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Enclosure 2 - Volume 7 - Improved Technical Specifications Conversion, ITS Section 3.2 Power Distribution Limits, Revision 0
	ML13329A859
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Site:	Sequoyah
Issue date:	11/22/2013
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
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ML13329A881	List: ML13329A717; ML13329A718; ML13329A790; ML13329A791; ML13329A792; ML13329A854; ML13329A855; ML13329A858; ML13329A859; ML13329A916; ML13330A922; ML13330A924; ML13330A925; ML13330A927; ML13330A928; ML13330A929; ML13330A930; ML13330A931; ML13330A953;
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	NUREG-1431, Rev 4
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Enclosure 2, Volume 7, Rev. 0, Page 1 of 249 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 Enclosure 2, Volume 7, Rev. 0, Page 1 of 249

Enclosure 2, Volume 7, Rev. 0, Page 2 of 249 LIST OF ATTACHMENTS

1. ITS 3.2.1, - Heat Flux Hot Channel Factor (FQ(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)

Enclosure 2, Volume 7, Rev. 0, Page 2 of 249

Enclosure 2, Volume 7, Rev. 0, Page 3 of 249 ATTACHMENT 1 ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

Enclosure 2, Volume 7, Rev. 0, Page 3 of 249

Enclosure 2, Volume 7, Rev. 0, Page 4 of 249 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)

Enclosure 2, Volume 7, Rev. 0, Page 4 of 249

Enclosure 2, Volume 7, Rev. 0, Page 5 of 249 A01 ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS 3/4.2.2 HEAT FLUX HOT CHANNEL FACTOR-FQ(X,Y,Z)

LIMITING CONDITION FOR OPERATION LCO 3.2.1 3.2.2 FQ(X,Y,Z) shall be maintained within the acceptable limits specified in the COLR:

Applicability APPLICABILITY: MODE 1 ACTION: M01 Add proposed ACTION A Note steady state ACTION A With FQ(X,Y,Z) exceeding its limit: A02 FQC ( X , Y , Z)

Required Action a. Reduce THERMAL POWER at least 1% for each 1% FQ(X,Y,Z) exceeds the limit within 15 minutes, A.1 and similarly reduce the following: after each FQ(X,Y,Z) determination M02 Required Action A.2 1. Administratively reduce the allowable power at each point along the AFD limit lines within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and Required Action 72 L01 A.4

2. The Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

Required Action after each FQ(X,Y,Z) determination M02 A.3

b. POWER OPERATION may proceed for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Subsequent POWER OPERATION may proceed provided the Overpower Delta T Trip Setpoints (value of K4) have been reduced at least LA01 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR. C Required Action FQ ( X , Y , Z)

A.5 A02

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.

LA02 Add proposed ACTION D M03 SURVEILLANCE REQUIREMENTS SR NOTE 4.2.2.1 The provisions of Specification 4.0.4 are not applicable. M04 April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-5 Amendment No. 19, 95, 140, 155, 223 Page 1 of 10 Enclosure 2, Volume 7, Rev. 0, Page 5 of 249

Enclosure 2, Volume 7, Rev. 0, Page 6 of 249 A01 ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

SR 3.2.1.2 4.2.2.2 FQM (X, Y, Z) shall be evaluated to determine if FQ(X,Y,Z) is within its limit by:

SR 3.2.1.3

a. Using the moveable incore detectors to obtain a power distribution map ( FQM (X, Y, Z) *) at any THERMAL POWER greater than 5% of RATED THERMAL POWER.

b. Satisfying the following relationship:

( FQM (X, Y, Z) BQNOM(X,Y,Z)

LA03 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:

FQM (X,Y, Z)

SR 3.2.1.2 % AFD Margin = 1 - x 100%

BQDES(X,Y, Z)

LA03 FQM (X,Y, Z)

SR 3.2.1.3 % f 2 ( I) Margin = 1 - x 100%

BCDES(X,Y, Z) 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 LA03 Condition for Operation limits, and include allowances for the calculational and measurement uncertainties.

No additional uncertainties are required in the following equations for FQM (X, Y, Z) , because the limits include uncertainties.

LA03

- 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 Page 2 of 10 Enclosure 2, Volume 7, Rev. 0, Page 6 of 249

Enclosure 2, Volume 7, Rev. 0, Page 7 of 249 A01 ITS 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. LA03 f2(I) OPT min margin = minimum % margin value of all locations examined.

ACTION B 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. M05 REQUIRED ACTION (a) Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , administratively reduce the negative AFD limit lines at each power level B.2 by:

Reduced AFDLimit = (AFDLimit from COLR) + absolute value of (NSLOPEAFD* % x AFD min LA03 margin of 4.2.2.2.c.2)

REQUIRED ACTION (b) Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , administratively reduce the positive AFD limit lines at each power level B.1 by:

Reduced AFDLimit = (AFDLimit from COLR) absolute value of (PSLOPEAFD* % X AFD min LA03 margin)

ACTION C 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. M05 REQUIRED ACTION (a) Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , reduce the OPT negative f2(I) breakpoint limit by:

C.2 Reduced OPT negative f2(I) breakpoint limit = (f2(I) limit of Table 2.2-1) + absolute value of LA03 (NSLOPEf 2 ( I )** % x f 2 ( I) min margin)

REQUIRED

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

ACTION B.1/B.2 that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14 LA03 REQUIRED

- NSLOPE f 2( I) and PSLOPE f 2 ( I) are the amounts of the OPT f2(I) limit adjustment required to ACTION C.1/C.2 compensate for each 1% that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification LA03 6.9.1.14 April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-7 Amendment No. 19, 95, 140, 155, 216, 223 Page 3 of 10 Enclosure 2, Volume 7, Rev. 0, Page 7 of 249

Enclosure 2, Volume 7, Rev. 0, Page 8 of 249 A01 ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

REQUIRED ACTION C.1 (b) Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , reduce the OPT positive f2(I) breakpoint limit by:

LA03 Reduced OPT positive f2(I) breakpoint limit = (f2(I) limit of Table 2.2-1) absolute value of (PSLOPEf 2( I) * * % x f 2 (I) min margin)

d. Measuring FQM (X, Y, Z) according to the following schedule:

INSERT 1 M06 Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after M07 SR 3.2.1.1 1. Upon achieving equilibrium conditions after exceeding by 10 percent or more SR 3.2.1.2 of RATED THERMAL POWER, the THERMAL POWER at which FQ(X,Y,Z) M08 SR 3.2.1.3 and was last determined,*** or In accordance with the Surveillance Frequency Control Program LA04

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

thereafter M08 SR 3.2.1.2/SR 3.2.1.3 e. With two measurements extrapolated to 31 EFPD beyond the most recent measurement NOTE yielding F QM (X, Y, Z) f BQNOM(X, Y, Z), either of the following actions specified shall be taken.

SR 3.2.1.2 / 1. FQM (X, Y, Z) shall be increased over that specified in 4.2.2.2.a by the SR 3.2.1.3 NOTE a. appropriate factor specified in the COLR, and 4.2.2.2.c repeated, or SR 3.2.1.2 / 2. FQM (X, Y, Z) shall be evaluated according to 4.2.2.2 at or before the time when SR 3.2.1.3 NOTE b. 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. M09 INSERT 2 SR 3.2.1.1 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% LA02 to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty, and compared to the FQ(X,Y,Z) limit specified in the COLR according to Specification 3.2.2.

FQC ( X , Y , Z) A02

( I)

REQUIRED ** NSLOPE f 2 and PSLOPE f 2( I) are the amounts of the OPT f2(I) limit adjustment required to ACTION C.1/C.2 compensate for each 1% that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification LA03 6.9.1.14 Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after an equilibrium SR Note *** During power escalation at the beginning of each cycle, power level may be increased until a M04 power level for extended operation has been achieved and power distribution map obtained.

can be April 21, 1997 SEQUOYAH - UNIT 1 3/4 2-8 Amendment No. 19, 140, 223 Page 4 of 10 Enclosure 2, Volume 7, Rev. 0, Page 8 of 249

Enclosure 2, Volume 7, Rev. 0, Page 9 of 249 CTS 3.2.1 DOC M06 INSERT 1 Once after each refueling prior to THERMAL POWER exceeding 75% RTP DOC M09 INSERT 2 Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the C

THERMAL POWER at which FQ (X, Y, Z) was last verified AND In accordance with the Surveillance Frequency Control Program LA04 At least once per 31 Effective Full Power Days Insert Page 3/4 2-8 (Page 4 of 10)

Enclosure 2, Volume 7, Rev. 0, Page 9 of 249

Enclosure 2, Volume 7, Rev. 0, Page 10 of 249 A01 ITS 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 Enclosure 2, Volume 7, Rev. 0, Page 10 of 249

Enclosure 2, Volume 7, Rev. 0, Page 11 of 249 A01 ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS 3/4.2.2 HEAT FLUX HOT CHANNEL FACTOR- FQ(X,Y,Z)

LIMITING CONDITION FOR OPERATION LCO 3.2.1 3.2.2 FQ(X,Y,Z) shall be maintained within the acceptable limits specified in the COLR.

Applicability APPLICABILITY: MODE 1 ACTION: Add proposed ACTION A Note M01 steady state ACTION A With FQ(X,Y,Z) exceeding its limit:

FQC ( X , Y , Z) A02 Required Action a. Reduce THERMAL POWER at least 1% for each 1% FQ(X,Y,Z) exceeds the limit within 15 minutes, A.1 and similarly reduce the following: after each FQ(X,Y,Z) determination M02 Required Action 1. Administratively reduce the allowable power at each point along the AFD limit lines within 2 A.2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , and 72 L01 Required Action 2. The Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

A.4 after each FQ(X,Y,Z) determination M02 Required Action b. POWER OPERATION may proceed for up to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . Subsequent POWER OPERATION may A.3 proceed provided the Overpower Delta T Trip Setpoints (value of K4) have been reduced at least LA01 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR. C FQ ( X , Y , Z)

A02 Required Action c. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER A.5 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. LA02 Add proposed ACTION D M03 SURVEILLANCE REQUIREMENTS SR NOTE 4.2.2.1 The provisions of Specification 4.0.4 are not applicable. M04 April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-4 Amendment Nos. 21, 95, 131, 146, 214 Page 6 of 10 Enclosure 2, Volume 7, Rev. 0, Page 11 of 249

Enclosure 2, Volume 7, Rev. 0, Page 12 of 249 A01 ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

M SR 3.2.1.2 4.2.2.2 FQ(X,Y,Z) shall be evaluated to determine if FQ(X,Y,Z) is within its limit by:

SR 3.2.1.3

a. Using the moveable incore detectors to obtain a power distribution map ( FQ M(X,Y,Z)

) at any THERMAL POWER greater than 5% of RATED THERMAL POWER.

b. Satisfying the following relationship:

F QM (X,Y,Z) BQNOM (X,Y,Z) where BQNOM (X,Y,Z)** represents the nominal design increased by an allowance LA03 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:

FQM (X,Y, Z)

SR 3.2.1.2 % AFD Margin = 1 - x 100%

BQDES(X,Y, Z) LA03 FQM (X,Y, Z)

SR 3.2.1.3 % f 2 ( I) Margin = 1 - x 100%

BCDES(X, Y, Z) 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.

LA03

No additional uncertainties are required in the following equations for FQ M(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 Page 7 of 10 Enclosure 2, Volume 7, Rev. 0, Page 12 of 249

Enclosure 2, Volume 7, Rev. 0, Page 13 of 249 A01 ITS 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.

LA03 f2(I) OPT min margin = minimum % margin value of all locations examined.

ACTION B 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. M05 REQUIRED ACTION (a) Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , administratively reduce the negative AFD limit lines at each power B.2 level by:

Reduced AFDLimit = (AFDLimit from COLR) + absolute value of (NSLOPEAFD* % x LA03 AFD min margin of 4.2.2.2.c.2)

REQUIRED ACTION (b) Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , administratively reduce the positive AFD limit lines at each power B.1 level by:

Reduced AFDLimit = (AFDLimit from COLR)-absolute value of (PSLOPEAFD* % X AFD LA03 min margin)

ACTION C 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. M05 REQUIRED ACTION (a) Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , reduce the OPT negative f2(I) breakpoint limit by:

C.2 Reduced OPT negative f2(I) breakpoint limit = (f2(I) limit of Table 2.2-1) + absolute value of LA03

( NSLOPE f 2 ( I)** % x f 2 ( I) min margin)

REQUIRED

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

ACTION B.1/B.2 that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification 6.9.1.14. LA03 f 2 ( I) and

- NSLOPE PSLOPE f 2 ( I) are the amounts of the OPT f2(I) limit adjustment required to REQUIRED ACTION C.1/C.2 compensate for each 1% that FQ(X,Y,Z) exceeds the limit provided in the COLR per Specification LA03 6.9.1.14.

April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-6 Amendment No. 21, 95, 131, 146, 206, 214 Page 8 of 10 Enclosure 2, Volume 7, Rev. 0, Page 13 of 249

Enclosure 2, Volume 7, Rev. 0, Page 14 of 249 A01 ITS ITS 3.2.1 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)

REQUIRED ACTION (b) Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , reduce the OPT positive f2(I) breakpoint limit by:

C.1 Reduced OPT positive f2(I) breakpoint limit = (f2(I) limit of Table 2.2-1) f 2 ( I) ** % x LA03

(

absolute value of PSLOPE f 2 ( I) min margin)

d. Measuring FQ M (X, Y, Z) according to the following schedule:

INSERT 3 M06 Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after M07

1. Upon achieving equilibrium conditions after exceeding by 10 percent or more of SR 3.2.1.1 SR 3.2.1.2 RATED THERMAL POWER, the THERMAL POWER at which FQ(X,Y,Z) was M08 and SR 3.2.1.3 last determined,*** or In accordance with the Surveillance Frequency Control Program LA04

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

thereafter M08 SR 3.2.1.2/SR 3.2.1.3 e. With two measurements extrapolated to 31 EFPD beyond the most recent measurement NOTE M(X,Y,Z) f BQNOM(X,Y,Z), either of the following actions specified shall be yielding FQ taken.

SR 3.2.1.2 / 1. FQM(X,Y,Z) shall be increased over that specified in 4.2.2.2.a by the SR 3.2.1.3 NOTE a.

appropriate factor specified in the COLR, and 4.2.2.2.c repeated, or SR 3.2.1.2 /

2. FQM(X,Y,Z)shall be evaluated according to 4.2.2.2 at or before the time when SR 3.2.1.3 NOTE b. 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. M09 INSERT 4 SR 3.2.1.1 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 LA02 uncertainty, and compared to the FQ(X,Y,Z) limit specified in the COLR according to Specification 3.2.2.

FQC ( X , Y , Z) A02 REQUIRED ACTION ** NSLOPEf2(I) and PSLOPEf2(I) are the amounts of the OPT f2(I) limit adjustment required C.1/C.2 to compensate for each 1% that FQ(X,Y,Z) exceeds the limit provided in the COLR per LA03 Specification 6.9.1.14.

