ML22089A205
| ML22089A205 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 03/30/2022 |
| From: | Florida Power & Light Co |
| To: | Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML22089A195 | List:
|
| References | |
| L-2022-040, NUREG-1431 R5 | |
| Download: ML22089A205 (136) | |
Text
ENCLOSURE 2 VOLUME 7 TURKEY POINT NUCLEAR GENERATING STATION UNIT 3 AND UNIT 4 IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 1
LIST OF ATTACHMENTS
- 1. ITS 3.2.1 - Heat Flux Hot Channel Factor (FQZ)
- 2. ITS 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor ( FNH )
- 3. ITS 3.2.3 - Axial Flux Difference (AFD)
ATTACHMENT 1 ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQZ)
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
ITS 3.2.1 A01 ITS 1 A01 POWER DISTRIBUTION LIMITS 3.2.1 3/4.2.2 HEAT FLUX HOT CHANNEL FACTOR - FQ (Z) FQ(Z) shall be within the limits A01 specified in the COLR.
LIMITING CONDITION FOR OPERATION L
LCO 3.2.1 3.2.2 F Q (Z) shall be limited by the following relationships:
LX M [FQ ]
F Q (Z) [K(Z)] for P > 0.5 P
L M [FQ ] X F Q (Z) [K(Z)] for P 0.5 0.5 LA01 where: [FQ] =L FQ limit at RATED THERMAL POWER as specified in the CORE OPERATING LIMITS REPORT Thermal Power P= ,
Rated Thermal Power
[FQ]M = The Measured Value, and K(Z) for a given core height, is specified in the K(Z) curve, defined in the CORE OPERATING LIMITS REPORT.
APPLICABILITY: MODE 1 ACTION:
not within A01 M after each determination Action A With the measured value of F Q (Z) exceeding its limit:
A04 when determined by limit Required Action A.1 a. Reduce THERMAL POWER at least 1% for each 1% F M (Z) exceeds F L Q (Z) within 15 minutes A03 Q
Required Action A.2 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />s:
Required Action A.3 POWER OPERATION may proceed for up to a total of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; subsequent POWER 72 L01 OPERATION may proceed provided the Overpower Delta-T Trip Setpoints (value of K4) have been reduced at least 1% for each 1% F M L Q (Z) exceeds the F Q (Z); and Perform SR 3.2.1.1 limit A03 A02 Required Action A.4 b. Identify and correct the cause of the out-of-limit condition prior to increasing THERMAL POWER above the reduced power limit required by ACTION a., above; THERMAL POWER may then be increased provided F M (Z) is demonstrated through incore mapping to be within its limit. LA01 Q
Action E Insert 1 M01 TURKEY POINT - UNITS 3 & 4 3/4 2-3 AMENDMENT NOS. 260 AND 255
ITS 3.2.1 INSERT 1 M01 E. Required Action and E.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met.
Insert Page 3/4 2-3
ITS 3.2.1 A01 ITS POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS LA01 SR 3.2.1.2 4.2.2.1 If [FQ]P as predicted by approved physics calculations is greater than [FQ]L and P is greater than PT* as defined in 4.2.2.2, FQ(Z) shall be evaluated by MIDS (Specification 4.2.2.2), BASE LOAD (Specification 4.2.2.3) or A01 RADIAL BURNDOWN (Specification 4.2.2.4) to determine if FQ is within its limit [FQ]P = Predicted FQ).
as specified in the COLR LA02 SR 3.2.1.1 If [FQ]P, is less than [FQ]L or P is less than PT, FQ(Z) shall be evaluated to determine if FQ(Z) is within its limit as follows:
- a. Using the movable incore detectors to obtain power distribution map at any THERMAL POWER LA01 greater than 5% of RATED THERMAL POWER.
- b. Increasing the measured FQ(Z) component of the power distribution map by 3% to account for manufacturing tolerances and further increasing the value by 5% to account for measurement uncertainties. Verifying that the requirements of Specification 3.2.2 are satisfied.
L FM LA02
- c. Q (Z) F Q (Z)
M Where F Q (Z) is the measured FQ(Z) increased by the allowance for manufacturing tolerances and measurement uncertainty and L (Z) is the FQ limit defined in 3.2.2.
FQ M A01
- d. Measuring F Q (Z) according to the following schedule:
- 1. Prior to exceeding 75% of RATED THERMAL POWER,** after refueling,
- 2. In accordance with the Surveillance Frequency Control Program.
- e. With the relationship specified in Specification 4.2.2.1.c above not being satisfied:
- 1) Calculate the percent F M(Z) exceeds its limit by the following expression:
Q M
F (Z)
Q 1 X 100 for P 0.5 L
[F ] X K(Z)/P Q
LA02 M
F (Z)
Q 1 X 100 for P < 0.5 L
[F ] X K(Z)/0.5 Q
LA01
- PT = Reactor power level at which predicted FQ would exceed its limit.
SR Note ** 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.
TURKEY POINT - UNITS 3 & 4 3/4 2-4 AMENDMENT NOS. 263 AND 258
ITS 3.2.1 ITS A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
- 2) The following action shall be taken:
Action A a) Comply with the requirements of Specification 3.2.2 for F M Q (Z) exceeding its limit by the percent calculated above.
4.2.2.2 MIDS Operation is permitted at power above PT where PT equals the ratio of [FQ]L divided by [FQ]P if the following Augmented Surveillance (Movable Incore Detection System, MIDS) requirements are satisfied: LA02
- a. The axial power distribution shall be measured by MIDS when required such that the limit of [FQ]L/P times K(Z) is not exceeded. Fj(Z) is the normalized axial power distribution LA01 from thimble j at core elevation (Z).
limit within 15 minutes A01 L02 Action B
- 1) If Fj(Z) exceeds [Fj(Z)]s* as defined in the bases by 4%, immediately reduce Insert Required Actions B.2, B.3, and thermal power one percent for every percent by which [Fj(Z)]s is exceeded. M02 B4 limit A01 Action C 2) If Fj(Z) exceeds [Fj(Z)]s by > 4% immediately reduce thermal power below PT.
Corrective action to reduce Fj(Z) below the limit will permit return to thermal A05 power not to exceed current PL** as defined in the bases.
augmented calculation SR 3.2.1.2 b. Fj(Z) shall be determined to be within limits by using MIDS to monitor the thimbles required per Specification 4.2.2.2.c at the following frequencies.
- 1. In accordance with the Surveillance Frequency Control Program, and Within
- 2. Immediately following and as a minimum at 2, 4 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following the events A01 listed below and in accordance with the Surveillance Frequency Control Program thereafter.
- 1) Raising the thermal power above PT, or
- 2) Movement of control-bank D more than an accumulated total of 15 steps in any one direction.
- 1) At least two thimbles available for which Rj and j as defined in the bases have LA03 been determined.
- [Fj(Z)]s is the alarm setpoint for MIDS.
LA01
- PL is reactor thermal power expressed as a fraction of the Rated Thermal Power that is used to calculate
[Fj(Z)]s.
TURKEY POINT - UNITS 3 & 4 3/4 2-5 AMENDMENT NOS. 263 AND 258
ITS 3.2.1 ITS A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued)
- 2. At least two movable detectors available for mapping Fj(Z).
- 3. The continued accuracy and representativeness of the selected thimbles shall be verified by using the most recent flux map to update the R for each selected thimble. The flux map must be updated in accordance with the Surveillance Frequency Control Program.
where:
R = Total peaking factor from a full flux map ratioed to the axial peaking factor in a selected thimble.
j - The thimble location selected for monitoring.
4.2.2.3 Base Load LA03 Base Load operation is permitted at powers above PT if the following requirements are satisfied:
- a. Either of the following preconditions for Base Load operation must be satisfied.
- 1. For entering Base Load operation with power less than PT, a) Maintain THERMAL POWER between PT/1.05 and PT for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, b) Maintain the AFD (Delta-I) to within a +/- 2% or +/- 3% target band for at least 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> per 24-hour period.
c) After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have elapsed, take a full core flux map to determine F M (Z)
Q unless a valid full core flux map was taken within the time period specified in 4.2.2.1d.
A01 SR 3.2.1.3 d) Calculate PBL per 4.2.2.3b.
- 2. For entering Base Load operation with power greater than PT, a) Maintain THERMAL POWER between PT and the power limit determined in 4.2.2.2 for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and maintain Augmented Surveillance requirements of 4.2.2.2 during this period. LA03 b) Maintain the AFD (Delta-I) to within a +/- 2% or +/- 3% target band for at least 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> per 24-hour period, TURKEY POINT - UNITS 3 & 4 3/4 2-6 AMENDMENT NOS. 263 AND 258
ITS 3.2.1 A01 ITS POWER DISTRIBUTION LIMITS Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of A01 entering base load operation SURVEILLANCE REQUIREMENTS (Continued)
M SR 3.2.1.2 c) After 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> have elapsed, take a full core flux map to determine F Q (Z) unless a valid full core flux map was taken within the time period specified in 4.2.2.1d.
A01 SR 3.2.1.3 d) Calculate PBL per 4.2.2.3b.
- b. Base Load operation is permitted provided:
LCO 3.2.1 1. THERMAL POWER is maintained between PT and PBL or between PT and 100% A01 (whichever is most limiting).
A06
- 2. AFD (Delta-I) is maintained within a +/- 2% or +/- 3% target band.
SR 3.2.1.2 3. Full core flux maps are taken at least once per 31 effective Full Power Days. A01 PBL and PT are defined as: thereafter during base load operation
[FQ ] L X K(Z)
PBL =
FM (Z) X W(Z) BL X 1.09 Q
PT = [FQ]L/[FQ]P M
where: F Q (Z) is the measured FQ(Z) with no allowance for manufacturing tolerances or measurement uncertainty. For the purpose of this Specification [ F M Q (Z) ] shall be LA02 obtained between elevations bounded by 10% and 90% of the active core height. [FQ]L is the FQ limit. K(Z) is given in the CORE OPERATING LIMITS REPORT. W(Z)BL is the cycle dependent function that accounts for limited power distribution transients encountered during base load operation.
COLR The function is given in the Peaking Factor Limit Report as per Specification 6.9.1.6. The 9% uncertainty factor accounts for manufacturing tolerance, measurement error, rod bow and any burnup and power dependent peaking factor increases. LA01
- c. During Base Load operation, if the THERMAL Power is decreased below PT, then the LA03 conditions of 4.2.2.3.a shall be satisfied before re-entering Base Load operation.
ACTION D d. If any of the conditions of 4.2.2.3b are not maintained, reduce THERMAL POWER to less than or equal to PT, or, within 15 minutes initiate the Augmented Surveillance (MIDS) requirements of 4.2.2.2.
If FQP > FQL and THERMAL SR 3.2.1.2 A01 POWER > PBL specified in the COLR A07 TURKEY POINT - UNITS 3 & 4 3/4 2-7 AMENDMENT NOS. 260 AND 255
ITS 3.2.1 ITS A01 POWER DISTRIBUTION LIMITS SURVEILLANCE REQUIREMENTS (Continued) 4.2.2.4 RADIAL BURNDOWN Operation is permitted at powers above PT if the following Radial Burndown conditions are satisfied:
LCO 3.2.1 a. Radial Burndown operation is restricted to use at powers between PT and PRB or PT and 1.00 (whichever is most limiting). The maximum relative power permitted under Radial Burndown LA02 operation, PRB, is equal to minimum value of the ratio of [F L Z)]/[FQ(Z)]RB Meas.
Q where: [FQ(Z)]RB Meas. =[Fxy(Z)]Map Meas. x FZ(Z) x 1.09 and L
[ F Q(Z)] is equal to [ F L ] x K(Z).
Q SR 3.2.1.2 b. A full core flux map to determine [Fxy(Z)]Map Meas. shall be taken within the time period A01 specified in Section 4.2.2.1d.2. For the purpose of the specification, [Fxy(Z)]Map Meas.
in accordance with the shall be obtained between the elevations bounded by 10% and 90% of the active core Surveillance Frequency height.
Control Program COLR LA01
- c. The function Fz(Z), provided in the Peaking Factor Limit Report (6.9.1.6), is determined analytically and accounts for the most perturbed axial power shapes which can occur under axial power distribution control. The uncertainty factor of 9% accounts for manufacturing tolerances, measurement error, rod bow, and any burnup dependent peaking factor increases.
A01 LCO 3.2.1 d. Radial Burndown operation may be utilized at powers between PT and PRB, or PT and 1.00 (whichever is most limiting) provided that the AFD (Delta-I) is within +/- 5% of the A06 target axial offset.
Action D e. If the requirements of Section 4.2.2.4d are not maintained, then the power shall be A07 reduced to less than or equal to PT, or within 15 minutes Augmented Surveillance of hot channel factors shall be initiated if the power is above PT. A01 4.2.2.5 When FQ(Z) is measured for reasons other than meeting the requirements of Specifications 4.2.2.1, 4.2.2.2, 4.2.2.3 or 4.2.2.4 an overall measured FQ(Z) shall be obtained from a power distribution map and L03 increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty.
If FQP > FQL and THERMAL A07 POWER > PRB specified in the COLR TURKEY POINT - UNITS 3 & 4 3/4 2-8 AMENDMENT NOS. 263 AND 258
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point (PTN) Unit 3 and Unit 4, 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. 5.0, "Standard Technical Specifications-Westinghouse Plants" (ISTS).
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.2 Action b specifically requires the identification and correction of the cause of the out of limit condition prior to increasing thermal power above the reduced power limit and that the F M (Z) be demonstrated through incore Q
mapping. ITS 3.2.1 Action A.4 requires that Surveillance Requirement (SR) 3.2.1.1 be performed prior to increasing power above the reduced power limit. Performing SR 3.2.1.1 confirms the out-of-limit condition is identified and corrected and is, therefore, considered equivalent.
This change is designated as administrative because the ITS requires SR 3.2.1.1, which is equivalent to the requirements of the CTS. This change is acceptable because it does not result in technical changes to the CTS.
A03 CTS 3.2.2 Action a requires a reduction in the Power Range Neutron Flux - High and Overpower T trip setpoints at least 1% for every 1% F M Q (Z) exceeds the L M F Q (Z). The CTS 3.2.2 term F (Z) refers to the measured FQ(Z) and is changed Q
to FQ(Z) since the FQ(Z) at the time of the measurement is the actual FQ(Z). The L
CTS term F Q (Z) is changed to limit because the measured FQ(Z) is being compared to the FQ(Z) limit. The measured FQ(Z) is referred to throughout ITS 3.2.1 as FQ(Z). ITS 3.2.1 Required Actions A.2 and A.3 require a reduction in the Power Range Neutron Flux - High and Overpower T trip setpoints 1% for each 1% FQ(Z) exceeds the limit. This changes the CTS by referencing the measured value of FQ(Z) as FQ(Z) and replacing acronym for the FQL(Z) limit with the term limit.
This change is acceptable because the amount THERMAL POWER is reduced remains unchanged. In addition, changing the measured FQ(Z) to FQ(Z) and the acronym for the specific reference to the FQ(Z) limit to limit has no affect on the value. The values are calculated per the requirements in the COLR. This change is designated as administrative because no technical change is being made to the CTS.
A04 ITS 3.2.1, Required Actions A.1, A.2, and A.3 state that the Required Actions must be taken "after each FQ(Z) determination." CTS 3.2.2, Action a does not explicitly state this requirement.
This change is acceptable because it does not result in a technical change to the Technical Specifications. The CTS is understood to apply after each Turkey Point Unit 3 and Unit 4 Page 1 of 7
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
measurement of FQ(Z). This change is designated as administrative because it does not result in a technical change to the CTS.
A05 CTS 4.2.2.2.a.2) states that corrective action to reduce Fj(Z) below the limit will permit return to thermal power not to exceed current PL** as defined in the bases. The ** footnote states PL is reactor thermal power expressed as a fraction of the Rated Thermal Power that is used to calculate [Fj(Z)]s. PL, as defined in the CTS Bases, is thermal power expressed as a fraction of 1 (i.e.,
100% RTP). ITS 3.2.1 ACTION C does not explicitly state the corrective action that must be taken to permit return to thermal power not to exceed PL because the statement is redundant to the requirements of CTS 3.0.2.
CTS 3.0.2 (ITS LCO 3.0.2) state that if the LCO is met or is no longer applicable prior to expiration of the specified time interval, completion of the ACTION(S) is not required unless otherwise stated. Whether stated as a Required Action or not, correction of the entered Condition is an action that may always be considered upon entering ACTIONS. If it is determined that FQ(Z) requirements are met as specified in the COLR using the augmented calculation per SR 3.2.1.2, the LCO is met and the ACTIONS, except for Required Action C.4, are no longer required. This obviates the need to explicitly state that operation above PT may continue provided the requirements of the augmented surveillance are initiated. Performance of Required Action C.4 confirms FQ(Z) is within limits and operation above PT may proceed. This change is designated as administrative because it does not result in a technical change to the CTS.
A06 CTS 4.2.2.3.b.2 requires AFD (Delta-I) to be maintained within a +/- 2% or +/- 3%
target band to permit base load operation. CTS 4.2.2.4.d requires, in part, AFD (Delta-I) to be maintained within +/- 5% of the target axial offset to permit radial burndown operation. ITS 3.2.1 does include requirements associated with AFD.
ITS 3.2.3 provides requirements for AFD and LCO 3.2.3 states that the AFD in %
flux difference units shall be maintained within the limits specified in the COLR.
AFD limits associated with base load operation are proposed to be relocated to the COLR (i.e., within a +/- 2% or +/- 3% target band) (Refer to DOC LA02). AFD limits associated with radial burndown operation are also proposed to be relocated to the COLR (i.e., within +/- 5% of the target axial offset) (Refer to DOC LA02). Therefore, it is unnecessary to explicitly state that AFD (Delta-I) be maintained within a required band. This change is acceptable because LCO 3.2.3 continues to require AFD to be maintained within the limits of the COLR, which includes target band requirements associated with base load and radial burndown operations. Therefore, this change is designated as administrative because it does not result in a technical change to the CTS.
A07 CTS 4.2.2.3.d provides actions to perform if any of the conditions of 4.2.2.3b are not maintained during base load operation. CTS 4.2.2.4.e provides actions to perform if the requirements of Section 4.2.2.4d are not maintained during radial burndown operation. ITS 3.2.1 Condition D applies if FQP > FQL and THERMAL POWER > PBL specified in the COLR or when FQP > FQL and THERMAL POWER
Turkey Point Unit 3 and Unit 4 Page 2 of 7
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
It is unnecessary to require action when AFD (Delta-I) is not within the required target band. LCO 3.2.3 states that the AFD in % flux difference units shall be maintained within the limits specified in the COLR and provides action when AFD is not within the required limits. The required AFD (Delta-I) target bands for base load and radial burndown operations are proposed to be relocated to the COLR (Refer to DOC LA02). Therefore, when AFD (Delta-I) is outside the required target band during these operations, action will be required per ITS 3.2.3 ACTIONS. In addition, if CTS 4.2.2.3.b.3 (ITS SR 3.2.1.2), which requires full core flux maps to be taken at least once per 31 effective Full Power Days, is not performed within the required Frequency, CTS 4.0.1 and CTS 3.0.2 (ITS SR 3.0.1 and ITS LCO 3.0.2) require ITS 3.2.1 ACTIONS to be performed when a Surveillance is not performed within the required interval. Considering Technical Specification actions will continue to be performed for the stated conditions, this change is designated as administrative and does not result in a technical change to the CTS.
MORE RESTRICTIVE CHANGES M01 CTS 3.2.2 does not contain an Action to follow if ACTIONS a and b cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ITS 3.2.1 ACTION E, states that the plant must be in MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shut down and, consequently, allowing one hour less for the unit to be in MODE 2.
The purpose of CTS 3.0.3 is to delineate the ACTION to be taken for circumstances not directly provided 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 Limiting Condition for Operation (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 complying with 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.
M02 CTS 4.2.2.2 requires reducing THERMAL POWER one percent for every percent by which [Fj(Z)]s is exceeded when Fj(Z) exceeds [Fj(Z)]s* as defined in the bases by 4%, . ITS 3.2.1 Required Action B.1 also requires reducing THERMAL POWER 1% RTP for each 1% Fj(Z) exceeds limit.. However, ITS 3.2.1 Required Actions B.2, B.3, and B.4, also requires reducing the Power Range Neutron Flux - High and Overpower T trip setpoints along with ensuring SR 3.2.1.1 is performed successfully prior to increasing power above THERMAL POWER limit of Required Action B.1. This changes the CTS by requiring Turkey Point Unit 3 and Unit 4 Page 3 of 7
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
additional Required Actions (reducing trip setpoints and requiring SR 3.2.1.1 to be performed successfully prior to increasing THERMAL POWER) whenever FQ(Z) not within limit when determined per SR 3.2.1.2 and Fj(Z) exceeds limit by 4%.
The purpose of CTS 3.2.2 is to ensure the Heat Flux Hot Channel Factor is maintained within the limits specified in the COLR and when not maintained appropriate Action is taken to ensure the peak value is maintained with the limits of the safety analysis. The addition of Required Actions to reduce the Power Range Neutron Flux - High and Overpower T trip setpoints consistent with the reduction in THERMAL POWER is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions.
