation, because events that could significantly perturb the HNF value (e.g., static control rod misalignment) are considered in the safety analyses. However, the DNBR limit may be violated if a DNB limiting event occurs. Thus, the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides an acceptable time to restore HNF to within its limits without allowing the plant to remain in an unacceptable condition for an extend ed period of time.

Condition A is modified by a Note that requires that Required Actions A.

2 and A.3 must be completed whenever Condition A is entered.

Thus, if power is not reduced because this Required Action is completed within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period, Required Action A.2 nevertheless requires another measurement and calculation of HNF within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with SR 3.2.2.1.

However, if power is reduced below 50% RTP, Required Action A.

3 requires that another determination of HNF must be done prior to exceeding 50% RTP, prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching or exceeding 95% RTP. In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A.1.2.1 and A.1.2.2 If the value of HNF is not restored to within its specified limit either by adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in accordance with Required Action A.1

.2.1 and reduce the Power Range Neutron Flux - High to 55% RTP in accordance with Required Action A.

1.2.2. Reducing RTP to < 50% RTP increases the DNB margin and does not likely cause the DNBR limit to be violated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptable low power level with adequate DNBR

margin. The allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Required Action A.1

.2.1 is consistent with those allowed for in Required Action A.1.1 and provides an acceptable time to reach the required power level from full power operation without allowing the plant to remain in an unacceptable condition for an extended period of time.

The Completion Times of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Required Actions A.1.1 and A.1.2.1 are not additive

. FH min margin 445 5 41FH min marginINSERT 5 INSERT 6 INSERT 7 2 41335allowableINSERT 3 2verified3 INSERT 4 B 3.2.2 Insert Page B 3.2.2-4a INSERT 3 The % FH margin is based on the relationship between FHRM(X,Y) and the limit, BHDES (X,Y), as follows:

100% x Y)BHDES(X,Y)(X,HRF 1 =Margin F %MH If the reactor core is operating as designed, then FHRM(X,Y) is less than BHDES (X,Y) and calculation of %FH margin is not required. If the

%FH margin is less than zero, then FHRM(X,Y) is greater than BHDES (X, Y) and the FH(X,Y) limits may not be adequate to prevent exceeding the initial DNB conditions assumed for transients such as a LOFA. BHDES (X,Y) represents the maximum allowable design radial peaking factors which ensures that the initial conditions DNB will be preserved for operation within the LCO limits, and includes allowances for calculational and measurement uncertainties. The FH min margin is the minimum for all core locations examined.

INSERT 4 If FH min margin < 0 is restored to within limits prior to completion of the THERMAL POWER reduction in Required Action A.1, compliance of Required Actions A.3 and A.5 must be met.

24 B 3.2.2 Insert Page B 3.2.2-4b INSERT 5 from RTP by at least RRH % (where RRH = Thermal power reduction required to compensate for each 1% that FH(X,Y) exceeds its limit) multiplied times the FH min margin

INSERT 6 trip setpoints, as specified in TS Table 3.3.1-1 by RRH% multiplied times the FH min margin INSERT 7 by at least RRH% multiplied times the FH min margin 444 HNF B 3.2.2

WOG STS B 3.2.2-5 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 1 Revision XXX 11BASES ACTIONS (continued)

The allowed Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to reset the trip setpoints per

Required Action A.

1.2.2 recognizes that, once power is reduced, the safety analysis assumptions are satisfied and there is no urgent need to reduce the trip setpoints. This is a sensitive operation that may inadvertently trip the Reactor Protection System.

A.2 Once the power level has been reduced to < 50% RTP per Required Action A.1

.2.1, an incore flux map (SR 3.2.2.1) must be obtained and the measured value of HNF verified not to exceed the allowed limit at the lower power level. The unit is provided 20 additional hours to perform this task over and above the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed by either Action A.1.1 or Action A.1

.2.1. The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is acceptable because of the increase in the DNB margin, which is obtained at lower power levels, and the low probability of having a DNB limiting event within this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Additionally, operating experience has indicated that this Completion Time is sufficient to obtain the incore flux map, perform the required calculations, and evaluate HNF. A.3 Verification that HNF is within its specified limits after an out of limit occurrence ensures that the cause that led to the HNF exceeding its limit is corrected, and that subsequent operation proceeds within the LCO limit. This Action demonstrates that the HNF limit is within the LCO limits prior to exceeding 50% RTP, again prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is 95% RTP.

This Required Action is modified by a Note that states that THERMAL POWER does not have to be reduced prior to performing this Action.

B.1 When Required Actions A.1

.1 through A.

3 cannot be completed within their required Completion Times, the plant must be placed in a mode in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.

FH min margin is verified > 0 FHmin margin FHmin margin is > 0 FH min margin FH min margin 1114INSERT 8 4322 2 INSERT 945 45, and B.1, 4C 2allowable 3 >0INSERT 10 B 3.2.2 Insert Page B 3.2.2-5a INSERT 8 by at least RRH% multiplied times the FH min margin INSERT 9 A.4 If the value of FHRM(X,Y) is not restored to within its specified limit, Overtemperarture T K1 (OTT K1) term is required to be reduced by at least TRH multiplied times the FH min margin. The value of TRH is provided in the COLR. Completing Required Action A.4 ensures protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Also, completing Required Action A.4 within the allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is sufficient considering the small likelihood of a limiting transient in this time period.

44 B 3.2.2 Insert Page B 3.2.2-5b INSERT 10 B.1 The %f1(I) margin is based on the relationship between FHRM(X,Y) and the limit, BRDES (X,Y), as follows:

% f(I)Margin = 1 FHR(X,Y)BRDES(X,Y) x 100%1M If the reactor core is operating as designed, then FHRM(X,Y) is less than BRDES (X,Y) and calculation of %f 1(I) margin is not required. If the

%f1(I) margin is less than zero, then FHRM(X,Y) is greater than BRDES (X, Y) and the OTT setpoint limits may not be adequate to prevent exceeding DNB requirements.

BRDES (X,Y) represents the maximum allowable design radial peaking factors which ensure that the steady state DNBR limit will be preserved for operation within the LCO limits, including allowances for calculational

and measurement uncertainties Required Action B.1 requires the reduction of the OTT K1 term by at least TRH multiplied by the f 1(I) min margin. TRH is the amount of OTT K1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR. Completing Required Action B.1 within the allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, restricts FH(X,Y) such that even if a transient occurred, DNB requirements are met. The f 1(I) min margin is the minimum % of f 1(I) margin for all core locations examined.

2 HNF B 3.2.2

WOG STS B 3.2.2-6 Rev. 4.0, FH(X,Y)1SEQUOYAH UNIT 1 Revision XXX 1BASES

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The value of HNF is determined by using the movable incore detector system to obtain a flux distribution map. A data reduction computer program then calculates the maximum value of HNF from the measured flux distributions. The measured value of HNF must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the HNF limit. After each refueling, HNF must be determined in MODE 1 prior to exceeding 75%

RTP. This requirement ensures that HNF limits are met at the beginning of each fuel cycle.

[ The 31 EFPD Frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup. Accordingly, this Frequency is short enough that the HNF limit cannot be exceeded for any significant period of o peration.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES 1. Regulatory Guide 1.77, Rev.

[0], May 1974.

2. 10 CFR 50, Appendix A, GDC 26.
3. 10 CFR 50.46.

1INSERT 12 4467INSERT 11 B 3.2.2 Insert Page B 3.2.2-6a INSERT 11 SR 3.2.2.1 and SR 3.2.2.2 are modified by a Note. It states that, "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium power level has been achieved at which a power distribution map can be obtained."

SR 3.2.2.1 and SR 3.2.2.2 require using the incore detector system to provide the necessary data to create a power distribution map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level. These surveillances could not be satisfactorily performed if the requirement for performance of the Surveillances was included in MODE 2 prior to entering MODE 1.

In a reload core,HMF(X,Y)could not have previously been measured, therefore, there is a Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of HMF(X,Y) is made at a lower power level at which adequate margin is available before going to 100% RTP.

4 B 3.2.2 Insert Page B 3.2.2-6b INSERT 12 SR 3.2.2.1 and SR 3.2.2.2

In addition to ensuring via Surveillance that the nuclear enthalpy rise hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Y,X(FMH for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an FHRM(X,Y) > BHNOM(X,Y), further consideration is required.

The implications of these extrapolations are considered separately for BHDES(X,Y) and BRDES(X,Y) limits. If the extrapolations of )Y,X(FMH are unfavorable, additional actions must be taken. These actions are to meet the FH(X,Y) limit with the last HMF(X,Y) increased by the appropriate factor specified in the COLR or to evaluateHMF(X,Y) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These al ternative requirements attempt to prevent FH(X,Y) from exceeding its limit for any significant period of time without detection using the best available data.

Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.

4 HNF B 3.2.2

WOG STS B 3.2.2-1 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor (

HNF )

BASES BACKGROUND The purpose of this LCO is to establish limits on the power density at any point in the core so that the fuel design criteria are not exceeded and the accident analysis assumptions remain valid. The design limits on local (pellet) and integrated fuel rod peak power density are expressed in terms of hot channel factors. Control of the core power distribution with respect to these factors ensures that local conditions in the fuel rods and coolant channels do not challenge core integrity at any location during either normal operation or a postulated accident analyzed in the safety analyses.

HNF is defined as the ratio of the integral of the linear power along the fuel rod with the highest integrated power to the average integrated fuel rod power. Therefore, HNF is a measure of the maximum total power produced in a fuel rod.

HNF is sensitive to fuel loading patterns, bank insertion, and fuel burnup.

HNF typically increases with control bank insertion and typically decreases with fuel burnup.

HNF is not directly measurable but is inferred from a power distribution map obtained with the movable incore detector system. Specifically, the results of the three dimensional power distribution map are analyzed by a computer to determine HNF. This factor is calculated at least every 31 EFPD. However, during power operation, the global power distribution is monitored by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," which address directly and continuously measured process variables.

The COLR provides peaking factor limits that ensure that the design basis

value of the departure from nucleate boiling (DNB) is met for normal operation, operational transients, and any transient condition arising from events of moderate frequency. The DNB design basis precludes DNB and is met by limiting the minimum local DNB heat flux ratio to [1.3] using the [W3] CHF correlation. All DNB limited transient events are assumed to begin with an HNF value that satisfies the LCO requirements.

Operation outside the LCO limits may produce unacceptable consequences if a DNB limiting event occurs. The DNB design basis ensures that there is no overheating of the fuel that results in possible cladding perforation with the release of fission products to the reactor coolant.

FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y) FH(X,Y)FH(X,Y)1111FH(X,Y)the design limit value usin g an NRC approved critical heat flux 1INSERT 1 2

B 3.2.2 Insert Page B 3.2.2-1a INSERT 1 An FH(X,Y) evaluation requires obtaining an incore flux map in MODE 1. The incore flux map results provide the measured value ()Y,X(FMH of FH(X,Y) for each assembly location (X,Y). The FH ratio (FDHR) is used in order to determine the FH limit for the measured and design power distributions. Then,

FHRM(X,Y) = )Y,X(AXIAL/MAP)Y,X(FMMMH where MMAP is the maximum allowable peak from the COLR for the measured assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties, and )Y,X(AXIAL M is the measured ratio of the peak-to-average axial power at assembly location (X,Y).

BHDES(X,Y) is a cycle dependent design limit to preserve Departure from Nucleate Boiling(DNB) assumed for initial conditions at the time of limiting transients such as a Loss of Flow Accident (LOFA). BRDES(X,Y) is a cycle dependent design limit to preserve reactor protection system safety limits for DNB requirements.

The expression for BHDES(X,Y) is:

BHDES(X,Y) = FHRd(X,Y)

  • MH(X,Y) where: FHRd(X,Y) = )Y,X(AXIAL/MAP)Y,X(FdddH
  • dMAP is the maximum allowable peak from the COLR for the design assembly power distribution at assembly location (X,Y) which accounts for calculational and measurement uncertainties,
  • )Y,X(AXIAL d is the design ratio of the peak-to-average axial power at assembly location (X,Y),
  • )Y,X(FdH is the design FH assembly location (X, Y), and
  • MH(X,Y) is the minimum available margin ratio for initial condition DNB at the limiting conditions at assembly location (X,Y).

2 B 3.2.2 Insert Page B 3.2.2-1b INSERT 1 (continued)

The expression for BRDES(X,Y) is:

BRDES(X,Y) = FHRd(X,Y)

  • MH s(X,Y) where: MH s(X,Y) is the minimum available margin ratio for steady state DNB at the limiting conditions at assembly location (X,Y).

The reactor core is operating as designed if the measured steady state core power distribution agrees with prediction within statistical variation. This guarantees that the operating limits will preserve the thermal criteria in the applicable safety analyses. The core is operating as designed if the following relationship is satisfied:

FHRM(X,Y) BHNOM(X,Y)

where: BHNOM(X,Y) is the nominal design radial peaking factor for an assembly at core location (X,Y) increased by an allowance for the expected deviation between the measured and predicted design power distribution.