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after an equilibrium SR Note

- - During power escalation at the beginning of each cycle, power level may be increased until a M04 power level for extended operation has been achieved and power distribution map obtained.

can be April 21, 1997 SEQUOYAH - UNIT 2 3/4 2-6a Amendment No. 21, 95, 131, 214 Page 9 of 10 Enclosure 2, Volume 7, Rev. 0, Page 14 of 249

Enclosure 2, Volume 7, Rev. 0, Page 15 of 249 CTS 3.2.1 DOC M06 INSERT 3 Once after each refueling prior to THERMAL POWER exceeding 75% RTP DOC M09 INSERT 4 Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the C

THERMAL POWER at which FQ (X, Y, Z) was last verified AND In accordance with the Surveillance Frequency Control Program LA04 At least once per 31 Effective Full Power Days Insert Page 3/4 2-6a (Page 9 of 10)

Enclosure 2, Volume 7, Rev. 0, Page 15 of 249

Enclosure 2, Volume 7, Rev. 0, Page 16 of 249 A01 ITS 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 Enclosure 2, Volume 7, Rev. 0, Page 16 of 249

Enclosure 2, Volume 7, Rev. 0, Page 17 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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 FQM ( X , Y , Z) to determine if FQ(X,Y,Z) is within the limits.

CTS 4.2.2.3 evaluates FQ(X,Y,Z) for reasons other than meeting the requirements of CTS 4.2.2.2 and requires the overall measured FQ(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 FQ(X,Y,Z) limit specified in the COLR. ITS 3.2.1 ACTION A and SR 3.2.1.1 use FQC (X, Y, Z) to represent the overall measured FQ(X,Y,Z) adjusted for measurement uncertainty and manufacturing tolerances. This changes the CTS by adding a new term, FQC (X, Y, Z) which reflects the requirements in CTS 4.2.2.3 for evaluating the steady state limit of FQ(X,Y,Z) specified in the COLR.

BAW-10163PA, "Core Operating Limit Methodology for Westinghouse-Designed PWRs" June 1989, requires that FQ(X,Y,Z) is compared against three limits: (1) steady state limit, (FQRTP / 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 FQM (X, Y, Z) for both BQDES(X,Y,Z) and BCDES(X,Y,Z) to ensure the FQ(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 FQ(X,Y,Z) adjusted by the two penalty factors, FQC ( X, Y, Z) . ITS 3.2.1 uses FQC ( X, Y, Z) throughout 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 FQ(X,Y,Z) exceeding its limit "Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL Sequoyah Unit 1 and Unit 2 Page 1 of 9 Enclosure 2, Volume 7, Rev. 0, Page 17 of 249

Enclosure 2, Volume 7, Rev. 0, Page 18 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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 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 FQC ( X, Y, Z) verification to be made even if FQC (X, Y, Z) is restored to within its limit.

The purpose of CTS 3.2.2 ACTION c is to ensure that when FQ(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 FQ(X,Y,Z) limit. As power is reduced under ITS Required Action A.1, the margin to the FQ(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 FQ(X,Y,Z) has exceeded the limit, to (1) Reduce THERMAL POWER at least 1% for each 1% FQ(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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , (3) Reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , (4) Reduce the Overpower Delta T Trip Setpoints (value of K4) at least 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit specified in the COLR within the next 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , (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 FQ(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 FQC ( X , Y , Z) determination. 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 FQ(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 FQC ( X , Y , Z) not within limits will be re-performed after each FQC ( X , Y , Z) determination within the prescribed Completion Time. When FQC ( X , Y , Z) 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 Sequoyah Unit 1 and Unit 2 Page 2 of 9 Enclosure 2, Volume 7, Rev. 0, Page 18 of 249

Enclosure 2, Volume 7, Rev. 0, Page 19 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.2.1 ACTION D, states that the plant must be in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 Sequoyah Unit 1 and Unit 2 Page 3 of 9 Enclosure 2, Volume 7, Rev. 0, Page 19 of 249

Enclosure 2, Volume 7, Rev. 0, Page 20 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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 f2(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 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." 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 f2(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 f2(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, FQ(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 FQ(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 FQ(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 FQ(X,Y,Z) is within its limit after each refueling prior to THERMAL POWER exceeding 75% RTP, once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the THERMAL POWER at which FQC ( X , Y , Z ) and FQM (X, Y, Z) was 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months " is discussed in DOC M07.

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Enclosure 2, Volume 7, Rev. 0, Page 21 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

The purpose of SR 3.2.1.1, SR 3.2.1.2 and SR 3.2.1.3 is to verify that FQ(X,Y,Z) is within the limits assumed in the safety analysis. This change is acceptable, because adopting the new Frequency of confirming FQC ( X , Y , Z ) and FQM (X, Y, Z) are within the limits prior to exceeding 75% RTP following each core reload, will ensure that some determination of FQC ( X , Y , Z ) and FQM (X, Y, Z) 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 FQ(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 FQ(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 FQ(X,Y,Z) is within its limit after each refueling prior to THERMAL POWER exceeding 75% RTP, once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by greater than or equal to 10% RTP, the THERMAL POWER at which FQ(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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 FQ(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 FQ(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 FQM (X, Y, Z) is measured. The intent of the CTS Frequency logical connector "or" does not provide an exclusion to perform either the situational performance or the Sequoyah Unit 1 and Unit 2 Page 5 of 9 Enclosure 2, Volume 7, Rev. 0, Page 21 of 249

Enclosure 2, Volume 7, Rev. 0, Page 22 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

repetitive performance of the test, because both are continuously applicable when FQM (X, Y, Z) is 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 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 FQ(X,Y,Z) limit specified in the COLR according to Specification 3.2.2. Proposed ITS SR 3.2.1.1, verifies FQC (X, Y, Z) is 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC ( X, Y, Z) was last verified, and (3) In accordance with the Surveillance Frequency Control Program. This changes the CTS from a 4.2.2.3 measurement of FQ(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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC (X, Y, Z) was 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, FQC ( X, Y, Z) ).

The purpose of CTS 4.2.2.3 is to evaluate FQ(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 FQ(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 Sequoyah Unit 1 and Unit 2 Page 6 of 9 Enclosure 2, Volume 7, Rev. 0, Page 22 of 249

Enclosure 2, Volume 7, Rev. 0, Page 23 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months when FQ(X,Y,Z) is not within limits to reduce the Overpower Delta T Trip setpoints (value of K4) at least 1% (in T span) for each 1% that FQ(X,Y,Z) exceeds the limit provided in the COLR. ITS LCO 3.2.1 Required Action A.3 requires within C

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of discovery that FQ (X, Y, Z) is not within limits, to reduce Overpower C

T trip setpoints at least 1% for each 1% that FQ (X, Y, Z) 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 C

Overpower T trip setpoints at least 1% for each 1% that FQ (X, Y, Z) exceeds 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 FQ(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 FQ(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 FQC (X, Y, Z) is within its limit. This changes the CTS by moving the manner in which the FQ(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.

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Enclosure 2, Volume 7, Rev. 0, Page 24 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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 FMQ(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 FQ(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 FMQ(X,Y,Z) to determine if FQ(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 FQ(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 FQ(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.

Sequoyah Unit 1 and Unit 2 Page 8 of 9 Enclosure 2, Volume 7, Rev. 0, Page 24 of 249

Enclosure 2, Volume 7, Rev. 0, Page 25 of 249 DISCUSSION OF CHANGES ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.2 ACTION a.2 states, in part, that when FQ(X,Y,Z) exceeds its limit, reduce the Power Range Neutron Flux - High Trip setpoints within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . ITS 3.2.1 Required Actions A.4 states with FQC (X, Y, Z) not within limit, reduce the Power Range Neutron Flux -

High Trip setpoints by 1% for each 1% FQC (X, Y, Z) exceeds the limit. The ITS 3.2.1 Required Action A.4 Completion Time is "within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (X, Y, Z) determination." 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 FQC (X, Y, Z) 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is allowed to reestablish steady state xenon concentration and power distribution and to take and analyze a flux map. If it is determined that FQC (X, Y, Z) 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.

Sequoyah Unit 1 and Unit 2 Page 9 of 9 Enclosure 2, Volume 7, Rev. 0, Page 25 of 249

Enclosure 2, Volume 7, Rev. 0, Page 26 of 249 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 7, Rev. 0, Page 26 of 249

Enclosure 2, Volume 7, Rev. 0, Page 27 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B 3.2 POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology) 2 1 X,Y,Z X,Y,Z 3.2.2 LCO 3.2.1B FQ(Z), as approximated by FQC ( Z ) and FQW ( Z ) , shall be within the limits 2 1 specified in the COLR.

Applicability APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A. ------------NOTE------------ 5 A.1 Reduce THERMAL 15 minutes after each 3 DOC M01 Required Action A.4 POWER 1% RTP for FQC ( Z ) determination DOC M02 shall be completed each 1% FQC ( Z ) exceeds 1 FQC ( X , Y , Z )

whenever this Condition limit. C is entered. INSERT 1 FQ ( X , Y , Z ) 3

AND the steady state 4 3 DOC L01 FQC ( Z ) not within limit. A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each ACTION a.2 DOC M02 Neutron Flux - High trip FQC ( Z ) determination 1 FQC ( X , Y , Z ) setpoints 1% for each C F ( X ,Y , Z )

1% FQC ( Z ) exceeds limit. Q FQC ( X , Y , Z )

AND 48 3

ACTION b A.3 Reduce Overpower T trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each DOC M02 setpoints 1% for each FQC ( Z ) determination 1 1% FQC ( Z ) exceeds limit.

FQC ( X , Y , Z )

AND FQC ( X , Y , Z )

5 3

ACTION c A.4 Perform SR 3.2.1.1 and Prior to increasing DOC M02 SR 3.2.1.2. THERMAL POWER 4 3 above the limit of

, SR 3.2.1.2 Required Action A.1 SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.1B-1 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 27 of 249

Enclosure 2, Volume 7, Rev. 0, Page 28 of 249 CTS 3.2.1 3 INSERT 1 CONDITION REQUIRED ACTION COMPLETION TIME AND ACTION a.1 DOC M02 A.2 Reduce, by administrative 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each means, AFD limits 1% for FQC (X, Y, Z)

C each 1% FQ (X, Y, Z) determination exceeds limit.

Insert Page 3.2.1-1 Enclosure 2, Volume 7, Rev. 0, Page 28 of 249

Enclosure 2, Volume 7, Rev. 0, Page 29 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ------------NOTE------------ B.1 Reduce AFD limits 1% for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Required Action B.4 each 1% FQW ( Z ) exceeds shall be completed limit.

whenever this Condition is entered. AND B.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months FQW ( Z ) not within limits. Neutron Flux - High trip setpoints 1% for each 1%

that the maximum allowable power of the AFD limits is reduced.

INSERT 2 AND B.3 Reduce Overpower T trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months setpoints 1% for each 1% 4 that the maximum allowable power of the AFD limits is reduced.

AND B.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the maximum allowable power of the AFD limits DOC M03 C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion D D Time not met.

SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.1B-2 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 29 of 249

Enclosure 2, Volume 7, Rev. 0, Page 30 of 249 CTS 3.2.1 4 INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME 4.2.2.2.c.3 B. AFD min margin < 0 B.1 Reduce, by administrative 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.2.2.2.c.3.b means, positive AFD limit 4.2.2.2.c.3 Note

lines for each power level by PSLOPEAFD for each 1%

FQ(X,Y,Z) exceeds limit.

AND 4.2.2.2.c.3.a Note

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B.2 Reduce, by administrative means, negative AFD limit lines for each power level by NSLOPEAFD for each 1%

FQ(X,Y,Z) exceeds limit.

4.2.2.2.c.4 C. f2(I) min margin < 0 C.1 Reduce Overpower T 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 4.2.2.2.c.4.b positive f2(I) breakpoint Note ** limit by PSLOPEf2(I) for each 1% FQ(X,Y,Z) exceeds limit.

AND 4.2.2.2.c.4.a Note ** C.2 Reduce Overpower T 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months negative f2(I) breakpoint limit by NSLOPEf2(I) for each 1% FQ(X,Y,Z) exceeds limit.

Insert Page 3.2.1-2 Enclosure 2, Volume 7, Rev. 0, Page 30 of 249

Enclosure 2, Volume 7, Rev. 0, Page 31 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after SURVEILLANCE REQUIREMENTS

NOTE----------------------------------------------------------- 5 4.2.2.2 Note *** During power escalation at the beginning of each cycle, THERMAL POWER may be increased 4.2.2.1 until an equilibrium power level has been achieved, at which a power distribution map is DOC M04 obtained. can be 5 SURVEILLANCE FREQUENCY the steady state 6 INSERT 3 4.2.2.2 4.2.2.3 SR 3.2.1.1 Verify FQC ( Z ) is within limit. Once after each 1 DOC M06 refueling prior to DOC M09 DOC A02 FQC ( X , Y , Z ) THERMAL POWER exceeding 75% RTP AND Once within 4.2.2.2.d.1 DOC M07 [12] hours after 7 achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC ( Z ) was last 1 verified FQC ( X , Y , Z )

AND 4.2.2.2.d.2

[ 31 EFPD thereafter 8 OR In accordance with the Surveillance Frequency Control Program ] 8 SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.1B-3 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 31 of 249

Enclosure 2, Volume 7, Rev. 0, Page 32 of 249 CTS 3.2.1 6 INSERT 3

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

Not required to be performed if SR 3.2.1.2 and SR 3.2.1.3 are met.

4.2.2.2 --------------------------------------------------------------------------------------

Insert Page 3.2.1-3 Enclosure 2, Volume 7, Rev. 0, Page 32 of 249

Enclosure 2, Volume 7, Rev. 0, Page 33 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------ 4 If measurements indicate that the maximum over z [ FQC ( Z ) / K(Z) ]

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

a. Increase FQW ( Z ) by the greater of a factor of

[1.02] or by an appropriate factor specified in the COLR and reverify FQW ( Z ) is within limits or

b. Repeat SR 3.2.1.2 once per 7 EFPD until either

a. above is met or two successive flux maps indicate that the maximum over z [ FQC ( Z ) / K(Z) ]

has not increased.