Limiting THERMAL POWER increases until the SR is successfully performed ensures that core conditions during operation at higher power levels and future operation are consistent with safety analysis assumptions. This change is designated as more restrictive because additional Required Actions are imposed.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 2 - Removing Descriptions of System Operation) CTS 3.2.2 contains specific equations for the Heat Flux Hot Channel Factors (FQ(Z)) in the LCO to ensure FQ(Z) is within limits. In addition, CTS 3.2.2, Action b allows THERMAL POWER to be increased above the action limit provided FQM(Z) is demonstrated through incore mapping to be within its limit. CTS 4.2.2.1 clarifies [FQ]P as predicted by approved physics calculations, and includes details related to how a power distribution map is obtained, explanation of the term PT. CTS 4.2.2.2.a and associated footnotes, CTS 4.2.2.3.b, and CTS 4.2.2.4.c contain information detail related to uncertainty and explanation of terms. ITS 3.2.1 does not contain these informational details but rather a requirement to maintain FQ(Z) within limits specified in the COLR. This changes the CTS by relocating specific details of the LCO, Actions, and Surveillance Requirements to the Technical Specification (TS)
Bases.
The removal of these details that input into the determination of FQ(Z) is acceptable because the equations for determining FQ(Z) are followed whether or not contained within the Technical Specifications. In addition, it is not necessary to state that THERMAL POWER may be increased following satisfactory performance of the Surveillance to demonstrate through incore mapping that FQM(Z) is within its limit or [FQ]P is predicted by approved physics calculations.
Moreover, detail related to calculational uncertainty and explanation of terms is more appropriately discussed in the Technical Specifications Bases. The removal of this information 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 for Turkey Point Unit 3 and Unit 4 Page 4 of 7
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
FQ(Z) to be within limits and it provides appropriate Actions to ensure reactor safety is maintained. The ITS SRs continue to require verification that FQ(Z) is within limits specified in the COLR. Also, this change is acceptable because the removed information will be adequately controlled in the TS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. These controls provide for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system operation is being removed from the Technical Specifications.
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.2.1, 4.2.2.2, 4.2.2.3, 4.2.2.4. and 4.2.2.5 provide details for evaluating FQ(Z) by using various methods and parameters, depending on whether the method being used is the normal method, Movalbe Incore Detector System (MIDS) (i.e., augmented calculation), Base Load, or Radial Burndown. These methods ensure FQ(Z) is within limits by surveillance, or certain actions must be taken. ITS SR 3.2.1.1 verifies that FQ(Z) is within the limits specified in the COLR using the normal method. ITS SR 3.2.1.2 verifies that FQ(Z) is within the limits specified in the COLR using augmented calculation method or the calculation methods for based load operation or radial burndown.
This changes the CTS by moving the details of the methods for verifying FQ(Z) is within the limits to the COLR where the limits are specified.
The removal of these details from the Technical Specifications is acceptable because the procedural details for making a determination that FQ(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 SRs to verify FQ(Z) is within its limits will more closely align with the LCO requirement for FQ(Z) to be within the limits specified in the COLR. ITS also retains the COLR requirement to establish core operating limits prior to each reload cycle, or prior to any remaining portion of a reload cycle, and shall be documented in the COLR. The documents containing the analytical methods used, which have been previously reviewed and approved by the NRC, are also retained in ITS. Relocating specific procedural details to determine FQ(Z) is acceptable because these types of procedural details will be adequately controlled in the COLR. Changes to the COLR are controlled via 10 CFR 50.59 and are subject to NRC review each cycle. These controls provide for the evaluation of changes to ensure the COLR are properly controlled. This change is designated as a less restrictive removal of detail change because procedural type information is being removed from the Technical Specifications.
LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.2.2.c provides requirements to consider the MIDS Operable when thermal power exceeds PT. CTS 4.2.2.3.a and c provide precondition and operational requirements to enter base load operation. ITS 3.2.1 does not contain these procedural requirements. This changes the CTS by relocating specific procedural details related to entering and operating in base load operation or radial burndown conditions to the Technical Requirements Manual (TRM).
Turkey Point Unit 3 and Unit 4 Page 5 of 7
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
The removal of operational details related to pre-conditions and requirements for entering base load operation or radial burndown conditions 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 for FQ(Z) to be within limits specified in the COLR and ITS continues to provide appropriate Actions to ensure reactor safety is maintained. Also, this change is acceptable because this type of procedural detail will be adequately controlled in the TRM.
Any changes to the TRM are made under 10 CFR 50.59, which ensures changes are properly evaluated. 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.
LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.2 ACTION a states, in part, that when the FQ(Z) measured value exceeds its limit and THERMAL POWER has been reduced, to reduce the Power Range Neutron Flux - High Trip setpoints at least 1% the FQ(Z) measured value exceeds the limit within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
ITS 3.2.1 Required Actions A.2 states to reduce the Power Range Neutron Flux -
High trip at least by 1% for each 1% that THERMAL POWER reduced in Required Action A.1 within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by increasing the time allowed to reduce the trip setpoints.
The purpose of CTS 3.2.2 ACTION a 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 margin and avoids violating the 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 Design Basis Accident (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.
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.
L02 (Category 3 - Relaxation of Completion Time) CTS 4.2.2.a.1) states that if Fj(Z) exceeds [Fj(Z)]s* as defined in the bases by 4%, immediately reduce thermal power one percent for every percent by which [Fj(Z)]s is exceeded. ITS Required Action B.1 requires the same action with a Completion Time of 15 minutes to reduce THERMAL POWER. This changes the CTS by relaxing the Completion Time from immediately to 15 minutes.
The purpose of CTS 4.2.2.a.1) Action is to promptly reduce THERMAL POWER to provide margin to the FQ(Z) limit. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the low probability of a DBA occurring during the allowed Completion Time. The ITS Completion Time of 15 minutes is adequate time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable Turkey Point Unit 3 and Unit 4 Page 6 of 7
DISCUSSION OF CHANGES ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
condition for an extended period of time. In addition, the Completion Time of 15 minutes is consistent with the Completion Time specified in CTS 3.2.2, Action a (ITS 3.2.1, Required Action A.1). This change is designated as less restrictive because additional time is allowed to perform an action than was allowed in the CTS.
L03 (Category 5 - Deletion of Surveillance Requirement) CTS 4.2.2.5 requires an overall measured FQ(Z) to be obtained from a power distribution map and increased by 3% to account for manufacturing tolerances and further increased by 5% to account for measurement uncertainty when FQ(Z) is measured for reasons other than meeting the requirements of Specifications 4.2.2.1, 4.2.2.2, 4.2.2.3 or 4.2.2.4. ITS 3.2.1 does not require an explicit requirement to obtained from a power distribution map and account for manufacturing tolerances and measurement uncertainty when FQ(Z) is measured for reasons other than Technical Specification requirements. This changes the CTS by eliminating an explicit surveillance requirement.
The purpose of CTS 4.2.2.5 is to ensure measurement of FQ(Z) includes manufacturing tolerances and measurement uncertainty when FQ(Z) is obtained from a power distribution map for reasons other than performance of Technical Specification Surveillance Requirements. This change is acceptable because CTS 4.0.1 (ITS SR 3.0.1) requires SRs to be met during the Operational Modes or other conditions specified for individual Limiting Conditions for Operation unless otherwise stated in an individual Surveillance Requirement. ITS SR 3.0.1 further clarifies that failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, is failure to meet the LCO. Therefore, when determining FQ(Z) for any reason to confirm the status of the LCO between Surveillance performance intervals, appropriate tolerances and uncertainties must be included to ensure the LCO is met. Moreover, the surveillance testing and associated testing interval associated with FQ(Z) is considered adequate to assure, pursuant to the requirements of 10 CFR 50.36(c)(3), that facility operation will be within safety limits and that the limiting condition for operation associated with heat flux hot channel factor will be met. This change is designated as less restrictive because a Surveillance that was required in the CTS will not be performed in the ITS.
Turkey Point Unit 3 and Unit 4 Page 7 of 7
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
FQ(Z) (RAOC-W(Z) Methodology) 1 3.2.1B CTS 3.2 POWER DISTRIBUTION LIMITS 1
3.2.2 3.2.1B Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology)
LCO 3.2.2 LCO 3.2.1B FQ(Z), as approximated by FQC ( Z ) and FQW ( Z ) , shall be within the limits 2 specified in the COLR.
3 Insert 1 APPLICABILITY: MODE 1.
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME ACTION a A. ------------NOTE------------ A.1 Reduce THERMAL 15 minutes after each 4.2.2.1.e.2 Required Action A.4 POWER 1% RTP for FQC ( Z ) determination shall be completed each 1% FQC ( Z ) exceeds whenever this Condition limit.
is entered.
AND FQC ( Z ) not within limit. A.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each Neutron Flux - High trip FQC ( Z ) determination when determined by setpoints 1% for each C
SR 3.2.1.1 1% FQ ( Z ) exceeds limit. 2 AND A.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after each setpoints 1% for each FQC ( Z ) determination C
1% FQ ( Z ) exceeds limit.
AND A.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the limit of Required Action A.1 3
Insert 2 Westinghouse STS 3.2.1B-1 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY
ITS 3.2.1 CTS INSERT 1 3 AND 4.2.2.1 With predicted FQ (FQP) > FQ limit (FQL) and THERMAL POWER > predicted threshold power (PT) calculated as specified in the COLR, THERMAL POWER shall be less than the following limit calculated as specified in the COLR:
4.2.2.3.b.1 a. Base load power limit (PBL) during base load operation, and 4.2.2.4.a b. Radial burndown power limit (PRB) during radial burndown conditions.
4.2.2.4.d INSERT 2 (page 1 of 2) 3 ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME 4.2.2.2.a.1)
B. ------------NOTE------------ B.1 Reduce THERMAL 15 minutes Required Action B.4 POWER 1% RTP for shall be completed each 1% Fj(Z) exceeds whenever this Condition limit.
is entered.
AND 4.2.2.2.a.1) FQ(Z) not within limit B.2 Reduce Power Range 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> DOC M02 when determined per Neutron Flux - High trip SR 3.2.1.2 and Fj(Z) 1% RTP for each exceeds limit by 4%. 1% Fj(Z) exceeds limit.
AND DOC M02 B.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> setpoints 1% RTP for each 1% Fj(Z) exceeds limit.
AND DOC M02 B.4 Perform SR 3.2.1.2. Prior to increasing THERMAL POWER above the limit of Required Action B.1 Insert Page 3.2.1-1a
INSERT 2 (page 2 of 2)
CONDITION REQUIRED ACTION COMPLETION TIME 4.2.2.2.a.2) C. FQ(Z) not within limits C.1 Reduce THERMAL Immediately when determined per POWER PT.
SR 3.2.1.2 and Fj(Z) exceeds limit by > 4%.
D. FQP > FQL and D.1 Reduce THERMAL 15 minutes 4.2.2.3.d THERMAL POWER POWER PT.
> PBL specified in the COLR. OR OR D.2 Initiate action to perform 15 minutes SR 3.2.1.2 using 4.2.2.4.e FQP > FQL and augmented calculation.
THERMAL POWER
Insert Page 3.2.1-1b
FQ(Z) (RAOC-W(Z) Methodology) 1 3.2.1B CTS ACTIONS (continued)
REQUIRED ACTION COMPLETION TIME B. ------------NOTE------------ B.1 Reduce AFD limits 1% for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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.
AND 2 B.3 Reduce Overpower T trip 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> setpoints 1% for each 1%
that the maximum allowable power of the AFD limits is reduced.
AND B.4 Perform SR 3.2.1.1 and Prior to increasing SR 3.2.1.2. THERMAL POWER above the maximum allowable power of the AFD limits DOC M01 C. Required Action and C.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 2 associated Completion Time not met.
E Westinghouse STS 3.2.1B-2 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY
FQ(Z) (RAOC-W(Z) Methodology) 1 3.2.1B SURVEILLANCE REQUIREMENTS
NOTE----------------------------------------------------------- 2 During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.
SURVEILLANCE FREQUENCY Insert 3 Once after each SR 3.2.1.1 Verify FQC ( Z ) is within limit. refueling prior to THERMAL POWER exceeding 75% RTP AND Once within
[12] hours after achieving equilibrium 4 conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC ( Z ) was last verified AND
[ 31 EFPD 5
thereafter OR In accordance with the Surveillance Frequency Control Program ]
Insert 4 3 Westinghouse STS 3.2.1B-3 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY
ITS 3.2.1 CTS INSERT 3 3 4.2.2.1 -----------------------------NOTE------------------------------
Not required to be performed when FQP exceeds FQL and THERMAL POWER is > PT.
Insert 3.2.1-3
ITS 3.2.1 CTS INSERT 4 (page 1 of 2) 3 SR 3.2.1.2 -----------------------------NOTE------------------------------
Only required to be performed when FQP exceeds 4.2.2.1 FQL and THERMAL POWER is > PT.
4.2.2.2.b Verify FQ(Z) is within limit specified in the COLR Within 2, 4, and 8 4.2.2.3.a.1.c) using calculation for base load operation or radial hours following 4.2.2.4.b burndown conditions, or augmented calculation. THERMAL POWER exceeding PT AND Within 2, 4, and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> following movement of Control Bank D more than accumulated total of 15 steps in any direction AND Once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of entering base load operation AND 31 EFPDs thereafter during base load operation AND In accordance with the Surveillance Frequency Control Program Insert 3.2.1-3
ITS 3.2.1 CTS INSERT 4 (Page 2 of 2)
SR 3.2.1.3 -----------------------------NOTE------------------------------
4.2.2.1 Only required to be performed when FQP exceeds FQL and THERMAL POWER is > PT.
4.2.2.3.a.1.d) Calculate PBL. Prior to entering 4.2.2.3.a.2.d) base load operation Insert 3.2.1-3
FQ(Z) (RAOC-W(Z) Methodology) 1 3.2.1B SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY SR 3.2.1.2 -------------------------------NOTE------------------------------
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.
2 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 Westinghouse STS 3.2.1B-4 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY
FQ(Z) (RAOC-W(Z) Methodology) 1 3.2.1B SURVEILLANCE REQUIREMENTS (continued)
SURVEILLANCE FREQUENCY
In accordance with the Surveillance Frequency Control Program ]
Westinghouse STS 3.2.1B-5 Rev. 5.0 1 Turkey Point Unit 3 and Unit 4 Amendment XXX and YYY
JUSTIFICATION FOR DEVIATIONS ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
- 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. The plant specific methodology of calculating heat flux hot channel factor (FQ(Z))
C W does not use the approximation terms FQ (Z) and FQ (Z). Therefore, the LCO C W phrase, as approximated by FQ (Z) and FQ (Z), is not included in the ITS.
Subsequently, conforming changes include removing ISTS 3.2.1 ACTION B and ISTS SR 3.2.1.2 and revising ITS 3.2.1 Required Action A.4 to remove and SR 3.2.1.2. The plant specific methodology of calculating FQ(Z) compares the measured FQ(Z) to the FQ(Z) limit as specified in CTS 3.2.2 and 4.2.2.1 (ITS SR C
3.2.1.1). Therefore, ISTS 3.2.1 ACTION A and SR 3.2.1.1 are revised from FQ (Z) to FQ(Z) and Condition A is modified to state: FQ(Z) not within limit when determined by SR 3.2.1.1.
- 3. ISTS LCO 3.2.1 is modified to include CTS requirements related to operation with THERMAL POWER predicted power limit (PT) when predicted FQ (FQP) exceeds the FQ limit (FQL). When FQP exceeds FQL and THERMAL POWER is (PT),
additional criteria are required. Specifically, during base load operation with FQP >
FQL and THERMAL POWER PT, THERMAL POWER must be maintained below the calculated base load limit (PBL) specified in the COLR, which may more restrictive than 100% RTP. Likewise, during radial burndown conditions with FQP
> FQL and THERMAL POWER PT, THERMAL POWER must be maintained below the calculated radial burndown limit (PRB) specified in the COLR, which may more restrictive than 100% RTP. Consistent with CTS 4.2.2.2 requirements when FQ(Z) is not within limits as determined by SR 3.2.1.2, ACTIONS B and C are added. Proposed Required Actions B.2, B.3, and B.4 and the Note to Condition B are similar to ISTS 3.2.1 Required Actions A.2, A.3, and A.4 and the Note to Condition A. Additionally, proposed ACTION D is provided for conditions when FQP > FQL and THERMAL POWER exceeds the allowable power limits during base load operation or radial burndown conditions as specified in CTS. ITS SR 3.2.1.2 is added to verify FQ(Z) is within the limits specified in the COLR using calculation for base load operation or radial burndown conditions, or augmented calculation.
This SR is based on the CTS Surveillances for MIDS, Base Load, and Radial Burndown. ITS SR 3.2.1.3 is added to ensure PBL is calculated prior to entering base load operation based on CTS 4.2.2.3 requirements. ITS SRs 3.2.1.1, 3.2.1.2 and 3.2.1.3 are conditionally based on if the FQP exceeds FQL and if THERMAL POWER is at or above the predicted power limit. The Note to SR 3.2.1.1 states that the SR is not required to be performed when FQP exceeds FQL and THERMAL POWER is PT. The Note to proposed SR 3.2.1.2 and 3.2.1.3 only requires these SRs to be performed when FQP exceeds FQL and THERMAL POWER is PT. These deviations from the ISTS were made to capture PTN plant specific requirements.
- 4. The second Frequency for ISTS SR 3.2.1.1, Once within [12] hours after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQ(Z) was last verified, is not included in the PTN ITS. This frequency is not currently required by the CTS and, therefore is not retained in the ITS.
Turkey Point Unit 3 and Unit 4 Page 1 of 2
JUSTIFICATION FOR DEVIATIONS ITS SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
- 5. 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 provided. This is acceptable since the information/value is changed to reflect the current licensing basis.
Turkey Point Unit 3 and Unit 4 Page 2 of 2
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B B 3.2 POW ER DISTRIBU TION L IMITS B 3.2.1B H eat F lux H ot Channel F actor ( F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 BASES BACK G ROU ND The purpose of the limits on the v alues of F Q ( Z ) is to limit the local
( i.e., pellet) peak pow er density . The v alue of F Q ( Z ) v aries along the ax ial height ( Z ) of the core.
F Q ( Z ) is def ined as the max imum local f uel rod linear pow er density div ided b y the av erage f uel rod linear pow er density , assuming nominal f uel pellet and f uel rod dimensions. Theref ore, F Q ( Z ) is a measure of the peak f uel pellet pow er w ithin the reactor core.
During pow er operation, the glob al pow er distrib ution is limited b y L CO 3.2.3, " AX IAL F L U X DIF F ERENCE ( AF D) , " and L CO 3.2.4,
" Q U ADRANT POW ER TIL T RATIO( Q PTR) , " w hich are directly and continuously measured process v ariab les. These L COs, along w ith L CO 3.1.6, " Control Bank Insertion L imits, " maintain the core limits on pow er distrib utions on a continuous b asis.
F Q ( Z ) v aries w ith f uel loading patterns, control b ank insertion, f uel b urnup, and changes in ax ial pow er distrib ution.
F Q ( Z ) is measured periodically using the incore detector sy stem. These measurements are generally tak en w ith the core at or near equilib rium conditions.
U sing the measured three dimensional pow er distrib utions, it is possib le to deriv e a measured v alue f or F Q ( Z ) . H ow ev er, b ecause this v alue represents an equilib rium condition, it does not include the v ariations in the v alue of F Q ( Z ) w hich are present during nonequilib rium situations such as load f ollow ing or pow er ascension.
To account f or these possib le v ariations, the equilib rium v alue of F Q ( Z ) is adj usted as F ( Z ) b y an elev ation dependent f actor that accounts f or the W
Q 1 calculated w orst case transient conditions.
Core monitoring and control under non-equilib rium conditions are accomplished b y operating the core w ithin the limits of the appropriate L COs, including the limits on AF D, Q PTR, and control rod insertion.
W estinghouse STS B 3.2.1B-1 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES APPL ICABL E This L CO precludes core pow er distrib utions that v iolate the f ollow ing SAF ETY f uel design criteria:
ANAL Y SES
- a. During a large b reak loss of coolant accident ( L OCA) , the peak cladding temperature must not ex ceed 220 0 ° F ( Ref . 1) ,
b . During a loss of f orced reactor coolant f low accident, there must b e at least 9 5 % prob ab ility at the 9 5 % conf idence lev el ( the 9 5 /9 5 DNB criterion) that the hot f uel rod in the core does not ex perience a departure f rom nucleate b oiling ( DNB) condition,
- c. During an ej ected rod accident, the energy deposition to the f uel must not ex ceed 28 0 cal/gm ( Ref . 2) , and 1 20 0
- d. The control rods must b e capab le of shutting dow n the reactor w ith a minimum required SDM w ith the highest w orth control rod stuck f ully w ithdraw n ( Ref . 3) .