2 HNF B 3.2.2

WOG STS B 3.2.2-2 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES APPLICABLE Limits on HNF preclude core power distributions that exceed the following SAFETY fuel design limits: ANALYSES

a. There must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hottest fuel rod in the core does not experience a DNB condition,
b. During a large break loss of coolant accident (LOCA), peak cladding temperature (PCT) must not exceed 2200°F,
c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm

[Ref. 1], and d. Fuel design limits required by GDC 26 (Ref. 2) for the condition when control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn.

For transients that may be DNB limited, the Reactor Coolant System flow and HNF are the core parameters of most importance. The limits on HNF ensure that the DNB design basis is met for normal operation, operational transients, and any transients arising from events of moderate frequency. The DNB design basis is met by limiting the minimum DNBR to the 95/95 DNB criterion of [1.3] using the [W3

] CHF correlation. This value provides a high degree of assurance that the hottest fuel rod in the core does not experience a DNB.

The allowable HNF limit increase s with decreasing power level. This functionality in HNF is included in the analyses that provide the Reactor Core Safety Limits (SLs) of SL 2.1.1. Therefore, any DNB events in which the calculation of the core limits is modeled implicitly use this variable value of HNF in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial HNF as a function of power level defined by the COLR limit equation.

The LOCA safety analysis indirectly models HNF as an input parameter.

The Nuclear Heat Flux Hot Channel Factor (F Q(Z)) and the axial peaking factors are inserted directly into the LOCA safety analyses that verify the acceptability of the resulting peak cladding temperature

[Ref. 3].

The fuel is protected in part by Technical Specifications, which ensure that the initial conditions assumed in the safety and accident analyses remain valid. The following LCOs ensure this: LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, "QUADRANT POWER TILT RATIO FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y) FH(X,Y)1113X,Y, local DNB heat flux ratio to the desi gn limit value usin g an NRC approved critical heat flux 1limits, FH min margin and f1(I) min margin,

)(8) ( 83 HNF B 3.2.2

WOG STS B 3.2.2-3 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES

APPLICABLE SAFETY ANALYSES (continued)

(QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor )F(HN," and LCO 3.2.1, "Heat Flux Hot Channel Factor (F Q(Z))." HNF and FQ(Z) are measured periodically using the movable incore detector system. Measurements are generally taken with the core at, or near, steady state conditions. Core monitoring and control under transient conditions (Condition 1 events) are accomplished by operating the core within the limits of the LCOs on AFD, QPTR, and Bank Insertion

Limits.

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

LCO HNF shall be maintained within the limits of the relationship provided in the COLR.

The HNF limit identifies the coolant flow channel with the maximum enthalpy rise. This channel has the least heat removal capability and thus the highest probability for a DNB.

The limiting value of HNF, described by the equation contained in the COLR, is the design radial peaking factor used in the unit safety analyses.

A power multiplication factor in this equation includes an additional margin for higher radial peaking from reduced thermal feedback and greater control rod insertion at low power levels. The limiting value of is HNF allowed to increase 0.3% for every 1%

RTP reduction in THERMAL POWER. APPLICABILITY The HNF limits must be maintained in MODE 1 to preclude core power distributions from exceeding the fuel design limits for DNBR and PCT.

Applicability in other modes is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the coolant to require a limit on the distribution of core power. Specifically, the design bases events that are sensitive to HNF in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict HNF in these modes.

FH(X,Y) FH(X,Y) FH(X,Y)FH(X,Y)FH(X,Y)FH(X,Y)1211X, Y, ZX, Y, ZINSERT 2 indirectly B 3.2.2 Insert Page B 3.2.2-3 INSERT 2 The LCO states that FH(X,Y) shall be less than the limits provided in the COLR. This LCO relationship must be satisfied even if the core is operating at limiting conditions. This requires adjustment to the measured

FH(X,Y) to account for limiting conditions and the differences between design and measured conditions. The adjustments are accounted for by

comparing FHRM(X,Y) to the limits BHDES(X,Y) and BRDES(X,Y). Therefore, if the FH min margin is >0 and f 1(I) min margin >0 the LCO is satisfied.

2 HNF B 3.2.2

WOG STS B 3.2.2-4 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES

ACTIONS A.1.1 With HNF exceeding its limit, the unit is allowed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore HNF to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring HNF within its power dependent limit. When the HNF limit is exceeded, the DNBR limit is not likely violated in steady state operation, because events that could significantly perturb the HNF value (e.g., static control rod misalignment) are considered in the safety analyses. However, the DNBR limit may be violated if a DNB limiting event occurs. Thus, the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides an acceptable time to restore HNF to within its limits without allowing the plant to remain in an unacceptable condition for an extend ed period of time.

Condition A is modified by a Note that requires that Required Actions A.

2 and A.3 must be completed whenever Condition A is entered.

Thus, if power is not reduced because this Required Action is completed within the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period, Required Action A.2 nevertheless requires another measurement and calculation of HNF within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with SR 3.2.2.1.

However, if power is reduced below 50% RTP, Required Action A.

3 requires that another determination of HNF must be done prior to exceeding 50% RTP, prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching or exceeding 95% RTP. In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

A.1.2.1 and A.1.2.2 If the value of HNF is not restored to within its specified limit either by adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in accordance with Required Action A.1

.2.1 and reduce the Power Range Neutron Flux - High to 55% RTP in accordance with Required Action A.

1.2.2. Reducing RTP to < 50% RTP increases the DNB margin and does not likely cause the DNBR limit to be violated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptable low power level with adequate DNBR

margin. The allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Required Action A.1

.2.1 is consistent with those allowed for in Required Action A.1.1 and provides an acceptable time to reach the required power level from full power operation without allowing the plant to remain in an unacceptable condition for an extended period of time.

The Completion Times of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for Required Actions A.1.1 and A.1.2.1 are not additive

. FH min margin 445 5 41FH min marginINSERT 5 INSERT 6 INSERT 7 2 41335allowableINSERT 3 2verified3 INSERT 4 B 3.2.2 Insert Page B 3.2.2-4a INSERT 3 The % FH margin is based on the relationship between FHRM(X,Y) and the limit, BHDES (X,Y), as follows:

100% x Y)BHDES(X,Y)(X,HRF 1 =Margin F %MH If the reactor core is operating as designed, then FHRM(X,Y) is less than BHDES (X,Y) and calculation of %FH margin is not required. If the

%FH margin is less than zero, then FHRM(X,Y) is greater than BHDES (X, Y) and the FH(X,Y) limits may not be adequate to prevent exceeding the initial DNB conditions assumed for transients such as a LOFA. BHDES (X,Y) represents the maximum allowable design radial peaking factors which ensures that the initial conditions DNB will be preserved for operation within the LCO limits, and includes allowances for calculational and measurement uncertainties. The FH min margin is the minimum for all core locations examined.

INSERT 4 If FH min margin < 0 is restored to within limits prior to completion of the THERMAL POWER reduction in Required Action A.1, compliance of Required Actions A.3 and A.5 must be met.

24 B 3.2.2 Insert Page B 3.2.2-4b INSERT 5 from RTP by at least RRH % (where RRH = Thermal power reduction required to compensate for each 1% that FH(X,Y) exceeds its limit) multiplied times the FH min margin

INSERT 6 trip setpoints, as specified in TS Table 3.3.1-1 by RRH% multiplied times the FH min margin INSERT 7 by at least RRH% multiplied times the FH min margin 444 HNF B 3.2.2

WOG STS B 3.2.2-5 Rev. 4.0, FH(X,Y)SEQUOYAH UNIT 2 Revision XXX 11BASES ACTIONS (continued)

The allowed Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to reset the trip setpoints per

Required Action A.

1.2.2 recognizes that, once power is reduced, the safety analysis assumptions are satisfied and there is no urgent need to reduce the trip setpoints. This is a sensitive operation that may inadvertently trip the Reactor Protection System.

A.2 Once the power level has been reduced to < 50% RTP per Required Action A.1

.2.1, an incore flux map (SR 3.2.2.1) must be obtained and the measured value of HNF verified not to exceed the allowed limit at the lower power level. The unit is provided 20 additional hours to perform this task over and above the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allowed by either Action A.1.1 or Action A.1

.2.1. The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is acceptable because of the increase in the DNB margin, which is obtained at lower power levels, and the low probability of having a DNB limiting event within this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Additionally, operating experience has indicated that this Completion Time is sufficient to obtain the incore flux map, perform the required calculations, and evaluate HNF. A.3 Verification that HNF is within its specified limits after an out of limit occurrence ensures that the cause that led to the HNF exceeding its limit is corrected, and that subsequent operation proceeds within the LCO limit. This Action demonstrates that the HNF limit is within the LCO limits prior to exceeding 50% RTP, again prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is 95% RTP.

This Required Action is modified by a Note that states that THERMAL POWER does not have to be reduced prior to performing this Action.

B.1 When Required Actions A.1

.1 through A.

3 cannot be completed within their required Completion Times, the plant must be placed in a mode in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems.

FH min margin is verified > 0 FHmin margin FHmin margin is > 0 FH min margin FH min margin 1114INSERT 8 4322 2 INSERT 945 45, and B.1, 4C 2allowable 3 >0INSERT 10 B 3.2.2 Insert Page B 3.2.2-5a INSERT 8 by at least RRH% multiplied times the FH min margin INSERT 9 A.4 If the value of FHRM(X,Y) is not restored to within its specified limit, Overtemperarture T K1 (OTT K1) term is required to be reduced by at least TRH multiplied times the FH min margin. The value of TRH is provided in the COLR. Completing Required Action A.4 ensures protection against the consequences of transients since this adjustment limits the peak transient power level which can be achieved during an anticipated operational occurrence. Also, completing Required Action A.4 within the allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is sufficient considering the small likelihood of a limiting transient in this time period.

44 B 3.2.2 Insert Page B 3.2.2-5b INSERT 10 B.1 The %f1(I) margin is based on the relationship between FHRM(X,Y) and the limit, BRDES (X,Y), as follows:

% f(I)Margin = 1 FHR(X,Y)BRDES(X,Y) x 100%1M If the reactor core is operating as designed, then FHRM(X,Y) is less than BRDES (X,Y) and calculation of %f 1(I) margin is not required. If the

%f1(I) margin is less than zero, then FHRM(X,Y) is greater than BRDES (X, Y) and the OTT setpoint limits may not be adequate to prevent exceeding DNB requirements.

BRDES (X,Y) represents the maximum allowable design radial peaking factors which ensure that the steady state DNBR limit will be preserved for operation within the LCO limits, including allowances for calculational

and measurement uncertainties Required Action B.1 requires the reduction of the OTT K1 term by at least TRH multiplied by the f 1(I) min margin. TRH is the amount of OTT K1 setpoint reduction required to compensate for each 1% that FH(X,Y) exceeds the limit provided in the COLR. Completing Required Action B.1 within the allowed Completion Time of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, restricts FH(X,Y) such that even if a transient occurred, DNB requirements are met. The f 1(I) min margin is the minimum % of f 1(I) margin for all core locations examined.

2 HNF B 3.2.2

WOG STS B 3.2.2-6 Rev. 4.0, FH(X,Y)1SEQUOYAH UNIT 2 Revision XXX 1BASES

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The value of HNF is determined by using the movable incore detector system to obtain a flux distribution map. A data reduction computer program then calculates the maximum value of HNF from the measured flux distributions. The measured value of HNF must be multiplied by 1.04 to account for measurement uncertainty before making comparisons to the HNF limit. After each refueling, HNF must be determined in MODE 1 prior to exceeding 75%

RTP. This requirement ensures that HNF limits are met at the beginning of each fuel cycle.

[ The 31 EFPD Frequency is acceptable because the power distribution changes relatively slowly over this amount of fuel burnup. Accordingly, this Frequency is short enough that the HNF limit cannot be exceeded for any significant period of o peration.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

REFERENCES 1. Regulatory Guide 1.77, Rev.

[0], May 1974.

2. 10 CFR 50, Appendix A, GDC 26.
3. 10 CFR 50.46.

1INSERT 12 4467INSERT 11 B 3.2.2 Insert Page B 3.2.2-6a INSERT 11 SR 3.2.2.1 and SR 3.2.2.2 are modified by a Note. It states that, "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after an equilibrium power level has been achieved at which a power distribution map can be obtained."

SR 3.2.2.1 and SR 3.2.2.2 require using the incore detector system to provide the necessary data to create a power distribution map. To provide the necessary data, MODE 1 needs to be entered, power escalated, stabilized and equilibrium conditions established at some higher power level. These surveillances could not be satisfactorily performed if the requirement for performance of the Surveillances was included in MODE 2 prior to entering MODE 1.

In a reload core,HMF(X,Y)could not have previously been measured, therefore, there is a Frequency condition, applicable only for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of HMF(X,Y) is made at a lower power level at which adequate margin is available before going to 100% RTP.

4 B 3.2.2 Insert Page B 3.2.2-6b INSERT 12 SR 3.2.2.1 and SR 3.2.2.2

In addition to ensuring via Surveillance that the nuclear enthalpy rise hot channel factor is within its limits when a measurement is taken, there are also requirements to extrapolate trends in )Y,X(FMH for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an FHRM(X,Y) > BHNOM(X,Y), further consideration is required.