Verify FQW ( Z ) 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 FQW ( Z ) was last verified AND SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.1B-4 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 33 of 249

Enclosure 2, Volume 7, Rev. 0, Page 34 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD 4 thereafter OR In accordance with the Surveillance Frequency Control Program ]

INSERT 4 4

SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.1B-5 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 34 of 249

Enclosure 2, Volume 7, Rev. 0, Page 35 of 249 CTS 3.2.1 4 INSERT 4 SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD 4.2.2.2.e beyond the most recent measurement yield:

FQM (X, Y, Z) > BQNOM(X,Y,Z) 4.2.2.2.e.1 a. Increase FQM (X, Y, Z) by the appropriate factor specified in the COLR and reverify AFD min margin > 0; or 4.2.2.2.e.2

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

4.2.2.2.c.1 Verify AFD min margin > 0. Once after each DOC M06 refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 4.2.2.2.d.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after DOC M07 achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQM (X, Y, Z) was last verified AND Insert Page 3.2.1-5a Enclosure 2, Volume 7, Rev. 0, Page 35 of 249

Enclosure 2, Volume 7, Rev. 0, Page 36 of 249 CTS 3.2.1 4

INSERT 4 (continued)

SURVEILLANCE FREQUENCY 4.2.2.2.d.2 [ 31 EFPD thereafter]

OR In accordance with the Surveillance Frequency Control Program ]

Insert Page 3.2.1-5b Enclosure 2, Volume 7, Rev. 0, Page 36 of 249

Enclosure 2, Volume 7, Rev. 0, Page 37 of 249 CTS 3.2.1 4

INSERT 4 (continued)

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

If two measurements extrapolated to 31 EFPD 4.2.2.2.e beyond the most recent measurement yield:

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

M 4.2.2.2.e.1

a. Increase FQ (X, Y, Z) by the appropriate factor specified in the COLR and reverify f2(I) min margin > 0; or 4.2.2.2.e.2 b. Repeat SR 3.2.1.3 prior to the time at which the projected f2(I) min margin will be < 0.

4.2.2.2.c.1 Verify f2(I) min margin > 0. Once after each DOC M06 refueling prior to THERMAL POWER exceeding 75% RTP AND 4.2.2.2.d.1 Once within DOC M07 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQM (X, Y, Z) was last verified AND Insert Page 3.2.1-5c Enclosure 2, Volume 7, Rev. 0, Page 37 of 249

Enclosure 2, Volume 7, Rev. 0, Page 38 of 249 CTS 3.2.1 4

INSERT 4 (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD 4.2.2.2.d.2 thereafter OR In accordance with the Surveillance Frequency Control Program ]

Insert Page 3.2.1-5d Enclosure 2, Volume 7, Rev. 0, Page 38 of 249

Enclosure 2, Volume 7, Rev. 0, Page 39 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B 3.2 POWER DISTRIBUTION LIMITS 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology) 2 1 X,Y,Z X,Y,Z 3.2.2 LCO 3.2.1B FQ(Z), as approximated by FQC ( Z ) and FQW ( Z ) , shall be within the limits 2 1 specified in the COLR.

Applicability APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A. ------------NOTE------------ 5 A.1 Reduce THERMAL 15 minutes after each 3 DOC M01 Required Action A.4 POWER 1% RTP for FQC ( Z ) determination DOC M02 shall be completed each 1% FQC ( Z ) exceeds 1 FQC ( X , Y , Z )

whenever this Condition limit. C is entered. INSERT 1 FQ ( X , Y , Z ) 3

AND the steady state 4 3 DOC L01 FQC ( Z ) not within limit. A.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each ACTION a.2 DOC M02 Neutron Flux - High trip FQC ( Z ) determination 1 FQC ( X , Y , Z ) setpoints 1% for each C F ( X ,Y , Z )

1% FQC ( Z ) exceeds limit. Q FQC ( X , Y , Z )

AND 48 3

ACTION b A.3 Reduce Overpower T trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each DOC M02 setpoints 1% for each FQC ( Z ) determination 1 1% FQC ( Z ) exceeds limit.

FQC ( X , Y , Z )

AND FQC ( X , Y , Z )

5 3

ACTION c A.4 Perform SR 3.2.1.1 and Prior to increasing DOC M02 SR 3.2.1.2. THERMAL POWER 4 3 above the limit of

, SR 3.2.1.2 Required Action A.1 SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.1B-1 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 39 of 249

Enclosure 2, Volume 7, Rev. 0, Page 40 of 249 CTS 3.2.1 3 INSERT 1 CONDITION REQUIRED ACTION COMPLETION TIME AND ACTION a.1 DOC M02 A.2 Reduce, by administrative 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months after each means, AFD limits 1% for FQC (X, Y, Z)

C each 1% FQ (X, Y, Z) determination exceeds limit.

Insert Page 3.2.1-1 Enclosure 2, Volume 7, Rev. 0, Page 40 of 249

Enclosure 2, Volume 7, Rev. 0, Page 41 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. ------------NOTE------------ B.1 Reduce AFD limits 1% for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Required Action B.4 each 1% FQW ( Z ) exceeds shall be completed limit.

whenever this Condition is entered. AND B.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months FQW ( Z ) not within limits. Neutron Flux - High trip setpoints 1% for each 1%

that the maximum allowable power of the AFD limits is reduced.

INSERT 2 AND B.3 Reduce Overpower T trip 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months setpoints 1% for each 1% 4 that the maximum allowable power of the AFD limits is reduced.

AND B.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the maximum allowable power of the AFD limits DOC M03 C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion D D Time not met.

SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.1B-2 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 41 of 249

Enclosure 2, Volume 7, Rev. 0, Page 42 of 249 CTS 3.2.1 4 INSERT 2 CONDITION REQUIRED ACTION COMPLETION TIME 4.2.2.2.c.3 B. AFD min margin < 0 B.1 Reduce, by administrative 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4.2.2.2.c.3.b means, positive AFD limit 4.2.2.2.c.3 Note

lines for each power level by PSLOPEAFD for each 1%

FQ(X,Y,Z) exceeds limit.

AND 4.2.2.2.c.3.a Note

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B.2 Reduce, by administrative means, negative AFD limit lines for each power level by NSLOPEAFD for each 1%

FQ(X,Y,Z) exceeds limit.

4.2.2.2.c.4 C. f2(I) min margin < 0 C.1 Reduce Overpower T 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 4.2.2.2.c.4.b positive f2(I) breakpoint Note ** limit by PSLOPEf2(I) for each 1% FQ(X,Y,Z) exceeds limit.

AND 4.2.2.2.c.4.a Note ** C.2 Reduce Overpower T 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months negative f2(I) breakpoint limit by NSLOPEf2(I) for each 1% FQ(X,Y,Z) exceeds limit.

Insert Page 3.2.1-2 Enclosure 2, Volume 7, Rev. 0, Page 42 of 249

Enclosure 2, Volume 7, Rev. 0, Page 43 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after SURVEILLANCE REQUIREMENTS

NOTE----------------------------------------------------------- 5 4.2.2.2 Note *** During power escalation at the beginning of each cycle, THERMAL POWER may be increased 4.2.2.1 until an equilibrium power level has been achieved, at which a power distribution map is DOC M04 obtained. can be 5 SURVEILLANCE FREQUENCY the steady state 6 INSERT 3 4.2.2.2 4.2.2.3 SR 3.2.1.1 Verify FQC ( Z ) is within limit. Once after each 1 DOC M06 refueling prior to DOC M09 DOC A02 FQC ( X , Y , Z ) THERMAL POWER exceeding 75% RTP AND Once within 4.2.2.2.d.1 DOC M07 [12] hours after 7 achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC ( Z ) was last 1 verified FQC ( X , Y , Z )

AND 4.2.2.2.d.2

[ 31 EFPD thereafter 8 OR In accordance with the Surveillance Frequency Control Program ] 8 SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.1B-3 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 43 of 249

Enclosure 2, Volume 7, Rev. 0, Page 44 of 249 CTS 3.2.1 6 INSERT 3

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

Not required to be performed if SR 3.2.1.2 and SR 3.2.1.3 are met.

4.2.2.2 --------------------------------------------------------------------------------------

Insert Page 3.2.1-3 Enclosure 2, Volume 7, Rev. 0, Page 44 of 249

Enclosure 2, Volume 7, Rev. 0, Page 45 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------ 4 If measurements indicate that the maximum over z [ FQC ( Z ) / K(Z) ]

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

a. Increase FQW ( Z ) by the greater of a factor of

[1.02] or by an appropriate factor specified in the COLR and reverify FQW ( Z ) is within limits or

b. Repeat SR 3.2.1.2 once per 7 EFPD until either

a. above is met or two successive flux maps indicate that the maximum over z [ FQC ( Z ) / K(Z) ]

has not increased.

Verify FQW ( Z ) 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 FQW ( Z ) was last verified AND SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.1B-4 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 45 of 249

Enclosure 2, Volume 7, Rev. 0, Page 46 of 249 CTS FQ(Z) (RAOC-W(Z) Methodology) 1 2

X,Y,Z 3.2.1B SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD 4 thereafter OR In accordance with the Surveillance Frequency Control Program ]

INSERT 4 4

SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.1B-5 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 46 of 249

Enclosure 2, Volume 7, Rev. 0, Page 47 of 249 CTS 3.2.1 4 INSERT 4 SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD 4.2.2.2.e beyond the most recent measurement yield:

FQM (X, Y, Z) > BQNOM(X,Y,Z) 4.2.2.2.e.1 a. Increase FQM (X, Y, Z) by the appropriate factor specified in the COLR and reverify AFD min margin > 0; or 4.2.2.2.e.2

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

4.2.2.2.c.1 Verify AFD min margin > 0. Once after each DOC M06 refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 4.2.2.2.d.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after DOC M07 achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQM (X, Y, Z) was last verified AND Insert Page 3.2.1-5a Enclosure 2, Volume 7, Rev. 0, Page 47 of 249

Enclosure 2, Volume 7, Rev. 0, Page 48 of 249 CTS 3.2.1 4

INSERT 4 (continued)

SURVEILLANCE FREQUENCY 4.2.2.2.d.2 [ 31 EFPD thereafter]

OR In accordance with the Surveillance Frequency Control Program ]

Insert Page 3.2.1-5b Enclosure 2, Volume 7, Rev. 0, Page 48 of 249

Enclosure 2, Volume 7, Rev. 0, Page 49 of 249 CTS 3.2.1 4

INSERT 4 (continued)

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

If two measurements extrapolated to 31 EFPD 4.2.2.2.e beyond the most recent measurement yield:

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

M 4.2.2.2.e.1

a. Increase FQ (X, Y, Z) by the appropriate factor specified in the COLR and reverify f2(I) min margin > 0; or 4.2.2.2.e.2 b. Repeat SR 3.2.1.3 prior to the time at which the projected f2(I) min margin will be < 0.

4.2.2.2.c.1 Verify f2(I) min margin > 0. Once after each DOC M06 refueling prior to THERMAL POWER exceeding 75% RTP AND 4.2.2.2.d.1 Once within DOC M07 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQM (X, Y, Z) was last verified AND Insert Page 3.2.1-5c Enclosure 2, Volume 7, Rev. 0, Page 49 of 249

Enclosure 2, Volume 7, Rev. 0, Page 50 of 249 CTS 3.2.1 4

INSERT 4 (continued)

SURVEILLANCE FREQUENCY

[ 31 EFPD 4.2.2.2.d.2 thereafter OR In accordance with the Surveillance Frequency Control Program ]

Insert Page 3.2.1-5d Enclosure 2, Volume 7, Rev. 0, Page 50 of 249

Enclosure 2, Volume 7, Rev. 0, Page 51 of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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-FXY 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 C

ACTION A is entered for FQ (X, Y, Z) not 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . 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 FQW ( Z) is within limits, or actions to take if FQW ( Z) is not within limits. However, CTS does require the verification that both AFD min margin is > 0 and f2(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 f2(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.

Sequoyah Unit 1 and Unit 2 Page 1 of 2 Enclosure 2, Volume 7, Rev. 0, Page 51 of 249

Enclosure 2, Volume 7, Rev. 0, Page 52 of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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.

Sequoyah Unit 1 and Unit 2 Page 2 of 2 Enclosure 2, Volume 7, Rev. 0, Page 52 of 249

Enclosure 2, Volume 7, Rev. 0, Page 53 of 249 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 7, Rev. 0, Page 53 of 249

Enclosure 2, Volume 7, Rev. 0, Page 54 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 B 3.2 POWER DISTRIBUTION LIMITS 2 1 B 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology)

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

and by assembly location, X, Y 1 FQ(Z) is defined as the maximum local fuel rod linear power density X,Y,Z divided by the average fuel rod linear power density, assuming nominal 8 X,Y,Z fuel pellet and fuel rod dimensions. Therefore, FQ(Z) is a measure of the peak fuel pellet power within the reactor core.

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

FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, 1 X,Y,Z and changes in axial power distribution.

FQ(Z) is measured periodically using the incore detector system. These 1 X,Y,Z measurements are generally taken with the core at or near equilibrium conditions.

Using the measured three dimensional power distributions, it is possible X,Y,Z to derive a measured value for FQ(Z). However, because this value represents an equilibrium condition, it does not include the variations in the value of FQ(Z) which are present during nonequilibrium situations X,Y,Z such as load following or power ascension. 1 INSERT 1 To account for these possible variations, the equilibrium value of FQ(Z) is adjusted as FQW ( Z) by 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.

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Enclosure 2, Volume 7, Rev. 0, Page 55 of 249 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."

Insert Page B 3.2.1-1 Enclosure 2, Volume 7, Rev. 0, Page 55 of 249

Enclosure 2, Volume 7, Rev. 0, Page 56 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES 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 FQ(Z) ensure that the value of the initial total peaking factor X,Y,Z 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. 1 X,Y,Z FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the FQ(Z) limit assumed in safety analyses for other X,Y,Z postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents 8 X,Y,Z FQ(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The Heat Flux Hot Channel Factor, FQ(Z), shall be limited by the following relationships: RTP X,Y,Z FQ X,Y,Z FQ(Z) (CFQ / P) K(Z) for P > 0.5 1

F QRTP X,Y,Z FQ(Z) (CFQ / 0.5) K(Z) for P 0.5 F QRTP X,Y,Z where: CFQ is the FQ(Z) limit at RTP provided in the COLR, FQ (X,Y,Z)

K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and P = THERMAL POWER / RTP SEQUOYAH UNIT 1 Revision XXX 2

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Enclosure 2, Volume 7, Rev. 0, Page 57 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES LCO (continued)

SQN F QRTP 1

F QRTP For this facility, the actual values of CFQ and K(Z) are given in the COLR; 2.62 3 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.

INSERT 2 For Relaxed Axial Offset Control operation, FQ(Z) is approximated by FQC ( Z) and FQW ( Z) . Thus, both FQC ( Z) and FQW ( Z) must meet the preceding limits on FQ(Z).

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

From the incore flux map results we obtain the measured value ( FQM ( Z) ) of FQ(Z). Then, FQC ( Z) = FQM ( Z) [1.0815]

where [1.0815] is a factor that accounts for fuel manufacturing tolerances 4

and flux map measurement uncertainty.

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

The expression for FQW ( Z) is:

FQW ( Z) = FQC ( Z) W(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 FQC ( Z) 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 X,Y,Z 1 that it can stay within the LOCA FQ(Z) limits. If FQC ( Z) cannot be FQC (X, Y, Z) maintained within the LCO limits, reduction of the core power is required and if FQW ( Z) cannot be maintained within the LCO limits, reduction of the 5 AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.

X,Y,Z X,Y,Z Violating the LCO limits for FQ(Z) produces unacceptable consequences if 1 a design basis event occurs while FQ(Z) is outside its specified limits.