L imits on F Q ( Z ) ensure that the v alue of the initial total peak ing f actor assumed in the accident analy ses remains v alid. Other criteria must also b e met ( e.g., max imum cladding ox idation, max imum hy drogen generation, coolab le geometry , and long term cooling) . H ow ev er, the peak cladding temperature is ty pically most limiting.
F Q ( Z ) limits assumed in the L OCA analy sis are ty pically limiting relativ e to
( i.e., low er than) the F Q ( Z ) limit assumed in saf ety analy ses f or other postulated accidents. Theref ore, this L CO prov ides conserv ativ e limits f or other postulated accidents F Q ( Z ) satisf ies Criterion 2 of 10 CF R 5 0 .36( c) ( 2) ( ii) .
INSERT 1 L CO The H eat F lux H ot Channel F actor, F Q ( Z ) , shall b e limited b y the f ollow ing relationships:
FQ(Z) ( CF Q / P) K ( Z ) f or P > 0 .5 FQ(Z) ( CF Q / 0 .5 ) K ( Z ) for P 0 .5 1
w here: CF Q is the F Q ( Z ) limit at RTP prov ided in the COL R, K ( Z ) is the normaliz ed F Q ( Z ) as a f unction of core height prov ided in the COL R, and P = TH ERMAL POW ER / RTP W estinghouse STS B 3.2.1B-2 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
INSERT 1 LCO 3.2.2 F LQ (Z) shall be limited by the following relationships:
LX
[FQ ]
FM Q (Z) [K(Z)] for P > 0.5 P
L
[FQ ] X FM Q (Z) [K(Z)] for P 0.5
0.5 where
[FQ]L = FQ limit at RTP as specified in the COLR THERMAL POWER P=
[FQ]M = measured value, and K(Z) for a given core height, is specified in the K(Z) curve, defined in the COLR.
Insert B 3.2.1-2
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES L CO ( continued)
F or this f acility , the actual v alues of CF Q and K ( Z ) are giv en in the COL R; how ev er, CF Q is normally a numb er on the order of [ 2.32] , and K ( Z ) is a f unction that look s lik e the one prov ided in F igure B 3.2.1B-1.
F or Relax ed Ax ial Of f set Control operation, F Q ( Z ) is approx imated b y F Q C
( Z ) and F Q W
( Z ) . Thus, b oth F Q C
( Z ) and F Q W
( Z ) must meet the preceding limits on F Q ( Z ) .
An F ( Z ) ev aluation requires ob taining an incore f lux map in MODE 1.
C Q
F rom the incore f lux map results w e ob tain the measured v alue ( F Q ( Z ) ) of M
F Q ( Z ) . Then, F Q C
(Z ) = F Q M
( Z ) [ 1.0 8 15 ]
w here [ 1.0 8 15 ] is a f actor that accounts f or f uel manuf acturing tolerances 1 and f lux map measurement uncertainty .
F Q C
( Z ) is an ex cellent approx imation f or F Q ( Z ) w hen the reactor is at the steady state pow er at w hich the incore f lux map w as tak en.
The ex pression f or F ( Z ) is:
W Q
F Q W
(Z ) = F Q C
(Z ) W (Z )
w here W ( Z ) is a cy cle dependent f unction that accounts f or pow er distrib ution transients encountered during normal operation. W ( Z ) is included in the COL R. The F ( Z ) is calculated at equilib rium conditions.
C Q
The F Q ( Z ) limits def ine limiting v alues f or core pow er peak ing that precludes peak cladding temperatures ab ov e 220 0 ° F during either a large or small b reak L OCA.
This L CO requires operation w ithin the b ounds assumed in the saf ety analy ses. Calculations are perf ormed in the core design process to conf irm that the core can b e controlled in such a manner during operation that it can stay w ithin the L OCA F Q ( Z ) limits. If F Q C ( Z ) cannot b e 1 maintained w ithin the L CO limits, reduction of the core pow er is required and if F Q ( Z ) cannot b e maintained w ithin the L CO limits, reduction of the W
AF D limits is required. Note that suf f icient reduction of the AF D limits w ill 1 also result in a reduction of the core pow er.
V iolating the L CO limits f or F Q ( Z ) produces unacceptab le consequences if INSERT 2 a design b asis ev ent occurs w hile F Q ( Z ) is outside its specif ied limits.
W estinghouse STS B 3.2.1B-3 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
ITS 3.2.1 1
INSERT 2 When utilizing augmented surveillance methods to determine if FQ is within its predicted limit, a predicted threshold power (PT) is calculated as specified in the COLR. PT is defined as that reactor power level at which predicted FQ would exceed its limit. With predicted FQ (FQP) > FQ limit (FQL) and THERMAL POWER > PT calculated as specified in the COLR, FQ(Z) could exceed the limit during base load operation or during radial burndown conditions. Therefore, THERMAL POWER is required to be maintained below specific limits when the calculated limits are less than 100% RTP. During base load operation, THERMAL POWER must be maintained below the base load power limit (PBL) as calculated per the method specified in the COLR and during radial burndown conditions, THERMAL POWER must be maintained below the radial burndown power limit (PRB) as calculated per the method specified in the COLR.
The following are augmented surveillance methods used to ensure peaking factors are acceptable for continued operation above:
Base Load - This method uses the following equation to determine peaking factors:
FQBL = FQ(Z) measured x 1.09 x W(Z)BL where: W(Z)BL = accounts for power shapes; 1.09 = accounts for uncertainty; FQ(Z) = measured data; FQBL = Base load peaking factor.
Insert B 3.2.1-3a
ITS 3.2.1 1
INSERT 2 (cont.)
The analytically determined FQP is formulated to generate limiting shapes for all load follow maneuvers consistent with control to a +/- 5%
band about the target flux difference. FQP must be determined using approved physics calculations. For base load operation the severity of the shapes that need to be considered is significantly reduced relative to load follow operation.
The severity of possible shapes is small due to the restrictions imposed by preconditions and requirements to enter base load operation defined in the Technical Requirements Manual. To quantify the effect of the limiting transients which could occur during base load operation, the function W(Z)BL is calculated from the following relationship:
FQ (Z) (Base Load Case(s), 150 MWD/T) FQ (Z) (Base Case(s), 85% EOL BU)
W(Z) BL = Max ,
F (Z) (ARO, 150 MWD/T) F (Z) (ARO, 85% BOL BU)
Q Q Radial Burndown - This method uses the following equation to determine peaking factors.
FQ(Z)R.B.. = Fxy(Z)measured x F (Z) x 1.09 z
where: 1.09 = accounts for uncertainty Fz(Z) = accounts for axial power shapes Fxy(Z) measured = ratio of peak power density to average power density at elevation(Z)
FQ(Z)RB= Radial Burndown Peaking Factor.
For radial burndown operation the full spectrum of possible shapes consistent with control to a +/-5% Delta-I band needs to be considered in determining power capability. Accordingly, to quantify the effect of the limiting transients which could occur during radial burndown operation, the function Fz(Z) is calculated from the following relationship:
Fz(Z) = [FQ(Z)] FAC Analysis/[ Fxy(Z)] ARO Insert B 3.2.1-3b
ITS 3.2.1 1
INSERT 2 (cont.)
The essence of the procedure is to maintain the xenon distribution in the core as close to the equilibrium full power condition as possible.
This can be accomplished by using the boron system to position the full length control rods to produce the required indicated flux difference.
Above the power level of PT, additional flux shape monitoring is required. In order to assure that the total power peaking factor, FQ, is maintained at or below the limiting value, the movable incore instrumentation will be utilized. Thimbles are selected initially during startup physics tests so that the measurements are representative of the peak core power density. By limiting the core average axial power distribution, the total power peaking factor FQ can be limited since all other components remain relatively fixed. The remaining part of the total power peaking factor can be derived from incore measurements, i.e., an effective radial peaking factor, can be determined as the ratio of the total peaking factor resulting from a full core flux map and the axial peaking factor in a selected thimble.
The limiting value of [Fj (Z)]s is derived as follows:
[FQ ]L x [K(Z)]
[Fj (Z)]s =
PL R j (1 + j ) (1.03) (1.07)
Where:
a) Fj (Z) is the normalized axial power distribution from thimble j at elevation Z.
b) PL is reactor thermal power expressed as a fraction of 1.
c) K(Z) is the reduction in the FQ limit as a function of core elevation (Z) as specified in the COLR.
d) [Fj (Z)]s is the alarm setpoint for the Movable Incore Detector System.
e) Rj, for thimble j, is determined from n=6 incore flux maps covering the full configuration of permissible rod patterns at the THERMAL POWER limit of PT.
Insert B 3.2.1-3c
ITS 3.2.1 1
INSERT 2 (cont.)
n R ij i=1 Rj =
n where FQi meas.
R ij =
[Fi j (Z)] max and Fj(Z) is the normalized axial distribution at elevation Z from thimble j in map i which has a measure peaking factor without uncertainties or densification allowance of FQi meas.
f) j is the standard deviation, expressed as a fraction or percentage of R j and is derived from n flux maps and the relationship below, or 0.02 (2%), whichever is greater.
1 1 n 2 (R ij R j )
2 n 1 j = i=1 Rj g) The factor 1.03 reduction in the kw/ft limit is the engineering uncertainty factor.
h) The factors (1+ j) and 1.07 represent the margin between (Fj(Z)]L limit and the MIDS alarm setpoint [Fj(Z)]s. Since (1 +j) is bounded by a lower limit of 1.02, there is at least a 9% reduction of the alarm setpoint. Operations are permitted in excess of the operational limit 4% while making power adjustment on a percent for percent basis.
Insert B 3.2.1-3d
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES APPL ICABIL ITY The F Q ( Z ) limits must b e maintained in MODE 1 to prev ent core pow er 1 distrib utions f rom ex ceeding the limits assumed in the saf ety analy ses.
Applicab ility in other MODES is not required b ecause there is either insuf f icient stored energy in the f uel or insuf f icient energy b eing transf erred to the reactor coolant to require a limit on the distrib ution of core pow er.
ACTIONS A.1 Reducing THERMAL POWER by 1% RTP f or each 1% b y w hich F Q C
(Z )
1 ex ceeds its limit, maintains an acceptab le ab solute pow er density . F (Z )
C Q
is F ( Z ) multiplied b y a f actor accounting f or manuf acturing tolerances M
Q and measurement uncertainties. F Q ( Z ) is the measured v alue of F Q ( Z ) .
M The Completion Time of 15 minutes prov ides an acceptab le time to reduce pow er in an orderly manner and w ithout allow ing the plant to remain in an unacceptab le condition f or an ex tended period of time. The max imum allow ab le pow er lev el initially determined b y Required Action A.1 may b e af f ected b y sub sequent determinations of F Q C ( Z ) and w ould 1
require pow er reductions w ithin 15 minutes of the F Q C ( Z ) determination, if necessary to comply w ith the decreased max imum allow ab le pow er lev el.
Decreases in F Q C ( Z ) w ould allow increasing the max imum allow ab le 1 pow er lev el and increasing pow er up to this rev ised limit.
A.2 A reduction of the Pow er Range Neutron F lux - H igh trip setpoints b y 1% f or each 1% b y w hich F Q C ( Z ) ex ceeds its limit, is a conserv ativ e 1 action f or protection against the consequences of sev ere transients w ith unanaly z ed pow er distrib utions. The Completion Time of 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is suf f icient considering the small lik elihood of a sev ere transient in this time period and the preceding prompt reduction in TH ERMAL POW ER in accordance w ith Required Action A.1. The max imum allow ab le Pow er Range Neutron F lux - H igh trip setpoints initially determined b y Required Action A.2 may b e af f ected b y sub sequent determinations of F Q C ( Z ) and 1 w ould require Pow er Range Neutron F lux - H igh trip setpoint reductions w ithin 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the F Q C ( Z ) determination, if necessary to comply w ith 1 the decreased max imum allow ab le Pow er Range Neutron F lux - H igh trip setpoints. Decreases in F Q C ( Z ) w ould allow increasing the max imum 1 allow ab le Pow er Range Neutron F lux - H igh trip setpoints.
W estinghouse STS B 3.2.1B-4 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES ACTIONS ( continued)
A.3 Reduction in the Overpower T trip setpoints (value of K4) by 1% f or each 1% b y w hich F Q C ( Z ) ex ceeds its limit, is a conserv ativ e action f or 1 protection against the consequences of sev ere transients w ith unanaly z ed pow er distrib utions. The Completion Time of 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is suf f icient considering the small lik elihood of a sev ere transient in this time period, and the preceding prompt reduction in TH ERMAL POW ER in accordance w ith Required Action A.1. The max imum allow ab le Overpower T trip setpoints initially determined by Required Action A.3 may b e af f ected b y sub sequent determinations of F Q C ( Z ) and w ould 1 require Overpower T trip setpoint reductions within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of the F Q C ( Z ) determination, if necessary to comply w ith the decreased 1
maximum allowable Overpower T trip setpoints. Decreases in F Q C ( Z )
w ould allow increasing the maximum allowable Overpower T trip setpoints.
A.4 V erif ication that F Q C ( Z ) has b een restored to w ithin its limit, b y perf orming 1 SR 3.2.1.1 and SR 3.2. 1.2 prior to increasing TH ERMAL POW ER ab ov e 2 the limit imposed b y Required Action A.1, ensures that core conditions during operation at higher pow er lev els and f uture operation are consistent w ith saf ety analy ses assumptions.
Condition A is modif ied b y a Note that requires Required Action A.4 to b e perf ormed w henev er the Condition is entered. This ensures that SR 3.2.1.1 and SR 3.2.1.2 w ill b e perf ormed prior to increasing 2 TH ERMAL POW ER ab ov e the limit of Required Action A.1, ev en w hen is Condition A is ex ited prior to perf orming Required Action A.4.
Once SR 3.2.1.1, as Perf ormance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure F Q ( Z ) 2 demonstrated through incore is properly ev aluated prior to increasing TH ERMAL POW ER.
mapping, has b een satisf actorily perf ormed, TH ERMAL POW ER may b e increased. 2 B.1 If it is f ound that the max imum calculated v alue of F Q ( Z ) that can occur during normal maneuv ers, F ( Z ) , ex ceeds its specif ied limits, there ex ists W
Q a potential f or F Q ( Z ) to b ecome ex cessiv ely high if a normal operational C
INSERT 3 2 transient occurs. Reducing the AFD by 1% f or each 1% b y w hich F Q W
( Z ) ex ceeds its limit w ithin the allow ed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, restricts the ax ial f lux distrib ution such that ev en if a transient occurred, core peak ing f actors are not ex ceeded.
W estinghouse STS B 3.2.1B-5 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
ITS 3.2.1 INSERT 3 (page 1 of 2) 2 B.1 Reducing THERMAL POWER by 1% RTP for each 1% by which Fj(Z) exceeds its limit, maintains an acceptable absolute power density. The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time.
B.2 A reduction of the Power Range Neutron Flux - High trip setpoints by 1% for each 1% by which Fj(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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER in accordance with Required Action B.1.
B.3 Reduction in the Overpower T trip setpoints, consistent with the THERMAL POWER reduction, provides protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is sufficient considering the small likelihood of a severe transient in this period, and the preceding prompt reduction in THERMAL POWER in accordance with Required Actions.
B.4 Verification that FQ(Z) has been restored to within its limit, by performing SR 3.2.1.2 prior to increasing THERMAL POWER above the 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 3.2.1.2 will be performed prior to increasing THERMAL POWER above the limit of Required Action B.1, even when Condition B is exited prior to performing Required Action B.4. Performance of SR 3.2.1.2 is necessary to assure FQ(Z) is properly evaluated prior to increasing THERMAL POWER.
Insert B 3.2.1-5a
ITS 3.2.1 INSERT 3 (page 2 of 2) 2 C.1 Condition C applies when FQ(Z) is not within limits as determined per SR 3.2.1.2 and Fj(Z) exceeds limit by > 4%. Since FQ(Z) is calculated using augmented surveillance methods, continued operation above PT is not allowed if Fj(Z) is above the Movable Incore Detector System alarm setpoint by more than 4%. Therefore, action must be taken immediately to reduce THERMAL POWER to at least PT.
D.1 and D.2 Condition D applies when FQP > FQL and THERMAL POWER > PBL specified in the COLR or when FQP > FQL and THERMAL POWER > PRB specified in the COLR. With FQP greater than FQL and THERMAL POWER greater than PT specified in the COLR, THERMAL POWER is limited to PBL during base load operation and limited to PRB during radial burndown conditions.
When these power limitations are exceeded, FQ(Z) may have exceeded the limit. Therefore, a power reduction is required to below PT to ensure FQ(Z) remains within the limit. Alternately, action may be initiated to perform SR 3.2.1.2 using the augmented calculation method to verify FQ(Z) continues to be within limits. The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner or initiate action to perform SR 3.2.1.2 without allowing the plant to remain in an unacceptable condition for an extended period of time.
Insert B 3.2.1-5b
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES ACTIONS ( continued)
The implicit assumption is that if W ( Z ) v alues w ere recalculated
( consistent w ith the reduced AF D limits) , then F Q ( Z ) times the C
recalculated W ( Z ) v alues w ould meet the F Q ( Z ) limit. Note that comply ing w ith this action ( of reducing AF D limits) may also result in a pow er reduction. H ence the need f or Required Actions B.2, B.3 and B.4.
B.2 A reduction of the Pow er Range Neutron F lux -High trip setpoints by 1%
f or each 1% b y w hich the max imum allow ab le pow er is reduced, is a conserv ativ e action f or protection against the consequences of sev ere transients w ith unanaly z ed pow er distrib utions. The Completion Time of 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is suf f icient considering the small lik elihood of a sev ere transient in this time period and the preceding prompt reduction in TH ERMAL POW ER as a result of reducing AF D limits in accordance w ith Required Action B.1.
B.3 Reduction in the Overpower T trip setpoints value of K4 by 1% f or each 1% b y w hich the max imum allow ab le pow er is reduced, is a 2
conserv ativ e action f or protection against the consequences of sev ere transients w ith unanaly z ed pow er distrib utions. The Completion Time of 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is suf f icient considering the small lik elihood of a sev ere transient in this time period, and the preceding prompt reduction in TH ERMAL POW ER as a result of reducing AF D limits in accordance w ith Required Action B.1.
B.4 V erif ication that F Q W ( Z ) has b een restored to w ithin its limit, b y perf orming SR 3.2.1.1 and SR 3.2.1.2 prior to increasing TH ERMAL POW ER ab ov e the max imum allow ab le pow er limit imposed b y Required Action B.1 ensures that core conditions during operation at higher pow er lev els and f uture operation are consistent w ith saf ety analy ses assumptions.
Condition B is modif ied b y a Note that requires Required Action B.4 to b e perf ormed w henev er the Condition is entered. This ensures that SR 3.2.1.1 and SR 3.2.1.2 w ill b e perf ormed prior to increasing TH ERMAL POW ER ab ov e the limit of Required Action B.1, ev en w hen Condition A is ex ited prior to perf orming Required Action B.4.
Perf ormance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to assure F Q ( Z )
is properly ev aluated prior to increasing TH ERMAL POW ER.
W estinghouse STS B 3.2.1B-6 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES ACTIONS ( continued)
E C.1 If Required Actions A.1 through A.4 or B.1 through B.4 are not met w ithin their associated Completion Times, the plant must b e placed in a mode or condition in w hich the L CO requirements are not applicab le. This is done b y placing the plant in at least MODE 2 w ithin 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
This allow ed Completion Time is reasonab le b ased on operating ex perience regarding the amount of time it tak es to reach MODE 2 f rom f ull pow er operation in an orderly manner and w ithout challenging plant sy stems. , and, SR 3.2.1.3 SU RV EIL L ANCE SR 3.2.1.1, and SR 3.2.1.2 are modif ied b y a Note. The Note applies REQ U IREMENTS during the f irst pow er ascension af ter a ref ueling. It states that A pow er distrib ution TH ERMAL POW ER may b e increased until an equilib rium pow er lev el map may b e ob tained has b een achiev ed at w hich a pow er distrib ution map can b e ob tained.
using the mov ab le This allow ance is modif ied, how ev er, b y one of the F requency conditions incore detectors at any that requires v erif ication that F Q ( Z ) and F Q ( Z ) are w ithin their specif ied C W TH ERMAL POW ER in 2
MODE 1 b ef ore limits af ter a pow er rise of more than 10 % RTP ov er the TH ERMAL ex ceeding 7 5 % RTP.
POW ER at w hich they w ere last v erif ied to b e w ithin specif ied limits.