The implications of these extrapolations are considered separately for BHDES(X,Y) and BRDES(X,Y) limits. If the extrapolations of )Y,X(FMH are unfavorable, additional actions must be taken. These actions are to meet the FH(X,Y) limit with the last HMF(X,Y) increased by the appropriate factor specified in the COLR or to evaluateHMF(X,Y) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These al ternative requirements attempt to prevent FH(X,Y) from exceeding its limit for any significant period of time without detection using the best available data.

Extrapolation is not required for the initial flux map taken after reaching equilibrium conditions following a refueling outage since the initial flux map establishes the baseline measurement for future trending.

4 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, BASES, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y)) Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made (additions, deletions, and/or changes) to the ISTS Bases which reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.

2. The ISTS 3.2.2 LCO and Action A Bases have been modified to add details associated with the relationship between FHRM(X,Y) and BHDES(X,Y) in accordance with NRC Safety Evaluation dated April 27, 1997 (ML013320456).
3. The ISTS contains bracketed information and/or values that are generic to all Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is changed to reflect the current licensing basis.
4. Changes have been made to be consistent with changes made to the Specification.
5. The ISTS 3.2.2 Bases for A.1.1, 2nd paragraph, contains in part, "Required Action A.2 nevertheless requires another measurement and calculation of HNF within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance with SR 3.2.2.1." The last paragraph contains a similar statement, " In addition, Required Action A.2 is performed if power ascension is delayed past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />." SQN is deleting the redundant statement in last paragraph.
6. ISTS SR 3.2.2.1 provides two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies for ITS SR 3.2.2.1 under the Surveillance Frequency Control Program.
7. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
8. Editorial change made for clarification.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y)) Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 3 ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01ITS ITS 3.2.3 3/4.2 POWER DISTRIBUTION LIMITS 3/4.2.1 AXIAL FLUX DIFFERENCE (AFD)

LIMITING CONDITION FOR OPERATION

3.2.1 The indicated AXIAL FLUX DIFFERENCE (

AFD) shall be maintained within the limits specified in the COLR.

APPLICABILITY

MODE 1 above 50% RATED THERMAL POWER
  • ACTION: a. With the indicated AXIAL FLUX DIFFERENCE outside of the limits specified in the COLR; 1. Either restore the indicated AFD to within the limits within 15 minutes, or
2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 30 minutes and reduce the Power Range Neutron Flux

-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. b. THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR.

  • See Special Test Exception 3.10.2 October 4, 1995 SEQUOYAH - UNIT 1 3/4 2-1 Amendment No. 19, 155, 213 Page 1 of 6 LCO 3.2.3 Applicabilit y L01L02A04A02M01 in % flux difference units A03A03ACTION A A02A02 A01ITS ITS 3.2.3 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.1.1 The indicated AXIAL FLUX DIFFERENCE shall be determined to be within its limits during POWER OPERATION above 50% of RATED THERMAL POWER by:
a. Monitoring the indicated AFD for each OPERABLE excore channel at least once per 7 days when the AFD Monitor Alarm is OPERABLE

.

b. Monitoring and logging the indicated AXIAL FLUX DIFFERENCE for each OPERABLE excore channel at least once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 30 minutes thereafter, when the AXIAL FLUX DIFFERENCE Monitor Alarm is inoperable. The logged values of the indicated AXIAL FLUX DIFFERENCE shall be assumed to exist during the interval preceding each logging.

4.2.1.2 The indicated AFD shall be considered outside of its limits when at least 2 OPERABLE excore channels are indicating the AFD to be outside the limits.

December 2, 1986 SEQUOYAH - UNIT 1 3/4 2-2 Amendment No. 51 SR 3.2.3.1 LCO 3.2.3 Note L03Page 2 of 6 LA01In accordance with the Surveillance Frequency Control Program A02A02A02 A01ITS ITS 3.2.3 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

This page left blank intentionally.

December 23, 1982 SEQUOYAH - UNIT 1 3/4 2-3 Amendment No. 19 Page 3 of 6 A01ITS ITS 3.2.3 3/4.2 POWER DISTRIBUTION LIMITS

3/4.2.1 AXIAL FLUX DIFFERENCE (AFD)

LIMITING CONDITION FOR OPERATION 3.2.1 The indicated AXIAL FLUX DIFFERENCE (

AFD) shall be maintained within the limits specified in the COLR.

APPLICABILITY

MODE 1 above 50% of RATED THERMAL POWER
  • .

ACTION: a. With the indicated AXIAL FLUX DIFFERENCE outside of the limits specified in the COLR; 1. Either restore the indicated AFD to within the limits within 15 minutes, or

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 30 minutes and reduce the Power Range Neutron Flux

-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

b. THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR.
  • See Special Test Exception 3.10.2

October 4, 1995 SEQUOYAH - UNIT 2 3/4 2-1 Amendment Nos. 21, 146, 203 Page 4 of 6 LCO 3.2.3 Applicabilit y ACTION A L01L02A04M01 in % flux difference units A03A03A02A02 A01ITS ITS 3.2.3 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS 4.2.1.1 The indicated AXIAL FLUX DIFFERENCE shall be determined to be within its limits during POWER OPERATION above 50% of RATED THERMAL POWER by:

a. Monitoring the indicated AFD for each OPERABLE excore channel at least once per 7 days when the AFD Monitor Alarm is OPERABLE, and
b. Monitoring and logging the indicated AXIAL FLUX DIFFERENCE for each OPERABLE excore channel at least once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 30 minutes thereafter, when the AXIAL FLUX DIFFERENCE Monitor Alarm is inoperable. The logged values of the indicated AXIAL FLUX DIFFERENCE shall be assumed to exist during the interval preceding each logging.

4.2.1.2 The indicated AFD shall be considered outside of its limits when at least 2 OPERABLE excore channels are indicating the AFD to be outside the limits.

December 2, 1986 SEQUOYAH - UNIT 2 3/4 2-2 Amendment No. 43

Page 5 of 6 SR 3.2.3.1 LCO 3.2.3 Note L03LA01In accordance with the Surveillance Frequency Control Program A02A02A02 A01ITS ITS 3.2.3

This page intentionally deleted

March 30, 1992 SEQUOYAH - UNIT 2 3/4 2-3 Amendment Nos. 21, 146

Page 6 of 6 DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and Unit 2 Page 1 of 4 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this

submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.2.1 states "The indicated AXIAL FLUX DIFFERENCE (AFD) shall be maintained within the limits specified in the COLR." CTS 3.2.1 ACTION a provides ACTIONs to take when the indicated AFD is outside the limits. CTS 4.2.1.1 requires a determination that the indicated AFD is within limits. CTS 4.2.1.2 states that the indicated AFD shall be considered outside the limits when at least 2 OPERABLE excore channels are indicating the AFD to be outside the limits. ITS LCO 3.2.3 states "The AFD in % flux difference units shall be maintained within the limits specified in the COLR." ITS LCO 3.2.3 is modified by a Note specifying when AFD is considered to be outside the limits. ITS SR 3.2.3.1 requires verification that AFD is within limits. This changes the CTS by deleting "indicated and adding "% flux difference units" to the LCO statement.

The purpose of CTS 3.2.1 is to ensure the AFD remains within the limits specified in the COLR. AFD is the difference in normalized flux signals between the top and bottom excore detectors, therefore, this is a presentation change.

This change is designated as administrative because it does not result in a technical change to the CTS.

A03 CTS 3.2.1 Applicability contains a footnote (footnote *) which states "See Special Test Exception 3.10.2." ITS 3.2.3 Applicability does not contain this footnote. This changes the CTS by not including Footnote*.

The purpose of Footnote

  • is to alert the Technical Specification user that a Special Test Exception exists that may modify the Applicability of this Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative because it does not result in a technical change to the CTS.

A04 CTS 3.2.1 ACTION b states "THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR." ITS 3.2.3 does not contain a similar requirement. This changes the CTS by eliminating a prohibition contained in the CTS.

This change is acceptable because the requirements have not changed. CTS 3.0.4 and ITS 3.0.4 prohibit entering the MODE of Applicability of a Technical Specification unless the requirements of the LCO are met. CTS 3.2.1 and ITS 3.2.3 are applicable in MODE 1 with THERMAL POWER > 50% RTP (CTS) and 50 RTP (ITS). Therefore, both the CTS and ITS prohibit exceeding DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and Unit 2 Page 2 of 4 50% RTP without the LCO requirements being met. CTS 3.2.1 ACTION b is duplicative of CTS 3.0.4 and ITS 3.0.4 and its elimination does not make a technical change to the Specification. This change is designated as an administrative change because it does not result in technical changes to the CTS. MORE RESTRICTIVE CHANGES

M01 CTS 3.2.1 is applicable in MODE 1 with THERMAL POWER > 50% RTP. ITS 3.2.3 is applicable in MODE 1 with THERMAL POWER 50% RTP. This changes the CTS by requiring LCO 3.2.3 to be met when THERMAL POWER is equal to 50 % RTP.

The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR. When AFD is not within limits, CTS 3.2.1 ACTION a.2, requires reducing THERMAL POWER to less than 50% RTP. This change is acceptable because it aligns the Applicability to the Required Actions. The CTS and ITS Required Action is to reduce THERMAL POWER to less than 50% RTP. When the THERMAL POWER is reduced to this value, it places the core in a condition outside of the Applicability of the LCO. Therefore, changing the Applicability from in MODE 1 with THERMAL POWER > 50% RTP to MODE 1 with THERMAL POWER 50% RTP has no affect on the LCO. This change is designated as more restrictive because it provides additional requirements to the Applicability.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.2.1.1.a requires monitoring the indicated AFD for each OPERABLE excore channel at least once per 7days. ITS SR 3.2.3.1 requires a similar Surveillance and specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequency for this SR and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and Unit 2 Page 3 of 4 Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES

L01 (Category 4 - Relaxation of Required Action) CTS 3.2.1 ACTION a.1 requires with the AXIAL FLUX DIFFERENCE (AFD) outside of the limits, to restore the indicated AFD to within the limits within 15 minutes. ITS 3.2.3 does not include a Required Action to restore the indicated AFD to within the limits within 15 minutes. This changes the CTS by not including a specific requirement to restore the AFD to within limits.

The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR. This change is acceptable because the requirement to restore the AFD to within limits has not changed. ITS 3.2.3 allows a Completion Time of 30 minutes to reduce THERMAL POWER to < 50% RTP. During the time that power is being reduced, AFD can be restored to within limits. Per ITS LCO 3.0.2, if the LCO is met prior to expiration of the Completion Time, completion of the Required Actions is not required. This allowance also is provided in CTS 3.0.2.

Therefore, restoration of AFD is always an option and a specific ACTION is not required. This change is designated as less restrictive because additional

Completion Time is provided that was not provided in the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.2.1 ACTION a.2 states that with the indicated AFD outside of the limits specified in the COLR, reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.3 ACTION A only requires THERMAL POWER to be reduced to less than 50% RTP. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux - High trip setpoints to 55 % of RTP within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

The purpose of CTS 3.2.1 ACTION a.2 is to reduce THERMAL POWER to the point at which the LCO is met if AFD is not restored within its limit. With the AFD meeting the Technical Specification requirements, further actions are not required to ensure that the assumptions of the safety analyses are met.

Increases in THERMAL POWER are governed by ITS LCO 3.0.4, which requires the LCO to be met prior to entering a MODE or other specified condition in which the LCO applies. Therefore, power increases are prohibited while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

L03 (Category 7 - Relaxation of Surveillance Frequency)

CTS 4.2.1.1.a requires the monitoring of the indicated AFD for each OPERABLE excore channel at least once per 7 days when the AFD Monitor Alarm is OPERABLE. CTS 4.2.1.1.b DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and Unit 2 Page 4 of 4 requires the monitoring and logging of the indicated AFD for each OPERABLE excore channel at least once per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 30 minutes thereafter, when the AFD Monitor Alarm is inoperable. The logged values of the indicated AFD shall be assumed to exist during the interval preceding each logging. This changes the CTS by eliminating all AFD Surveillance Frequencies based on the OPERABILITY of the AFD Monitor Alarm.

The purpose of ITS 3.2.3 is to ensure that AFD is within its limit. This change is acceptable because the remaining Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of monitoring AFD when the AFD Monitor Alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that AFD is outside of its limit. The AFD Monitor Alarm is for indication only. Its use is not credited in any safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

AFD (RAOC Methodology) 3.2.3B Westinghouse STS 3.2.3B-1 Rev. 4.0 Amendment XXX SEQUOYAH UNIT 1 11CTS 23.2 POWER DISTRIBUTION LIMITS

3.2.3B AXIAL FLUX DIFFERENCE (AFD)

(Relaxed Axial Offset Control (RAOC)

Methodology)

LCO 3.2.3 B The AFD in % flux difference units shall be maintained within the limits specified in the COLR.

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

The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits. --------------------------------------------------------------------------------------------------

APPLICABILITY: MODE 1 with THERMAL POWER 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. AFD not within limits.

A.1 Reduce THERMAL POWER to < 50% RTP.

30 minutes

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AFD within limits for each OPERABLE excore channel.