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Enclosure 2, Volume 7, Rev. 0, Page 58 of 249 3.2.1 4

INSERT 2 Measured FQ(X,Y,Z) is compared against three limits:

Steady state limit, (FQRTP / 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 FQC (X, Y, Z) for the steady state limit on FQ(X,Y,Z). An FQC (X, Y, Z) 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 ( FQM ( X, Y, Z) ) of FQ(X,Y,Z). Then, FQC (X, Y, Z) = overall measured FQ(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 ( FQM ( X, Y, Z) ) of FQ(X,Y,Z). FQM (X, Y, Z) 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) = Pd(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.

Insert Page B 3.2.1-3a Enclosure 2, Volume 7, Rev. 0, Page 58 of 249

Enclosure 2, Volume 7, Rev. 0, Page 59 of 249 3.2.1 4

INSERT 2 (continued)

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

FQM (X, Y, Z) 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.

Insert Page B 3.2.1-3b Enclosure 2, Volume 7, Rev. 0, Page 59 of 249

Enclosure 2, Volume 7, Rev. 0, Page 60 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES X,Y,Z 1

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

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

ACTIONS A.1 FQC (X, Y, Z)

FQC (X, Y, Z)

Reducing THERMAL POWER by 1% RTP for each 1% by which FQC ( Z) exceeds its limit, maintains an acceptable absolute power density. FQC ( Z)

FQM (X, Y, Z) is FQM ( Z) multiplied by a factor accounting for manufacturing tolerances F (X,Y,Z)

FQM (X, Y, Z) Q and measurement uncertainties. FQM ( Z) is the measured value of FQ(Z).

The Completion Time of 15 minutes provides an acceptable time to 5 reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The FQC (X, Y, Z) maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of FQC ( Z) and would FQC (X, Y, Z) require power reductions within 15 minutes of the FQC ( Z) determination, if FQC (X, Y, Z) necessary to comply with the decreased maximum allowable power level.

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

INSERT 3 4 5 A.2 FQC (X, Y, Z)

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

FQC (X, Y, Z) would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQC ( Z) determination, if necessary to comply with FQC (X, Y, Z) the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in FQC ( Z) would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

Move to next page after A.3 SEQUOYAH UNIT 1 Revision XXX 2

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Enclosure 2, Volume 7, Rev. 0, Page 61 of 249 3.2.1 5

INSERT 3 A.2 Required Action A.2 requires an administrative reduction of the AFD limits by 1% for each 1% by which FQC ( X, Y, Z) exceeds the steady state limit. The allowed Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded. The maximum allowable AFD limits initially determined by Required Action A.2 may be affected by subsequent determinations of FQC (X, Y, Z) and would require further AFD limit reductions within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the FQC (X, Y, Z) determination, if necessary to comply with the decreased maximum allowable AFD limits.

Decreases in FQ ( X , Y , Z ) would allow increasing the maximum allowable AFD C

limits.

Insert Page B 3.2.1-4 Enclosure 2, Volume 7, Rev. 0, Page 61 of 249

Enclosure 2, Volume 7, Rev. 0, Page 62 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES ACTIONS (continued)

A.3 in T span C

F ( X , Y , Z)

Reduction in the Overpower T trip setpoints (value of K4) by 1% for each 1% by which FQC ( Z) exceeds its limit, is a conservative action for Q

protection against the consequences of severe transients with 48 unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER in 5 accordance with Required Action A.1. The maximum allowable FQC (X, Y, Z) Overpower T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of FQC ( Z) and would FQC (X, Y, Z) require Overpower T trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the 48 FQC ( Z) determination, if necessary to comply with the decreased maximum FQC (X, Y, Z) allowable Overpower T trip setpoints. Decreases in FQC ( Z) would allow increasing the maximum allowable Overpower T trip setpoints.

5 A.4 FQC (X, Y, Z) steady state and transient Verification that F ( Z) has been restored to within its limit, by performing C

Q 1

3 5

, SR 3.2.1.2 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.

5 INSERT 4 5

Condition A is modified by a Note that requires Required Action A.4 to be performed whenever the Condition is entered. This ensures that 3 5

, SR 3.2.1.2 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. 5 3 5 1

, SR 3.2.1.2 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. F C ( X , Y , Z)

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

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Enclosure 2, Volume 7, Rev. 0, Page 63 of 249 3.2.1 5

INSERT 4 Since FQC ( X, Y, Z) 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.

Insert Page B 3.2.1-5a Enclosure 2, Volume 7, Rev. 0, Page 63 of 249

, Volume 7, Rev. 0, Page 64 of 249 3.2.1 4 5 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 FQM ( X, Y, Z) and the limiting condition operational limit, BQDES (X,Y,Z), as follows:

FQM ( X ,Y , Z )

1

100 %

%AFD margin = BQDES ( X ,Y , Z )

The AFD min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then FQM ( X, Y, Z) is less than BQDES (X,Y,Z) and calculation of %AFD margin is not required. If the AFD margin is less than zero, then FQM ( X, Y, Z) 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 (PSLOPEAFD * % AFD Margin)

ANL = NAFDL + Absolute Value of (NSLOPEAFD * % 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 FQM (X, Y, Z) 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 FQM (X, Y, Z) 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded.

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, Volume 7, Rev. 0, Page 65 of 249 3.2.1 4 5 INSERT 6 C.1 and C.2 The FQ(X,Y,Z) margin supporting the Overpower T f2(I) breakpoints (f2(I) margin) during transient operations is based on the relationship between FQM (X, Y, Z) and the limit, BCDES(X,Y,Z), as follows:

FQM ( X ,Y , Z )

1

100%

% f2(I) margin =

BCDES( X ,Y , Z )

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

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

Posf2(I)Adjusted = Posf2(I)Limit - Absolute Value of (PSLOPEf2(I) * % f2(I)

Margin)

Negf2(I)Adjusted = Negf2(I)Limit + Absolute Value of (NSLOPEf2(I) * %

f2(I) Margin) where:

Posf2(I)Adjusted is the adjusted OPT positive f2(I) breakpoint limit.

Negf2(I)Adjusted is the adjusted OPT negative f2(I) breakpoint limit.

Posf2(I)Limit is the OPT positive f2(I) breakpoint limit defined in the COLR.

Negf2(I)Limit is the OPT negative f2(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 FQM (X, Y, Z) 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 FQM (X, Y, Z) exceeds BCDES(X,Y,Z) as defined in the COLR.

% f2(I) Margin is the most negative margin determined above.

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, Volume 7, Rev. 0, Page 66 of 249 3.2.1 5

4 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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is sufficient considering the small likelihood of a limiting transient in this time period.

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Enclosure 2, Volume 7, Rev. 0, Page 67 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES ACTIONS (continued)

The implicit assumption is that if W(Z) values were recalculated (consistent with the reduced AFD limits), then FQC ( Z) times the recalculated W(Z) values would meet the FQ(Z) limit. Note that complying with this action (of reducing AFD limits) may also result in a power reduction. Hence the need for Required Actions B.2, B.3 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.3 5

Reduction in the Overpower T trip setpoints value of K4 by 1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.4 Verification that FQW ( Z) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.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 FQ(Z) is properly evaluated prior to increasing THERMAL POWER.

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Enclosure 2, Volume 7, Rev. 0, Page 68 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES ACTIONS (continued)

D C.1 5 A.5, B.1, B.2, C.1 or C.2 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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 3.2.1.2 performance 3 is not required SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.2 are modified by a Note. The Note applies 5 REQUIREMENTS during the first power ascension after a refueling. It states that 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained.

FQC (X, Y, Z)

This allowance is modified, however, by one of the Frequency conditions that requires verification that FQC ( Z) and FQW ( Z) are within their specified FQM (X, Y, Z) limits after a power rise of more than 10% RTP over the THERMAL FQC (X, Y, Z)

POWER at which they were last verified to be within specified limits.

Because FQC ( Z) and FQW ( Z) could not have previously been measured in FQM (X, Y, Z) this reload core, there is a second Frequency condition, applicable only FQC (X, Y, Z) for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of FQC ( Z) and FQM (X, Y, Z)

FQW ( Z) are made at a lower power level at which adequate margin is 1

FQC (X, Y, Z) available before going to 100% RTP. Also, this Frequency condition, FQM (X, Y, Z) together with the Frequency condition requiring verification of FQC ( Z) and FQW ( Z) 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 FQC (X, Y, Z) increase power to RTP and operate for 31 days without verification of FQC ( Z) and FQW ( Z) . The Frequency condition is not intended to require FQM (X, Y, Z) verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level X,Y,Z is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.

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Enclosure 2, Volume 7, Rev. 0, Page 69 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.1 the overall measured FQ (X,Y,Z)

C F ( X , Y , Z)

Q Direct verification Verification that FQC ( Z) is within its specified limits involves increasing FQM ( Z) to allow for manufacturing tolerance and measurement FQC (X, Y, Z) 1 uncertainties in order to obtain FQC ( Z) . Specifically, FQM ( Z) is the measured value of FQ(Z) obtained from incore flux map results and FQC ( Z)

= FQM ( Z) [1.0815] (Ref. 4). FQC ( Z) is then compared to its specified limits. 3 FQC (X, Y, Z)

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

INSERT 7 4 C

F ( X , Y , Z)

Performing this Surveillance in MODE 1 prior to exceeding 75% RTP 1

ensures that the FQC ( Z) limit is met when RTP is achieved, because Q

peaking factors generally decrease as power level is increased.

FQC (X, Y, Z)

If THERMAL POWER has been increased by 10% RTP since the last determination of FQC ( Z) , another evaluation of this factor is required 1 C

[12] hours after achieving equilibrium conditions at this higher power level F ( X , Y , Z) 2 Q

(to ensure that FQC ( Z) values are being reduced sufficiently with power 1

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 6 Specifications (TS).

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

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SEQUOYAH UNIT 1 Revision XXX 2

WOG STS B 3.2.1B-8 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 69 of 249

Enclosure 2, Volume 7, Rev. 0, Page 70 of 249 3.2.1 4 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 f2(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 f2(I) min margin is negative then a direct evaluation of the steady state limit is required to satisfy this surveillance requirement.

Insert Page B 3.2.1-8 Enclosure 2, Volume 7, Rev. 0, Page 70 of 249

Enclosure 2, Volume 7, Rev. 0, Page 71 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES SURVEILLANCE REQUIREMENTS (continued) and 3.2.1.3 5

SR 3.2.1.2 2

The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps FQ (X,Y,Z) 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 INSERT 8 maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, FQC ( Z) , by W(Z) gives the maximum FQ(Z) calculated to occur in normal operation, FQW ( Z) .

4 The limit with which FQW ( Z) is compared varies inversely with power INSERT 9 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.

BQDES (X,Y,Z) and BCDES (X,Y,Z) Flux map data are typically taken for 30 to 75 core elevations. FQW ( Z) limits 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.

and found to be within the applicable limiting condition limits based on future projections This Surveillance has been modified by a Note that may require that more frequent surveillances be performed. If FQW ( Z) is evaluated, an evaluation FQM (X, Y, Z) of the expression below is required to account for any increase to FQM ( Z) that may occur and cause the FQ(Z) limit to be exceeded before the next required FQ(Z) evaluation. FQ (X,Y,Z)

INSERT 10 If the two most recent FQ(Z) evaluations show an increase in the 4 expression maximum over z [ FQC ( Z) / K(Z) ], it is required to meet the FQ(Z) limit with the last FQW ( Z) increased by the greater of a factor of

[1.02] or by an appropriate factor specified in the COLR (Ref. 5)

SEQUOYAH UNIT 1 Revision XXX 2

WOG STS B 3.2.1B-9 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 71 of 249

Enclosure 2, Volume 7, Rev. 0, Page 72 of 249 3.2.1 4

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).

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

Insert Page B 3.2.1-9a Enclosure 2, Volume 7, Rev. 0, Page 72 of 249

, Volume 7, Rev. 0, Page 73 of 249 3.2.1 4

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 FQM ( X, Y, Z) for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an FQM ( X, Y, Z) > 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 FQM ( X, Y, Z) are unfavorable, additional actions must be taken. These actions are to meet the FQ(X,Y,Z) limit with the last FQM (X, Y, Z) increased by the appropriate factor specified in the COLR or to evaluate FQM (X, Y, Z) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative requirements prevent FQ(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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions to ensure that FQ(X,Y,Z) is within its limit at higher power levels.

Insert Page B 3.2.1-9b , Volume 7, Rev. 0, Page 73 of 249

Enclosure 2, Volume 7, Rev. 0, Page 74 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS 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 FQ(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection. 4 Performing the Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the FQ(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 FQ(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 FQ(Z) evaluations.

[ The Frequency of 31 EFPD is adequate to monitor the change of power 6

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.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SEQUOYAH UNIT 1 Revision XXX 2

WOG STS B 3.2.1B-10 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 74 of 249

Enclosure 2, Volume 7, Rev. 0, Page 75 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 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 4 Control (and) FQ Surveillance Technical Specification," February 1994.

BAW-10163PA Core Operating Limit Methodology for Westinghouse-Designed PWRs June 1989.

SEQUOYAH UNIT 1 Revision XXX WOG STS B 3.2.1B-11 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 75 of 249

Enclosure 2, Volume 7, Rev. 0, Page 76 of 249 Fq(z)@

arzrj B 3'2'1s %

DO NOT OPERATE IN THIS AREA (6.0, 1 .0)

9, o.g4)

(12.0,0.65) g 06

\<

IGURE FOR ILLUS RATION ONLY.

NOT USE FOR OPERATION FT. 2 46 I 12

(.) % 16.6 33.3 50.0 66.7 100 CORE HEIGHT Fo r c re height of 12 feet Figure B 3.2. 1B-1 (page 1 of 1)

K(Z) , Normalized Fo(Z) as a Function of Core Height

+

WOG STS B 3.2.1s12 oo Enclosure 2, Volume 7, Rev. 0, Page 76 of 249

Enclosure 2, Volume 7, Rev. 0, Page 77 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 B 3.2 POWER DISTRIBUTION LIMITS 2 1 B 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology)

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

and by assembly location, X, Y 1 FQ(Z) is defined as the maximum local fuel rod linear power density X,Y,Z divided by the average fuel rod linear power density, assuming nominal 8 X,Y,Z fuel pellet and fuel rod dimensions. Therefore, FQ(Z) is a measure of the peak fuel pellet power within the reactor core.

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

FQ(Z) varies with fuel loading patterns, control bank insertion, fuel burnup, 1 X,Y,Z and changes in axial power distribution.

FQ(Z) is measured periodically using the incore detector system. These 1 X,Y,Z measurements are generally taken with the core at or near equilibrium conditions.

Using the measured three dimensional power distributions, it is possible X,Y,Z to derive a measured value for FQ(Z). However, because this value represents an equilibrium condition, it does not include the variations in the value of FQ(Z) which are present during nonequilibrium situations X,Y,Z such as load following or power ascension. 1 INSERT 1 To account for these possible variations, the equilibrium value of FQ(Z) is adjusted as FQW ( Z ) by 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.

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-1 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 77 of 249

Enclosure 2, Volume 7, Rev. 0, Page 78 of 249 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."