Because F Q ( Z ) and F Q ( Z ) could not hav e prev iously b een measured in C W f or SR 3.2.1.1 is The f irst this reload core, there is a second F requency condition, applicab le only f or reload cores, that requires determination of these parameters b ef ore ex ceeding 7 5 % RTP. This ensures that some determination of F Q ( Z ) and C
F Q W ( Z ) are made at a low er pow er lev el at w hich adequate margin is F Q ( Z ) is av ailab le b ef ore going to 10 0 % RTP. Also, this F requency condition, together w ith the F requency condition requiring v erif ication of F Q ( Z ) and C
F Q W ( Z ) f ollow ing a pow er increase of more than 10 % , ensures that they are v erif ied as soon as RTP ( or any other lev el f or ex tended operation) is achiev ed. In the ab sence of these F requency conditions, it is possib le to increase pow er to RTP and operate f or 31 day s w ithout v erif ication of F Q C
( Z ) and F Q W
( Z ) . The F requency condition is not intended to require v erif ication of these parameters af ter ev ery 10 % increase in pow er lev el ab ov e the last v erif ication. It only requires v erif ication af ter a pow er lev el is achiev ed f or ex tended operation that is 10 % higher than that pow er at w hich F Q ( Z ) w as last measured.
W estinghouse STS B 3.2.1B-7 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES SU RV EIL L ANCE REQ U IREMENTS ( continued)
SR 3.2.1.1 V erif ication that F Q C ( Z ) is w ithin its specif ied limits inv olv es increasing F Q M ( Z ) to allow f or manuf acturing tolerance and measurement uncertainties in order to ob tain F ( Z ) . Specif ically ,
C Q F Q M
( Z ) is the measured v alue of F Q ( Z ) ob tained f rom incore f lux map results and F Q ( Z ) = F Q ( Z )
C M
[ 1.0 8 15 ] ( Ref . 4) . F Q ( Z ) is then compared to its specif ied limits.
C The limit w ith w hich F Q C ( Z ) is compared v aries inv ersely w ith pow er ab ov e 5 0 % RTP and directly w ith a f unction called K ( Z ) prov ided in the COL R.
2 This SR, w hich uses the Perf orming this Surv eillance in MODE 1 prior to ex ceeding 7 5 % RTP normal method, is modif ied b y a Note stating that the ensures that the F Q C ( Z ) limit is met w hen RTP is achiev ed, b ecause SR is not required to b e peak ing f actors generally decrease as pow er lev el is increased.
perf ormed if F Q P ex ceeds F Q L and TH ERMAL POW ER is > PT. W hen F Q P ex ceeds If THERMAL POWER has been increased by 10 % RTP since the last determination of F ( Z ) , another ev aluation of this f actor is required F Q L and TH ERMAL POW ER Q C
is > PT, F Q ( Z ) is calculated per SR 3.2.1.2 using an [ 12] hours af ter achiev ing equilib rium conditions at this higher pow er lev el augmented calculational
( to ensure that F Q ( Z ) v alues are b eing reduced suf f iciently w ith pow er C
method or calculational methods f or b ase load or increase to stay w ithin the L CO limits) .
radial b urndow n, as applicab le, in accordance w ith the COL R. [ The F requency of 31 EF PD is adequate to monitor the change of pow er distrib ution w ith core b urnup b ecause such changes are slow and w ell 4 controlled w hen the plant is operated in accordance w ith the Technical Specif ications ( TS) .
OR The Surv eillance F requency is controlled under the Surv eillance F requency Control Program.
REV IEW ER S NOTE-----------------------------------
Plants controlling Surv eillance F requencies under a Surv eillance F requency Control Program should utiliz e the appropriate F requency 3 description, giv en ab ov e, and the appropriate choice of F requency in the Surv eillance Requirement.
]
W estinghouse STS B 3.2.1B-8 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES SU RV EIL L ANCE REQ U IREMENTS ( continued)
SR 3.2.1.2 INSERT 4 The nuclear design process includes calculations perf ormed to determine that the core can b e operated w ithin the F Q ( Z ) limits. Because f lux maps are tak en in steady state conditions, the v ariations in pow er distrib ution resulting f rom normal operational maneuv ers are not present in the f lux map data. These v ariations are, how ev er, conserv ativ ely calculated b y considering a w ide range of unit maneuv ers in normal operation. The max imum peak ing f actor increase ov er steady state v alues, calculated as a f unction of core elev ation, Z , is called W ( Z ) . Multiply ing the measured total peak ing f actor, F ( Z ) , b y W ( Z ) giv es the max imum F Q ( Z ) calculated C
Q to occur in normal operation, F Q ( Z ) .
W The limit w ith w hich F Q ( Z ) is compared v aries inv ersely w ith pow er ab ov e W
5 0 % RTP and directly w ith the f unction K ( Z ) prov ided in the COL R.
The W ( Z ) curv e is prov ided in the COL R f or discrete core elev ations.
F lux map data are ty pically tak en f or 30 to 7 5 core elev ations. F Q ( Z )
W ev aluations are not applicab le f or the f ollow ing ax ial core regions, measured in percent of core height:
2
- a. L ow er core region, f rom 0 to 15 % inclusiv e and b . U pper core region, f rom 8 5 to 10 0 % inclusiv e.
The top and b ottom 15 % of the core are ex cluded f rom the ev aluation b ecause of the low prob ab ility that these regions w ould b e more limiting in the saf ety analy ses and b ecause of the dif f iculty of mak ing a precise measurement in these regions.
This Surv eillance has b een modif ied b y a Note that may require that more f requent surv eillances b e perf ormed. If F ( Z ) is ev aluated, an ev aluation W
Q is required to account f or any increase to F Q ( Z )
M of the ex pression b elow that may occur and cause the F Q ( Z ) limit to b e ex ceeded b ef ore the nex t required F Q ( Z ) ev aluation.
If the tw o most recent F Q ( Z ) ev aluations show an increase in the ex pression max imum ov er z [ F Q ( Z ) / K ( Z ) ] , it is required to meet the C
F Q ( Z ) limit w ith the last F Q ( Z ) increased b y the greater of a f actor of W
[ 1.0 2] or b y an appropriate f actor specif ied in the COL R ( Ref . 5 )
W estinghouse STS B 3.2.1B-9 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
INSERT 4 (page 1 of 1) 2 The nuclear design process includes calculations performed to determine that the core can be operated within the FQ(Z) limits. A 9% uncertainty factor accounts for manufacturing tolerances, measurement error, rod bow, and any burn up dependent peaking factor increases. During radial burndown conditions, measured [Fxy(Z)]MAP is obtained between core elevations bounded by 10% and 90% of the active core height. The value of function Fz(Z) is provided in the COLR and is analytically determined and accounts for the most perturbed axial power shapes which can occur under axial distribution control.
The periodic Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Above the power level of PT, additional flux shape monitoring is required to verify FQ(Z) is within limits.
The SR is modified by a Note. The Note indicates that the SR is only required to be performed if FQP exceeds FQL and THERMAL POWER is > PT. When FQP is FQL or THERMAL POWER is PT, FQ(Z) is calculated per SR 3.2.1.1 using normal manufacturing tolerances and measurement uncertainty.
SR 3.2.1.3 One of the requirements for base load operation with FQP > FQL and THERMAL POWER is > PT is that THERMAL POWER be maintained < PBL. Therefore, the base load power limit PBL must be calculated. The Surveillance Frequency of prior to entering base load operation ensures the power limit value PBL is known upon entry into base load operation with THERMAL POWER >
PT. The SR is modified by a Note indicating that calculating PBL is only required to be performed when FQP exceeds FQL and THERMAL POWER is > PT.
Insert B 3.2.1-9
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES SU RV EIL L ANCE REQ U IREMENTS ( continued)
REV IEW ER S NOTE-----------------------------------
W CAP-10 216-P-A, Rev . 1A, " Relax ation of Constant Ax ial Of f set Control and F Q Surv eillance Technical Specif ication, " F eb ruary 19 9 4, or other 3
appropriate plant specif ic methodology , is to b e listed in the COL R description in the Administrativ e Controls Section 5 .0 to address the methodology used to deriv e this f actor.
or to ev aluate F Q ( Z ) more f requently , each 7 EF PD. These alternativ e requirements prev ent F Q ( Z ) f rom ex ceeding its limit f or any signif icant period of time w ithout detection.
Perf orming the Surv eillance in MODE 1 prior to ex ceeding 7 5 % RTP ensures that the F Q ( Z ) limit is met w hen RTP is achiev ed, b ecause 2 peak ing f actors are generally decreased as pow er lev el is increased.
FQ(Z) is verified at power levels 10 % RTP ab ov e the TH ERMAL POW ER of its last v erif ication, [ 12] hours af ter achiev ing equilib rium conditions to ensure that F Q ( Z ) is w ithin its limit at higher pow er lev els.
[ The Surv eillance F requency of 31 EF PD is adequate to monitor the change of pow er distrib ution w ith core b urnup. The Surv eillance may b e done more f requently if required b y the results of F Q ( Z ) ev aluations.
The F requency of 31 EF PD is adequate to monitor the change of pow er distrib ution b ecause such a change is suf f iciently slow , w hen the plant is operated in accordance w ith the TS, to preclude adv erse peak ing f actors 4 b etw een 31 day surv eillances.
OR The Surv eillance F requency is controlled under the Surv eillance F requency Control Program.
REV IEW ER S NOTE-----------------------------------
Plants controlling Surv eillance F requencies under a Surv eillance F requency Control Program should utiliz e the appropriate F requency 3 description, giv en ab ov e, and the appropriate choice of F requency in the Surv eillance Requirement.
]
W estinghouse STS B 3.2.1B-10 Rev . 5 .0 Rev ision X X X 1 Turk ey Point U nit 3 and U nit 4
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B BASES REF ERENCES 1. 10 CF R 5 0 .46, 19 7 4.
U F SAR Section 14.2.6
- 2. Regulatory G uide 1.7 7 , Rev . 0 , May 19 7 4.
19 67 Atomic Energy Commission Proposed G eneral Design Criteria 27 , 28 , and 29 .
U F SAR Section 3.1.2
- 4. W CAP-7 30 8 -L -P-A, " Ev aluation of Nuclear H ot Channel F actor 1 U ncertainties, " J une 19 8 8 .
5 . W CAP-10 216-P-A, Rev . 1A, " Relax ation of Constant Ax ial Of f set Control ( and) F Q Surv eillance Technical Specif ication, " F eb ruary 19 9 4.
W estinghouse STS B 3.2.1B-11 Rev . 5 .0 1
Turk ey Point U nit 3 and U nit 4 Rev ision X X X
F Q ( Z ) ( RAOC-W ( Z ) Methodology ) 1 B 3.2.1B W estinghouse STS B 3.2.1B-12 Rev . 5 .0 1
Turk ey Point U nit 3 and U nit 4 Rev ision X X X
JUSTIFICATION FOR DEVIATIONS ITS BASES SECTION 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
- 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) Bases which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. Changes are being made to the PTN ITS Bases to reflect the Turkey Point Nuclear Generating Station (PTN) Improved Technical Specification (ITS) and changes made to reflect the PTN plant specific FQ(Z) requirements.
- 3. 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.
- 4. This bracketed requirement/information is deleted because it is not applicable to
[name of plant]. The following requirements are renumbered, where applicable, to reflect this deletion.
- 5. ITS Bases 3.2.1 contains Figure B 3.2.1 B-1, K(Z) - Normalized FQ(Z) as a Function of Core Height. The PTN CTS 3.2.1 Bases do not contain this figure, rather the figure is defined in the COLR. Therefore, this figure is not being retained in the PTN ITS 3.2.1 Bases.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, HEAT FLUX HOT CHANNEL FACTOR (FQ(Z))
There are no specific No Significant Hazards Considerations for this Specification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
ATTACHMENT 2 ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR FNH
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
ITS A0 1 ITS 3.2.2 3.2 POW ER DISTRIBU TION L IMITS N 3.2.2 F H A0 1 3/4.2.3 NU CL EAR ENTH AL PY RISE H OT CH ANNEL F ACTOR L IMITING CONDITION F OR OPERATION w ithin the limits specif ied in the COL R.
N A0 1 L CO 3.2.2 3.2.3 F shall b e limited b y the f ollow ing relationship:
H N
F H F RTP [ 1.0 + PF H ( 1-P) ] ,
H W here: RTP F H = F H limit at RATED TH ERMAL POW ER as specif ied in the CORE OPERATING L IMITS REPORT L A0 2 PF H = Pow er F actor Multiplier f or F H as specif ied in the CORE OPERATING L IMITS REPORT TH ERMAL POW ER P =
RATED TH ERMAL POW ER Applicab ility APPL ICABIL ITY : MODE 1.
ACTION: M0 1 Add proposed ACTION A Note ACTION A W ith F N ex ceeding its limit:
H 4
- a. W ithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either: L 0 3 Required Action A.1.1 1. Restore F N to w ithin the ab ov e limit, or H
Required Action A.1.2.1 2. Reduce TH ERMAL POW ER to less than 5 0 % of RATED TH ERMAL POW ER and reduce the Pow er Range Neutron F lux - H igh Trip Setpoint to less than or equal to 5 5 % of Required Action A.1.2.2 L 0 1 RATED TH ERMAL POW ER w ithin the nex t 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. 7 2 Required ACTION A.2 Required Action A.3 b . W ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of initially b eing outside the ab ov e limit, v erif y through incore f lux mapping that L A0 1 N
F H has b een restored to w ithin the ab ov e limit, or reduce TH ERMAL POW ER to less than 5 %
6 L 0 2 ACTION B of RATED TH ERMAL POW ER w ithin the nex t 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
- c. Identif y and correct the cause of the out-of -limit condition prior to increasing TH ERMAL POW ER Add proposed Required Action A.3 Note A0 2 ab ov e the reduced TH ERMAL POW ER limit required b y ACTION a.2. and /or b ., ab ov e; N
Required Action A.3 sub sequent POW ER OPERATION may proceed prov ided that F H is demonstrated, through L A0 1 incore f lux mapping, to b e w ithin the limit of acceptab le operation prior to ex ceeding the f ollow ing TH ERMAL POW ER lev els:
- 1. A nominal 5 0 % of RATED TH ERMAL POW ER, Completion Time A.3
- 2. A nominal 7 5 % of RATED TH ERMAL POW ER, and
- 3. W ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 9 5 % or RATED TH ERMAL POW ER.
Add proposed ACTION B M0 2 TU RK EY POINT - U NITS 3 & 4 3/4 2-9 AMENDMENT NOS. 260 AND 25 5 Page 1 of 2
ITS A0 1 ITS 3.2.2 POW ER DISTRIBU TION L IMITS SU RV EIL L ANCE REQ U IREMENTS A0 3 4.2.3.1 The prov isions of Specif ication 4.0 .4 are not applicab le.
4.2.3.2 W hen a measurement of F N is tak en, the measured F N shall b e increased b y 4% to account f or L A0 3 H H measurement error.
N L A0 1 4.2.3.3 This corrected F H shall b e determined to b e w ithin its limit through incore f lux mapping:
SR 3.2.2.1 a. Prior to operation ab ov e 7 5 % of RATED TH ERMAL POW ER af ter each f uel loading, and b . In accordance w ith the Surv eillance F requency Control Program.
TU RK EY POINT - U NITS 3 & 4 3/4 2-10 AMENDMENT NOS. 263 AND 25 8 Page 2 of 2
DISCUSSION OF CHANGES N
ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - F H ADMINISTRATIV E CH ANG ES A0 1 In the conv ersion of the Turk ey Point Nuclear G enerating Station ( PTN) Current Technical Specif ications ( CTS) to the plant specif ic Improv ed Technical Specif ications ( ITS) , certain changes ( w ording pref erences, editorial changes, ref ormatting, rev ised numb ering, etc.) are made to ob tain consistency w ith NU REG -1431, Rev . 5 .0 , " Standard Technical Specif ications - W estinghouse Plants" ( ISTS) .
These changes are designated as administrativ e changes and are acceptab le b ecause they do not result in technical changes to the CTS.
N N A0 2 CTS 3.2.3 ACTION c states in part that w ith F H ex ceeding its limit, F H must b e demonstrated to b e w ithin its limit prior to ex ceeding 5 0 % RATED TH ERMAL POW ER ( RTP) and 7 5 % RTP, and w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining or ex ceeding 9 5 % RTP. ITS 3.2.2 Required Action A.3 contains the same requirements.
H ow ev er, ITS 3.2.2 Required Action A.3 is modif ied b y a Note w hich states
" TH ERMAL POW ER does not hav e to b e reduced to comply w ith this Required Action." This modif ies the CTS b y adding a Note stating that TH ERMAL POW ER does not hav e to b e reduced to comply w ith the Required Action.
This change is acceptab le, b ecause the requirements hav e not changed. The Note is included in the ITS to mak e clear that TH ERMAL POW ER does not hav e N
to b e reduced to perf orm the Required Action. F or ex ample, if F H ex ceeds its limit and, per ITS Required Action A.1.2.1, TH ERMAL POW ER is reduced to 60 % RTP, TH ERMAL POW ER does not hav e to b e reduced to less than 5 0 %
N RTP to v erif y F H is w ithin its limit to comply w ith ITS Required Action A.3.
N H ow ev er, F H must still b e measured prior to ex ceeding 7 5 % RTP and w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining or ex ceeding 9 5 % RTP. The Note is needed b ecause the ITS contains a Note in ITS 3.2.2 ACTION A that states " Required Actions A.2 and A.3 must b e completed w henev er Condition A is entered." The ITS 3.2.2 ACTION A Note does not ex ist in the CTS and could b e construed as requiring TH ERMAL POW ER to b e reduced to comply w ith Required Action A.3. ( Addition of the ACTION A Note is discussed in DOC M0 1.) As a result, the Required Action A.3 Note mak es the ITS and CTS actions consistent. This change is designated as administrativ e, b ecause it does not result in technical changes to the CTS.
A0 3 CTS 4.2.3.1 " The prov isions of Specif ication 4.0 .4 are not applicab le" prov ides an allow ance f or entering the nex t higher MODE of Applicab ility w hen the L imiting Condition f or Operation ( L CO) is not met. ITS L CO 3.2.2 has no specif ic allow ance f or changing MODES at any time w ith ITS L CO 3.2.2 not met. ITS Surv eillance Requirement ( SR) 3.0 .4 is similar to the CTS ex ception to Specif ication 4.0 .4 b y stating " W hen an L CO is not met due to Surv eillances not hav ing b een met, entry into a MODE or other specif ied condition in the Applicab ility shall only b e made in accordance w ith L CO 3.0 .4."
Turk ey Point U nit 3 and U nit 4 Page 1 of 6
DISCUSSION OF CHANGES N
ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH The purpose of CTS 4.2.3.1 is to provide an exception to Specification 4.0.4.
Specification 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. ITS SR 3.0.4 is similar and applicable to all SRs (unless specifically noted otherwise) and effectively replaces the need to maintain the aforementioned CTS Specification 4.0.4 exception. This change is designated as administrative, because it does not result in technical changes to the CTS.
MORE RESTRICTIVE CHANGES N
M01 CTS 3.2.3 ACTION c states that with FH exceeding its limit "subsequent N
POWER OPERATION may proceed provided that FH is demonstrated, through incore flux mapping, to be within the above limit prior to exceeding the following THERMAL POWER levels: 1. A nominal 50% of RATED THERMAL POWER,
- 2. A nominal 75% of RATED THERMAL POWER, and 3. Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of attaining greater than or equal to 95% of RATED THERMAL POWER." However, under CTS 3.0.2, these measurements do not have to be completed, if compliance with the LCO is restored. ITS 3.2.2 ACTION A contains a Note which states, "Required Actions A.2 and A.3 must be completed whenever Condition A is entered." ITS 3.2.2 Required Action A.2 requires verification that FH min margin is within limits specified in the Core Operating Limits Report (COLR) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after entry into Condition A. Required Action A.3 requires verification that FH min margin is within limits specified in the COLR prior to THERMAL POWER exceeding 50% RTP and 75% RTP, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is greater than or equal to 95% RTP. This changes the CTS by requiring the verification that FH min margin is within limits specified in N
the COLR to be made even if FH is restored to within its limit.
This change is acceptable because it establishes appropriate compensatory N
measurements for violation of the FH limit. As power is reduced under ITS 3.2.2 N
Required Action A.1.2.1, the margin to the FH 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. This change is 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 and c cannot be met. Therefore, CTS 3.0.3 would be entered, which would allow 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to initiate a shutdown and to be in HOT STANDBY within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ITS 3.2.2 ACTION B, states that the plant must be in MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, if any Required Action and associated Completion Time is not met. This changes the CTS by eliminating the one hour to initiate a shut down and, consequently, allowing one hour less for the unit to be in MODE 2.
Turkey Point Unit 3 and Unit 4 Page 2 of 6
DISCUSSION OF CHANGES N
ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH 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 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 complying with 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.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or N
Reporting Requirements) CTS 3.2.3 ACTIONS b and c require FH to be determined to be within its limit through incore flux mapping. Additionally, N
CTS 4.2.3.3 requires FH to be within its limit through incore flux mapping.
N ITS SR 3.2.2.1 verifies that FH is within its limit. This changes the CTS by N
moving the manner in which the FH determination is performed to the Bases.
The removal of these details for performing Actions and an SR 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 N
determine FH 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.