[ 7 days OR In accordance

with the

Surveillance Frequency Control Program

] 1333.2.1 Applicabilit y ACTION A.2 4.2.1.2 4.2.1.1.a 1

AFD (RAOC Methodology) 3.2.3B Westinghouse STS 3.2.3B-1 Rev. 4.0 Amendment XXX SEQUOYAH UNIT 2 11CTS 23.2 POWER DISTRIBUTION LIMITS

3.2.3B AXIAL FLUX DIFFERENCE (AFD)

(Relaxed Axial Offset Control (RAOC)

Methodology)

LCO 3.2.3 B The AFD in % flux difference units shall be maintained within the limits specified in the COLR.

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

The AFD shall be considered outside limits when two or more OPERABLE excore channels indicate AFD to be outside limits. --------------------------------------------------------------------------------------------------

APPLICABILITY: MODE 1 with THERMAL POWER 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

A. AFD not within limits.

A.1 Reduce THERMAL POWER to < 50% RTP.

30 minutes

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify AFD within limits for each OPERABLE excore channel.

[ 7 days OR In accordance

with the

Surveillance Frequency Control Program

] 1333.2.1 Applicabilit y ACTION A.2 4.2.1.2 4.2.1.1.a 1

JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one AFD Specification is used in the Sequoyah Nuclear (SQN) Plant ITS.) This information is provided in NUREG-1431, Rev. 4.0, to assist in indentifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Constant Axial Offset Control (CAOC) methodology Specification (ISTS 3.2.3A) is not used and is not shown.

2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. ISTS SR 3.2.3.1 provides two options for controlling the Frequency of the Surveillance Requirement. SQN is proposing to control the Surveillance Frequency under the Surveillance Frequency Control Program.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-1 Rev. 4.0 211SEQUOYAH UNIT 1 Revision XXX B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.3B AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC Methodology)

BASES

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

RAOC is a calculational procedure that defines the allowed operational space of the AFD versus THERMAL POWER.

The AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of the AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidate the conclusions of the accident and transient analyses with regard to fuel cladding integrity.

The AFD is monitored on an automatic basis using the unit process computer, which has an AFD monitor alarm. The computer determines the 1 minute average of each of the OPERABLE excore detector outputs

and provides an alarm message immediately if the AFD for two or more OPERABLE excore channels is outside its specified limits.

Although the RAOC defines limits that must be met to satisfy safety analyses, typically an operating scheme, Constant Axial Offset Control (CAOC), is used to control axial power distribution in day to day operation (Ref. 1). CAOC requires that the AFD be controlled within a narrow tolerance band around a burnup dependent target to minimize the variation of axial peaking factors and axial xenon distribution during unit maneuvers.

The CAOC operating space is typically smaller and lies within the RAOC operating space. Control within the CAOC operating space constrains the variation of axial xenon distributions and axial power distributions. RAOC calculations assume a wide range of xenon distributions and then confirm that the resulting power distributions satisfy the requirements of the accident analyses.

1111 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-2 Rev. 4.0 211SEQUOYAH UNIT 1 Revision XXX BASES

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

The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements.

The RAOC methodology (Ref.

2) establishes a xenon distribution library with tentatively wide AFD limits. One dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requi rements.

The limits on the AFD ensure that the Heat Flux Hot Channel Factor

(FQ(Z)) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents.

The most important Condition 4 event is the LOCA. The most important Condition 3 event is the loss of flow accident. The most i mportant Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents.

Condition 2 accidents simulated to begin from within the AFD limits are used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.

The limits on the AFD satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The shape of the power profile in the axial (i.e., the vertical) direction is largely under the control of the operator through the manual operation of the control banks or automatic motion of control banks. The automatic motion of the control banks is in response to temperature deviations resulting from manual operation of the Chemical and Volume Control System to change boron concentration or from power level changes.

Signals are available to the operator from the Nuclear Instrumentation System (NIS) excore neutron detectors (Ref.

3). Separate signals are taken from the top and bottom detectors. The AFD is defined as the difference in normalized flux signals between the top and bottom excore detectors in each detector well. For convenience, this flux difference is

converted to provide flux difference units expressed as a percentage and labeled as % flux or %I. 1 and 212X, Y, 22s 6, 6 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-3 Rev. 4.0 211SEQUOYAH UNIT 1 Revision XXX BASES LCO (continued)

The AFD limits are provided in the COLR.

Figure B 3.2.3B-1 shows typical RAOC AFD limits. The AFD limits for RAOC do not depend on the target flux difference. However, the target flux difference may be used to minimize changes in the axial power distribution.

Violating this LCO on the AFD could produce unacceptable consequences if a Condition 2, 3, or 4 event occurs while the AFD is outside its specified limits.

APPLICABILITY The AFD requirements are applicable in MODE 1 greater than or equal to 50% RTP when the combination of THERMAL POWER and core peaking factors are of primary importance in safety analysis.

For AFD limits developed using RAOC methodology, the value of the AFD does not affect the limiting accident consequences with THERMAL POWER < 50% RTP and for lower operating power MODES.

ACTIONS A.1 As an alternative to restoring the AFD to within its specified limits, Required Action A.1 requires a THERMAL POWER reduction to

< 50% RTP. This places the core in a condition for which the value of the AFD is not important in the applicable safety analyses. A Completion Time of 30 minutes is reasonable, based on operating experience, to reach 50% RTP without challenging plant systems.

SURVEILLANCE SR 3.2.3.1 REQUIREMENTS This Surveillance verifies that the AFD, as indicated by the NIS excore channel, is within its specified limits.

[ The Surveillance Frequency of 7 days is adequate considering that the AFD is monitored by a computer and any deviation from requirements is alarmed. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] INSERT 1151343 B 3.2.3 Insert Page B 3.2.3-3 INSERT 1 The AFD limits resulting from analysis of core power distributions relative to the initial condition peaking limits comprise a power-dependant envelope of acceptable AFD values. During steady-state operation, the core normally is controlled to a target AFD within a narrow (approximately +/- 5% AFD) band. However, the limiting AFD values may be somewhat greater than the extremes of the normal operating band.

1 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-4 Rev. 4.0 1Revision XXX 1SEQUOYAH UNIT 1 2BASES

REFERENCES 1.

WCAP-8403 (nonproprietary), "Power Distribution Control and Load Following Procedures," Westinghouse Electric Corporation, September 1974.

2. R. W. Miller et al., "Relaxation of Constant Axial Offset Control: F Q Surveillance Technical Specification," WCAP

-10217(NP), June 1983.

3. FSAR, Chapter

[15].

UFSAR, Section 4.3.2.BAW 10163P-A, Core Operating Limit Methodology for Westinghouse-Designed PWRs, June 1989.

222 Encfosure 2, Volume 7, Rev. 0, Page 195 of 249d,l!=oo-J=d,Lt.l-rFoL&JFd,Fc)o\o100BO604020AFD lffB 3.2.38 ,1 \-/5040-50-30_ L0-20AXIAL FLUXDr FFERENCE

(%)20Figure B 3.2.38-1 (page 1 of 1)AXIAL FLUX DIFFERENCE Acceptable Operation Limits as a Funct'i on of RATED THERMAL P0WERB 3.2.3s-5Volume 7, Rev. 0,@Rev,t4,O t?U(-15,100)

(6, too)PTABLEUNACCE PTABLEOPERATION

-31 ,50PTABL20,50)THIS FIGURI LLUSTRATDO NOTIS FOREnclosure 2,Page 195 of 249 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-1 Rev. 4.0 211SEQUOYAH UNIT 2 Revision XXX B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.3B AXIAL FLUX DIFFERENCE (AFD) (Relaxed Axial Offset Control (RAOC Methodology)

BASES

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

RAOC is a calculational procedure that defines the allowed operational space of the AFD versus THERMAL POWER.

The AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of the AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidate the conclusions of the accident and transient analyses with regard to fuel cladding integrity.

The AFD is monitored on an automatic basis using the unit process computer, which has an AFD monitor alarm. The computer determines the 1 minute average of each of the OPERABLE excore detector outputs

and provides an alarm message immediately if the AFD for two or more OPERABLE excore channels is outside its specified limits.

Although the RAOC defines limits that must be met to satisfy safety analyses, typically an operating scheme, Constant Axial Offset Control (CAOC), is used to control axial power distribution in day to day operation (Ref. 1). CAOC requires that the AFD be controlled within a narrow tolerance band around a burnup dependent target to minimize the variation of axial peaking factors and axial xenon distribution during unit maneuvers.

The CAOC operating space is typically smaller and lies within the RAOC operating space. Control within the CAOC operating space constrains the variation of axial xenon distributions and axial power distributions. RAOC calculations assume a wide range of xenon distributions and then confirm that the resulting power distributions satisfy the requirements of the accident analyses.

1111 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-2 Rev. 4.0 211SEQUOYAH UNIT 2 Revision XXX BASES

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

The allowed range of the AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements.

The RAOC methodology (Ref.

2) establishes a xenon distribution library with tentatively wide AFD limits. One dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for the LOCA and loss of flow accident, and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requi rements.

The limits on the AFD ensure that the Heat Flux Hot Channel Factor

(FQ(Z)) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on the AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition 2, 3, or 4 events. This ensures that the fuel cladding integrity is maintained for these postulated accidents.

The most important Condition 4 event is the LOCA. The most important Condition 3 event is the loss of flow accident. The most i mportant Condition 2 events are uncontrolled bank withdrawal and boration or dilution accidents.

Condition 2 accidents simulated to begin from within the AFD limits are used to confirm the adequacy of the Overpower T and Overtemperature T trip setpoints.

The limits on the AFD satisfy Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The shape of the power profile in the axial (i.e., the vertical) direction is largely under the control of the operator through the manual operation of the control banks or automatic motion of control banks. The automatic motion of the control banks is in response to temperature deviations resulting from manual operation of the Chemical and Volume Control System to change boron concentration or from power level changes.

Signals are available to the operator from the Nuclear Instrumentation System (NIS) excore neutron detectors (Ref.

3). Separate signals are taken from the top and bottom detectors. The AFD is defined as the difference in normalized flux signals between the top and bottom excore detectors in each detector well. For convenience, this flux difference is

converted to provide flux difference units expressed as a percentage and labeled as % flux or %I. 1 and 212X, Y, 22s 6, 6 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-3 Rev. 4.0 211SEQUOYAH UNIT 2 Revision XXX BASES LCO (continued)

The AFD limits are provided in the COLR.

Figure B 3.2.3B-1 shows typical RAOC AFD limits. The AFD limits for RAOC do not depend on the target flux difference. However, the target flux difference may be used to minimize changes in the axial power distribution.

Violating this LCO on the AFD could produce unacceptable consequences if a Condition 2, 3, or 4 event occurs while the AFD is outside its specified limits.

APPLICABILITY The AFD requirements are applicable in MODE 1 greater than or equal to 50% RTP when the combination of THERMAL POWER and core peaking factors are of primary importance in safety analysis.

For AFD limits developed using RAOC methodology, the value of the AFD does not affect the limiting accident consequences with THERMAL POWER < 50% RTP and for lower operating power MODES.

ACTIONS A.1 As an alternative to restoring the AFD to within its specified limits, Required Action A.1 requires a THERMAL POWER reduction to

< 50% RTP. This places the core in a condition for which the value of the AFD is not important in the applicable safety analyses. A Completion Time of 30 minutes is reasonable, based on operating experience, to reach 50% RTP without challenging plant systems.

SURVEILLANCE SR 3.2.3.1 REQUIREMENTS This Surveillance verifies that the AFD, as indicated by the NIS excore channel, is within its specified limits.

[ The Surveillance Frequency of 7 days is adequate considering that the AFD is monitored by a computer and any deviation from requirements is alarmed. OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] INSERT 1151343 B 3.2.3 Insert Page B 3.2.3-3 INSERT 1 The AFD limits resulting from analysis of core power distributions relative to the initial condition peaking limits comprise a power-dependant envelope of acceptable AFD values. During steady-state operation, the core normally is controlled to a target AFD within a narrow (approximately +/- 5% AFD) band. However, the limiting AFD values may be somewhat greater than the extremes of the normal operating band.

1 AFD (RAOC Methodology)

B 3.2.3B Westinghouse STS B 3.2.3B-4 Rev. 4.0 1Revision XXX 1SEQUOYAH UNIT 2 2BASES

REFERENCES 1.

WCAP-8403 (nonproprietary), "Power Distribution Control and Load Following Procedures," Westinghouse Electric Corporation, September 1974.

2. R. W. Miller et al., "Relaxation of Constant Axial Offset Control: F Q Surveillance Technical Specification," WCAP

-10217(NP), June 1983.

3. FSAR, Chapter

[15].

UFSAR, Section 4.3.2.BAW 10163P-A, Core Operating Limit Methodology for Westinghouse-Designed PWRs, June 1989.