Insert Page B 3.2.1-1 Enclosure 2, Volume 7, Rev. 0, Page 78 of 249

Enclosure 2, Volume 7, Rev. 0, Page 79 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES 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 FQ(Z) ensure that the value of the initial total peaking factor X,Y,Z 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. 1 X,Y,Z FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the FQ(Z) limit assumed in safety analyses for other X,Y,Z postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents 8 X,Y,Z FQ(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The Heat Flux Hot Channel Factor, FQ(Z), shall be limited by the following relationships: RTP X,Y,Z FQ X,Y,Z FQ(Z) (CFQ / P) K(Z) for P > 0.5 1

F QRTP X,Y,Z FQ(Z) (CFQ / 0.5) K(Z) for P 0.5 F QRTP X,Y,Z where: CFQ is the FQ(Z) limit at RTP provided in the COLR, FQ (X,Y,Z)

K(Z) is the normalized FQ(Z) as a function of core height provided in the COLR, and P = THERMAL POWER / RTP SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-2 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 79 of 249

Enclosure 2, Volume 7, Rev. 0, Page 80 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES LCO (continued)

SQN F QRTP 1

F QRTP For this facility, the actual values of CFQ and K(Z) are given in the COLR; 2.62 3 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.

INSERT 2 For Relaxed Axial Offset Control operation, FQ(Z) is approximated by FQC ( Z) and FQW ( Z ) . Thus, both FQC ( Z) and FQW ( Z ) must meet the preceding limits on FQ(Z).

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

From the incore flux map results we obtain the measured value ( FQM ( Z) ) of FQ(Z). Then, FQC ( Z) = FQM ( Z) [1.0815]

where [1.0815] is a factor that accounts for fuel manufacturing tolerances 4

and flux map measurement uncertainty.

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

The expression for FQW ( Z ) is:

FQW ( Z ) = FQC ( Z) W(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 FQC ( Z) 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 X,Y,Z 1 that it can stay within the LOCA FQ(Z) limits. If FQC ( Z) cannot be FQC (X, Y, Z) maintained within the LCO limits, reduction of the core power is required and if FQW ( Z ) cannot be maintained within the LCO limits, reduction of the 5 AFD limits is required. Note that sufficient reduction of the AFD limits will also result in a reduction of the core power.

X,Y,Z X,Y,Z Violating the LCO limits for FQ(Z) produces unacceptable consequences if 1 a design basis event occurs while FQ(Z) is outside its specified limits.

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-3 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 80 of 249

Enclosure 2, Volume 7, Rev. 0, Page 81 of 249 3.2.1 4

INSERT 2 Measured FQ(X,Y,Z) is compared against three limits:

Steady state limit, (FQRTP / 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 FQC (X, Y, Z) for the steady state limit on FQ(X,Y,Z). An FQC (X, Y, Z) 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 ( FQM ( X, Y, Z) ) of FQ(X,Y,Z). Then, FQC (X, Y, Z) = overall measured FQ(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 ( FQM ( X, Y, Z) ) of FQ(X,Y,Z). FQM (X, Y, Z) 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) = Pd(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.

Insert Page B 3.2.1-3a Enclosure 2, Volume 7, Rev. 0, Page 81 of 249

Enclosure 2, Volume 7, Rev. 0, Page 82 of 249 3.2.1 4

INSERT 2 (continued)

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

FQM (X, Y, Z) 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.

Insert Page B 3.2.1-3b Enclosure 2, Volume 7, Rev. 0, Page 82 of 249

Enclosure 2, Volume 7, Rev. 0, Page 83 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES X,Y,Z 1

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

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

ACTIONS A.1 FQC (X, Y, Z)

FQC (X, Y, Z)

Reducing THERMAL POWER by 1% RTP for each 1% by which FQC ( Z) exceeds its limit, maintains an acceptable absolute power density. FQC ( Z)

FQM (X, Y, Z) is FQM ( Z) multiplied by a factor accounting for manufacturing tolerances F (X,Y,Z)

FQM (X, Y, Z) Q and measurement uncertainties. FQM ( Z) is the measured value of FQ(Z).

The Completion Time of 15 minutes provides an acceptable time to 5 reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The FQC (X, Y, Z) maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of FQC ( Z ) and would FQC (X, Y, Z) require power reductions within 15 minutes of the FQC ( Z) determination, if FQC (X, Y, Z) necessary to comply with the decreased maximum allowable power level.

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

INSERT 3 4 5 A.2 FQC (X, Y, Z)

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

FQC (X, Y, Z) would require Power Range Neutron Flux - High trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the FQC ( Z) determination, if necessary to comply with FQC (X, Y, Z) the decreased maximum allowable Power Range Neutron Flux - High trip setpoints. Decreases in FQC ( Z) would allow increasing the maximum allowable Power Range Neutron Flux - High trip setpoints.

Move to next page after A.3 SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-4 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 83 of 249

Enclosure 2, Volume 7, Rev. 0, Page 84 of 249 3.2.1 5

INSERT 3 A.2 Required Action A.2 requires an administrative reduction of the AFD limits by 1% for each 1% by which FQC ( X, Y, Z) exceeds the steady state limit. The allowed Completion Time of 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded. The maximum allowable AFD limits initially determined by Required Action A.2 may be affected by subsequent determinations of FQC (X, Y, Z) and would require further AFD limit reductions within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the FQC (X, Y, Z) determination, if necessary to comply with the decreased maximum allowable AFD limits.

Decreases in FQ ( X , Y , Z ) would allow increasing the maximum allowable AFD C

limits.

Insert Page B 3.2.1-4 Enclosure 2, Volume 7, Rev. 0, Page 84 of 249

Enclosure 2, Volume 7, Rev. 0, Page 85 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES ACTIONS (continued)

A.3 in T span C

F (X, Y, Z)

Reduction in the Overpower T trip setpoints (value of K4) by 1% for each 1% by which FQC ( Z) exceeds its limit, is a conservative action for Q

protection against the consequences of severe transients with 48 unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER in 5 accordance with Required Action A.1. The maximum allowable FQC (X, Y, Z) Overpower T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of FQC ( Z) and would FQC (X, Y, Z) require Overpower T trip setpoint reductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of the 48 FQC ( Z) determination, if necessary to comply with the decreased maximum FQC (X, Y, Z) allowable Overpower T trip setpoints. Decreases in FQC ( Z) would allow increasing the maximum allowable Overpower T trip setpoints.

5 A.4 FQC (X, Y, Z) steady state and transient Verification that F ( Z) has been restored to within its limit, by performing C

Q 1

3 5

, SR 3.2.1.2 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.

5 INSERT 4 5

Condition A is modified by a Note that requires Required Action A.4 to be performed whenever the Condition is entered. This ensures that 3 5

, SR 3.2.1.2 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. 5 3 5 1

, SR 3.2.1.2 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. FC (X, Y, Z)

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

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-5 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 85 of 249

Enclosure 2, Volume 7, Rev. 0, Page 86 of 249 3.2.1 5

INSERT 4 Since FQC ( X, Y, Z) 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.

Insert Page B 3.2.1-5a Enclosure 2, Volume 7, Rev. 0, Page 86 of 249

, Volume 7, Rev. 0, Page 87 of 249 3.2.1 4 5 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 FQM ( X, Y, Z) and the limiting condition operational limit, BQDES (X,Y,Z), as follows:

FQM ( X ,Y , Z )

1

100 %

%AFD margin = BQDES ( X ,Y , Z )

The AFD min margin = minimum % margin value of all locations examined. If the reactor core is operating as designed, then FQM ( X, Y, Z) is less than BQDES (X,Y,Z) and calculation of %AFD margin is not required. If the AFD margin is less than zero, then FQM ( X, Y, Z) 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 (PSLOPEAFD * % AFD Margin)

ANL = NAFDL + Absolute Value of (NSLOPEAFD * % 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 FQM (X, Y, Z) 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 FQM (X, Y, Z) 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , restricts the axial flux distribution such that even if a transient occurred, core peaking factor limits are not exceeded.

Insert Page B 3.2.1-5b , Volume 7, Rev. 0, Page 87 of 249

, Volume 7, Rev. 0, Page 88 of 249 3.2.1 4 5 INSERT 6 C.1 and C.2 The FQ(X,Y,Z) margin supporting the Overpower T f2(I) breakpoints (f2(I) margin) during transient operations is based on the relationship between FQM (X, Y, Z) and the limit, BCDES(X,Y,Z), as follows:

FQM ( X ,Y , Z )

1

100%

% f2(I) margin =

BCDES( X ,Y , Z )

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

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

Posf2(I)Adjusted = Posf2(I)Limit - Absolute Value of (PSLOPEf2(I) * % f2(I)

Margin)

Negf2(I)Adjusted = Negf2(I)Limit + Absolute Value of (NSLOPEf2(I) * %

f2(I) Margin) where:

Posf2(I)Adjusted is the adjusted OPT positive f2(I) breakpoint limit.

Negf2(I)Adjusted is the adjusted OPT negative f2(I) breakpoint limit.

Posf2(I)Limit is the OPT positive f2(I) breakpoint limit defined in the COLR.

Negf2(I)Limit is the OPT negative f2(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 FQM (X, Y, Z) 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 FQM (X, Y, Z) exceeds BCDES(X,Y,Z) as defined in the COLR.

% f2(I) Margin is the most negative margin determined above.

Insert Page B 3.2.1-5c , Volume 7, Rev. 0, Page 88 of 249

, Volume 7, Rev. 0, Page 89 of 249 3.2.1 5

4 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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is sufficient considering the small likelihood of a limiting transient in this time period.

Insert Page B 3.2.1-5d , Volume 7, Rev. 0, Page 89 of 249

Enclosure 2, Volume 7, Rev. 0, Page 90 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES ACTIONS (continued)

The implicit assumption is that if W(Z) values were recalculated (consistent with the reduced AFD limits), then FQC ( Z) times the recalculated W(Z) values would meet the FQ(Z) limit. Note that complying with this action (of reducing AFD limits) may also result in a power reduction. Hence the need for Required Actions B.2, B.3 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.3 5

Reduction in the Overpower T trip setpoints value of K4 by 1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER as a result of reducing AFD limits in accordance with Required Action B.1.

B.4 Verification that FQW ( Z ) has been restored to within its limit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the maximum allowable power limit imposed by Required Action B.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 FQ(Z) is properly evaluated prior to increasing THERMAL POWER.

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-6 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 90 of 249

Enclosure 2, Volume 7, Rev. 0, Page 91 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES ACTIONS (continued)

D C.1 5 A.5, B.1, B.2, C.1 or C.2 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

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 3.2.1.2 performance 3 is not required SURVEILLANCE SR 3.2.1.1 and SR 3.2.1.2 are modified by a Note. The Note applies 5 REQUIREMENTS during the first power ascension after a refueling. It states that 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER may be increased until an equilibrium power level has been achieved at which a power distribution map can be obtained.

FQC (X, Y, Z)

This allowance is modified, however, by one of the Frequency conditions that requires verification that FQC ( Z) and FQW ( Z ) are within their specified FQM (X, Y, Z) limits after a power rise of more than 10% RTP over the THERMAL FQC (X, Y, Z)

POWER at which they were last verified to be within specified limits.

Because FQC ( Z) and FQW ( Z ) could not have previously been measured in FQM (X, Y, Z) this reload core, there is a second Frequency condition, applicable only FQC (X, Y, Z) for reload cores, that requires determination of these parameters before exceeding 75% RTP. This ensures that some determination of FQC ( Z) and FQM (X, Y, Z)

FQW ( Z ) are made at a lower power level at which adequate margin is 1

FQC (X, Y, Z) available before going to 100% RTP. Also, this Frequency condition, FQM (X, Y, Z) together with the Frequency condition requiring verification of FQC ( Z) and FQW ( Z ) 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 FQC (X, Y, Z) increase power to RTP and operate for 31 days without verification of FQC ( Z) and FQW ( Z ) . The Frequency condition is not intended to require FQM (X, Y, Z) verification of these parameters after every 10% increase in power level above the last verification. It only requires verification after a power level X,Y,Z is achieved for extended operation that is 10% higher than that power at which FQ(Z) was last measured.

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-7 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 91 of 249

Enclosure 2, Volume 7, Rev. 0, Page 92 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.1 the overall measured FQ (X,Y,Z)

C F (X, Y, Z)

Q Direct verification Verification that FQC ( Z) is within its specified limits involves increasing FQM ( Z) to allow for manufacturing tolerance and measurement FQC (X, Y, Z) 1 uncertainties in order to obtain FQC ( Z) . Specifically, FQM ( Z) is the measured value of FQ(Z) obtained from incore flux map results and FQC ( Z)

= FQM ( Z) [1.0815] (Ref. 4). FQC ( Z) is then compared to its specified limits. 3 FQC (X, Y, Z)

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

INSERT 7 4 C

F (X, Y, Z)

Performing this Surveillance in MODE 1 prior to exceeding 75% RTP 1

ensures that the FQC ( Z) limit is met when RTP is achieved, because Q

peaking factors generally decrease as power level is increased.

FQC (X, Y, Z)

If THERMAL POWER has been increased by 10% RTP since the last determination of FQC ( Z) , another evaluation of this factor is required 1 C

[12] hours after achieving equilibrium conditions at this higher power level F (X, Y, Z) 2 Q

(to ensure that FQC ( Z) values are being reduced sufficiently with power 1

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 6 Specifications (TS).

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

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7 description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-8 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 92 of 249

Enclosure 2, Volume 7, Rev. 0, Page 93 of 249 3.2.1 4 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 f2(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 f2(I) min margin is negative then a direct evaluation of the steady state limit is required to satisfy this surveillance requirement.

Insert Page B 3.2.1-8 Enclosure 2, Volume 7, Rev. 0, Page 93 of 249

Enclosure 2, Volume 7, Rev. 0, Page 94 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES SURVEILLANCE REQUIREMENTS (continued) and 3.2.1.3 5

SR 3.2.1.2 2

The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. Because flux maps FQ (X,Y,Z) 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 INSERT 8 maximum peaking factor increase over steady state values, calculated as a function of core elevation, Z, is called W(Z). Multiplying the measured total peaking factor, FQC ( Z) , by W(Z) gives the maximum FQ(Z) calculated to occur in normal operation, FQW ( Z ) .

4 The limit with which FQW ( Z ) is compared varies inversely with power INSERT 9 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.

BQDES (X,Y,Z) and BCDES (X,Y,Z) Flux map data are typically taken for 30 to 75 core elevations. FQW ( Z )

limits 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.

and found to be within the applicable limiting condition limits based on future projections This Surveillance has been modified by a Note that may require that more frequent surveillances be performed. If FQW ( Z ) is evaluated, an evaluation FQM (X, Y, Z) of the expression below is required to account for any increase to FQM ( Z) that may occur and cause the FQ(Z) limit to be exceeded before the next required FQ(Z) evaluation. FQ (X,Y,Z)

INSERT 10 If the two most recent FQ(Z) evaluations show an increase in the 4 expression maximum over z [ FQC ( Z) / K(Z) ], it is required to meet the FQ(Z) limit with the last FQW ( Z ) increased by the greater of a factor of

[1.02] or by an appropriate factor specified in the COLR (Ref. 5)

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-9 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 94 of 249

Enclosure 2, Volume 7, Rev. 0, Page 95 of 249 3.2.1 4

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).