Turkey Point Unit 3 and Unit 4 Page 3 of 6
DISCUSSION OF CHANGES N
ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH LA02 (Type 1 - Removing Details of System Design and System Description, Including N
Design Limits) CTS LCO 3.2.3 states FH shall be limited by the following relationship:
N RTP [1.0 + PFH (1-P)],
FH FH RTP Where: FH = FH limit at RATED THERMAL POWER as specified in the CORE OPERATING LIMITS REPORT PFH = Power Factor Multiplier for FH as specified in the CORE OPERATING LIMITS REPORT THERMAL POWER P =
RATED THERMAL POWER N
ITS LCO 3.2.3 requires the definition of FH for its use but the details of what constitutes this definition is moved to the Bases. This changes the CTS by N
removing the details of what constitutes the definition of FH to the Bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate N
protection of public health and safety. The ITS retains the requirement that FH shall be within the limits specified in the COLR. The details on the capability requirements of the systems do not need to appear in the specification in order for the requirement to apply. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
LA03 (Type 3 - Removing Procedural Details for Meeting TS Requirements or N
Reporting Requirements) CTS SR 4.2.3.2 states "When a measurement of FH is taken, the measured shall be increased by 4% to account for measurement error." ITS SR 3.2.2.1 does not address measurement error. This changes the CTS by not accounting for measurement error.
The removal of these details for performing surveillance requirements 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 this measurement error in the Bases. Also, this change is acceptable because these types of procedural details will be adequately controlled in the TS Bases. The Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This Turkey Point Unit 3 and Unit 4 Page 4 of 6
DISCUSSION OF CHANGES N
ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH 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.
LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION a.2 states, in N
part, that when FH exceeds its limit, reduce the Power Range Neutron Flux -
High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER N
within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.2 Required Actions A.1.2.2 states with FH not within limit, reduce the Power Range Neutron Flux - High trip setpoints to 55%
RTP within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. This changes the CTS by increasing the time allowed to reduce the trip setpoints.
The purpose of CTS 3.2.3 ACTION 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 Departure from Nucleate Boiling Ratio (DNBR)
N margin and avoids violating the FH 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 Design Basis Accident (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 due to this sensitive operation that may inadvertently trip the Reactor Protection System. If the value of F N H is not restored to within its specified limit either by adjusting a misaligned rod or by reducing THERMAL POWER, the alternative option is to reduce THERMAL POWER to < 50% RTP in accordance with Required Action A.1.2.1 and reduce the Power Range Neutron Flux - High to 55% RTP in accordance with Required Action A.1.2.2. Reducing RTP to
< 50% RTP increases the DNBR margin and does not likely cause the DNBR limit to be violated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptable low power level with adequate DNBR margin. 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.
L02 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION b states, N
"Verify through incore flux mapping that FH has been restored to within the above limit, or reduced THERMAL POWER to less than 5% of RATED THERMAL POWER within the next two hours." ITS 3.2.2 ACTION B states, "Required Action and associated Completion Time not met." Required Action B.1 states, "Be in MODE 2" within a Completion Time of "6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." This changes the CTS by increasing the time allowed to exit the MODE of Applicability when the Required Actions or associated Completion Times are not met.
Turkey Point Unit 3 and Unit 4 Page 5 of 6
DISCUSSION OF CHANGES N
ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR - FH N
The purpose of CTS 3.2.3 ACTION b is to, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, either verify FH is restored within limits for the reduced power level or within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, enter MODE 2. Under similar conditions, ITS will require the plant to be placed in a MODE in which the LCO requirements are not applicable. This is done by placing the plant in at least MODE 2 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allowed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonable, based on operating experience regarding the time required to reach MODE 2 from full power conditions in an orderly manner and without challenging plant systems. This change is acceptable, because the Completion Time is consistent with safe operation and recognizes that the safety analysis assumptions are satisfied once power is reduced. This change is designated as less restrictive, because additional time is allowed to exit the LCO than was allowed in the CTS.
L03 (Category 3 - Relaxation of Completion Time) CTS 3.2.3 ACTION a.1 states, in N N part, that when FH exceeds its limit, restore FH to within the limits, or Reduce THERMAL POWER to less than 50% of RATED THERMAL Power within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. ITS 3.2.2 Required Actions A.1 states that with FNH not within limit, Restore FNH to within limits, or Reduce THERMAL POWER to
< 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This changes the CTS by increasing the time allowed to restore limits or reduce power.
N The purpose of CTS 3.2.3 ACTION a and ITS 3.2.2 ACTION A is to restore FH to within the allowable limits or reduce power. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. With F N H exceeding its limit, the unit is allowed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore 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 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 DNBR limiting event occurs. Thus, the allowed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> provides an acceptable time to restore F N H to within its limits without allowing the plant to remain in an unacceptable condition for an extended period of time. This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.
Turkey Point Unit 3 and Unit 4 Page 6 of 6
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
CTS F NH 3.2.2 3.2 POW ER DISTRIBU TION L IMITS N
3.2.2 Nuclear Enthalpy Rise H ot Channel F actor ( F H )
N 3.2.3 L CO 3.2.2 F H shall b e w ithin the limits specif ied in the COL R.
Applicab ility APPL ICABIL ITY : MODE 1.
ACTIONS CONDITION REQ U IRED ACTION COMPL ETION TIME N
ACTION A.1 A. ------------NOTE------------ A.1.1 Restore F H to w ithin limit. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Required Actions A.2 and A.3 must b e OR completed w henev er ACTION a.2 Condition A is entered. A.1.2.1 Reduce TH ERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />
POW ER to < 5 0 % RTP.
N F H not w ithin limit. AND ACTION a.2 A.1.2.2 Reduce Pow er Range 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Neutron F lux - H igh trip setpoints to 5 5 % RTP.
AND ACTION b A.2 Perf orm SR 3.2.2.1. 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.2-1 Rev . 5 .0 1
CTS F NH 3.2.2 ACTIONS ( continued)
CONDITION REQ U IRED ACTION COMPL ETION TIME ACTION c A.3 --------------NOTE--------------
DOC A0 3 TH ERMAL POW ER does not hav e to b e reduced to comply w ith this Required Action.
Perf orm SR 3.2.2.1. Prior to TH ERMAL ACTION c.1 POW ER ex ceeding 5 0 % RTP AND ACTION c.2 Prior to TH ERMAL POW ER ex ceeding 7 5 % RTP AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter ACTION c.3 TH ERMAL POW ER reaching 9 5 % RTP ACTION b B. Required Action and B.1 Be in MODE 2. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> DOC M0 2 associated Completion Time not met.
Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.2-2 Rev . 5 .0 1
CTS F NH 3.2.2 SU RV EIL L ANCE REQ U IREMENTS SU RV EIL L ANCE F REQ U ENCY N
SR 3.2.2.1 V erif y F H is w ithin limits specif ied in the COL R. Once af ter each ref ueling prior to TH ERMAL POW ER ex ceeding 7 5 % RTP AND
[ 31 EF PD 2 thereaf ter OR In accordance w ith the Surv eillance F requency Control Program ]
Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.2-3 Rev . 5 .0 1
JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR ( FNH )
- 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) which reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
N F H B 3.2.2 B 3.2 POW ER DISTRIBU TION L IMITS B 3.2.2 Nuclear Enthalpy Rise H ot Channel F actor ( F N H )
BASES BACK G ROU ND The purpose of this L CO is to estab lish limits on the pow er density at any point in the core so that the f uel design criteria are not ex ceeded and the accident analy sis assumptions remain v alid. The design limits on local
( pellet) and integrated f uel rod peak pow er density are ex pressed in terms of hot channel f actors. Control of the core pow er distrib ution w ith respect to these f actors ensures that local conditions in the f uel rods and coolant channels do not challenge core integrity at any location during either normal operation or a postulated accident analy z ed in the saf ety analy ses.
F N
H is def ined as the ratio of the integral of the linear pow er along the f uel rod w ith the highest integrated pow er to the av erage integrated f uel rod pow er. Theref ore, F N H is a measure of the max imum total pow er produced in a f uel rod.
F N
H is sensitiv e to f uel loading patterns, b ank insertion, and f uel b urnup.
F N
H ty pically increases w ith control b ank insertion and ty pically decreases w ith f uel b urnup.
F N
H is not directly measurab le b ut is inf erred f rom a pow er distrib ution map ob tained w ith the mov ab le incore detector sy stem. Specif ically , the results of the three dimensional pow er distrib ution map are analy z ed b y a computer to determine F N H . This f actor is calculated at least ev ery 31 EF PD. H ow ev er, during pow er operation, the glob al pow er distrib ution is monitored b y L CO 3.2.3, " AX IAL F L U X DIF F ERENCE ( AF D) , " and L CO 3.2.4, " Q U ADRANT POW ER TIL T RATIO ( Q PTR) , " w hich address directly and continuously measured process v ariab les. the design limit v alue using an NRC approv ed critical heat f lux The COL R prov ides peak ing f actor limits that ensure that the design b asis v alue of the departure f rom nucleate b oiling ( DNB) is met f or normal operation, operational transients, and any transient condition arising f rom ev ents of moderate f requency . The DNB design b asis precludes DNB and is met b y limiting the minimum local DNB heat f lux ratio to [ 1.3] using 1 the [ W 3] CH F correlation. All DNB limited transient ev ents are assumed to b egin w ith an F N H v alue that satisf ies the L CO requirements.
Operation outside the L CO limits may produce unacceptab le consequences if a DNB limiting ev ent occurs. The DNB design b asis ensures that there is no ov erheating of the f uel that results in possib le cladding perf oration w ith the release of f ission products to the reactor coolant.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.2-1 Rev . 5 .0 1
N F H B 3.2.2 BASES APPL ICABL E L imits on F N H preclude core pow er distrib utions that ex ceed the f ollow ing SAF ETY f uel design limits:
ANAL Y SES
- a. There must b e at least 9 5 % prob ab ility at the 9 5 % conf idence lev el
( the 9 5 /9 5 DNB criterion) that the hottest f uel rod in the core does not ex perience a DNB condition, b . During a large b reak loss of coolant accident ( L OCA) , peak cladding temperature ( PCT) must not ex ceed 220 0 ° F ,
- c. During an ej ected rod accident, the energy deposition to the f uel 2 5 must not ex ceed 28 0 cal/gm [ Ref . 1] , and 20 0 7 Ref s. 2 and 4 1
- d. F uel design limits required b y G DC 26 ( Ref . 2) f or the condition w hen control rods must b e capab le of shutting dow n the reactor w ith a minimum required SDM w ith the highest w orth control rod stuck f ully w ithdraw n.
F or transients that may b e DNB limited, the Reactor Coolant Sy stem f low and F N H are the core parameters of most importance. The limits on F N H ensure that the DNB design b asis is met f or normal operation, operational transients, and any transients arising f rom ev ents of moderate f requency .
The DNB design b asis is met b y limiting the minimum DNBR to the 1 9 5 /9 5 DNB criterion of [ 1.3] using the [ W 3] CH F correlation. This v alue prov ides a high degree of assurance that the hottest f uel rod in the core does not ex perience a DNB. local DNB heat f lux ratio to the design limit v alue using an NRC approv ed critical heat f lux The allow ab le F N H limit increases w ith decreasing pow er lev el. This f unctionality in F H is included in the analy ses that prov ide the Reactor N
Core Saf ety L imits ( SL s) of SL 2.1.1. Theref ore, any DNB ev ents in w hich the calculation of the core limits is modeled implicitly use this v ariab le v alue of F N H in the analy ses. L ik ew ise, all transients that may b e DNB limited are assumed to b egin w ith an initial F N H as a f unction of pow er lev el def ined b y the COL R limit equation.
The L OCA saf ety analy sis indirectly models F N H as an input parameter.
The Nuclear H eat F lux H ot Channel F actor ( F Q ( Z ) ) and the ax ial peak ing f actors are inserted directly into the L OCA saf ety analy ses that v erif y the acceptab ility of the resulting peak cladding temperature [ Ref . 3] . 2 5
( )
The f uel is protected in part b y Technical Specif ications, w hich ensure that the initial conditions assumed in the saf ety and accident analy ses remain v alid. The f ollow ing L COs ensure this: L CO 3.2.3, " AX IAL F L U X DIF F ERENCE ( AF D) , " L CO 3.2.4, " Q U ADRANT POW ER TIL T RATIO Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.2-2 Rev . 5 .0 1
N F H B 3.2.2 BASES APPL ICABL E SAF ETY ANAL Y SES ( continued)
( Q PTR) , " L CO 3.1.6, " Control Bank Insertion L imits, " L CO 3.2.2, " Nuclear Enthalpy Rise H ot Channel F actor ( F N H ) , " and L CO 3.2.1, " H eat F lux H ot Channel F actor ( F Q ( Z ) ) ."
indirectly F N and F Q ( Z ) are measured periodically using the mov ab le incore 1 H
detector sy stem. Measurements are generally tak en w ith the core at, or near, steady state conditions. Core monitoring and control under transient conditions ( Condition 1 ev ents) are accomplished b y operating the core w ithin the limits of the L COs on AF D, Q PTR, and Bank Insertion L imits.
F N
H satisf ies Criterion 2 of 10 CF R 5 0 .36( c) ( 2) ( ii) .
L CO F N
H shall b e maintained w ithin the limits of the relationship prov ided in the COL R.
The F N H limit identif ies the coolant f low channel w ith the max imum enthalpy rise. This channel has the least heat remov al capab ility and thus the highest prob ab ility f or a DNB.
The limiting v alue of F N H , describ ed b y the equation contained in the COL R, is the design radial peak ing f actor used in the unit saf ety analy ses.
INSERT 1 3 A pow er multiplication f actor in this equation includes an additional margin f or higher radial peak ing f rom reduced thermal f eedb ack and 1 greater control rod insertion at low pow er lev els. The limiting v alue of is F N H allow ed to increase 0 .3% f or ev ery 1% RTP reduction in TH ERMAL POW ER.
APPL ICABIL ITY The F N H limits must b e maintained in MODE 1 to preclude core pow er distrib utions f rom ex ceeding the f uel design limits f or DNBR and PCT.
Applicab ility in other modes is not required b ecause there is either insuf f icient stored energy in the f uel or insuf f icient energy b eing transf erred to the coolant to require a limit on the distrib ution of core pow er. Specif ically , the design b ases ev ents that are sensitiv e to F N H in other modes ( MODES 2 through 5 ) hav e signif icant margin to DNB, and theref ore, there is no need to restrict F N H in these modes.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.2-3 Rev . 5 .0 1
ITS 3.2.2 3
INSERT 1 FNH shall be limited by the following relationship:
N RTP FH FH [1.0 + PFH (1-P)],
RTP Where: F=H FH limit at RATED THERMAL POWER as specified in the CORE OPERATING LIMITS REPORT PFH = Power Factor Multiplier for FH as specified in the CORE OPERATING LIMITS REPORT THERMAL POWER P =
RATED THERMAL POWER Insert Page B 3.2.2-3
N F H B 3.2.2 BASES ACTIONS A.1.1 W ith F N H ex ceeding its limit, the unit is allow ed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore F N H to w ithin its limits. This restoration may , f or ex ample, inv olv e realigning any misaligned rods or reducing pow er enough to b ring F N H w ithin its pow er dependent limit. W hen the F N H limit is ex ceeded, the DNBR limit is not lik ely v iolated in steady state operation, b ecause ev ents that could signif icantly perturb the F N H v alue ( e.g., static control rod misalignment) are considered in the saf ety analy ses. H ow ev er, the DNBR limit may b e v iolated if a DNB limiting ev ent occurs. Thus, the allow ed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prov ides an acceptab le time to restore F N H to w ithin its limits w ithout allow ing the plant to remain in an unacceptab le condition f or an ex tended period of time.
Condition A is modif ied b y a Note that requires that Required Actions A.2 and A.3 must b e completed w henev er Condition A is entered. Thus, if pow er is not reduced b ecause this Required Action is completed w ithin the 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> time period, Required Action A.2 nev ertheless requires another measurement and calculation of F N H w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in accordance w ith SR 3.2.2.1.
H ow ev er, if pow er is reduced b elow 5 0 % RTP, Required Action A.3 v erif ied requires that another determination of F N H must b e done prior to 1 ex ceeding 5 0 % RTP, prior to ex ceeding 7 5 % RTP, and w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter reaching or ex ceeding 9 5 % RTP. In addition, Required Action A.2 is perf ormed if pow er ascension is delay ed past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
A.1.2.1 and A.1.2.2 If the v alue of F N H is not restored to w ithin its specif ied limit either b y adj usting a misaligned rod or b y reducing TH ERMAL POW ER, the alternativ e option is to reduce TH ERMAL POW ER to < 5 0 % RTP in accordance w ith Required Action A.1.2.1 and reduce the Pow er Range Neutron F lux - High to 5 5 % RTP in accordance w ith Required Action A.1.2.2. Reducing RTP to < 5 0 % RTP increases the DNB margin and does not lik ely cause the DNBR limit to b e v iolated in steady state operation. The reduction in trip setpoints ensures that continuing operation remains at an acceptab le low pow er lev el w ith adequate DNBR margin. The allow ed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> f or Required Action A.1.2.1 is consistent w ith those allow ed f or in Required Action A.1.1 and prov ides an acceptab le time to reach the required pow er lev el f rom f ull pow er operation w ithout allow ing the plant to remain in an unacceptab le condition f or an ex tended period of time. The Completion Times of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> f or Required Actions A.1.1 and A.1.2.1 are not additiv e.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.2-4 Rev . 5 .0 1
N F H B 3.2.2 BASES ACTIONS ( continued)
The allow ed Completion Time of 7 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to reset the trip setpoints per Required Action A.1.2.2 recogniz es that, once pow er is reduced, the saf ety analy sis assumptions are satisf ied and there is no urgent need to reduce the trip setpoints. This is a sensitiv e operation that may inadv ertently trip the Reactor Protection Sy stem.
A.2 Once the pow er lev el has b een reduced to < 5 0 % RTP per Required Action A.1.2.1, an incore f lux map ( SR 3.2.2.1) must b e ob tained and the measured v alue of F N H v erif ied not to ex ceed the allow ed limit at the low er pow er lev el. The unit is prov ided 20 additional hours to perf orm this task ov er and ab ov e the 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> allow ed b y either Action A.1.1 or Action A.1.2.1. The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is acceptab le b ecause of the increase in the DNB margin, w hich is ob tained at low er pow er lev els, and the low prob ab ility of hav ing a DNB limiting ev ent w ithin this 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period. Additionally , operating ex perience has indicated that this Completion Time is suf f icient to ob tain the incore f lux map, perf orm the required calculations, and ev aluate F N H .
A.3 V erif ication that F N H is w ithin its specif ied limits af ter an out of limit occurrence ensures that the cause that led to the F N H ex ceeding its limit is corrected, and that sub sequent operation proceeds w ithin the L CO limit. This Action demonstrates that the F N H limit is w ithin the L CO limits prior to ex ceeding 5 0 % RTP, again prior to ex ceeding 7 5 % RTP, and w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after THERMAL POWER is 9 5 % RTP.
This Required Action is modif ied b y a Note that states that TH ERMAL POW ER does not hav e to b e reduced prior to perf orming this Action.
B.1 W hen Required Actions A.1.1 through A.3 cannot b e completed w ithin their required Completion Times, the plant must b e placed in a mode in w hich the L CO requirements are not applicab le. This is done b y placing the plant in at least MODE 2 w ithin 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The allow ed Completion Time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is reasonab le, b ased on operating ex perience regarding the time required to reach MODE 2 f rom f ull pow er conditions in an orderly manner and w ithout challenging plant sy stems.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.2-5 Rev . 5 .0 1
N F H B 3.2.2 BASES SU RV EIL L ANCE SR 3.2.2.1 REQ U IREMENTS The v alue of F N H is determined b y using the mov ab le incore detector sy stem to ob tain a f lux distrib ution map. A data reduction computer program then calculates the max imum v alue of F N H f rom the measured f lux distrib utions. The measured v alue of F N H must b e multiplied b y 1.0 4 to account f or measurement uncertainty b ef ore mak ing comparisons to the F N H limit.
Af ter each ref ueling, F N H must b e determined in MODE 1 prior to ex ceeding 7 5 % RTP. This requirement ensures that F N H limits are met at the b eginning of each f uel cy cle.
[ The 31 EF PD F requency is acceptab le b ecause the pow er distrib ution 2 changes relativ ely slow ly ov er this amount of f uel b urnup. Accordingly ,
this F requency is short enough that the F N H limit cannot b e ex ceeded f or any signif icant period of operation.
OR The Surv eillance F requency is controlled under the Surv eillance F requency Control Program.
REV IEW ER S NOTE-----------------------------------
Plants controlling Surv eillance F requencies under a Surv eillance 4 F requency Control Program should utiliz e the appropriate F requency description, giv en ab ov e, and the appropriate choice of F requency in the Surv eillance Requirement.
] 2 U F SAR, Section 14.2.6 REF ERENCES 1. Regulatory G uide 1.7 7 , Rev . [ 0 ] , May 19 7 4. 1 1
19 67 AEC Proposed G eneral Design Criteria, G DC 27
- 3. 10 CF R 5 0 .46.