222

(-15,100)

(6,100)PTABLEUNACCEPTABLE OPERAT ION-31 ,50PTABL20,50)THIS FIGURI LL USTRAT DO NOTIS FOREnclosure 2, Volume 7, Rev. 0, Page 201 of 249Eu-l=Oo-J=d.lrl-Fol-lJFd,q-oo\o100806040AFD -[ nl83-2-3ts-J\r50-50-30_ L0-20AXIAL FLUXDTFFERENCE

(%)40F'i gure B 3.2.38-1 (page 1 of 1)AXIAL FLUX DIFFERENCE Acceptabl e Operati on Li mi tsas a Functi on of RATED THERMAL P0II'IERB 3.2.38-5Volume 7, Rev. 0, Page 201ooSEQUOYAH UNIT 2Enclosure 2,of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one AFD Specification is used in the Sequoyah Nuclear (SQN) Plant ITS.) This information is provided in NUREG-1431, Rev. 4.0, to assist in indentifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Constant Axial Offset Control (CAOC) methodology Specification (ISTS B 3.2.3A) is not used and is not shown.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. ISTS SR 3.2.3.1 Bases provides two options for controlling the Frequency of Surveillance Requirement. SQN is proposing to control the Surveillance Frequency under the Surveillance Frequency Control Program. Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.
4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
5. ISTS 3.2.3 Bases contains Figure B 3.2.3B-1. This Figure is located in the Sequoyah Nuclear Plant (SQN) COLR. Therefore, this figure is not included in the Bases for ITS 3.2.3.
6. Editorial changes made to enhance clarity/consistency.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)

Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 4 ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS 3/4.2.4 QUADRANT POWER TILT RATIO LIMITING CONDITION FOR OPERATION 3.2.4 The QUADRANT POWER TILT RATIO shall not exceed 1.02.

APPLICABILITY: MODE 1 above 50% of RATED THERMAL POWER

  • ACTION:
a. With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09:
1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until:

a) Either the QUADRANT POWER TILT RATIO is reduced to within its limit, or b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.

2. Within 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s:

a) Either reduce the QUADRANT POWER TILT RATIO to within its limit

, or b) Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux

-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

.

3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

.

4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL power may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified acceptable at 95% or greater RATED THERMAL POWER.

__________________

  • See Special Test Exception 3.10.2.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-12 Amendment No. 138, 223 be A02A03L0112 hours A04not within limit A05A05L03L02LCO 3.2.4 Applicabilit y ACTION A, ACTION B ACTION A ACTION B ACTION A A03Add proposed Required Actions A.3, A.4, A.5, and A.6 and proposed ACTION B Page 1 of 6 or equal to A06after each QPTR determination M01 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS ACTION: (Continued)

b. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to misalignment of either a shutdown or control rod
1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until:

a) Either the QUADRANT POWER TILT RATIO is reduced to within its limit, or b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.

2. Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 within 30 minutes. 3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

. 4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified acceptable at 95% or greater RATED THERMAL POWER.

c. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod
1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until:

a) Either the QUADRANT POWER TILT RATIO is reduced to within its limit, or b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.

April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-13 Amendment No. 138, 223 A05L0112 hours A04not within limit L03A0412 hoursnot within limit L01L042 hours A05ACTION A, ACTION B ACTION A ACTION B ACTION A, ACTION B ACTION A ACTION B ACTION A Page 2 of 6 or equal to A06or equal to A06 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS ACTION: (Continued)

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux

-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. 3. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for l2 hours or until verified at 95% or greater RATED THERMAL POWER.

d. With the indicated QUADRANT POWER TILT RATIO not confirmed as required by Surveillance Requirement 4.2.4.2, reduce THERMAL POWER to less than 75 percent RATED THERMAL POWER within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
e. With the QUADRANT POWER TILT RATIO not monitored as required by Surveillance Requirement 4.2.4.1, reduce THERMAL POWER to less than 50 percent of RATED THERMAL POWER within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

SURVEILLANCE REQUIREMENTS 4.2.4.1 The QUADRANT POWER TILT RATIO shall be determined to be within the limit above 50% of RATED THERMAL POWER by:

a. Calculating the ratio at least once per 7 days when the alarm is OPERABLE.
b. Calculating the ratio at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady state operation when the alarm is inoperable

.

4.2.4.2 The QUADRANT POWER TILT RATIO shall be determined to be within the limit when above 75 percent of RATED THERMAL POWER with one Power Range Channel inoperable by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained from the 4 pairs of symmetric thimble locations or from performance of a full core map, is consistent with the indicated QUADRANT POWER TILT RATIO at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

April 11, 2005 SEQUOYAH - UNIT 1 3/4 2-14 Amendment Nos. 135, 138, 301 L03L05L05L06Add proposed SR 3.2.4.1 Notes 1 and 2 LA01LA01LA02SR 3.2.4.1 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program L07Add proposed SR 3.2.4.2 Note SR 3.2.4.2 SR 3.2.4.2 Note SR 3.2.4.2 L08Page 3 of 6 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS 3/4.2.4 QUADRANT POWER TILT RATIO LIMITING CONDITION FOR OPERATION 3.2.4 The QUADRANT POWER TILT RATIO shall not exceed 1.02.

APPLICABILITY: MODE 1 above 50% of RATED THERMAL POWER

  • ACTION: a. With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09:
1. Calculate the QUARANT POWER TILT RATIO at least once per hour until either:

a) The QUADRANT POWER TILT RATIO is reduced to within its limit, or b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER. 2. Within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either: a) Reduce the QUADRANT POWER TILT RATIO to within its limit

, or b) Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux

-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL power may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified acceptable at 95% or greater RATED THERMAL POWER.
  • See Special Test Exception 3.10.2.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-10 Amendment No. 130, 214 be A02A03L0112 hoursA04A05L03LCO 3.2.4 Applicabilit y ACTION A, ACTION B ACTION A ACTION B ACTION A A03Add proposed Required Actions A.3, A.4, A.5, and A.6 and proposed ACTION B L02A05Page 4 of 6 or equal to A06not within limit after each QPTR determination M01 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS

ACTION: (Continued)

b. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to misalignment of either a shutdown or control rod:
1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until either: a) The QUADRANT POWER TILT RATIO is reduced to within its limit, or b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.
2. Reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 within

30 minutes. 3. Verify that the QUADRANT POWER TILT RATIO is within its limit within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. 4. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified acceptable at 95% or greater RATED THERMAL POWER.

c. With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod
1. Calculate the QUADRANT POWER TILT RATIO at least once per hour until either: a) The QUADRANT POWER TILT RATIO is reduced to within its limit, or b) THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-11 Amendment No. 130, 214 A05L0112 hours A04not within limit L03A0412 hoursnot within limit L01A05ACTION A, ACTION B ACTION A ACTION B ACTION A, ACTION B ACTION A ACTION B ACTION A L042 hours Page 5 of 6 or equal to A06or equal to A06 A01ITS ITS 3.2.4 POWER DISTRIBUTION LIMITS

ACTION: (Continued)

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux

-High Trip Setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

3. Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified at 95% or greater RATED THERMAL POWER.
d. With the indicated QUADRANT POWER TILT RATIO not confirmed as required by Surveillance Requirement 4.2.4.2, reduce TH ERMAL POWER to less than 75 percent RATED THERMAL POWER within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. e. With the QUADRANT POWER TILT RATIO not monitored as required by Surveillance Requirement 4.2.4.1, reduce THERMAL POWER to less than 50 percent of RATED THERMAL POWER within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. SURVEILLANCE REQUIREMENTS 4.2.4.1 The QUADRANT POWER TILT RATIO shall be determined to be within the limit above 50% of RATED THERMAL POWER by:
a. Calculating the ratio at least once per 7 days when the alarm is OPERABLE.
b. Calculating the ratio at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady state operation when the alarm is inoperable.

4.2.4.2 The QUADRANT POWER TILT RATIO shall be determined to be within the limit when above 75 percent of RATED THERMAL POWER with one Power Range channel inoperable by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained from 4 pairs of symmetric thimble locations or from performance of a full core map, is consistent with the indicated QUADRANT POWER TILT RATIO at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

April 11, 2005 SEQUOYAH - UNIT 2 3/4 2-12 Amendment No. 122, 130, 290 L03L05L05L06Add proposed SR 3.2.4.1 Notes 1 and 2 LA01LA01LA02SR 3.2.4.1 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program L07Add proposed SR 3.2.4.2 Note SR 3.2.4.2 SR 3.2.4.2 NoteSR 3.2.4.2 L08Page 6 of 6 DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 1 of 9 ADMINISTRATIVE CHANGES A01 In the conversion of the Sequoyah Nuclear Plant (SQN) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG - 1431, Rev. 4.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS) and additional Technical Specification Task Force (TSTF) travelers included in this

submittal.

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS 3.2.4 states "The QUADRANT POWER TILT RATIO shall not exceed 1.02." ITS LCO 3.2.4 states "The QPTR shall be 1.02. This changes the CTS by requiring the QPTR to be less than or equal to 1.02.

This change is acceptable because nothing has changed. This is a presentation change for clarity. Stating that the QPTR shall be less than or equal to 1.02 is clearer than stating that it shall not exceed. This change is designated as an administrative change because it does not result in a technical change to the CTS.

A03 CTS 3.2.4 Applicability contains a footnote (footnote *) that states "See Special Test Exceptions 3.10.2." ITS 3.2.4 Applicability does not contain this footnote.

This changes the CTS by not including the footnote reference.

The purpose of CTS 3.2.4 footnote

  • is to alert the user that a Special Test Exception exists which may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as an administrative change since it does not result in a technical change to the CTS.

A04 CTS 3.2.4 ACTION a states "With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09." CTS 3.2.4 ACTION b states "With the QUADRANT POWER TILT RATIO determined to exceed 1.09 resulting from misalignment of either a shutdown or control rod." CTS 3.2.4 ACTION c states "With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod." ITS 3.2.4 ACTION A states "QPTR not within limit." This changes the CTS by specifying that action must be taken when the QPTR is not within limits. (See DOCS L02, L03, and L04 for changes to the compensatory

measures.)

The purpose of CTS 3.2.4 is to provide compensatory actions when the QPTR exceeds 1.02. ITS 3.2.4 continues to provide compensatory actions when the QPTR exceeds 1.02. This change is a presentation change. This change is designated as an administrative change since it does not result in technical changes to the CTS.

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 2 of 9 A05 CTS 3.2.4 ACTION a.1.a) states that with QPTR greater than 1.02 and less than or equal to 1.09, calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RTP. CTS 3.2.4 ACTION a.2.a) states within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, either QUADRANT POWER TILT RATIO is reduced to within its limit or reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. CTS 3.2.4 ACTION b.1.a) states that with QPTR greater than 1.09 due to misalignment of either a shutdown or control rod, calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within its limit or THEMAL POWER is reduced to less than 50% of RTP. CTS 3.2.4 ACTION c.1.a) states that with QPTR greater than 1.09 due to causes other than the misalignment of either a shutdown or control rod, calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RTP. ITS 3.2.4 does not contain a Required Action stating QPTR must be reduced to within its limit. This changes the CTS by not specifically stating that the restoration of QUADRANT POWER TILT RATIO is required.

This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as an administrative change since it does not result in technical changes to the CTS.

A06 CTS 3.2.4 LCO APPLICABLITY is MODE 1 above 50% RTP. CTS 3.2.4 ACTION a.1.b, ACTION b.1.b and ACTION c.1.b state, in part, to calculate the QUADRANT POWER TILT RATIO at least once per hour until either QUADRANT POWER TILT RATIO is reduced to within limit, or THERMAL POWER is reduced to less than 50% of RTP. ITS 3.2.4 LCO APPLICABILITY is MODE 1 with THERMAL POWER >50% RTP. ITS 3.2.4 CONDITION B states that when the Required Action and associated Completion Time are not met to reduce THERMAL POWER to 50% RTP. This changes the CTS requirement of reducing power and exiting the MODE of APPLICABILITY to a value of < 50%

RTP and allow stopping at a value of 50% RTP.

This change is acceptable because the technical requirements have not changed. LCO 3.0.2 states that that when a Required Action to restore variables within limits is not met, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. In this case, both CTS and ITS require a reduction of power to exit the MODE of APPLICABILITY when compliance with the LCO is not met within the prescribed amount of time. Once the MODE of APPLICABILITY for LCO 3.2.4 is exited(>50%), the new power level(50%) is no longer controlled by this specification. This change is designated as an administrative change since it does not result in technical changes to CTS LCO 3.2.4.

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 3 of 9 MORE RESTRICTIVE CHANGES M01 CTS 3.2.4 ACTION a.2.b states in part, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02. ITS 3.2.4 Required Action

A.1 has a similar requirement to reduce THERMAL POWER 3% from RTP for each 1% of QPTR > 1.02. The Completion Time for ITS 3.2.4 Required Action A.1 is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after each QPTR determination. This changes the CTS by specifically requiring a power reduction, if applicable, after each QPTR

determination.

The purpose CTS 3.2.4 ACTION a.2.b is to commence a power level reduction to ensure that core power distributions that violate fuel design criteria are minimized. The maximum allowable power level initially determined by ITS 3.2.4 Required Action A.1 may be affected by subsequent determinations of QPTR.

However, any increases in QPTR would require additional power reductions within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of each QPTR determination, if necessary to comply with the decreased maximum allowable power level. This change is designated as more restrictive because it adds required actions to the CTS.