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

Insert Page B 3.2.1-9a Enclosure 2, Volume 7, Rev. 0, Page 95 of 249

, Volume 7, Rev. 0, Page 96 of 249 3.2.1 4

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 FQM ( X, Y, Z) for the last two measurements out to 31 EFPD beyond the most recent measurement. If the extrapolation yields an FQM ( X, Y, Z) > 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 FQM ( X, Y, Z) are unfavorable, additional actions must be taken. These actions are to meet the FQ(X,Y,Z) limit with the last FQM (X, Y, Z) increased by the appropriate factor specified in the COLR or to evaluate FQM (X, Y, Z) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative requirements prevent FQ(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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions to ensure that FQ(X,Y,Z) is within its limit at higher power levels.

Insert Page B 3.2.1-9b , Volume 7, Rev. 0, Page 96 of 249

Enclosure 2, Volume 7, Rev. 0, Page 97 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 2 BASES SURVEILLANCE REQUIREMENTS (continued)

REVIEWERS 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 FQ(Z) more frequently, each 7 EFPD. These alternative requirements prevent FQ(Z) from exceeding its limit for any significant period of time without detection. 4 Performing the Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the FQ(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 FQ(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 FQ(Z) evaluations.

[ The Frequency of 31 EFPD is adequate to monitor the change of power 6

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.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7

description, given above, and the appropriate choice of Frequency in the Surveillance Requirement.

]

SEQUOYAH UNIT 2 Revision XXX 2

WOG STS B 3.2.1B-10 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 97 of 249

Enclosure 2, Volume 7, Rev. 0, Page 98 of 249 FQ(Z) (RAOC-W(Z) Methodology) 1 X,Y,Z B 3.2.1B 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 4 Control (and) FQ Surveillance Technical Specification," February 1994.

BAW-10163PA Core Operating Limit Methodology for Westinghouse-Designed PWRs June 1989.

SEQUOYAH UNIT 2 Revision XXX WOG STS B 3.2.1B-11 Rev. 4.0, 1 2 Enclosure 2, Volume 7, Rev. 0, Page 98 of 249

Enclosure 2, Volume 7, Rev. 0, Page 99 of 249 Fo(z)@

EvaJ B 3'218 %

DO NOT OPERATE IN THIS AREA (6.0, 1 .0)

.8,0.94)

(12.0,0.65)

\t

\<

0.6 IGURE FOR ILLUS RATION ONLY.

NOT USE FOR OPERATION FT. 2 46 I 12

(-) To 16.6 33.3 50.0 66 .7 100 CORE HEIGHT

For c re height of 12 feet Figure B 3.2. 1B-1 (page 1 of 1)

K(Z) - Normalized Fo(Z) as a Function of Core Height WOGTSTS B 3.2.1912 oo Enclosure 2, Volume 7, Rev. 0, Page 99 of 249

Enclosure 2, Volume 7, Rev. 0, Page 100 of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, BASES, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

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-FXY 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.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 7, Rev. 0, Page 100 of 249

Enclosure 2, Volume 7, Rev. 0, Page 101 of 249 Specific No Significant Hazards Considerations (NSHCs)

Enclosure 2, Volume 7, Rev. 0, Page 101 of 249

Enclosure 2, Volume 7, Rev. 0, Page 102 of 249 DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(X,Y,Z))

There are no specific No Significant Hazards Considerations for this Specification.

Sequoyah Unit 1 and 2 Page 1 of 1 Enclosure 2, Volume 7, Rev. 0, Page 102 of 249

Enclosure 2, Volume 7, Rev. 0, Page 103 of 249 ATTACHMENT 2 ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))

Enclosure 2, Volume 7, Rev. 0, Page 103 of 249

, Volume 7, Rev. 0, Page 104 of 249 Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs) , Volume 7, Rev. 0, Page 104 of 249

Enclosure 2, Volume 7, Rev. 0, Page 105 of 249 A01 ITS ITS 3.2.2 POWER DISTRIBUTION LIMITS 3/4.2.3 NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)

LIMITING CONDITION FOR OPERATION LCO 3.2.2 3.2.3 FH(X,Y) shall be maintained within the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1 ACTION:

Add proposed ACTION A Note M01 With FH(X,Y) exceeding the limit specified in the COLR:

ACTION A

a. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months either:

1. Restore FH(X,Y) to within the limit specified in the COLR, or A02 Required Action 2. Reduce the allowable THERMAL POWER from RATED THERMAL POWER at least A.1 RRH*% for each 1% that FH(X,Y) exceeds the limit, and LA01 ACTION A

b. Within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months either:

72 L01

1. Restore FH(X,Y) to within the limit specified in the COLR, or A02 LA01 Required Action

2. Reduce the Power Range Neutron Flux-High Trip Setpoint in Table 2.2-1 at least RRH*%

A.2 for each 1% that FH(X,Y) exceeds that limit, and ACTION A

c. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of initially being outside the limit specified in the COLR, either:

A02

1. Restore FH(X,Y) to within the limit specified in the COLR, or LA02 Required Action 2. Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the A.3 reduced THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to ACTION C less than 5% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . L02 6

Add proposed ACTION C M02

RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds LA01 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 Page 1 of 8 Enclosure 2, Volume 7, Rev. 0, Page 105 of 249

Enclosure 2, Volume 7, Rev. 0, Page 106 of 249 A01 ITS ITS 3.2.2 POWER DISTRIBUTION LIMITS ACTION: (Continued)

d. Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of initially being outside the limit specified in the COLR, reduce the Required Action A.4 Overtemperature Delta T K1 term in Table 2.2-1 by at least TRH** for each 1% that FH(X,Y)

LA03 exceeds the limit, and Add proposed Required Action A.5 Note

e. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL A03 Required Action POWER above the reduced THERMAL POWER limit required by ACTION a.2 and/or b.

A.5 and/or c. and/or d., above: subsequent POWER OPERATION may proceed provided that LA02 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, Completion Time 2. A nominal 75% of RATED THERMAL POWER, and A.5

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining greater than or equal to 95% of RATED THERMAL POWER.

- TRH is the amount of Overtemperature Delta T K1 setpoint reduction required to compensate for LA03 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 Page 2 of 8 Enclosure 2, Volume 7, Rev. 0, Page 106 of 249

Enclosure 2, Volume 7, Rev. 0, Page 107 of 249 A01 ITS ITS 3.2.2 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS M03 SR NOTE 4.2.3.1 The provisions of Specification 4.0.4 are not applicable.

SR 3.2.2.1 M (X,Y) shall be evaluated to determine if FH(X,Y) is within its limit by:

SR 3.2.2.2 4.2.3.2 FH M

a. Using the movable incore detectors to obtain a power distribution map FH (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:

FMH (X,Y) LA04 F HR M (X,Y) =

MAP M / AXIAL(X,Y)

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:

F HR M (X,Y)

SR 3.2.2.1 % FH Margin = 1 x 100%

BHDES(X,Y)

LA04 SR 3.2.2.2 F HR (X, Y)

M

% f 1 ( I)Margin = 1 x 100%

BRDES(X, Y) 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 FH M (X,Y) and F)HRM(X,Y), LA04 because the limits include uncertainties.

- BHNOM(X,Y), MAPM, 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 Page 3 of 8 Enclosure 2, Volume 7, Rev. 0, Page 107 of 249

Enclosure 2, Volume 7, Rev. 0, Page 108 of 249 A01 ITS ITS 3.2.2 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 LA04 f1(I) min margin = minimum % margin value of all locations examined LA01 ACTION A 3. If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 M04 Action statements for 3.2.3 apply.

ACTION B LA03

4. If the f1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 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 M04 the action statements for 3.2.3 apply.

SR 3.2.2.1/SR 3.2.2.2 d. With two measurements extrapolated to 31 EFPD beyond the most recent measurement NOTE yielding FHRM(X,Y) > BHNOM(X,Y) either of the following actions shall be taken:

SR 3.2.2.1/SR 3.2.2.2 M NOTE a. 1. FH (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 SR 3.2.2.1/SR 3.2.2.2 M

NOTE b. 2. FH (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.

SR 3.2.2.1 4.2.3.3 FM H (X,Y) shall be determined to be within its limit by using the incore detectors to obtain a power LA02 SR 3.2.2.2 distribution map:

SR 3.2.2.1 a. Prior to operation above 75% of RATED THERMAL POWER after each fuel loading, and SR 3.2.2.2 In accordance with the Surveillance LA05

b. At least once per 31 EFPD. Frequency Control Program thereafter A04

RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds LA01 the limit provided in the COLR per Specification 6.9.1.14.

- TRH is the amount of Overtemperature Delta T K1 setpoint reduction required to compensate for LA03 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 Page 4 of 8 Enclosure 2, Volume 7, Rev. 0, Page 108 of 249

Enclosure 2, Volume 7, Rev. 0, Page 109 of 249 A01 ITS ITS 3.2.2 POWER DISTRIBUTION LIMITS 3/4.2.3 NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)

LIMITING CONDITION FOR OPERATION LCO 3.2.2 3.2.3 FH(X,Y) shall be maintained within the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1 ACTION:

Add proposed ACTION A Note M01 With FH(X,Y) exceeding the limit specified in the COLR:

ACTION A

a. Within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months either:

1. Restore FH(X,Y) to within the limit specified in the COLR, or A02 Required Action 2. Reduce the allowable THERMAL POWER from RATED THERMAL POWER at least RRH*% for A.1 each 1% that FH(X,Y) exceeds the limit, and LA01 ACTION A

b. Within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months either:

72 L01

1. Restore FH(X,Y) to within the limit specified in the COLR, or A02 Required Action 2. Reduce the Power Range Neutron Flux-High Trip Setpoint in Table 2.2-1 at least RRH*% for each A.2 1% that FH(X,Y) exceeds that limit, and LA01 ACTION A

c. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 A02 LA02 Required Action 2. Verify through incore flux mapping that FH(X,Y) is restored to within the limit for the reduced A.3 THERMAL POWER allowed by ACTION a.2 or reduce THERMAL POWER to less than 5% of ACTION C RATED THERMAL POWER within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

6 L02 Add proposed ACTION C M02

RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds LA01 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 Page 5 of 8 Enclosure 2, Volume 7, Rev. 0, Page 109 of 249

Enclosure 2, Volume 7, Rev. 0, Page 110 of 249 A01 ITS ITS 3.2.2 POWER DISTRIBUTION LIMITS ACTION: (Continued)

d. Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of initially being outside the limit specified in the COLR, reduce the Required Action A.4 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 LA03 Add proposed Required Action A.5 Note

e. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL A03 Required Action POWER above the reduced THERMAL POWER limit required by ACTION a.2 and/or b.

A.5 and/or c. and/or d., above; subsequent POWER OPERATION may proceed provided that LA02 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, Completion Time 2. A nominal 75% of RATED THERMAL POWER, and A.5

3. Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of attaining greater than or equal to 95% of RATED THERMAL POWER.

- TRH is the amount of Overtemperature Delta T K1 setpoint reduction required to compensate for LA03 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 Page 6 of 8 Enclosure 2, Volume 7, Rev. 0, Page 110 of 249

Enclosure 2, Volume 7, Rev. 0, Page 111 of 249 A01 ITS ITS 3.2.2 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS SR NOTE M03 4.2.3.1 The provisions of Specification 4.0.4 are not applicable.

SR 3.2.2.1 4.2.3.2 FHM (X,Y)

SR 3.2.2.2 shall be evaluated to determine if FH(X,Y) is within its limit by:

M (X,Y)

a. Using the movable incore detectors to obtain a power distribution map FH

at any THERMAL POWER greater than 5% of RATED THERMAL POWER.

b. Satisfying the following relationship:

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

Where:

LA04 M

F HR M (X,Y) = F H (X,Y)

M MAP / AXIAL(X, Y)

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:

F HR M (X,Y)

SR 3.2.2.1

% F H Margin = 1 x 100%

BHDES(X,Y)

LA04 F HR M (X, Y)

SR 3.2.2.2 % f 1 ( I)Margin = 1 x 100%

BRDES(X, Y) 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.

M No additional uncertainties are required in the following equations for FH(X,Y)1 and FHRM(X,Y),

because the limits include uncertainties. LA04

- BHNOM (X,Y), MAPM, 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 Page 7 of 8 Enclosure 2, Volume 7, Rev. 0, Page 111 of 249

Enclosure 2, Volume 7, Rev. 0, Page 112 of 249 A01 ITS ITS 3.2.2 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 LA04 f1(I) min margin = minimum % margin value of all locations examined ACTION A 3. If the FH min margin in 4.2.3.2.c.2 above is < 0, then within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months reduce the LA01 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; M04 otherwise the Action statements for 3.2.3 apply.

ACTION B

4. If the f1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months reduce the LA03 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 M04 the action statements for 3.2.3 apply.

SR 3.2.2.1/SR 3.2.2.2 d. With two measurements extrapolated to 31 EFPD beyond the most recent measurement NOTE yielding FHRM (X,Y) > BHNOM (X,Y) either of the following actions shall be taken:

SR 3.2.2.1/SR 3.2.2.2 NOTE a. 1. M F H (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 SR 3.2.2.1/SR 3.2.2.2 2. M FH (X,Y)

NOTE b 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.

M (X,Y)

SR 3.2.2.1 4.2.3.3 FH shall be determined to be within its limit by using the incore detectors to obtain a LA02 SR 3.2.2.2 power distribution map:

SR 3.2.2.1 a. Prior to operation above 75% of RATED THERMAL POWER after each fuel loading, and SR 3.2.2.2 In accordance with the Surveillance LA05 Frequency Control Program

b. At least once per 31 EFPD.

thereafter A04

RRH is the amount of power reduction required to compensate for each 1% that FH(X,Y) exceeds LA01 the limit provided in the COLR per Specification 6.9.1.14.