- 4. U F SAR, Section 3.1.2 1 Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.2-6 Rev . 5 .0 1
JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, BASES, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR ( FNH )
- 1. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) Bases which reflect the plant-specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 2. 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.
- 3. Changes have been made to be consistent with changes made to the Specification.
- 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 5. Editorial change made for clarification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (FH(X,Y))
There are no specific No Significant Hazards Considerations for this Specification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
ATTACHMENT 3 ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
A0 1 ITS 3.2.3 ITS 3/4.2 POW ER DISTRIBU TION L IMITS
( AF D) 3/4.2.1 AX IAL F L U X DIF F ERENCE L IMITING CONDITION F OR OPERATION in % f lux dif f erence units A0 2 L CO 3.2.3 3.2.1 The indicated AX IAL F L U X DIF F ERENCE ( AF D) shall b e maintained w ithin:
the limits specif ied
- a. the allow ed Relax ed Ax ial Of f set Control ( RAOC) operational space as def ined in the CORE A0 1 OPERATING L IMITS REPORT ( COL R) , or b . w ithin a + /- 2% or + /- 3% target b and ab out the target f lux dif f erence during Base L oad operation. L A0 3 Applicab ility APPL ICABIL ITY : MODE 1, ab ov e 5 0 % of RATED TH ERMAL POW ER* . M0 1 A0 3 ACTION* * * :
- a. F or RAOC operation w ith the indicated AF D outside of the limits specif ied in the COL R, either A0 2 ACTION B 1. Restore the indicated AF D to w ithin the RAOC limits w ithin 15 minutes, or L 0 1
- 2. Reduce TH ERMAL POW ER to less than 5 0 % of RATED TH ERMAL POW ER w ithin 30 minutes and reduce the Pow er Range Neutron F lux - H igh Trip setpoint to less than or L 0 2 equal to 5 5 % of RATED TH ERMAL POW ER w ithin the nex t 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
b . F or Base L oad operation ab ov e PT*
- w ith the indicated AF D outside of the applicab le target b and A0 2 ACTION A, ab out the target f lux dif f erence, either M0 2
- 1. Restore the indicated AF D to w ithin the Peak ing F actor L imit Report target b and limits L 0 1 w ithin 15 minutes, or
- 2. Reduce TH ERMAL POW ER to less than PT and discontinue Base L oad operation w ithin A0 5 30 minutes. OR
- c. TH ERMAL POW ER shall not b e increased ab ov e 5 0 % of RATED TH ERMAL POW ER unless A0 4 indicated AF D is w ithin the limits specif ied in the COL R.
- See Special Test Ex ceptions Specif ication 3.10 .2. A0 3
- PT = Reactor Pow er at w hich predicted F Q w ould ex ceed its limit ( consistent w ith Specif ication 4.2.2.1) . L A0 2 limits L CO 3.2.3 NOTE
limits A0 1 TU RK EY POINT - U NITS 3 & 4 3/4 2-1 AMENDMENT NOS. 15 6 AND 15 0 Page 1 of 2
A0 1 ITS 3.2.3 ITS POW ER DISTRIBU TION L IMITS SU RV EIL L ANCE REQ U IREMENTS SR 3.2.3.1 4.2.1.1 The indicated AF D shall b e determined to b e w ithin its limits during POW ER OPERATION ab ov e 5 0 % of A0 2 RATED TH ERMAL POW ER b y :
A0 2
- a. Monitoring the indicated AF D f or each OPERABL E ex core channel:
- 1) In accordance w ith the Surv eillance F requency Control Program w hen the alarm used to monitor the AF D is OPERABL E, and
- 2) At least once per hour f or the f irst 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> af ter restoring the alarm used to monitor the L 0 3 AF D to OPERABL E status.*
b . Monitoring and logging the indicated AF D f or each OPERABL E ex core channel at least once per hour f or the f irst 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 30 minutes thereaf ter, w hen the alarm used to monitor the AF D is inoperab le. The logged v alues of the indicated AF D shall b e assumed to ex ist during the interv al preceding each logging.
4.2.1.2 The target f lux dif f erence of each OPERABL E ex core channel shall b e determined b y measurement in accordance w ith the Surv eillance F requency Control Program. The prov isions of Specif ication 4.0 .4 are not applicab le. L A0 1 4.2.1.3 In accordance w ith the Surv eillance F requency Control Program, the target f lux dif f erence shall b e updated b y either determining the target f lux dif f erence pursuant to Specif ication 4.2.1.2 ab ov e or b y linear interpolation b etw een the most recently measured v alue and the predicted v alue at the end of the cy cle lif e. The prov isions of Specif ication 4.0 .4 are not applicab le.
- Perf ormance of a f unctional test to demonstrate OPERABIL ITY of the alarm used to monitor the AF D may b e L 0 3 sub stituted f or this requirement.
TU RK EY POINT - U NITS 3 & 4 3/4 2-2 AMENDMENT NOS. 263 AND 25 8 Page 2 of 2
DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) 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. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.1 states the Axial Flux Difference (AFD) "shall be maintained within:
- a. the allowed Relaxed Axial Offset Control (RAOC) operational space as defined in the CORE OPERATING LIMITS REPORT (COLR), or b. within a +/- 2% or
+/- 3% target band about the target flux difference during Base Load operation."
CTS 3.2.1 ACTION provides ACTIONs to take when the indicated AFD is outside the COLR limits or Peaking Factor Limit Report. CTS 4.2.1.1 requires a determination that the indicated AFD is within limits. CTS 4.2.1.2 requires a determination that the indicated AFD is within limits. CTS 3.2.1 ACTION states that the indicated AFD shall be considered outside the limits when at least two OPERABLE excore channels are indicating the AFD to be outside the limits. ITS Limiting Condition for Operation (LCO) 3.2.3 states in part the AFD in % flux difference units shall be maintained within the limits specified in the COLR and Peaking Factor Limit Report. ITS LCO 3.2.3 is modified by a Note specifying when AFD is considered to be outside the limits. ITS Surveillance Requirement (SR) 3.2.3.1 and ITS SR 3.2.3.2 require verification that AFD is within limits. This changes the CTS by deleting "indicated" and adding "% flux difference units" to the LCO statement.
The purpose of CTS 3.2.1 is to ensure the AFD remains within the limits specified in the COLR and Peaking Factor Limit Report. AFD is the difference in normalized flux signals between the top and bottom excore detectors, therefore, this is a presentation change. This change is designated as administrative because it does not result in a technical change to the CTS.
A03 CTS 3.2.1 Applicability contains a footnote (footnote *) which states, "See Special Test Exception 3.10.2." ITS 3.2.3 Applicability does not contain this footnote. This changes the CTS by not including Footnote*.
The purpose of Footnote
- is to alert the Technical Specification user that a Special Test Exception exists that may modify the Applicability of this Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as administrative because it does not result in a technical change to the CTS.
Turkey Point Unit 3 and Unit 4 Page 1 of 6
DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
A04 CTS 3.2.1 ACTION c states "THERMAL POWER shall not be increased above 50% of RATED THERMAL POWER unless the indicated AFD is within the limits specified in the COLR." ITS 3.2.3 does not contain a similar requirement. This changes the CTS by eliminating a prohibition contained in the CTS.
This change is acceptable because deletion of the specific requirement to not exceed 50% when the AFD is not within limits is prohibited via CTS 3.0.4 and ITS LCO 3.0.4. These requirements prohibit entering the Applicability of a Technical Specification unless certain requirements of the LCO are met. These requirements are as follows: the Actions to be entered permit continued operation, risk assessment addressing inoperable systems and components show acceptable risk results, or an allowance is stated in the individual value, parameter, or other specification. In this case, none of the exceptions for entering the Applicability applies. CTS 3.2.1 and ITS LCO 3.2.3 are applicable in MODE 1 with THERMAL POWER > 50% RATED THERMAL POWER (RTP) and 50 RTP (ITS). Therefore, both the CTS and ITS prohibit exceeding 50% RTP without the LCO requirements being met. This change is designated as an administrative change because it does not result in technical changes to the CTS.
A05 CTS Action b.2 requires THERMAL POWER to reduced to less than PT within 30 minutes and Base Load operation to be discontinued within 30 minutes. ITS ACTION A requires THERMAL POWER to be reduced to less than PT within 30 minutes (A.1) OR Base Load operation to be discontinued within 30 minutes (A.2). This changes the CTS by changing the conjunction between the two Actions from "and" to "OR."
This change is acceptable because if THERMAL POWER is reduced to less than PT within 30 minutes the Condition on longer applies, thus the Condition no longer applies. The same goes if base load operation is discontinued, the Condition no longer applies. Therefore, the current "and" conjunction is essentially an "OR" because if either ACTION is performed the condition no longer applies. This change is designated as administrative because no technical change is being made to the CTS.
MORE RESTRICTIVE CHANGES M01 CTS 3.2.1 is applicable in MODE 1 with THERMAL POWER > 50% RTP. ITS LCO 3.2.3 is applicable in MODE 1 with THERMAL POWER 50% RTP. This changes the CTS by requiring LCO 3.2.3 to be met when THERMAL POWER is equal to 50 % RTP.
The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR and Peaking Factor Limit Report. When AFD is not within limits, CTS 3.2.1 ACTION a.2 requires reducing THERMAL POWER to less than 50%
RTP, or CTS 3.2.1 ACTION b.2 requires reducing THERMAL POWER to less than PT and discontinue Base Load operation. This change is acceptable because it aligns the Applicability to the Required Actions. The CTS and ITS Turkey Point Unit 3 and Unit 4 Page 2 of 6
DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
Required Action is to reduce THERMAL POWER to less than 50% RTP or to less than PT and discontinue Base Load operation. When the THERMAL POWER is reduced to this value, it places the core in a condition outside of the Applicability of the LCO. Therefore, changing the Applicability from in MODE 1 with THERMAL POWER > 50% RTP to MODE 1 with THERMAL POWER 50%
RTP has no effect on the LCO. This change is designated as more restrictive because it provides additional requirements to the Applicability.
M02 CTS 3.2.1 Action b states "For Base Load operation above PT with the AFD" ITS 3.2.3 Condition A states "AFD not within limits during base load operation PT." This revises the CTS by changing "above" to "," which changes the Condition to include PT.
The purpose of the CTS Action is to ensure the AFD remains within limits during base load operation. This change revises condition to include the value of PT.
This change is acceptable, because including PT in the condition aligns with the requirement to reduce THERMAL POWER to below PT. to reduce RATED THERMAL POWER to less than PT. This change is designated as more restrictive because it provides additional requirements to the Condition.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.1.2 and CTS 4.2.1.3 contain AFD SRs specifically for the target flux difference. Specifically, CTS 4.2.1.2 requires determination by measurements and CTS 4.2.1.3 requires updating the target flux differences. ITS 3.2.3.2 does not contain these specific SRs. This changes the CTS by moving these SRs to the COLR.
The removal of these details for performing SRs 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 verify the AFD is within limits. The details of verifying the AFD, including determining and updating the target flux difference, will be moved to the COLR. This change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.3, "Core Operating Limits Report."
ITS 5.6.3 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 Shutdown Margin (SDM), transient analysis limits, and accident analysis limits) of the safety analysis are met. This change is designated as a less restrictive removal of detail change because TS details is being removed from the Technical Specifications.
Turkey Point Unit 3 and Unit 4 Page 3 of 6
DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
LA02 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.1 states in footnote ** "PT = Reactor Power at which predicted FQ would exceed its limit (consistent with Specification 4.2.2.1)."
ITS LCO 3.2.3 does not have this statement. This changes the CTS by having this statement removed.
The removal of these details for performing actions (PT is a definition) 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 Reactor Power definition (PT) at which predicted FQ would exceed its limit. Also, this change is acceptable because these types of procedural details will be adequately controlled in the ITS Bases and the COLR. 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. Removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.3, "Core Operating Limits Report."
ITS 5.6.3 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 Shutdown Margin (SDM), transient analysis limits, and accident analysis limits) of the safety analysis are met. This change is designated as a less restrictive removal of detail change because details are being removed from the Technical Specifications.
LA03 (Type 5 - Removal of Cycle-Specific Parameter Limits from the Technical Specifications to the Core Operating Limits Report) CTS 3.2.1 LCO states "within a +/- 2% or +/- 3% target band about the target flux difference during Base Load operation." ITS 3.2.3 does not have this statement. This changes the CTS by relocating this statement to the COLR.
The removal of these cycle-specific parameter limits from the Technical Specifications and their relocation into the COLR is acceptable because these limits are developed or utilized under NRC-approved methodologies. The NRC documented in Generic Letter 88-16, "Removal of Cycle-Specific Parameter Limits from the Technical Specifications," that 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 requirements and Surveillances that verify that the cycle-specific parameter limits are being met.
The ITS still retains requirement that the AFD in % flux difference units shall be maintained with the limits specified in the COLR. Also, this change is acceptable because the removed information will be adequately controlled in the COLR under the requirements provided in ITS 5.6.3, "Core Operating Limits Report."
ITS 5.6.3 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 Shutdown Margin (SDM), transient analysis limits, and accident analysis limits) of the safety analysis are met. This change is designated as a less restrictive removal of detail change because information relating to cycle-specific parameter limits is being removed from the Technical Specifications.
Turkey Point Unit 3 and Unit 4 Page 4 of 6
DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
LESS RESTRICTIVE CHANGES L01 (Category 4 - Relaxation of Required Action) CTS 3.2.1 ACTION a.1 and ACTION b.1 requires with the AXIAL FLUX DIFFERENCE (AFD) outside of the limits, to restore the indicated AFD to within the limits within 15 minutes. ITS LCO 3.2.3 does not include a Required Action to restore the indicated AFD to within the limits within 15 minutes. This changes the CTS by not including a specific requirement to restore the AFD to within limits.
The purpose of CTS 3.2.1 is to maintain the AFD within the limits specified in the COLR or Peaking Factor Limit Report. This change is acceptable because the requirement to restore the AFD to within limits has not changed. ITS LCO 3.2.3 allows a Completion Time of 30 minutes to reduce THERMAL POWER to < 50%
RTP or to reduce THERMAL POWER to less than PT and discontinue Base Load operation. During the time that power is being reduced, AFD can be restored to within limits. Per ITS LCO 3.0.2, if the LCO is met prior to expiration of the Completion Time, completion of the Required Actions is not required. This allowance also is provided in CTS 3.0.2. Therefore, restoration of AFD is always an option and a specific ACTION is not required. This change is designated as less restrictive because additional Completion Time is provided that was not provided in the CTS.
L02 (Category 4 - Relaxation of Required Action) CTS 3.2.1 ACTION a.2 states that with the indicated AFD outside of the limits specified in the COLR, reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55 percent of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS LCO 3.2.3 ACTION A only requires THERMAL POWER to be reduced to less than 50% RTP. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux - High trip setpoints to 55 % of RTP within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
The purpose of CTS 3.2.1 ACTION a.2 is to reduce THERMAL POWER to the point at which the LCO is met if AFD is not restored within its limit. With the AFD meeting the Technical Specification requirements, further actions are not required to ensure that the assumptions of the safety analyses are met.
Increases in THERMAL POWER are governed by ITS LCO 3.0.4, which requires the LCO to be met prior to entering a MODE or other specified condition in which the LCO applies, except under certain conditions. Therefore, power increases are prohibited while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L03 (Category 7 - Relaxation of Surveillance Frequency) CTS 4.2.1.1.a requires the monitoring of the indicated AFD for each OPERABLE excore channel in accordance with the Surveillance Frequency Control Program when the alarm used to monitor the AFD is OPERABLE. CTS 4.2.1.1.b requires the monitoring and logging the indicated AFD for each OPERABLE excore channel at least once Turkey Point Unit 3 and Unit 4 Page 5 of 6
DISCUSSION OF CHANGES ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD) per hour for the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and at least once per 30 minutes thereafter, when the alarm used to monitor the AFD is inoperable. The logged values of the indicated AFD shall be assumed to exist during the interval preceding each logging. This changes the CTS by eliminating all AFD Surveillance Frequencies based on the OPERABILITY of the AFD Monitor Alarm.
The purpose of ITS 3.2.3 is to ensure that AFD is within its limit. This change is acceptable because the remaining Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the Frequency of monitoring AFD when the AFD Monitor Alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that AFD is outside of its limit. The AFD monitor alarm is for indication only. Its use is not credited in any safety analyses. This change is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
Turkey Point Unit 3 and Unit 4 Page 6 of 6
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
CTS AF D ( RAOC Methodology ) 1 3.2.3B 3.2 POW ER DISTRIBU TION L IMITS 3.2.3B AX IAL F L U X DIF F ERENCE ( AF D) ( Relax ed Ax ial Of f set Control ( RAOC) 1 Methodology )
3.2.1 L CO 3.2.3B The AF D in % f lux dif f erence units shall b e maintained w ithin the limits 1 specif ied in the COL R.
NOTE---------------------------------------------
ACTION The AF D shall b e considered outside limits w hen tw o or more NOTE * *
- OPERABL E ex core channels indicate AF D to b e outside limits.
Applicab ility APPL ICABIL ITY : MODE with THERMAL POWER 5 0 % RTP.
ACTIONS CONDITION REQ U IRED ACTION COMPL ETION TIME INSERT 1 4 ACTION A.2 A. AF D not w ithin limits. A.1 Reduce TH ERMAL 30 minutes 2 B B POW ER to < 5 0 % RTP.
f or reasons other than Condition A. 2 SU RV EIL L ANCE REQ U IREMENTS SU RV EIL L ANCE F REQ U ENCY 3
4.2.1.1.a SR 3.2.3.1 V erif y AF D w ithin limits f or each OPERABL E ex core [ 7 day s channel.
OR In accordance w ith the Surv eillance F requency Control Program ] 3 4
Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.3B-1 Rev . 5 .0 2 1
4 INSERT 1 ACTION b A. AFD not within limits during A.1 Reduce THERMAL 30 minutes DOC M02 base load operation PT. POWER to < PT.
OR A.2 Discontinue base load 30 minutes operation.
Insert Page 3.2.3-1
JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
- 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one Axial Flux Difference (AFD) Specification is used in the Turkey Point Nuclear Generating Station (PTN) Plant Improved Technical Specifications (ITS)). This information is provided in the Improved Standard Technical Specifications (ISTS) of NUREG-1431, Rev. 5.0, 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 Constant Axial Offset Control (CAOC) methodology Specification (ISTS 3.2.3A) is not used and is not shown.
- 2. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 4. Changes are made to be consistent with the Specification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
AF D ( RAOC Methodology ) 1 B 3.2.3B B 3.2 POW ER DISTRIBU TION L IMITS B 3.2.3B AX IAL F L U X DIF F ERENCE ( AF D) ( Relax ed Ax ial Of f set Control ( RAOC 1 Methodology )
BASES BACK G ROU ND The purpose of this L CO is to estab lish limits on the v alues of the AF D in order to limit the amount of ax ial pow er distrib ution sk ew ing to either the top or b ottom of the core. By limiting the amount of pow er distrib ution sk ew ing, core peak ing f actors are consistent w ith the assumptions used in the saf ety analy ses. L imiting pow er distrib ution sk ew ing ov er time also minimiz es the x enon distrib ution sk ew ing, w hich is a signif icant f actor in ax ial pow er distrib ution control.
Relax ed Ax ial Of f set Control ( RAOC) RAOC is a calculational procedure that def ines the allow ed operational 6 methodology space of the AF D v ersus TH ERMAL POW ER. The AF D limits are selected b y considering a range of ax ial x enon distrib utions that may occur as a result of large v ariations of the AF D. Sub sequently , pow er peak ing f actors and pow er distrib utions are ex amined to ensure that the loss of coolant accident ( L OCA) , loss of f low accident, and anticipated transient limits are met. V iolation of the AF D limits inv alidate the conclusions of the accident and transient analy ses w ith regard to f uel cladding integrity .
The AF D is monitored on an automatic b asis using the unit process computer, w hich has an AF D monitor alarm. The computer determines the 1 minute av erage of each of the OPERABL E ex core detector outputs and prov ides an alarm message immediately if the AF D f or tw o or more OPERABL E ex core channels is outside its specif ied limits.
INSERT 1 7 Although the RAOC def ines limits that must b e met to satisf y saf ety analy ses, ty pically an operating scheme, Constant Ax ial Of f set Control
( CAOC) , is used to control ax ial pow er distrib ution in day to day operation 1
( Ref . 1) . CAOC requires that the AF D b e controlled w ithin a narrow tolerance b and around a b urnup dependent target to minimiz e the v ariation of ax ial peak ing f actors and ax ial x enon distrib ution during unit maneuv ers.
The CAOC operating space is ty pically smaller and lies w ithin the RAOC operating space. Control w ithin the CAOC operating space constrains 1 the v ariation of ax ial x enon distrib utions and ax ial pow er distrib utions.