RELOCATED SPECIFICATIONS

None

REMOVED DETAIL CHANGES

LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) CTS 4.2.4.1 states, in part, the QPTR shall be determined at least once per 7 days by calculating the ratio. CTS 4.2.4.2 states, in part, the QPTR shall be determined, at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, by using the movable incore detectors. ITS SR 3.2.4.1 and SR 3.2.4.2 require similar Surveillances and specify the periodic Frequencies as, "In accordance with the Surveillance Frequency Control Program." This changes the CTS by moving the specified Frequencies for these SRs and associated Bases to the Surveillance Frequency Control Program.

The removal of these details related to Surveillance Requirement Frequencies from the Technical Specifications is acceptable, because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. The existing Surveillance Frequencies are removed from Technical Specifications and placed under licensee control pursuant to the methodology described in NEI 04-10. A new program (Surveillance Frequency Control Program) is being added to the Administrative Controls section of the Technical Specifications describing the control of Surveillance Frequencies. The surveillance test requirements remain in the Technical Specifications. The control of changes to the Surveillance Frequencies will be in accordance with the Surveillance Frequency Control Program. The Program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 4 of 9 associated Limiting Conditions for Operation are met. This change is designated as a less restrictive removal of detail change, because the Surveillance Frequencies are being removed from the Technical Specifications.

LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained from the 4 pairs of

symmetric thimble locations or from performance of a full core map, is consistent with the indicated QUADRANT POWER TILT RATIO. ITS SR 3.2.4.2 requires verifying QPTR is within limit using the movable incore detectors. This changes the CTS by moving the procedural details for meeting the Surveillance to the Bases.

The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide protection of public health and safety. The ITS still retains the requirement that the QPTR is verified to be within the limits using the movable incore detectors. The details relating to system design do not need to appear in the specification in order for the requirement to apply. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES

L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.4 ACTIONS a.1, b.1, and c.1 require calculating the QPTR at least once per hour. ITS 3.2.4 ACTION A (Required Action A.2 and associated Completion Time) require, in part, that when the QPTR is not within limit to determine QPTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by requiring the determination of QPTR to be done once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> instead of once per hour.

The purpose of CTS 3.2.4 ACTIONS a.1, b.1, and c.1 is to verify QPTR until it is brought to within limit or reactor power has been lowered to less than or equal to 50% RTP. This action is taken because with the QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters

such as F Q (X, Y, Z) and FH (X,Y) may not be within their limits. In addition to ITS 3.2.4 Required Action A.2 Completion Time the other Required Actions and associated Completion Times of Condition A are consistent with safe operation, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. In addition to reducing reactor power by greater than or equal to 3% for each 1% QPTR exceeds 1.02, ITS 3.2.4 requires a determination of QPTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Additionally, ITS 3.2.4 requires DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 5 of 9 measurement of F Q (X, Y, Z) and FH (X,Y) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and every 7 days thereafter to verify that those parameters are within limit. Furthermore, ITS 3.2.4 requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, ITS 3.2.4 allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures the core is operated within the safety analyses. This change is designated as less restrictive because less stringent Completion Times are being applied in the ITS than were applied in

the CTS.

L02 (Category 4 - Relaxation of Required Action) CTS 3.2.4 ACTION a.2.b) requires that when QPTR is in excess of 1.02 but less than or equal to 1.09, to reduce THERMAL POWER at least 3% from RATED THERMAL POWER for each 1% of indicated QUADRANT POWER TILT RATIO in excess of 1.02 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.4 Required Action A.1 includes the requirement to reduce the THERMAL POWER, but does not include a requirement to reduce the Power Range Neutron Flux-High Trip Setpoints. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux-High Trip Setpoints.

The purpose of CTS 3.2.4 ACTION a.2.b) is to reduce THERMAL POWER to increase the margin to the core power distribution limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. With THERMAL POWER reduced by 3% from RTP for each 1% QPTR is greater than 1.02, further actions are not required to ensure that THERMAL POWER is not increased. Power increases are administratively prohibited by the Technical Specification while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS. L03 (Category 4 - Relaxation of Required Action) CTS 3.2.4 ACTION a.3 states "Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />." CTS 3.2.4 ACTION b.3 and b.4 contain the same compensatory actions as CTS ACTION a.3 but requires the QPTR to be within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. CTS 3.2.4 ACTIONS a.4, b.4, and c.3 state "Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL power may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified acceptable at 95% or greater RATED THERMAL POWER."

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 6 of 9 ITS 3.2.4 Required Action A.3 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.1.3, SR 3.2.2.1, SR 3.2.2.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 and once per 7 days thereafter. ITS 3.2.4 Required Action A.4 requires reevaluation of the safety analyses and confirmation that the results remain valid for duration of operation under this condition prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.5 requires normalization of excore detectors to restore QPTR to within limit prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.6 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.1.3, SR 3.2.2.1, SR 3.2.2.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after increasing THERMAL POWER above the limit of Required Action A.1. Additionally, ITS 3.2.4 Required Action A.5 contains two Notes and ITS 3.2.4 Required Action A.6 contains one Note. ITS 3.2.4 Required Action A.5 Note 1 states "Perform Required Action A.5 only after Required Action A.4 is completed." ITS 3.2.4 Required Action A.5 Note 2 states "Required Action A.6 shall be completed whenever Required Action A.5 is performed." ITS 3.2.4 Required Action A.6 Note states "Perform Required Action A.6 only after Required Action A.5 is completed." Furthermore, ITS 3.2.4 ACTION B states that with a Required Action and associated Completion Time (of

Condition A) not met, reduce THERMAL POWER to 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This changes the CTS by eliminating requirements to be 50% RTP within a specified time of exceeding the LCO and substituting compensatory measures in ITS 3.2.4 ACTION A, which if not met, results in a reduction in power per ITS 3.2.4 ACTION B.

The purpose of the CTS actions is to lower reactor power to less than 50% when QPTR is not within its limit and cannot be restored to within its limit within a reasonable time period. In addition, the Power Range Neutron Flux-High Trip setpoints are reduced to 55% to ensure that reactor power is not inadvertently increased without QPTR within its limit. This action is taken because with QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters such as F Q (X, Y, Z) and FH (X,Y) may not be within their limits. A QPTR not within limit may not be an unacceptable condition if the critical core parameters such as F Q (X, Y, Z) and FH (X,Y) are within their limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. ITS 3.2.4 requires measurement of FQ (X, Y, Z) and FH (X,Y) within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and every 7 days thereafter to verify that those parameters are within limit. In addition, ITS 3.2.4 requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, ITS 3.2.4 allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures the core is operated within the safety analyses. This change is designated as less restrictive because less DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 7 of 9 stringent Required Actions are being applied in the ITS than were applied in the CTS.

L04 (Category 3 - Relaxation of Completion Time) CTS 3.2.4 ACTION b.2, applies when QPTR is greater than 1.09 due to misalignment of either a shutdown or control rod, requires a THERMAL POWER reduction from RATED THERMAL POWER for each 1% of indicated QPTR in excess of 1.02 within 30 minutes. ITS 3.2.4 Required Action A.1 requires a THERMAL POWER reduction of 3%

from RTP for each 1% QPTR exceeds 1.02 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This changes the CTS by allowing 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform the required power reduction.

The purpose of CTS 3.2.4 is to provide appropriate compensatory actions for QPTR greater than that assumed in the safety analyses. This change is acceptable because the completion Time is consistent with safe operation under the specified Condition, considering other indications available to the operator, a reasonable time for restoring compliance with the LCO, and the low probability of a DBA occurring during the restoration period. Under the ITS, a QPTR of 1.09 would require THERMAL POWER to be reduced to 79% RTP. This will provide sufficient thermal margin to account for the radial power distribution. In addition, the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> time limit is consistent with the CTS time allowed when QPTR is

> 1.02 but 1.09. This change is designated as less restrictive because additional time is allowed to decrease power than was allowed in the CTS.

L05 (Category 4 - Relaxation of Required Action) CTS 3.2.4 ACTION d states "With the indicated QUADRANT POWER TILT RATIO not confirmed as required by Surveillance Requirement 4.2.4.2, reduce THERMAL POWER to less than 75

percent RATED THERMAL POWER within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." CTS 3.2.4 ACTION e states "With the QUADRANT POWER TILT RATIO not monitored as required by Surveillance Requirement 4.2.4.1, reduce THERMAL POWER to less than 50 percent of RATED THERMAL POWER within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." ITS 3.2.4 does not contain these ACTIONS. This changes the CTS by not requiring RTP to be reduced to less than 75 percent, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, when the QPTR is not confirmed and not requiring RTP to be reduced to less than 50 percent, within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, when the QPTR is not monitored.

The purpose of CTS 3.2.4 ACTIONs d and e is to provide compensatory actions to take when Surveillance 4.2.4.1 has not been met or Surveillance 4.2.4.2 have not been performed. ITS 3.2.4 does not contain these ACTIONS since ITS SR 3.0.1 and SR 3.0.3 provide guidance on missed and not performed Surveillances. ITS SR 3.0.1 states, in part, that failure to meet a Surveillance is a failure to meet the LCO. Therefore, the compensatory actions for ITS LCO 3.2.4 would be entered. Additionally, ITS SR 3.0.1 states, in part, that failure to perform a Surveillance shall be failure to meet the LCO, but allows an exception as provided in SR 3.0.3. ITS SR 3.0.3 allows a delayed entry into the LCO to perform the Surveillance. If the Surveillance is not performed in this time period, then the LCO must be declared not met and the compensatory actions for ITS LCO 3.2.4 entered. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.

DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 8 of 9 L06 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.2.4.1.a states, in part, that the QPTR shall be determined to be within the limit by calculating the ratio at least once per 7 days. ITS SR 3.2.4.1 requires the same determination, but includes two Notes. ITS SR 3.2.4.1 Note 1 states when the input from one Power Range Neutron Flux channel is inoperable, the remaining three power range channels can be used for calculating QPTR as long as THERMAL POWER is less than or equal to 75% RTP. ITS SR 3.2.4.1 Note 2 states that SR 3.2.4.2 may be performed in lieu of this Surveillance. This changes the CTS by allowing use of three Power Range Neutron Flux channels for calculating the QPTR and by allowing the movable incore detectors to be used to determine QPTR instead of the excore detectors.

The purpose of CTS 4.2.4.1.a is to periodically verify that QPTR is within limit. This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are sufficient for verification that the parameters meet the LCO. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. With only one Power Range Neutron Flux channel inoperable, QPTR can still be verified by calculation as long as three Power Range Neutron Flux channels are OPERABLE and THERMAL POWER is less than or equal to 75% RTP. The movable incore detector system provides a more accurate indication of QPTR than the excore detectors. In fact, the movable incore detector system is used to calibrate the excore detectors. Therefore, allowing the use of the movable incore detector system or excore detector is appropriate. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

L07 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.2.4.1.a states that the QPTR shall be determined to be within the limit by calculating the ratio at least once per 7 days when the alarm is OPERABLE.

CTS 4.2.4.1.b states that the QPTR shall be determined to be within the limit by calculating the ratio at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady state operation when the alarm is inoperable. ITS SR 3.2.4.1 requires verification that the QPTR is within limits every 7 days. This changes the CTS by eliminating the requirement to verify the QPTR more frequently when the QPTR alarm is inoperable.

The purpose of CTS 4.2.4.1.a and 4.2.4.1.b is to periodically verify that the QPTR is within limit. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the frequency of QPTR verification when the QPTR alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that the QPTR is outside its limit. The QPTR alarm is for indication only. It use is not credited in any of the safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.

L08 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)

CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit when above 75 percent of RATED THERMAL POWER with one Power Range Channel inoperable by using the movable incore detectors. ITS DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 9 of 9 SR 3.2.4.2 requires determination of the QPTR by use of the movable incore detectors. Additionally, ITS SR 3.2.4.2 contains a Note which states "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER

> 75% RTP." This changes the CTS by not requiring the Surveillance to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range Neutron Flux channels are inoperable.

The purpose of CTS 4.2.4.2 is to verify that the QPTR is within limit using the movable incore detectors. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. Therefore, the movable incore detector system provides a more accurate indication of QPTR than the excore detectors. The ITS SR 3.2.4.2 allowance, for not requiring performance of the Surveillance for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input when one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER > 75% RTP, is required to allow time for the movable incore detectors to perform the initial measurement of the QPTR before the Surveillance is declared not met. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

QPTR 3.2.4 Westinghouse STS 3.2.4-1 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 1 23.2 POWER DISTRIBUTION LIMITS

3.2.4 QUADRANT POWER TILT RATIO (QPTR)

LCO 3.2.4 The QPTR shall be 1.02.

APPLICABILITY: MODE 1 with THERMAL POWER > 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. QPTR not within limit.

A.1 Reduce THERMAL POWER 3% from RTP for each 1% of QPTR > 1.00. AND A.2 Determine QPTR.

AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

AND 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after each QPTR determination

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from a

THERMAL POWER reduction per

Required Action A.1

AND Once per 7 days

thereafter 3.2.4 Applicabilit y ACTION a, ACTION b, ACTION c DOC M01 121.02SR 3.2.1.3, SR 3.2.2.1 and SR 3.2.2.2.