- TRH is the amount of Overtemperature Delta T K1 setpoint reduction required to compensate for LA03 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 Page 8 of 8 Enclosure 2, Volume 7, Rev. 0, Page 112 of 249

Enclosure 2, Volume 7, Rev. 0, Page 113 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)

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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 Sequoyah Unit 1 and Unit 2 Page 1 of 8 Enclosure 2, Volume 7, Rev. 0, Page 113 of 249

Enclosure 2, Volume 7, Rev. 0, Page 114 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) 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 FMH (X,Y) to 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 Sequoyah Unit 1 and Unit 2 Page 2 of 8 Enclosure 2, Volume 7, Rev. 0, Page 114 of 249

Enclosure 2, Volume 7, Rev. 0, Page 115 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) 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 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months . ITS 3.2.2 ACTION C, states that the plant must be in MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , 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 for 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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 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 change allowance for not met is now limited to Sequoyah Unit 1 and Unit 2 Page 3 of 8 Enclosure 2, Volume 7, Rev. 0, Page 115 of 249

Enclosure 2, Volume 7, Rev. 0, Page 116 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) 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 f1(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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 f1(I) min margin in 4.2.3.2.c.2 above is < 0, then within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 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 f1(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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months when FH(X,Y) is not within limits, and states to reduce the allowable THERMAL POWER and within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 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)

Sequoyah Unit 1 and Unit 2 Page 4 of 8 Enclosure 2, Volume 7, Rev. 0, Page 116 of 249

Enclosure 2, Volume 7, Rev. 0, Page 117 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) 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 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 M

4.2.3.3 requires FH (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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months of FH(X,Y) being outside its limits, to 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. Similarly, CTS 4.2.3.2.c.4 requires in part to reduce Overtemperature Delta T K1 term in Sequoyah Unit 1 and Unit 2 Page 5 of 8 Enclosure 2, Volume 7, Rev. 0, Page 117 of 249

Enclosure 2, Volume 7, Rev. 0, Page 118 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)

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 f1(I) min margin. This changes the CTS by moving the details of the specific variable within OTT to be reduced, the location of the K1 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 f1(I) min margin. The specific variable within OTT to be reduced, the location of the K1 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 FMH(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 FMH(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 Sequoyah Unit 1 and Unit 2 Page 6 of 8 Enclosure 2, Volume 7, Rev. 0, Page 118 of 249

Enclosure 2, Volume 7, Rev. 0, Page 119 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y) 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . 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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

Sequoyah Unit 1 and Unit 2 Page 7 of 8 Enclosure 2, Volume 7, Rev. 0, Page 119 of 249

Enclosure 2, Volume 7, Rev. 0, Page 120 of 249 DISCUSSION OF CHANGES ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH(X,Y)

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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ." 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , either verify FH(X,Y) is restored within limits for the reduced power level or within the next 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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.

Sequoyah Unit 1 and Unit 2 Page 8 of 8 Enclosure 2, Volume 7, Rev. 0, Page 120 of 249

Enclosure 2, Volume 7, Rev. 0, Page 121 of 249 Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

Enclosure 2, Volume 7, Rev. 0, Page 121 of 249

Enclosure 2, Volume 7, Rev. 0, Page 122 of 249 FH(X,Y) 1 CTS FNH 3.2.2 3.2 POWER DISTRIBUTION LIMITS FH(X,Y) 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor ( FNH ) 1 FH(X,Y) 1 3.2.3 LCO 3.2.2 FNH shall be within the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3 2 DOC M01 A. ------------NOTE------------ A.1.1 Restore FNH to within limit. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Required Actions A.2 3 5

and A.3 must be OR ACTION a.2 completed whenever allowable 2 2 4 SR 4.2.3.2.c.3 Condition A is entered. A.1.2.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

POWER to < 50% RTP.

5 INSERT 1 SR 4.2.3.2.c.3 FNH not within limit. AND FH min margin < 0 6 2

A.1.2.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Neutron Flux - High trip ACTION b.2 setpoints to 55% RTP.

5 INSERT 2 AND 3

2 ACTION c.2 A.2 Perform SR 3.2.2.1 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND 3 INSERT 3 SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.2-1 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 122 of 249

Enclosure 2, Volume 7, Rev. 0, Page 123 of 249 CTS 3.2.2 5

INSERT 1 ACTION a.2 from RTP by RRH% multiplied times the FH min margin.

4.2.3.2.c.3 5

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

3 INSERT 3 ACTION d A.4 Reduce Overtemperature 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months T trip setpoint by TRH multiplied times the FH min margin.

AND Insert Page 3.2.2-1 Enclosure 2, Volume 7, Rev. 0, Page 123 of 249

Enclosure 2, Volume 7, Rev. 0, Page 124 of 249 FH(X,Y) 1 CTS FNH 3.2.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION e DOC A03 A.3 --------------NOTE-------------- 3 5 THERMAL POWER does not have to be reduced to comply with this Required Action.

ACTION e.1 Perform SR 3.2.2.1. Prior to THERMAL POWER exceeding 50% RTP AND ACTION e.2 Prior to THERMAL POWER exceeding 75% RTP AND ACTION e.3 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER INSERT 4 reaching 95% RTP 6 C C 6

ACTION c.2 DOC M02 B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.2-2 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 124 of 249

Enclosure 2, Volume 7, Rev. 0, Page 125 of 249 CTS 3.2.2 6

INSERT 4 CONDITION REQUIRED ACTION COMPLETION TIME B. f1(I) min margin < 0. B.1 Reduce Overtemperature 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months T trip setpoint by TRH 4.2.3.2.c.4 multiplied times the f1(I) min margin.

Insert Page 3.2.2-2 Enclosure 2, Volume 7, Rev. 0, Page 125 of 249

Enclosure 2, Volume 7, Rev. 0, Page 126 of 249 FH(X,Y) 1 CTS FNH 3.2.2 INSERT 5 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 8

INSERT 6 4.2.3.2.c.1 SR 3.2.2.1 Verify FNH is within limits specified in the COLR. Once after each 8 4.2.3.3.a 4.2.3.3.b FH min margin > 0 refueling prior to THERMAL POWER exceeding 75% RTP AND

[ 31 EFPD 9 thereafter OR 9 In accordance with the Surveillance Frequency Control Program ]

INSERT 7 8 SEQUOYAH UNIT 1 Amendment xxx WOG STS 3.2.2-3 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 126 of 249

Enclosure 2, Volume 7, Rev. 0, Page 127 of 249 CTS 3.2.2 7 INSERT 5

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

4.2.3.1 Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after an equilibrium power level has been achieved, at which a power distribution map can be obtained.

Insert Page 3.2.2-3a Enclosure 2, Volume 7, Rev. 0, Page 127 of 249

Enclosure 2, Volume 7, Rev. 0, Page 128 of 249 CTS 3.2.2 INSERT 6

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

If two measurements extrapolated to 31 EFPD 4.2.3.2.d beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) 4.2.3.2.d.1 a. Increase FM H (X,Y) by the appropriate factor specified in the COLR and reverify FH min margin > 0; or 4.2.3.2.d.2

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

Insert Page 3.2.2-3b Enclosure 2, Volume 7, Rev. 0, Page 128 of 249

Enclosure 2, Volume 7, Rev. 0, Page 129 of 249 CTS 3.2.2 8 INSERT 7 SURVEILLANCE FREQUENCY SR 3.2.2.2 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD 4.2.3.2.d beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) 4.2.3.2.d.1 a. Increase FM H (X,Y) by the appropriate factor specified in the COLR and reverify f1 (I) min margin > 0; or 4.2.3.2.d.2

b. Repeat SR 3.2.2.2 prior to the time at which the projected f1 (I) min margin will be < 0.

4.2.3.2.c.1 Verify f1(I) min margin > 0.

Once after each refueling prior to THERMAL POWER 4.2.3.3.a exceeding 75% RTP 4.2.3.3.b AND In accordance with the Surveillance Frequency Control Program Insert Page 3.2.2-3c Enclosure 2, Volume 7, Rev. 0, Page 129 of 249

Enclosure 2, Volume 7, Rev. 0, Page 130 of 249 FH(X,Y) 1 CTS FNH 3.2.2 3.2 POWER DISTRIBUTION LIMITS FH(X,Y) 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor ( FNH ) 1 FH(X,Y) 1 3.2.3 LCO 3.2.2 FNH shall be within the limits specified in the COLR.

Applicability APPLICABILITY: MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 3 2 DOC M01 A. ------------NOTE------------ A.1.1 Restore FNH to within limit. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Required Actions A.2 3 5

and A.3 must be OR ACTION a.2 completed whenever allowable 2 2 4 SR 4.2.3.2.c.3 Condition A is entered. A.1.2.1 Reduce THERMAL 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

POWER to < 50% RTP.

5 INSERT 1 SR 4.2.3.2.c.3 FNH not within limit. AND FH min margin < 0 6 2

A.1.2.2 Reduce Power Range 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Neutron Flux - High trip ACTION b.2 setpoints to 55% RTP.

5 INSERT 2 AND 3

2 ACTION c.2 A.2 Perform SR 3.2.2.1 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND 3 INSERT 3 SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.2-1 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 130 of 249

Enclosure 2, Volume 7, Rev. 0, Page 131 of 249 CTS 3.2.2 5

INSERT 1 ACTION a.2 from RTP by RRH% multiplied times the FH min margin.

4.2.3.2.c.3 5

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

3 INSERT 3 ACTION d A.4 Reduce Overtemperature 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months T trip setpoint by TRH multiplied times the FH min margin.

AND Insert Page 3.2.2-1 Enclosure 2, Volume 7, Rev. 0, Page 131 of 249

Enclosure 2, Volume 7, Rev. 0, Page 132 of 249 FH(X,Y) 1 CTS FNH 3.2.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME ACTION e DOC A03 A.3 --------------NOTE-------------- 3 5 THERMAL POWER does not have to be reduced to comply with this Required Action.

ACTION e.1 Perform SR 3.2.2.1. Prior to THERMAL POWER exceeding 50% RTP AND ACTION e.2 Prior to THERMAL POWER exceeding 75% RTP AND ACTION e.3 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER INSERT 4 reaching 95% RTP 6 C C 6

ACTION c.2 DOC M02 B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met.

SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.2-2 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 132 of 249

Enclosure 2, Volume 7, Rev. 0, Page 133 of 249 CTS 3.2.2 6

INSERT 4 CONDITION REQUIRED ACTION COMPLETION TIME B. f1(I) min margin < 0. B.1 Reduce Overtemperature 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months T trip setpoint by TRH 4.2.3.2.c.4 multiplied times the f1(I) min margin.

Insert Page 3.2.2-2 Enclosure 2, Volume 7, Rev. 0, Page 133 of 249

Enclosure 2, Volume 7, Rev. 0, Page 134 of 249 FH(X,Y) 1 CTS FNH 3.2.2 INSERT 5 7 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY 8

INSERT 6 4.2.3.2.c.1 SR 3.2.2.1 Verify FNH is within limits specified in the COLR. Once after each 8 4.2.3.3.a 4.2.3.3.b FH min margin > 0 refueling prior to THERMAL POWER exceeding 75% RTP AND

[ 31 EFPD 9 thereafter OR 9 In accordance with the Surveillance Frequency Control Program ]

INSERT 7 8 SEQUOYAH UNIT 2 Amendment xxx WOG STS 3.2.2-3 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 134 of 249

Enclosure 2, Volume 7, Rev. 0, Page 135 of 249 CTS 3.2.2 7 INSERT 5

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

4.2.3.1 Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after an equilibrium power level has been achieved, at which a power distribution map can be obtained.

Insert Page 3.2.2-3a Enclosure 2, Volume 7, Rev. 0, Page 135 of 249

Enclosure 2, Volume 7, Rev. 0, Page 136 of 249 CTS 3.2.2 INSERT 6

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

If two measurements extrapolated to 31 EFPD 4.2.3.2.d beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) 4.2.3.2.d.1 a. Increase FM H (X,Y) by the appropriate factor specified in the COLR and reverify FH min margin > 0; or 4.2.3.2.d.2

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

Insert Page 3.2.2-3b Enclosure 2, Volume 7, Rev. 0, Page 136 of 249

Enclosure 2, Volume 7, Rev. 0, Page 137 of 249 CTS 3.2.2 8 INSERT 7 SURVEILLANCE FREQUENCY SR 3.2.2.2 -------------------------------NOTE------------------------------

If two measurements extrapolated to 31 EFPD 4.2.3.2.d beyond the most recent measurement yield:

FHRM(X,Y) > BHNOM(X,Y) 4.2.3.2.d.1 a. Increase FM H (X,Y) by the appropriate factor specified in the COLR and reverify f1 (I) min margin > 0; or 4.2.3.2.d.2

b. Repeat SR 3.2.2.2 prior to the time at which the projected f1 (I) min margin will be < 0.

4.2.3.2.c.1 Verify f1(I) min margin > 0.

Once after each refueling prior to THERMAL POWER 4.2.3.3.a exceeding 75% RTP 4.2.3.3.b AND In accordance with the Surveillance Frequency Control Program Insert Page 3.2.2-3c Enclosure 2, Volume 7, Rev. 0, Page 137 of 249

Enclosure 2, Volume 7, Rev. 0, Page 138 of 249 JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))

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 FNH to 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 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 f1(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.

Sequoyah Unit 1 and Unit 2 Page 1 of 1 Enclosure 2, Volume 7, Rev. 0, Page 138 of 249

Enclosure 2, Volume 7, Rev. 0, Page 139 of 249 Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)

Enclosure 2, Volume 7, Rev. 0, Page 139 of 249

Enclosure 2, Volume 7, Rev. 0, Page 140 of 249 FH(X,Y)

F N H 1 B 3.2.2 B 3.2 POWER DISTRIBUTION LIMITS FH(X,Y)

B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor ( F N H ) 1 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.

FH(X,Y)

F N H is defined as the ratio of the integral of the linear power along the 1 fuel rod with the highest integrated power to the average integrated fuel FH(X,Y) rod power. Therefore, F N H is a measure of the maximum total power produced in a fuel rod.

F N H is sensitive to fuel loading patterns, bank insertion, and fuel burnup.

FH(X,Y)

F N H typically increases with control bank insertion and typically decreases with fuel burnup.

1 FH(X,Y)

F N H 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 FH(X,Y)

INSERT 1 computer to determine F N H . This factor is calculated at least every 2

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 design limit value using an NRC approved critical heat flux 1

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 F N H value that satisfies the LCO requirements.

FH(X,Y) 1 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.

SEQUOYAH UNIT 1 Revision XXX WOG STS B 3.2.2-1 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 140 of 249

, Volume 7, Rev. 0, Page 141 of 249 B 3.2.2 2

INSERT 1 An FH(X,Y) evaluation requires obtaining an incore flux map in MODE 1.

M The incore flux map results provide the measured value ( FH (X, Y) 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, M FMH (X, Y)

FHR (X,Y) =

MAP M / AXIALM (X, Y) where MAP M 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 AXIALM ( X, Y ) 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)

FdH (X, Y) where: FHRd(X,Y) =

MAP d / AXIALd (X, Y)

MAP d 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,

AXIALd (X, Y ) is the design ratio of the peak-to-average axial power at assembly location (X,Y),

FdH (X, Y) 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).

Insert Page B 3.2.2-1a , Volume 7, Rev. 0, Page 141 of 249

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INSERT 1 (continued)

The expression for BRDES(X,Y) is:

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

MHs(X,Y) where: MHs(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.

Insert Page B 3.2.2-1b , Volume 7, Rev. 0, Page 142 of 249

Enclosure 2, Volume 7, Rev. 0, Page 143 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES FH(X,Y) 1 APPLICABLE Limits on F N H 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 3 must not exceed 280 cal/gm [Ref. 1], and 8

( )

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 FH(X,Y) 1 and F N H are the core parameters of most importance. The limits on F N H 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. local DNB heat flux ratio to the design limit value using an NRC approved 1 limits, FH min margin and critical heat flux f1(I) min margin, The allowable F N H limit increases with decreasing power level. This FH(X,Y) functionality in F N H 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 FH(X,Y) 1 variable value of F N H in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial F N H as a function of power level defined by the COLR limit equation.