RAOC calculations assume a w ide range of x enon distrib utions and then conf irm that the resulting pow er distrib utions satisf y the requirements of the accident analy ses.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.3B-1 Rev . 5 .0 2 1
B 3.2.3 7
INSERT 1 PT is the Reactor Power at which predicted FQ would exceed its limit. At power level below PT, the limits on AFD are specified in the COLR for RAOC operation. These limits were calculated in a manner such that expected operational transients, e.g., load follow operations, would not result in the AFD deviating outside of those limits. However, in the event that such a deviation occurs, a 15 minute period of time allowed outside of the AFD limits at reduced power levels will not result in significant xenon redistribution such that the envelope of peaking factors would change sufficiently to prevent operation in the vicinity of the power level.
With PT greater than 100%, two modes are permissible: 1) RAOC with fixed AFD limits as a function of reactor power level, and 2) Base Load operation which is defined as the maintenance of the AFD within a band about a target value. Both the fixed AFD limits for RAOC operation and the target band for Base Load operation are defined in the COLR and the Peaking Factor Limit Report, respectively. However, it is possible during extended load following maneuvers that the AFD limits may result in restrictions in the maximum allowed power or AFD in order to guarantee operation with FQ(Z) less than its limiting value. Therefore, PT is calculated to be less than 100%. To allow operation at the maximum permissible value above PT Base Load operation restricts the indicated AFD to a relative small target band and power swings. For Base Load operation, it is expected that the plant will operate within the target band.
Operation outside of the target band for the short time period allowed (15 minutes) will not result in significant xenon redistribution such that the envelope of peaking factors will change sufficiently to prohibit continued operation in the power region defined above. To assure that there is no residual xenon redistribution impact from past operation on the Base Load operation, a 24-hour waiting period within a defined range of PT and AFD allowed by RAOC is necessary.
During this period, load changes and rod motion are restricted to that allowed by the Base Load requirement. After the waiting period, extended Base Load operation is permissible.
A target flux difference can be updated by linear interpolation between the most recently measured value and the predicted value at the end of cycle life.
Insert Page B 3.2.3-1
AF D ( RAOC Methodology ) 1 B 3.2.3B BASES APPL ICABL E The AF D is a measure of the ax ial pow er distrib ution sk ew ing to either the SAF ETY top or b ottom half of the core. The AF D is sensitiv e to many core related ANAL Y SES parameters such as control b ank positions, core pow er lev el, ax ial b urnup, ax ial x enon distrib ution, and, to a lesser ex tent, reactor coolant temperature and b oron concentration.
The allow ed range of the AF D is used in the nuclear design process to conf irm that operation w ithin these limits produces core peak ing f actors and ax ial pow er distrib utions that meet saf ety analy sis requirements.
The RAOC methodology ( Ref . 3) estab lishes a x enon distrib ution lib rary w ith tentativ ely w ide AF D limits. One dimensional ax ial pow er distrib ution calculations are then perf ormed to demonstrate that normal operation pow er shapes are acceptab le f or the L OCA and loss of f low accident, and f or initial conditions of anticipated transients. The tentativ e limits are adj usted as necessary to meet the saf ety analy sis requirements.
The limits on the AF D ensure that the H eat F lux H ot Channel F actor
( F Q ( Z ) ) is not ex ceeded during either normal operation or in the ev ent of x enon redistrib ution f ollow ing pow er changes. The limits on the AF D also restrict the range of pow er distrib utions that are used as initial conditions in the analy ses of Condition 2, 3, or 4 ev ents. This ensures that the f uel cladding integrity is maintained f or these postulated accidents. The most important Condition 4 ev ent is the L OCA. The most important Condition 3 2 ev ent is the loss of f low accident. The most important Condition 2 ev ents are uncontrolled b ank w ithdraw al and b oration or dilution accidents.
, Condition 2 accidents simulated to b egin f rom w ithin the AF D limits are 6 used to conf irm the adequacy of the Ov erpow er T and Ov ertemperature T trip setpoints.
The limits on the AF D satisf y Criterion 2 of 10 CF R 5 0 .36( c) ( 2) ( ii) .
L CO The shape of the pow er prof ile in the ax ial ( i.e., the v ertical) direction is largely under the control of the operator through the manual operation of the control b ank s or automatic motion of control b ank s. The automatic motion of the control b ank s is in response to temperature dev iations resulting f rom manual operation of the Chemical and V olume Control Sy stem to change b oron concentration or f rom pow er lev el changes.
1 and 2 Signals are av ailab le to the operator f rom the Nuclear Instrumentation Sy stem ( NIS) ex core neutron detectors ( Ref . 3) . Separate signals are 6 2 s
tak en f rom the top and b ottom detectors. The AF D is def ined as the dif f erence in normaliz ed f lux signals b etw een the top and b ottom ex core detectors in each detector w ell. F or conv enience, this f lux dif f erence is conv erted to prov ide f lux dif f erence units ex pressed as a percentage and lab eled as % f lux or % I.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.3B-2 Rev . 5 .0 2 1
AF D ( RAOC Methodology ) 1 B 3.2.3B BASES L CO ( continued)
The AF D limits are prov ided in the COL R. F igure B 3.2.3B-1 show s 5 ty pical RAOC AF D limits. The AF D limits f or RAOC do not depend on the target f lux dif f erence. H ow ev er, the target f lux dif f erence may b e used to 1 minimiz e changes in the ax ial pow er distrib ution. INSERT 2 V iolating this L CO on the AF D could produce unacceptab le consequences if a Condition 2, 3, or 4 ev ent occurs w hile the AF D is outside its specif ied limits.
APPL ICABIL ITY The AF D requirements are applicab le in MODE 1 greater than or equal to 5 0 % RTP w hen the comb ination of TH ERMAL POW ER and core peak ing f actors are of primary importance in saf ety analy sis.
F or AF D limits dev eloped using RAOC methodology , the v alue of the AF D does not af f ect the limiting accident consequences w ith TH ERMAL 1 POW ER < 5 0 % RTP and f or low er operating pow er MODES.
B ACTIONS A.1 2 INSERT 3 7 B As an alternativ e to restoring the AF D to w ithin its specif ied limits, Required Action A.1 requires a TH ERMAL POW ER reduction to 2
< 5 0 % RTP. This places the core in a condition f or w hich the v alue of the AF D is not important in the applicab le saf ety analy ses. A Completion Time of 30 minutes is reasonab le, b ased on operating ex perience, to reach 5 0 % RTP w ithout challenging plant sy stems.
SU RV EIL L ANCE SR 3.2.3.1 REQ U IREMENTS This Surv eillance v erif ies that the AF D, as indicated b y the NIS ex core 3
channel, is w ithin its specif ied limits. [ The Surv eillance F requency of 7 day s is adequate considering that the AF D is monitored b y a computer and any dev iation f rom requirements is alarmed.
OR The Surv eillance F requency is controlled under the Surv eillance F requency Control Program.
REV IEW ER S NOTE-----------------------------------
Plants controlling Surv eillance F requencies under a Surv eillance F requency Control Program should utiliz e the appropriate F requency 4 description, giv en ab ov e, and the appropriate choice of F requency in the Surv eillance Requirement.
3
]
7 Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.3B-3 Rev . 5 .0 2 1
B 3.2.3 1
INSERT 2 The AF D limits resulting f rom analy sis of core pow er distrib utions relativ e to the initial condition peak ing limits comprise a pow er er-dependant env elope of acceptab le AF D v alues. During steady -state operation, the core normally is controlled to a target AF D w ithin a narrow
( approx imately +/- 5 % AF D) b and. H ow ev er, the limiting AF D v alues may b e somew hat greater than the ex tremes of the normal operating b and.
7 INSERT 3 A.1, A.2 As an alternativ e to restoring the AF D to w ithin limits during b ase load operation, Required Action A.1 requires a TH ERMAL POW ER reduction to < PT. This places the core in a condition f or w hich the v alue of the AF D is not important in the applicab le saf ety analy ses. A Completion Time of 30 minutes is reasonab le, b ased on operating ex perience, to reach < PT w ithout challenging plant sy stems.
An alternativ e to restoring the AF D to w ithin limits during b ase load operation or ACTION A.1 is Required Action A.2, w hich requires discontinuation of b ase load operation. Once b ase load operation is discontinued Condition A is no longer applicab le. If the AF D is still not w ithin limits f ollow ing discontinued b ase load operation, Action B is required to b e entered. The Completion Time of 30 minutes to discontinue b ase load operation is reasonab le, b ased on operating ex perience to discontinue b ase load operation w ithout challenging plant sy stems.
Insert Page B 3.2.3-3
AF D ( RAOC Methodology ) 1 B 3.2.3B BASES U F SAR, Section 3.2 REF ERENCES 1. W CAP-8 40 3 ( nonproprietary ) , " Pow er Distrib ution Control and L oad 2
F ollow ing Procedures, " W estinghouse Electric Corporation, Septemb er 19 7 4. W CAP-17 15 2-P, Rev . 0 , Turk ey Point U nits 3 and 4 Ex tended Pow er U prate ( EPU ) Engineering Report , August 20 12.
- 2. R. W . Miller et al. , " Relax ation of Constant Ax ial Of f set Control: F Q 2 Surv eillance Technical Specif ication, " W CAP-10 217 ( NP) , J une 19 8 3.
W CAP-10 216-P-A, Rev . 1, Relax ation of Constant Ax ial Of f set
- 3. F SAR, Chapter [ 15 ] . Control, F Q Surv eillance Technical Specif ication, J une 19 8 3. 2 Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.3B-4 Rev . 5 .0 2 1
AF D ( RAOC Methodology ) 1 B 3.2.3B 5
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.3B-5 Rev . 5 .0 2 1
JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, AXIAL FLUX DIFFERENCE (AFD)
- 1. The type of Methodology (Relaxed Axial Offset Control (RAOC)) and the Specification designator "B" are deleted since they are unnecessary (only one AFD Specification is used in the Turkey Point Nuclear Generating Station (PTN) Plant Improved Technical Specifications (ITS)). This information is provided in NUREG-1431, Rev. 5.0, to assist in indentifying the appropriate Specification to be used as a model for the plant specific ITS conversion, but serves no purpose in a plant specific implementation. In addition, the Constant Axial Offset Control (CAOC) methodology Specification (Improved Standard Technical Specification (ISTS)
B 3.2.3A) is not used and is not shown. Note: Some RAOC shown to be consistent with CTS bases.
- 2. Changes are made (additions, deletions, and/or changes) to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
- 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 5. ISTS 3.2.3 Bases contains Figure B 3.2.3B-1. This Figure is located in the Turkey Point Nuclear Generating Station (PTN) Core Operating Limits Report (COLR).
Therefore, this figure is not included in the Bases for ITS 3.2.3.
- 6. Editorial changes made to enhance clarity/consistency.
- 7. Changes are made to be consistent with changes made to the Specification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, AXIAL FLUX DIFFERENCE (AFD)
There are no specific No Significant Hazards Considerations for this Specification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
ATTACHMENT 4 ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
Current Technical Specification (CTS) Markup and Discussion of Changes (DOCs)
ITS A0 1 ITS 3.2.4 POW ER DISTRIBU TION L IMITS
( Q PTR) 3/4.2.4 Q U ADRANT POW ER TIL T RATIO L IMITING CONDITION F OR OPERATION be A0 2 L CO 3.2.4 3.2.4 The Q U ADRANT POW ER TIL T RATIO shall not ex ceed 1.0 2.
A0 3 Applicab ility APPL ICABIL ITY : MODE 1, ab ov e 5 0 % of RATED TH ERMAL POW ER* .
ACTION:
not w ithin limits A0 4 ACTION A a. W ith the Q U ADRANT POW ER TIL T RATIO determined to ex ceed 1.0 2 b ut less than or equal to 1.0 9 :
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> L 0 1 ACTION A 1. Calculate the Q U ADRANT POW ER TIL T RATIO at least once per hour until either:
a) The Q U ADRANT POW ER TIL T RATIO is reduced to w ithin its limit, or A0 5 ACTION B b ) TH ERMAL POW ER is reduced to less than 5 0 % of RATED TH ERMAL POW ER. A0 6 or equal to af ter each Q PTR determination M0 1
- 2. W ithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> either:
a) Reduce the Q U ADRANT POW ER TIL T RATIO to w ithin its limit, or A0 5 ACTION A b ) Reduce TH ERMAL POW ER at least 3% f rom RATED TH ERMAL POW ER f or each 1% of indicated Q U ADRANT POW ER TIL T RATIO in ex cess of 1 and similarly reduce the Pow er Range Neutron F lux -H igh Trip Setpoints w ithin the L 0 2 nex t 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
- 3. V erif y that the Q U ADRANT POW ER TIL T RATIO is w ithin its limit w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter ex ceeding the limit or reduce TH ERMAL POW ER to less than 5 0 % of RATED TH ERMAL POW ER w ithin the nex t 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Pow er Range Neutron F lux -H igh Trip Setpoints to less than or equal to 5 5 % of RATED TH ERMAL POW ER w ithin the nex t 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; and L 0 3 Add proposed Required Actions A.3, A.4, A.5 , A6 and proposed ACTION B
- 4. Identif y and correct the cause of the out-of -limit condition prior to increasing TH ERMAL POW ER; sub sequent POW ER OPERATION ab ov e 5 0 % of RATED TH ERMAL POW ER may proceed prov ided that the Q U ADRANT POW ER TIL T RATIO is v erif ied w ithin its limit at least once per hour f or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until v erif ied acceptab le at 9 5 % or greater RATED TH ERMAL POW ER.
- See Special Test Ex ceptions Specif ication 3.10 .2. A0 3 TU RK EY POINT - U NITS 3 & 4 3/4 2-11 AMENDMENT NOS. 260 AND 25 5 Page 1 of 3
ITS A0 1 ITS 3.2.4 POW ER DISTRIBU TION L IMITS L IMITING CONDITION F OR OPERATION ( Continued)
ACTION ( Continued) not w ithin limits ACTION A b . W ith the Q U ADRANT POW ER TIL T RATIO determined to ex ceed 1.0 9 due to misalignment of A0 4 either a shutdow n or control rod:
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ACTION A 1. Calculate the Q U ADRANT POW ER TIL T RATIO at least once per hour until either: L 0 1 a) The Q U ADRANT POW ER TIL T RATIO is reduced to w ithin its limit, or A0 5 ACTION B b ) TH ERMAL POW ER is reduced to less than 5 0 % of RATED TH ERMAL POW ER. A0 6 or equal to ACTION A 2. Reduce TH ERMAL POW ER at least 3% f rom RATED TH ERMAL POW ER f or each 1% of indicated Q U ADRANT POW ER TIL T RATIO in ex cess of 1, w ithin 30 minutes; L 0 4 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
- 3. V erif y that the Q U ADRANT POW ER TIL T RATIO is w ithin its limit w ithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> af ter ex ceeding the limit or reduce TH ERMAL POW ER to less than 5 0 % of RATED TH ERMAL POW ER w ithin the nex t 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Pow er Range Neutron F lux -H igh Trip Setpoints to less than or equal to 5 5 % of RATED TH ERMAL POW ER w ithin the nex t 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; and L 0 3
- 4. Identif y and correct the cause of the out-of -limit condition prior to increasing TH ERMAL POW ER; sub sequent POW ER OPERATION ab ov e 5 0 % of RATED TH ERMAL POW ER may proceed prov ided that the Q U ADRANT POW ER TIL T RATIO is v erif ied w ithin its limit at least once per hour f or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until v erif ied acceptab le at 9 5 % or greater RATED TH ERMAL POW ER.
not w ithin limits ACTION A c. W ith the Q U ADRANT POW ER TIL T RATIO determined to ex ceed 1.0 9 due to causes other than A0 4 the misalignment of either a shutdow n or control rod:
12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> ACTION A 1. Calculate the Q U ADRANT POW ER TIL T RATIO at least once per hour until either: L 0 1 a) The Q U ADRANT POW ER TIL T RATIO is reduced to w ithin its limit, or A0 5 ACTION B b ) TH ERMAL POW ER is reduced to less than 5 0 % of RATED TH ERMAL POW ER. A0 6 or equal to TU RK EY POINT - U NITS 3 & 4 3/4 2-12 AMENDMENT NOS. 260 AND 25 5 Page 2 of 3
ITS A0 1 ITS 3.2.4 POW ER DISTRIBU TION L IMITS L IMITING CONDITION F OR OPERATION ( Continued)
ACTION ( Continued)
- 2. Reduce TH ERMAL POW ER to less than 5 0 % of RATED TH ERMAL POW ER w ithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Pow er Range Neutron F lux -H igh Trip Setpoints to less than or equal to 5 5 % of RATED TH ERMAL POW ER w ithin the nex t 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; and L 0 3
- 3. Identif y and correct the cause of the out-of -limit limit condition prior to increasing TH ERMAL POW ER; sub sequent POW ER OPERATION ab ov e 5 0 % of RATED TH ERMAL POW ER may proceed prov ided that the Q U ADRANT POW ER TIL T RATIO is v erif ied w ithin its limit at least once per hour f or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until v erif ied at 9 5 % or greater RATED TH ERMAL POW ER.
SU RV EIL L ANCE REQ U IREMENTS Add proposed SR 3.2.4.1 Notes 1 and 2 L 0 6 SR 3.2.4.1 4.2.4.1 The Q U ADRANT POW ER TIL T RATIO shall b e determined to b e w ithin the limit ab ov e 5 0 % of RATED TH ERMAL POW ER b y :
- a. Calculating the ratio in accordance w ith the Surv eillance F requency Control Program w hen the L 0 7 Pow er Range U pper Detector H igh F lux Dev iation and Pow er Range L ow er Detector H igh F lux Dev iation Alarms are OPERABL E, and b . Calculating the ratio at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> during steady -state operation w hen either alarm is inoperab le.
Add proposed SR 3.2.4.2 Note L 0 8 SR 3.2.4.2 4.2.4.2 The Q U ADRANT POW ER TIL T RATIO shall b e determined to b e w ithin the limit w hen ab ov e 7 5 % of SR 3.2.4.2 NOTE RATED TH ERMAL POW ER w ith one Pow er Range channel inoperab le b y using the mov ab le incore detectors to conf irm that the normaliz ed sy mmetric pow er distrib ution, ob tained either f rom tw o sets of SR 3.2.4.1 L A0 1 f our sy mmetric thimb le locations or f ull-core f lux map, or b y incore thermocouple map is consistent w ith the indicated Q U ADRANT POW ER TIL T RATIO in accordance w ith the Surv eillance F requency Control Program.
TU RK EY POINT - U NITS 3 & 4 3/4 2-13 AMENDMENT NOS. 27 9 AND 27 4 Page 3 of 3
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
ADMINISTRATIVE CHANGES A01 In the conversion of the Turkey Point Nuclear Generating Station (PTN) 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. 5.0, "Standard Technical Specifications - Westinghouse Plants" (ISTS).
These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.
A02 CTS 3.2.4 states "The QUADRANT POWER TILT RATIO shall not exceed 1.02."
ITS Limiting Condition for Operation (LCO) 3.2.4 states "The QPTR shall be 1.02. This changes the CTS by requiring the Quadrant Power Tilt Ratio (QPTR) to be less than or equal to 1.02.
This change is acceptable because nothing has changed. This is a presentation change for clarity. Stating that the QPTR shall be less than or equal to 1.02 is clearer than stating that it shall not exceed 1.02. This change is designated as an administrative change because it does not result in a technical change to the CTS.
A03 CTS 3.2.4 Applicability contains a footnote (footnote *) that states "See Special Test Exceptions Specification 3.10.2." ITS 3.2.4 Applicability does not contain this footnote. This changes the CTS by not including the footnote reference.
The purpose of CTS 3.2.4 footnote
- is to alert the user that a Special Test Exception exists which may modify the Applicability of the Specification. It is an ITS convention to not include these types of footnotes or cross-references. This change is designated as an administrative change since it does not result in a technical change to the CTS.
A04 CTS 3.2.4 ACTION a states "With the QUADRANT POWER TILT RATIO determined to exceed 1.02 but less than or equal to 1.09." CTS 3.2.4 ACTION b states "With the QUADRANT POWER TILT RATIO determined to exceed 1.09 resulting from misalignment of either a shutdown or control rod." CTS 3.2.4 ACTION c states "With the QUADRANT POWER TILT RATIO determined to exceed 1.09 due to causes other than the misalignment of either a shutdown or control rod." ITS 3.2.4 ACTION A states "QPTR not within limit." This changes the CTS by specifying that action must be taken when the QPTR is not within limits. (See DOCS L02, L03, and L04 for changes to the compensatory measures.)
The purpose of CTS 3.2.4 is to provide compensatory actions when the QPTR exceeds 1.02. ITS 3.2.4 continues to provide compensatory actions when the QPTR exceeds 1.02. This change is a presentation change. This change is designated as an administrative change since it does not result in technical changes to the CTS.