DOC L03 QPTR 3.2.4 Westinghouse STS 3.2.4-2 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 1 2ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.4 Reevaluate safety analyses and confirm results remain valid for duration of operation under this condition.

AND A.5 -------------NOTES------------- 1. Perform Required Action A.5 only after

Required Action A.4 is

completed.

2. Required Action A.6 shall be completed whenever Required

Action A.5 is performed. -------------------------------------

Normalize excore detectors to restore QPTR to within limit.

AND A.6 ---------------NOTE--------------

Perform Required Action A.6 only after Required Action A.5 is completed. -------------------------------------

Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

Prior to increasing

THERMAL POWER

above the limit of Required Action A.1

Prior to increasing

THERMAL POWER

above the limit of

Required Action A.1

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after increasing THERMAL

POWER above the limit

of Required Action A.1 DOC L03 1SR 3.2.1.3, SR 3.2.2.1 and SR 3.2.2.2.

DOC L03 DOC L03 QPTR 3.2.4 Westinghouse STS 3.2.4-3 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 1 2ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to 50% RTP.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.2.4.1 ------------------------------NOTES-----------------------------

1. With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channels can be used for calculating QPTR.
2. SR 3.2.4.2 may be performed in lieu of this Surveillance. ---------------------------------------------------------------------

Verify QPTR is within limit by calculation.

[ 7 days OR In accordance

with the Surveillance Frequency

Control Program

] ACTION a, ACTION b, ACTION c 4.2.4.1 DOC L06 33 QPTR 3.2.4 Westinghouse STS 3.2.4-4 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 1 2SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.4.2 -------------------------------NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER

> 75% RTP. ---------------------------------------------------------------------

Verify QPTR is within limit using the movable incore detectors.

[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance

with the

Surveillance

Frequency Control Program

] 334.2.4.2, DOC L08 QPTR 3.2.4 Westinghouse STS 3.2.4-1 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 2 23.2 POWER DISTRIBUTION LIMITS

3.2.4 QUADRANT POWER TILT RATIO (QPTR)

LCO 3.2.4 The QPTR shall be 1.02.

APPLICABILITY: MODE 1 with THERMAL POWER > 50% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. QPTR not within limit.

A.1 Reduce THERMAL POWER 3% from RTP for each 1% of QPTR > 1.00. AND A.2 Determine QPTR.

AND A.3 Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

AND 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after each QPTR determination

Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from a

THERMAL POWER reduction per

Required Action A.1

AND Once per 7 days

thereafter 3.2.4 Applicabilit y ACTION a, ACTION b, ACTION c DOC M01 121.02SR 3.2.1.3, SR 3.2.2.1 and SR 3.2.2.2.

DOC L03 QPTR 3.2.4 Westinghouse STS 3.2.4-2 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 2 2ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.4 Reevaluate safety analyses and confirm results remain valid for duration of operation under this condition.

AND A.5 -------------NOTES------------- 1. Perform Required Action A.5 only after

Required Action A.4 is

completed.

2. Required Action A.6 shall be completed whenever Required

Action A.5 is performed. -------------------------------------

Normalize excore detectors to restore QPTR to within limit.

AND A.6 ---------------NOTE--------------

Perform Required Action A.6 only after Required Action A.5 is completed. -------------------------------------

Perform SR 3.2.1.1, SR 3.2.1.2, and SR 3.2.2.1.

Prior to increasing

THERMAL POWER

above the limit of Required Action A.1

Prior to increasing

THERMAL POWER

above the limit of

Required Action A.1

Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after increasing THERMAL

POWER above the limit

of Required Action A.1 DOC L03 1SR 3.2.1.3, SR 3.2.2.1 and SR 3.2.2.2.

DOC L03 DOC L03 QPTR 3.2.4 Westinghouse STS 3.2.4-3 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 2 2ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to 50% RTP.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.2.4.1 ------------------------------NOTES-----------------------------

1. With input from one Power Range Neutron Flux channel inoperable and THERMAL POWER 75% RTP, the remaining three power range channels can be used for calculating QPTR.
2. SR 3.2.4.2 may be performed in lieu of this Surveillance. ---------------------------------------------------------------------

Verify QPTR is within limit by calculation.

[ 7 days OR In accordance

with the Surveillance Frequency

Control Program

] ACTION a, ACTION b, ACTION c 4.2.4.1 DOC L06 33 QPTR 3.2.4 Westinghouse STS 3.2.4-4 Rev. 4.0 CTS Amendment XXX SEQUOYAH UNIT 2 2SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.4.2 -------------------------------NOTE------------------------------

Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER

> 75% RTP. ---------------------------------------------------------------------

Verify QPTR is within limit using the movable incore detectors.

[ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance

with the

Surveillance

Frequency Control Program

] 334.2.4.2, DOC L08 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made to be consistent with changes made to Specification 3.2.1 and 3.2.2. 2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

3. ISTS SR 3.2.4.1 and SR 3.2.4.2 provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.

Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

QPTR B 3.2.4 Westinghouse STS B 3.2.4-1 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 1 B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

BASES BACKGROUND The QPTR limit ensures that the gross radial power distribution remains consistent with the design values used in the safety analyses. Precise radial power distribution measurements are made during startup testing, after refueling, and periodically during power operation.

The power density at any point in the core must be limited so that the fuel design criteria are maintained. Together, LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, and LCO 3.1.6, "Control Rod Insertion Limits," provide limits on process variables that characterize and control the three dimensional power distribution of the reactor core. Control of these variables ensures that the core operates within the fuel design criteria and that the power distribution remains within the bounds used in

the safety analyses.

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

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

b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 departure from nucleate boiling (DNB) criterion) that the hot fuel rod in the core does not experience a DNB condition,
c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (Ref. 3).

The LCO limits on the AFD, the QPTR, the Heat Flux Hot Channel Factor (FQ(Z)), the Nuclear Enthalpy Rise Hot Channel Factor

)F(HN, and control bank insertion are established to preclude core power distributions that exceed the safety analyses limits.

The QPTR limits ensure that HNF and FQ(Z) remain below their limiting values by preventing an undetected change in the gross radial power distribution. X, Y, (FH(X, Y)) X, Y, FH(X, Y) 111 QPTR B 3.2.4 Westinghouse STS B 3.2.4-2 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 1 BASES

APPLICABLE SAFETY ANALYSES (continued)

In MODE 1, the HNF and FQ(Z) limits must be maintained to preclude core power distributions from exceeding design limits assumed in the safety analyses.

The QPTR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The QPTR limit of 1.02, at which corrective action is required, provides a margin of protection for both the DNB ratio and linear heat generation rate contributing to excessive power peaks resulting from X-Y plane power tilts. A limiting QPTR of 1.02 can be tolerated before the margin for uncertainty in F Q(Z) and )F(HN is possibly challenged.

APPLICABILITY The QPTR limit must be maintained in MODE 1 with THERMAL POWER > 50% RTP to prevent core power distributions from exceeding the design limits. Applicability in MODE 1 50% RTP and in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require the implementation of a QPTR limit on the distribution of core power. The QPTR limit in these conditions is, therefore, not important. Note that the HNF and FQ(Z) LCOs still apply, but allow progressively higher peaking factors at 50% RTP or lower.

ACTIONS A.1 With the QPTR exceeding its limit, a power level reduction of 3% RTP for each 1% by which the QPTR exceeds 1.00 is a conservative tradeoff of total core power with peak linear power. The Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allows sufficient time to identify the cause and correct the tilt. Note that the power reduction itself may cause a change in the tilted condition.

The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of QPTR.

Increases in QPTR would require power reduction within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of QPTR determination, if necessary to comply with the decreased maximum allowable power level. Decreases in QPTR would allow increasing the maximum allowable power level and increasing power up to this revised limit.

X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111.021 QPTR B 3.2.4 Westinghouse STS B 3.2.4-3 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 1 BASES

ACTIONS (continued)

A.2 After completion of Required Action A.1, the QPTR alarm may still be in its alarmed state. As such, any additional changes in the QPTR are detected by requiring a check of the QPTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is sufficient because any additional change in QPTR would be relatively slow.

A.3 The peaking factors F Q(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are of primary importance in ensuring that the power distribution remains consistent with the initial conditions used in the safety analyses. Performing SRs on HNF and FQ(Z) within the Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from a Thermal Power reduction per Required Action A.1 ensures that these primary indicators of power distribution are within their respective limits. Equilibrium conditions are achieved when the core is sufficiently stable at intended operating conditions to support flux mapping. A Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from Thermal Power reduction per Required Action A.1 takes into consideration the rate at which peaking factors are likely to change, and the time required to stabilize the plant and perform a flux map. If these peaking factors are not within their limits, the Required Actions of these Surveillances provide an appropriate response for the abnormal condition. If the QPTR remains above its specified limit, the peaking factor surveillances are required each 7 days thereafter to evaluate HNF and FQ(Z) with changes in power distribution. Relatively small changes are expected due to either burnup and xenon redistribution or correction of the cause for exceeding the

QPTR limit.

A.4 Although HNF and FQ(Z) are of primary importance as initial conditions in the safety analyses, other changes in the power distribution may occur as the QPTR limit is exceeded and may have an impact on the validity of the safety analysis. A change in the power distribution can affect such reactor parameters as bank worths and peaking factors for rod X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111 the applicable LCOs 3 QPTR B 3.2.4 Westinghouse STS B 3.2.4-4 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 1 BASES

ACTIONS (continued)

malfunction accidents. When the QPTR exceeds its limit, it does not necessarily mean a safety concern exists. It does mean that there is an indication of a change in the gross radial power distribution that requires an investigation and evaluation that is accomplished by examining the incore power distribution. Specifically, the core peaking factors and the quadrant tilt must be evaluated because they are the factors that best characterize the core power distribution. This re-evaluation is required to ensure that, before increasing THERMAL POWER to above the limit of Required Action A.1, the reactor core conditions are consistent with the assumptions in the safety analyses.

A.5 If the QPTR has exceeded the 1.02 limit and a re-evaluation of the safety analysis is completed and shows that safety requirements are met, the

excore detectors are normalized to restore QPTR to within limits prior to increasing THERMAL POWER to above the limit of Required Action A.1.

Normalization is accomplished in such a manner that the indicated QPTR following normalization is near 1.00. This is done to detect any subsequent significant changes in QPTR.

Required Action A.5 is modified by two Notes. Note 1 states that the QPTR is not restored to within limits until after the re-evaluation of the safety analysis has determined that core conditions at RTP are within the safety analysis assumptions (i.e., Required Action A.4). Note 2 states that if Required Action A.5 is performed, then Required Action A.6 shall be performed. Required Action A.5 normalizes the excore detectors to restore QPTR to within limits, which restores compliance with LCO 3.2.4. Thus, Note 2 prevents exiting the Actions prior to completing flux mapping to verify peaking factors, per Required Action A.6. These Notes are intended to prevent any ambiguity about the required sequence of actions.

A.6 Once the flux tilt is restored to within limits (i.e., Required Action A.5 is performed), it is acceptable to return to full power operation. However, as an added check that the core power distribution is consistent with the safety analysis assumptions, Required Action A.6 requires verification 11.02is still exceedingshall be shall not be by excore detector normalization 266 QPTR B 3.2.4 Westinghouse STS B 3.2.4-5 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 1 BASES

ACTIONS (continued) that FQ(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are within their specified limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of achieving equilibrium conditions at RTP. As an added precaution, if the core power does not reach equilibrium conditions at RTP within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but is increased slowly, then the peaking factor surveillances must be performed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after increasing THERMAL POWER abov e the limit of Required Action A.1. These Completion Times are intended to allow adequate time to increase THERMAL POWER to above the limit of Required Action A.1, while not permitting the core to remain with unconfirmed power distributions for extended periods of time.

Required Action A.6 is modified by a Note that states that the peaking factor surveillances may only be done after the excore detectors have been normalized to restore QPTR to within limits (i.e., Required Action A.5). The intent of this Note is to have the peaking factor surveillances performed at operating power levels, which can only be accomplished after the excore detectors are normalized to restore QPTR to within limits and the core returned to power.

B.1 If Required Actions A.1 through A.6 are not completed within their associated Completion Times, the unit must be brought to a MODE or condition in which the requirements do not apply. To achieve this status, THERMAL POWER must be reduced to

< 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is reasonable, based on operating experience regarding the amount of time required to reach the reduced power level without challenging plant systems.

SURVEILLANCE SR 3.2.4.1 REQUIREMENTS SR 3.2.4.1 is modified by two Notes. Note 1 allows QPTR to be calculated with three power range channels if THERMAL POWER is 75% RTP and the input from one Power Range Neutron Flux channel is inoperable. Note 2 allows performance of SR 3.2.4.2 in lieu of

SR 3.2.4.1.

This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits.

[ The Frequency of 7 days takes into account other information and alarms available to the operator in the control room.

41X, Y, FH(X, Y) 1 QPTR B 3.2.4 Westinghouse STS B 3.2.4-6 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 1 BASES SURVEILLANCE REQUIREMENTS (continued)

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] For those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.

SR 3.2.4.2 This Surveillance is modified by a Note, which states that it is not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the input from one or more Power Range Neutron Flux channels are inoperable and the THERMAL POWER is > 75% RTP.