FH(X,Y)

X,Y, The LOCA safety analysis indirectly models F N H as an input parameter.

The Nuclear Heat Flux Hot Channel Factor (FQ(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]. 3

( ) 8 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 SEQUOYAH UNIT 1 Revision XXX WOG STS B 3.2.2-2 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 143 of 249

Enclosure 2, Volume 7, Rev. 0, Page 144 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES APPLICABLE SAFETY ANALYSES (continued)

(QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (F N H ) ," and LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))." FH(X,Y)

FH(X,Y) X, Y, Z X, Y, Z F

N H and FQ(Z) are measured periodically using the movable incore 1 indirectly 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.

FH(X,Y)

F N H satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO F N H shall be maintained within the limits of the relationship provided in the COLR. 2 INSERT 2 The F N H 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. 1 The limiting value of F N H , 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 F N H allowed to increase 0.3% for every 1% RTP reduction in THERMAL POWER.

FH(X,Y)

APPLICABILITY The F N H 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 1 transferred to the coolant to require a limit on the distribution of core FH(X,Y) power. Specifically, the design bases events that are sensitive to F N H in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict F N H in these modes.

FH(X,Y)

SEQUOYAH UNIT 1 Revision XXX WOG STS B 3.2.2-3 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 144 of 249

, Volume 7, Rev. 0, Page 145 of 249 B 3.2.2 2

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 f1(I) min margin >0 the LCO is satisfied.

Insert Page B 3.2.2-3 , Volume 7, Rev. 0, Page 145 of 249

Enclosure 2, Volume 7, Rev. 0, Page 146 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES INSERT 3 2

ACTIONS A.1.1 With F N H exceeding its limit, the unit is allowed 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore F N H to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring F N H within its power dependent limit. When the F N H limit is exceeded, the DNBR limit is not 4 likely violated in steady state operation, because events that could significantly perturb the F N H 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to restore F N H to within its limits without allowing the plant to remain in an unacceptable condition for an extended period of time.

Condition A is modified by a Note that requires that Required Actions A.2 3

5 and A.3 must be completed whenever Condition A is entered. Thus, if power is not reduced because this Required Action is completed within 4 the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time period, Required Action A.2 nevertheless requires another measurement and calculation of F N H within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with SR 3.2.2.1. INSERT 4 5

4 However, if power is reduced below 50% RTP, Required Action A.3 FH min margin 1

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

A.1.2.1 and A.1.2.2 FH min margin 1

If the value of F N H is not restored to within its specified limit either by INSERT 5 adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in 4

INSERT 6 accordance with Required Action A.1.2.1 and reduce the Power Range INSERT 7 Neutron Flux - High to 55% RTP in accordance with Required allowable 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 2 operation remains at an acceptable low power level with adequate DNBR 3

margin. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Required Actions A.1.1 and A.1.2.1 are not additive. 3 SEQUOYAH UNIT 1 Revision XXX 1

WOG STS B 3.2.2-4 Rev. 4.0, Enclosure 2, Volume 7, Rev. 0, Page 146 of 249

, Volume 7, Rev. 0, Page 147 of 249 B 3.2.2 2

INSERT 3 The % FH margin is based on the relationship between FHRM(X,Y) and the limit, BHDES (X,Y), as follows:

M (X, Y)

% F H Margin = 1 F HR x 100%

BHDES(X, Y)

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.

4 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.

Insert Page B 3.2.2-4a , Volume 7, Rev. 0, Page 147 of 249

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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 4

INSERT 6 trip setpoints, as specified in TS Table 3.3.1-1 by RRH% multiplied times the FH min margin 4

INSERT 7 by at least RRH% multiplied times the FH min margin Insert Page B 3.2.2-4b , Volume 7, Rev. 0, Page 148 of 249

Enclosure 2, Volume 7, Rev. 0, Page 149 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES ACTIONS (continued) 4 The allowed Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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.

3 A.2 INSERT 8 allowable 4

Once the power level has been reduced to < 50% RTP per Required FH min margin is verified > 0 Action A.1.2.1, an incore flux map (SR 3.2.2.1) must be obtained and the 1

22 measured value of F N H verified not to exceed the allowed limit at the lower power level. The unit is provided 20 additional hours to perform this 3 2

task over and above the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months allowed by either Action A.1.1 or Action A.1.2.1. The Completion Time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period. Additionally, operating experience has indicated that this Completion Time is sufficient to obtain the incore flux map, perform the required calculations, and evaluate F N H . 1 FH min margin INSERT 9 4 5

A.3 4 FH min margin is > 0 Verification that F N H is within its specified limits after an out of limit FH min margin 1

occurrence ensures that the cause that led to the F H exceeding its limit N

is corrected, and that subsequent operation proceeds within the LCO FH min margin limit. This Action demonstrates that the F N H limit is within the LCO limits

>0 prior to exceeding 50% RTP, again prior to exceeding 75% RTP, and within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

INSERT 10 2 C

B.1 4 5, and 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 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 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.

SEQUOYAH UNIT 1 Revision XXX WOG STS B 3.2.2-5 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 149 of 249

, Volume 7, Rev. 0, Page 150 of 249 B 3.2.2 4

INSERT 8 by at least RRH% multiplied times the FH min margin 4

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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is sufficient considering the small likelihood of a limiting transient in this time period.

Insert Page B 3.2.2-5a , Volume 7, Rev. 0, Page 150 of 249

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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 HR M (X,Y)

% f 1 ( I)Margin = 1 x 100%

BRDES(X,Y)

If the reactor core is operating as designed, then FHRM(X,Y) is less than BRDES (X,Y) and calculation of %f1(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 f1(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 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months , restricts FH(X,Y) such that even if a transient occurred, DNB requirements are met. The f1(I) min margin is the minimum % of f1(I) margin for all core locations examined.

Insert Page B 3.2.2-5b , Volume 7, Rev. 0, Page 151 of 249

Enclosure 2, Volume 7, Rev. 0, Page 152 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES INSERT 11 4 SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The value of F N H 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 F N H from the measured flux distributions. The measured value of F N H must be multiplied by 1.04 1

to account for measurement uncertainty before making comparisons to the F N H limit.

After each refueling, F N H must be determined in MODE 1 prior to exceeding 75% RTP. This requirement ensures that F N H 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, 6 this Frequency is short enough that the F N H limit cannot be exceeded for any significant period of operation.

OR INSERT 12 4 The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REVIEWERS NOTE-----------------------------------

Plants controlling Surveillance Frequencies under a Surveillance Frequency Control Program should utilize the appropriate Frequency 7

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.

SEQUOYAH UNIT 1 Revision XXX 1

WOG STS B 3.2.2-6 Rev. 4.0, Enclosure 2, Volume 7, Rev. 0, Page 152 of 249

, Volume 7, Rev. 0, Page 153 of 249 B 3.2.2 4

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 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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, FMH (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 M

75% RTP. This ensures that some determination of FH (X,Y) is made at a lower power level at which adequate margin is available before going to 100% RTP.

Insert Page B 3.2.2-6a , Volume 7, Rev. 0, Page 153 of 249

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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 M

also requirements to extrapolate trends in FH (X, Y) 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 M

BHDES(X,Y) and BRDES(X,Y) limits. If the extrapolations of FH (X, Y) are unfavorable, additional actions must be taken. These actions are to meet the FH(X,Y) limit with the last FMH (X,Y) increased by the M

appropriate factor specified in the COLR or to evaluate FH (X,Y) prior to the projected point in time when the extrapolated values are expected to exceed the extrapolated limits. These alternative 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.

Insert Page B 3.2.2-6b , Volume 7, Rev. 0, Page 154 of 249

Enclosure 2, Volume 7, Rev. 0, Page 155 of 249 FH(X,Y)

F N H 1 B 3.2.2 B 3.2 POWER DISTRIBUTION LIMITS FH(X,Y)

B 3.2.2 Nuclear Enthalpy Rise Hot Channel Factor ( F N H ) 1 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.

FH(X,Y)

F N H is defined as the ratio of the integral of the linear power along the 1 fuel rod with the highest integrated power to the average integrated fuel FH(X,Y) rod power. Therefore, F N H is a measure of the maximum total power produced in a fuel rod.

F N H is sensitive to fuel loading patterns, bank insertion, and fuel burnup.

FH(X,Y)

F N H typically increases with control bank insertion and typically decreases with fuel burnup.

1 FH(X,Y)

F N H 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 FH(X,Y)

INSERT 1 computer to determine F N H . This factor is calculated at least every 2

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 design limit value using an NRC approved critical heat flux 1

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 F N H value that satisfies the LCO requirements.

FH(X,Y) 1 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.

SEQUOYAH UNIT 2 Revision XXX WOG STS B 3.2.2-1 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 155 of 249

, Volume 7, Rev. 0, Page 156 of 249 B 3.2.2 2

INSERT 1 An FH(X,Y) evaluation requires obtaining an incore flux map in MODE 1.

M The incore flux map results provide the measured value ( FH (X, Y) 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, M FMH (X, Y)

FHR (X,Y) =

MAP M / AXIALM (X, Y) where MAP M 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 AXIALM ( X, Y ) 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)

FdH (X, Y) where: FHRd(X,Y) =

MAP d / AXIALd (X, Y)

MAP d 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,

AXIALd (X, Y ) is the design ratio of the peak-to-average axial power at assembly location (X,Y),

FdH (X, Y) 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).

Insert Page B 3.2.2-1a , Volume 7, Rev. 0, Page 156 of 249

, Volume 7, Rev. 0, Page 157 of 249 B 3.2.2 2

INSERT 1 (continued)

The expression for BRDES(X,Y) is:

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

MHs(X,Y) where: MHs(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.

Insert Page B 3.2.2-1b , Volume 7, Rev. 0, Page 157 of 249

Enclosure 2, Volume 7, Rev. 0, Page 158 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES FH(X,Y) 1 APPLICABLE Limits on F N H 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 3 must not exceed 280 cal/gm [Ref. 1], and 8

( )

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 FH(X,Y) 1 and F N H are the core parameters of most importance. The limits on F N H 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. local DNB heat flux ratio to the design limit value using an NRC approved 1 limits, FH min margin and critical heat flux f1(I) min margin, The allowable F N H limit increases with decreasing power level. This FH(X,Y) functionality in F N H 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 FH(X,Y) 1 variable value of F N H in the analyses. Likewise, all transients that may be DNB limited are assumed to begin with an initial F N H as a function of power level defined by the COLR limit equation.

FH(X,Y)

X,Y, The LOCA safety analysis indirectly models F N H as an input parameter.

The Nuclear Heat Flux Hot Channel Factor (FQ(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]. 3

( ) 8 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 SEQUOYAH UNIT 2 Revision XXX WOG STS B 3.2.2-2 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 158 of 249

Enclosure 2, Volume 7, Rev. 0, Page 159 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES APPLICABLE SAFETY ANALYSES (continued)

(QPTR)," LCO 3.1.6, "Control Bank Insertion Limits," LCO 3.2.2, "Nuclear Enthalpy Rise Hot Channel Factor (F N H ) ," and LCO 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z))." FH(X,Y)

FH(X,Y) X, Y, Z X, Y, Z F

N H and FQ(Z) are measured periodically using the movable incore 1 indirectly 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.

FH(X,Y)

F N H satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO F N H shall be maintained within the limits of the relationship provided in the COLR. 2 INSERT 2 The F N H 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. 1 The limiting value of F N H , 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 F N H allowed to increase 0.3% for every 1% RTP reduction in THERMAL POWER.

FH(X,Y)

APPLICABILITY The F N H 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 1 transferred to the coolant to require a limit on the distribution of core FH(X,Y) power. Specifically, the design bases events that are sensitive to F N H in other modes (MODES 2 through 5) have significant margin to DNB, and therefore, there is no need to restrict F N H in these modes.

FH(X,Y)

SEQUOYAH UNIT 2 Revision XXX WOG STS B 3.2.2-3 Rev. 4.0, 1 Enclosure 2, Volume 7, Rev. 0, Page 159 of 249

, Volume 7, Rev. 0, Page 160 of 249 B 3.2.2 2

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 f1(I) min margin >0 the LCO is satisfied.

Insert Page B 3.2.2-3 , Volume 7, Rev. 0, Page 160 of 249

Enclosure 2, Volume 7, Rev. 0, Page 161 of 249 FH(X,Y)

F N H 1 B 3.2.2 BASES INSERT 3 2

ACTIONS A.1.1 With F N H exceeding its limit, the unit is allowed 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to restore F N H to within its limits. This restoration may, for example, involve realigning any misaligned rods or reducing power enough to bring F N H within its power dependent limit. When the F N H limit is exceeded, the DNBR limit is not 4 likely violated in steady state operation, because events that could significantly perturb the F N H 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides an acceptable time to restore F N H to within its limits without allowing the plant to remain in an unacceptable condition for an extended period of time.

Condition A is modified by a Note that requires that Required Actions A.2 3

5 and A.3 must be completed whenever Condition A is entered. Thus, if power is not reduced because this Required Action is completed within 4 the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months time period, Required Action A.2 nevertheless requires another measurement and calculation of F N H within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in accordance with SR 3.2.2.1. INSERT 4 5

4 However, if power is reduced below 50% RTP, Required Action A.3 FH min margin 1

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

A.1.2.1 and A.1.2.2 FH min margin 1

If the value of F N H is not restored to within its specified limit either by INSERT 5 adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in 4

INSERT 6 accordance with Required Action A.1.2.1 and reduce the Power Range INSERT 7 Neutron Flux - High to 55% RTP in accordance with Required allowable 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 2 operation remains at an acceptable low power level with adequate DNBR 3

margin. The allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 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 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Required Actions A.1.1 and A.1.2.1 are not additive. 3 SEQUOYAH UNIT 2 Revision XXX 1

WOG STS B 3.2.2-4 Rev. 4.0, Enclosure 2, Volume 7, Rev. 0, Page 161 of 249

, Volume 7, Rev. 0, Page 162 of 249 B 3.2.2 2

INSERT 3 The % FH margin is based on the relationship between FHRM(X,Y) and the limit, BHDES (X,Y), as follows:

M (X, Y)

% F H Margin = 1 F HR x 100%

BHDES(X, Y)

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.

4 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.

Insert Page B 3.2.2-4a , Volume 7, Rev. 0, Page 162 of 249

, Volume 7, Rev. 0, Page 163 of 249 B 3.2.2 4

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 4

INSERT 6 trip setpoints, as specified in TS Table 3.3.1-1 by RRH% multiplied times the FH min margin 4

INSERT 7 by at least RRH% multiplied times the FH min margin Insert Page B 3.2.2-4b , Volume 7, Rev. 0, Page 163 of 249

Enclosure 2, Volume 7, Rev. 0, Page 164 of 249 FH(X,Y)