With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased.

[ Performing SR 3.2.4.2 at a Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides an accurate alternative means for ensuring that any tilt remains within its limits.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

4544544QPTR6 QPTR B 3.2.4 Westinghouse STS B 3.2.4-7 Rev. 4.0 2Revision XXXSEQUOYAH UNIT 1 BASES SURVEILLANCE REQUIREMENTS (continued)

For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and four loop cores

.

The symmetric thimble flux map can be used to generate symmetric thimble "tilt." This can be compared to a reference symmetric thimble tilt, from the most recent full core flux map, to generate an incore QPTR. Therefore, incore monitoring of QPTR can be used to confirm that QPTR

is within limits.

With one NIS channel inoperable, the indicated tilt may be changed from the value indicated with all four channels OPERABLE. To confirm that no change in tilt has actually occurred, which might cause the QPTR limit to be exceeded, the incore result may be compared against previous flux maps either using the symmetric thimbles as described above or a complete flux map. Nominally, quadrant tilt from the Surveillance should be within 2% of the tilt shown by the most recent flux map data.

REFERENCES 1. 10 CFR 50.46.

2. Regulatory Guide 1.77, Rev

[0], May 1974.

3. 10 CFR 50, Appendix A, GDC 26.

22 QPTR B 3.2.4 Westinghouse STS B 3.2.4-1 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 2 B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.4 QUADRANT POWER TILT RATIO (QPTR)

BASES BACKGROUND The QPTR limit ensures that the gross radial power distribution remains consistent with the design values used in the safety analyses. Precise radial power distribution measurements are made during startup testing, after refueling, and periodically during power operation.

The power density at any point in the core must be limited so that the fuel design criteria are maintained. Together, LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," LCO 3.2.4, and LCO 3.1.6, "Control Rod Insertion Limits," provide limits on process variables that characterize and control the three dimensional power distribution of the reactor core. Control of these variables ensures that the core operates within the fuel design criteria and that the power distribution remains within the bounds used in

the safety analyses.

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

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

b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 departure from nucleate boiling (DNB) criterion) that the hot fuel rod in the core does not experience a DNB condition,
c. During an ejected rod accident, the energy deposition to the fuel must not exceed 280 cal/gm (Ref. 2), and
d. The control rods must be capable of shutting down the reactor with a minimum required SDM with the highest worth control rod stuck fully withdrawn (Ref. 3).

The LCO limits on the AFD, the QPTR, the Heat Flux Hot Channel Factor (FQ(Z)), the Nuclear Enthalpy Rise Hot Channel Factor

)F(HN, and control bank insertion are established to preclude core power distributions that exceed the safety analyses limits.

The QPTR limits ensure that HNF and FQ(Z) remain below their limiting values by preventing an undetected change in the gross radial power distribution. X, Y, (FH(X, Y)) X, Y, FH(X, Y) 111 QPTR B 3.2.4 Westinghouse STS B 3.2.4-2 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 2 BASES

APPLICABLE SAFETY ANALYSES (continued)

In MODE 1, the HNF and FQ(Z) limits must be maintained to preclude core power distributions from exceeding design limits assumed in the safety analyses.

The QPTR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The QPTR limit of 1.02, at which corrective action is required, provides a margin of protection for both the DNB ratio and linear heat generation rate contributing to excessive power peaks resulting from X-Y plane power tilts. A limiting QPTR of 1.02 can be tolerated before the margin for uncertainty in F Q(Z) and )F(HN is possibly challenged.

APPLICABILITY The QPTR limit must be maintained in MODE 1 with THERMAL POWER > 50% RTP to prevent core power distributions from exceeding the design limits. Applicability in MODE 1 50% RTP and in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require the implementation of a QPTR limit on the distribution of core power. The QPTR limit in these conditions is, therefore, not important. Note that the HNF and FQ(Z) LCOs still apply, but allow progressively higher peaking factors at 50% RTP or lower.

ACTIONS A.1 With the QPTR exceeding its limit, a power level reduction of 3% RTP for each 1% by which the QPTR exceeds 1.00 is a conservative tradeoff of total core power with peak linear power. The Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allows sufficient time to identify the cause and correct the tilt. Note that the power reduction itself may cause a change in the tilted condition.

The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of QPTR.

Increases in QPTR would require power reduction within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of QPTR determination, if necessary to comply with the decreased maximum allowable power level. Decreases in QPTR would allow increasing the maximum allowable power level and increasing power up to this revised limit.

X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111.021 QPTR B 3.2.4 Westinghouse STS B 3.2.4-3 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 2 BASES

ACTIONS (continued)

A.2 After completion of Required Action A.1, the QPTR alarm may still be in its alarmed state. As such, any additional changes in the QPTR are detected by requiring a check of the QPTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.

A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is sufficient because any additional change in QPTR would be relatively slow.

A.3 The peaking factors F Q(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are of primary importance in ensuring that the power distribution remains consistent with the initial conditions used in the safety analyses. Performing SRs on HNF and FQ(Z) within the Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from a Thermal Power reduction per Required Action A.1 ensures that these primary indicators of power distribution are within their respective limits. Equilibrium conditions are achieved when the core is sufficiently stable at intended operating conditions to support flux mapping. A Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from Thermal Power reduction per Required Action A.1 takes into consideration the rate at which peaking factors are likely to change, and the time required to stabilize the plant and perform a flux map. If these peaking factors are not within their limits, the Required Actions of these Surveillances provide an appropriate response for the abnormal condition. If the QPTR remains above its specified limit, the peaking factor surveillances are required each 7 days thereafter to evaluate HNF and FQ(Z) with changes in power distribution. Relatively small changes are expected due to either burnup and xenon redistribution or correction of the cause for exceeding the

QPTR limit.

A.4 Although HNF and FQ(Z) are of primary importance as initial conditions in the safety analyses, other changes in the power distribution may occur as the QPTR limit is exceeded and may have an impact on the validity of the safety analysis. A change in the power distribution can affect such reactor parameters as bank worths and peaking factors for rod X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) X, Y, FH(X, Y) 1111 the applicable LCOs 3 QPTR B 3.2.4 Westinghouse STS B 3.2.4-4 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 2 BASES

ACTIONS (continued)

malfunction accidents. When the QPTR exceeds its limit, it does not necessarily mean a safety concern exists. It does mean that there is an indication of a change in the gross radial power distribution that requires an investigation and evaluation that is accomplished by examining the incore power distribution. Specifically, the core peaking factors and the quadrant tilt must be evaluated because they are the factors that best characterize the core power distribution. This re-evaluation is required to ensure that, before increasing THERMAL POWER to above the limit of Required Action A.1, the reactor core conditions are consistent with the assumptions in the safety analyses.

A.5 If the QPTR has exceeded the 1.02 limit and a re-evaluation of the safety analysis is completed and shows that safety requirements are met, the

excore detectors are normalized to restore QPTR to within limits prior to increasing THERMAL POWER to above the limit of Required Action A.1.

Normalization is accomplished in such a manner that the indicated QPTR following normalization is near 1.00. This is done to detect any subsequent significant changes in QPTR.

Required Action A.5 is modified by two Notes. Note 1 states that the QPTR is not restored to within limits until after the re-evaluation of the safety analysis has determined that core conditions at RTP are within the safety analysis assumptions (i.e., Required Action A.4). Note 2 states that if Required Action A.5 is performed, then Required Action A.6 shall be performed. Required Action A.5 normalizes the excore detectors to restore QPTR to within limits, which restores compliance with LCO 3.2.4. Thus, Note 2 prevents exiting the Actions prior to completing flux mapping to verify peaking factors, per Required Action A.6. These Notes are intended to prevent any ambiguity about the required sequence of actions.

A.6 Once the flux tilt is restored to within limits (i.e., Required Action A.5 is performed), it is acceptable to return to full power operation. However, as an added check that the core power distribution is consistent with the safety analysis assumptions, Required Action A.6 requires verification 11.02is still exceedingshall be shall not be by excore detector normalization 266 QPTR B 3.2.4 Westinghouse STS B 3.2.4-5 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 2 BASES

ACTIONS (continued) that FQ(Z), as approximated by )Z(FCQ and )Z(FWQ, and HNF are within their specified limits within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of achieving equilibrium conditions at RTP. As an added precaution, if the core power does not reach equilibrium conditions at RTP within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, but is increased slowly, then the peaking factor surveillances must be performed within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after increasing THERMAL POWER abov e the limit of Required Action A.1. These Completion Times are intended to allow adequate time to increase THERMAL POWER to above the limit of Required Action A.1, while not permitting the core to remain with unconfirmed power distributions for extended periods of time.

Required Action A.6 is modified by a Note that states that the peaking factor surveillances may only be done after the excore detectors have been normalized to restore QPTR to within limits (i.e., Required Action A.5). The intent of this Note is to have the peaking factor surveillances performed at operating power levels, which can only be accomplished after the excore detectors are normalized to restore QPTR to within limits and the core returned to power.

B.1 If Required Actions A.1 through A.6 are not completed within their associated Completion Times, the unit must be brought to a MODE or condition in which the requirements do not apply. To achieve this status, THERMAL POWER must be reduced to

< 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is reasonable, based on operating experience regarding the amount of time required to reach the reduced power level without challenging plant systems.

SURVEILLANCE SR 3.2.4.1 REQUIREMENTS SR 3.2.4.1 is modified by two Notes. Note 1 allows QPTR to be calculated with three power range channels if THERMAL POWER is 75% RTP and the input from one Power Range Neutron Flux channel is inoperable. Note 2 allows performance of SR 3.2.4.2 in lieu of

SR 3.2.4.1.

This Surveillance verifies that the QPTR, as indicated by the Nuclear Instrumentation System (NIS) excore channels, is within its limits.

[ The Frequency of 7 days takes into account other information and alarms available to the operator in the control room.

41X, Y, FH(X, Y) 1 QPTR B 3.2.4 Westinghouse STS B 3.2.4-6 Rev. 4.0 2Revision XXX SEQUOYAH UNIT 2 BASES SURVEILLANCE REQUIREMENTS (continued)

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

] For those causes of QPT that occur quickly (e.g., a dropped rod), there typically are other indications of abnormality that prompt a verification of core power tilt.

SR 3.2.4.2 This Surveillance is modified by a Note, which states that it is not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the input from one or more Power Range Neutron Flux channels are inoperable and the THERMAL POWER is > 75% RTP.

With an NIS power range channel inoperable, tilt monitoring for a portion of the reactor core becomes degraded. Large tilts are likely detected with the remaining channels, but the capability for detection of small power tilts in some quadrants is decreased.

[ Performing SR 3.2.4.2 at a Frequency of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides an accurate alternative means for ensuring that any tilt remains within its limits.

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

REVIEWER'S NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

4544544QPTR6 QPTR B 3.2.4 Westinghouse STS B 3.2.4-7 Rev. 4.0 2Revision XXXSEQUOYAH UNIT 2 BASES SURVEILLANCE REQUIREMENTS (continued)

For purposes of monitoring the QPTR when one power range channel is inoperable, the moveable incore detectors are used to confirm that the normalized symmetric power distribution is consistent with the indicated QPTR and any previous data indicating a tilt. The incore detector monitoring is performed with a full incore flux map or two sets of four thimble locations with quarter core symmetry. The two sets of four symmetric thimbles is a set of eight unique detector locations. These locations are C-8, E-5, E-11, H-3, H-13, L-5, L-11, and N-8 for three and four loop cores

.

The symmetric thimble flux map can be used to generate symmetric thimble "tilt." This can be compared to a reference symmetric thimble tilt, from the most recent full core flux map, to generate an incore QPTR. Therefore, incore monitoring of QPTR can be used to confirm that QPTR

is within limits.

With one NIS channel inoperable, the indicated tilt may be changed from the value indicated with all four channels OPERABLE. To confirm that no change in tilt has actually occurred, which might cause the QPTR limit to be exceeded, the incore result may be compared against previous flux maps either using the symmetric thimbles as described above or a complete flux map. Nominally, quadrant tilt from the Surveillance should be within 2% of the tilt shown by the most recent flux map data.

REFERENCES 1. 10 CFR 50.46.

2. Regulatory Guide 1.77, Rev

[0], May 1974.

3. 10 CFR 50, Appendix A, GDC 26.

22 JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT RATIO (QPTR)

Sequoyah Unit 1 and Unit 2 Page 1 of 1 1. Changes are made to be consistent with changes made to the Specification.

2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
3. ISTS 3.2.4 Bases Required Action A.3 refers to the Required Actions of the referenced Surveillances. There are no Required Actions in the ITS 3.2.1 or ITS 3.2.2 Surveillances. This reference has been corrected to refer to the Required Actions of the applicable LCOs.
4. ISTS SR 3.2.4.1 and SR 3.2.4.2 Bases provide two options for controlling the Frequencies of Surveillance Requirements. SQN is proposing to control the Surveillance Frequencies under the Surveillance Frequency Control Program.

Additionally, the Frequency description which is being removed will be included in the Surveillance Frequency Control Program.

5. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
6. Typographical/grammatical error corrected.

Specific No Significant Haza rds Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO Sequoyah Unit 1 and 2 Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

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