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DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
A05 CTS 3.2.4 ACTION a.1.a) states that with QPTR greater than 1.02 and less than or equal to 1.09, calculate the QPTR at least once per hour until either QPTR is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RATED THERMAL POWER (RTP). CTS 3.2.4 ACTION a.2.a) states that within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, either QPTR is reduced to within its limit or reduce THERMAL POWER at least 3% from RTP for each 1% of indicated QPTR in excess of 1.00 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. CTS 3.2.4 ACTION b.1.a) states that with QPTR greater than 1.09 due to misalignment of either a shutdown or control rod, calculate the QPTR at least once per hour until either QPTR is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RTP. CTS 3.2.4 ACTION c.1.a) states that with QPTR greater than 1.09 due to causes other than the misalignment of either a shutdown or control rod, calculate the QPTR at least once per hour until either QPTR is reduced to within its limit or THERMAL POWER is reduced to less than 50% of RTP. ITS 3.2.4 does not contain a Required Action stating QPTR must be reduced to within its limit. This changes the CTS by not specifically stating that the restoration of QPTR is required.
This change is acceptable because the technical requirements have not changed. Restoration of compliance with the LCO is always an available Required Action. The convention in the ITS is to not state such "restore" options explicitly unless it is the only action or is required for clarity. This change is designated as an administrative change since it does not result in technical changes to the CTS.
A06 CTS 3.2.4 LCO APPLICABLITY is MODE 1 above 50% RTP. CTS 3.2.4 ACTION a.1.b, ACTION b.1.b, and ACTION c.1.b state, in part, to calculate the QPTR at least once per hour until either QPTR is reduced to within limit, or THERMAL POWER is reduced to less than 50% of RTP. ITS 3.2.4 LCO APPLICABILITY is MODE 1 with THERMAL POWER > 50% RTP. ITS 3.2.4 CONDITION B states that when the Required Action and associated Completion Time are not met to reduce THERMAL POWER to 50% RTP. This changes the CTS requirement of reducing power and exiting the Mode of Applicability to a value of < 50% RTP and allow stopping at a value of 50% RTP.
This change is acceptable because the technical requirements have not changed. LCO 3.0.2 states that that when a Required Action to restore variables within limits is not met, a shutdown may be required to place the unit in a MODE or condition in which the Specification is not applicable. In this case, both CTS and ITS require a reduction of power to exit the Mode of Applicability when compliance with the LCO is not met within the prescribed amount of time. Once the Mode of Applicability for LCO 3.2.4 is exited ( 50% RTP), the new power level (50%) is no longer controlled by this specification. This change is designated as an administrative change since it does not result in technical changes to CTS LCO 3.2.4.
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DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
MORE RESTRICTIVE CHANGES M01 CTS 3.2.4 ACTION a.2.b states in part, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, reduce THERMAL POWER at least 3% from RTP for each 1% of indicated QPTR in excess of 1.00.
ITS 3.2.4 Required Action A.1 has a similar requirement to reduce THERMAL POWER 3% from RTP for each 1% of QPTR > 1.00. The Completion Time for ITS 3.2.4 Required Action A.1 is 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after each QPTR determination. This changes the CTS by specifically requiring a power reduction, if applicable, after each QPTR determination.
The purpose CTS 3.2.4 ACTION a.2.b is to commence a power level reduction to ensure that core power distributions that violate fuel design criteria are minimized. The maximum allowable power level initially determined by ITS 3.2.4 Required Action A.1 may be affected by subsequent determinations of QPTR.
However, any increases in QPTR would require additional power reductions within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of each QPTR determination, if necessary to comply with the decreased maximum allowable power level. This change is designated as more restrictive because it adds required actions to the CTS.
RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit by using the movable incore detectors to confirm that the normalized symmetric power distribution, obtained either from two sets of four symmetric thimble locations or full-core flux map, or by incore thermocouple map is consistent with the indicated QPTR. ITS Surveillance Requirement (SR) 3.2.4.2 requires verifying QPTR is within limit using the movable incore detectors. This changes the CTS by moving the procedural details for meeting the Surveillance to the Bases.
The removal of these details, which are related to system design, from the Technical Specifications, is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide protection of public health and safety. The ITS still retains the requirement that the QPTR is verified to be within the limits using the movable incore detectors. The details relating to system design do not need to appear in the specification in order for the requirement to apply. Additionally, this change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specification Bases Control Program in Chapter 5. This program provides for the evaluation of changes to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because information relating to system design is being removed from the Technical Specifications.
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DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
LESS RESTRICTIVE CHANGES L01 (Category 3 - Relaxation of Completion Time) CTS 3.2.4 ACTIONS a.1, b.1, and c.1 require calculating the QPTR at least once per hour. ITS 3.2.4 ACTION A (Required Action A.2 and associated Completion Time) require, in part, that when the QPTR is not within limit to determine QPTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This changes the CTS by requiring the determination of QPTR to be done once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> instead of once per hour.
The purpose of CTS 3.2.4 ACTIONS a.1, b.1, and c.1 is to verify QPTR until it is brought to within limit or reactor power has been lowered to less than or equal to 50% RTP. This action is taken because with the QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters such as F LQ (Z) and FNH may not be within their limits. In addition to ITS 3.2.4 Required Action A.2 Completion Time the other Required Actions and associated Completion Times of Condition A are consistent with safe operation, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a Design Basis Accident (DBA) occurring during the repair period. In addition to reducing reactor power by greater than or equal to 3% for each 1% QPTR exceeds 1.00, ITS 3.2.4 requires a determination of QPTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Additionally, ITS 3.2.4 requires measurement of F LQ (Z) and FNH within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and every 7 days thereafter to verify that those parameters are within limit. Furthermore, ITS 3.2.4 requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, ITS 3.2.4 allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures the core is operated within the safety analyses. This change is designated as less restrictive because less stringent Completion Times are being applied in the ITS than were applied in the CTS.
L02 (Category 4 - Relaxation of Required Action) CTS 3.2.4 ACTION a.2.b) requires that when QPTR is in excess of 1.00 but less than or equal to 1.09, to reduce THERMAL POWER at least 3% from RTP for each 1% of indicated QPTR in excess of 1.00 and similarly reduce the Power Range Neutron Flux-High Trip Setpoints within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. ITS 3.2.4 Required Action A.1 includes the requirement to reduce the THERMAL POWER, but does not include a requirement to reduce the Power Range Neutron Flux-High Trip Setpoints. This changes the CTS by eliminating the requirement to reduce the Power Range Neutron Flux-High Trip Setpoints.
The purpose of CTS 3.2.4 ACTION a.2.b) is to reduce THERMAL POWER to increase the margin to the core power distribution limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to Turkey Point Unit 3 and Unit 4 Page 4 of 8
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR) minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. With THERMAL POWER reduced by 3% from RTP for each 1% QPTR is greater than 1.00, further actions are not required to ensure that THERMAL POWER is not increased.
Power increases are administratively prohibited by the Technical Specification while avoiding the risk of changing Reactor Trip System setpoints during operation. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L03 (Category 4 - Relaxation of Required Action) CTS 3.2.4 ACTION a.3 states "Verify that the QUADRANT POWER TILT RATIO is within its limit within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after exceeding the limit or reduce THERMAL POWER to less than 50% of RATED THERMAL POWER within the next 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and reduce the Power Range Neutron Flux-High Trip setpoints to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />." CTS 3.2.4 ACTION b.3 and b.4 contain the same compensatory actions as CTS ACTION a.3 but requires the QPTR to be within limits within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. CTS 3.2.4 ACTIONS a.4, b.4, and c.3 state "Identify and correct the cause of the out of limit condition prior to increasing THERMAL POWER; subsequent POWER OPERATION above 50% of RATED THERMAL POWER may proceed provided that the QUADRANT POWER TILT RATIO is verified within its limit at least once per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or until verified acceptable at 95% or greater RATED THERMAL POWER." ITS 3.2.4 Required Action A.3 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.2.1 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions from a THERMAL POWER reduction per Required Action A.1 and once per 7 days thereafter. ITS 3.2.4 Required Action A.4 requires reevaluation of the safety analyses and confirmation that the results remain valid for duration of operation under this condition prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.5 requires normalization of excore detectors to restore QPTR to within limit prior to increasing THERMAL POWER above the limit of Required Action A.1. ITS 3.2.4 Required Action A.6 requires performance of SR 3.2.1.1, SR 3.2.1.2, SR 3.2.2.1, in accordance with the COLR, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after achieving equilibrium conditions at RTP not to exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after increasing THERMAL POWER above the limit of Required Action A.1. Additionally, ITS 3.2.4 Required Action A.5 contains two Notes and ITS 3.2.4 Required Action A.6 contains one Note. ITS 3.2.4 Required Action A.5 Note 1 states "Perform Required Action A.5 only after Required Action A.4 is completed." ITS 3.2.4 Required Action A.5 Note 2 states "Required Action A.6 shall be completed whenever Required Action A.5 is performed." ITS 3.2.4 Required Action A.6 Note states "Perform Required Action A.6 only after Required Action A.5 is completed."
Furthermore, ITS 3.2.4 ACTION B states that with a Required Action and associated Completion Time (of Condition A) not met, reduce THERMAL POWER to 50% RTP within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. This changes the CTS by eliminating requirements to be 50% RTP within a specified time of exceeding the LCO and substituting compensatory measures in ITS 3.2.4 ACTION A, which if not met, results in a reduction in power per ITS 3.2.4 ACTION B.
Turkey Point Unit 3 and Unit 4 Page 5 of 8
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
The purpose of the CTS actions is to lower reactor power to less than 50% when QPTR is not within its limit and cannot be restored to within its limit within a reasonable time period. In addition, the Power Range Neutron Flux-High Trip setpoints are reduced to 55% to ensure that reactor power is not inadvertently increased without QPTR within its limit. This action is taken because with QPTR not within limit, the core power distribution is not within the analyzed assumptions, and critical parameters such as F LQ (Z) and FNH may not be within the associated limits. A QPTR not within limit may not be an unacceptable condition if the critical core parameters such as F LQ (Z) and FNH are within the associated limits. This change is acceptable because the Required Actions are used to establish remedial measures that must be taken in response to the degraded conditions in order to minimize risk associated with continued operation while provided time to repair inoperable features. The Required Actions are consistent with safe operation under the specified Condition, considering the OPERABILITY status of the redundant systems of required features, the capacity and capability of remaining features, a reasonable time for repairs or replacement of required features, and the low probability of a DBA occurring during the repair period. ITS 3.2.4 Required Action A.3 requires measurement of F LQ (Z) and FNH within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and every 7 days thereafter to verify that those parameters are within limit. In addition, ITS 3.2.4 Required Action A.4 requires the safety analyses to be reevaluated to ensure that the results remain valid. Assuming that these actions are successful, ITS 3.2.4 allows indefinite operation with QPTR out of its limit and allows the excore nuclear detectors to be normalized to eliminate the indicated QPTR. This ensures the core is operated within the safety analyses. This change is designated as less restrictive because less stringent Required Actions are being applied in the ITS than were applied in the CTS.
L04 (Category 3 - Relaxation of Completion Time) CTS 3.2.4 ACTION b.2, applies when QPTR is greater than 1.09 due to misalignment of either a shutdown or control rod, requires a THERMAL POWER reduction from RTP for each 1% of indicated QPTR in excess of 1.00 within 30 minutes. ITS 3.2.4 Required Action A.1 requires a THERMAL POWER reduction of 3% from RTP for each 1% QPTR exceeds 1.00 within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This changes the CTS by allowing 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to perform the required power reduction.
The purpose of CTS 3.2.4 is to provide appropriate compensatory actions for QPTR greater than that assumed in the safety analyses. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering other indications available to the operator, a reasonable time for restoring compliance with the LCO, and the low probability of a DBA occurring during the restoration period. Under the ITS, a QPTR of 1.09 would require THERMAL POWER to be reduced to 79% RTP. This will provide sufficient thermal margin to account for the radial power distribution. In addition, the 2-hour time limit is consistent with the CTS time allowed when QPTR is Turkey Point Unit 3 and Unit 4 Page 6 of 8
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
> 1.00 but 1.09. This change is designated as less restrictive because additional time is allowed to decrease power than was allowed in the CTS.
L05 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.2.4.1.a states, in part, that the QPTR shall be determined to be within the limit by calculating the ratio in accordance with the Surveillance Frequency Control Program (SFCP). ITS SR 3.2.4.1 requires the same determination, but includes two Notes. ITS SR 3.2.4.1 Note 1 states when the input from one Power Range Neutron Flux channel is inoperable, the remaining three power range channels can be used for calculating QPTR as long as THERMAL POWER is less than or equal to 75% RTP. ITS SR 3.2.4.1 Note 2 states that SR 3.2.4.2 may be performed in lieu of this Surveillance. This changes the CTS by allowing use of three Power Range Neutron Flux channels for calculating the QPTR and by allowing the movable incore detectors to be used to determine QPTR instead of the excore detectors.
The purpose of CTS 4.2.4.1.a is to periodically verify that QPTR is within limit.
This change is acceptable because it has been determined that the relaxed Surveillance Requirement acceptance criteria are sufficient for verification that the parameters meet the LCO. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. With only one Power Range Neutron Flux channel inoperable, QPTR can still be verified by calculation as long as three Power Range Neutron Flux channels are OPERABLE and THERMAL POWER is less than or equal to 75% RTP. The movable incore detector system provides a more accurate indication of QPTR than the excore detectors. In fact, the movable incore detector system is used to calibrate the excore detectors. Therefore, allowing the use of the movable incore detector system or excore detector is appropriate. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
L06 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.2.4.1.a states that the QPTR shall be determined to be within the limit by calculating the ratio in accordance with the SFCP when the Power Range Upper Detector High Flux Deviation and Power Range Lower Detector High Flux Deviation Alarms are OPERABLE. CTS 4.2.4.1.b states that the QPTR shall be determined to be within the limit by calculating the ratio in accordance with the SFCP during steady state operation when the alarm is inoperable. ITS SR 3.2.4.1 requires verification that the QPTR is within limits in accordance with the SFCP. This changes the CTS by eliminating the requirement to verify the QPTR more frequently when the QPTR alarm is inoperable.
The purpose of CTS 4.2.4.1.a and 4.2.4.1.b is to periodically verify that the QPTR is within limit. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. Increasing the frequency of QPTR verification when the QPTR alarm is inoperable is unnecessary as inoperability of the alarm does not increase the probability that the QPTR is outside its limit. The QPTR alarm is for indication only. Its use is not credited in any of the safety analyses. This change Turkey Point Unit 3 and Unit 4 Page 7 of 8
DISCUSSION OF CHANGES ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR) is designated as less restrictive because Surveillances will be performed less frequently under the ITS than under the CTS.
L07 (Category 6 - Relaxation of Surveillance Requirement Acceptance Criteria)
CTS 4.2.4.2 states, in part, that the QPTR shall be determined to be within the limit when above 75 percent of RTP with one Power Range Channel inoperable by using the movable incore detectors, or by incore thermocouple map. ITS SR 3.2.4.2 requires determination of the QPTR by use of the movable incore detectors. Additionally, ITS SR 3.2.4.2 contains a Note which states "Not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER
> 75% RTP." This changes the CTS by not requiring the Surveillance to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input from one or more Power Range Neutron Flux channels are inoperable.
The purpose of CTS 4.2.4.2 is to verify that the QPTR is within limit using the movable incore detectors. This change is acceptable because the Surveillance Frequency has been evaluated to ensure that it provides an acceptable level of equipment reliability. When one or more Power Range Neutron Flux channels are inoperable, tilt monitoring becomes degraded. Therefore, the movable incore detector system provides a more accurate indication of QPTR than the excore detectors. The ITS SR 3.2.4.2 allowance, for not requiring performance of the Surveillance for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after input when one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER > 75% RTP, is required to allow time for the movable incore detectors to perform the initial measurement of the QPTR before the Surveillance is declared not met. This change is designated as less restrictive because less stringent Surveillance Requirements are being applied in the ITS than were applied in the CTS.
Turkey Point Unit 3 and Unit 4 Page 8 of 8
Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)
CTS Q PTR 3.2.4 3.2 POW ER DISTRIBU TION L IMITS 3.2.4 Q U ADRANT POW ER TIL T RATIO ( Q PTR) 3.2.4 L CO 3.2.4 The QPTR shall be 1.0 2.
Applicab ility APPL ICABIL ITY : MODE 1 w ith TH ERMAL POW ER > 5 0 % RTP.
ACTIONS CONDITION REQ U IRED ACTION COMPL ETION TIME ACTION a, A. Q PTR not w ithin limit. A.1 Reduce TH ERMAL 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> af ter each ACTION b ,
ACTION c POWER 3% f rom RTP f or Q PTR determination DOC M0 1 each 1% of Q PTR > 1.0 0 .
AND A.2 Determine Q PTR. Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND DOC L 0 3 A.3 Perf orm SR 3.2.1.1, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter 1 SR 3.2.1.2, and SR 3.2.2.1. achiev ing equilib rium or conditions f rom a TH ERMAL POW ER as applicab le, reduction per Required Action A.1 AND Once per 7 day s thereaf ter AND Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.4-1 Rev . 5 .0 2
CTS Q PTR 3.2.4 ACTIONS ( continued)
CONDITION REQ U IRED ACTION COMPL ETION TIME DOC L 0 3 A.4 Reev aluate saf ety analy ses Prior to increasing and conf irm results remain TH ERMAL POW ER v alid f or duration of ab ov e the limit of operation under this Required Action A.1 condition.
AND DOC L 0 3 A.5 -------------NOTES-------------
- 1. Perf orm Required Action A.5 only af ter Required Action A.4 is completed.
- 2. Required Action A.6 shall b e completed w henev er Required Action A.5 is perf ormed.
Normaliz e ex core detectors Prior to increasing to restore Q PTR to w ithin TH ERMAL POW ER limit. ab ov e the limit of Required Action A.1 AND DOC L 0 3 A.6 ---------------NOTE--------------
Perf orm Required Action A.6 only af ter Required Action A.5 is completed.
Perf orm SR 3.2.1.1, W ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter SR 3.2.1.2, and SR 3.2.2.1. achiev ing equilib rium or conditions at RTP not 1
to ex ceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> as applicab le, af ter increasing TH ERMAL POW ER ab ov e the limit of Required Action A.1 Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.4-2 Rev . 5 .0 2
CTS Q PTR 3.2.4 ACTIONS ( continued)
CONDITION REQ U IRED ACTION COMPL ETION TIME ACTION a, B. Required Action and B.1 Reduce TH ERMAL 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ACTION b ,
ACTION c associated Completion POWER to 5 0 % RTP.
Time not met.
SU RV EIL L ANCE REQ U IREMENTS SU RV EIL L ANCE F REQ U ENCY 4.2.4.1 SR 3.2.4.1 ------------------------------NOTES-----------------------------
DOC L 0 6
- 1. W ith input f rom one Pow er Range Neutron F lux channel inoperab le and TH ERMAL POW ER 7 5 % RTP, the remaining three pow er range channels can b e used f or calculating Q PTR.
- 2. SR 3.2.4.2 may b e perf ormed in lieu of this Surv eillance.
V erif y Q PTR is w ithin limit b y calculation. [ 7 day s 3 OR In accordance w ith the Surv eillance F requency Control Program ] 3 Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.4-3 Rev . 5 .0 2
CTS Q PTR 3.2.4 SU RV EIL L ANCE REQ U IREMENTS ( continued)
SU RV EIL L ANCE F REQ U ENCY 4.2.4.2, SR 3.2.4.2 -------------------------------NOTE------------------------------
DOC L 0 8 Not required to b e perf ormed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> af ter input f rom one or more Pow er Range Neutron F lux channels are inoperab le w ith TH ERMAL POW ER
> 7 5 % RTP.
V erif y Q PTR is w ithin limit using the mov ab le incore [ 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 3 detectors.
OR In accordance w ith the Surv eillance F requency Control Program ] 3 Turk ey Point U nit 3 and U nit 4 Amendment X X X and Y Y Y W estinghouse STS 3.2.4-4 Rev . 5 .0 2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO (QPTR)
- 1. Changes are made to be consistent with changes made to Specification 3.2.1 and 3.2.2.
- 2. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Improved Standard Technical Specifications (ISTS) Bases Markup and Bases Justification for Deviations (JFDs)
Q PTR B 3.2.4 B 3.2 POW ER DISTRIBU TION L IMITS B 3.2.4 Q U ADRANT POW ER TIL T RATIO ( Q PTR)
BASES BACK G ROU ND The Q PTR limit ensures that the gross radial pow er distrib ution remains consistent w ith the design v alues used in the saf ety analy ses. Precise radial pow er distrib ution measurements are made during startup testing, af ter ref ueling, and periodically during pow er operation.
The pow er density at any point in the core must b e limited so that the f uel design criteria are maintained. Together, L CO 3.2.3, " AX IAL F L U X DIF F ERENCE ( AF D) , " L CO 3.2.4, and L CO 3.1.6, " Control Rod Insertion L imits, " prov ide limits on process v ariab les that characteriz e and control the three dimensional pow er distrib ution of the reactor core. Control of these v ariab les ensures that the core operates w ithin the f uel design criteria and that the pow er distrib ution remains w ithin the b ounds used in the saf ety analy ses.
APPL ICABL E This L CO precludes core pow er distrib utions that v iolate the f ollow ing f uel SAF ETY design criteria:
ANAL Y SES
- a. During a large b reak loss of coolant accident, the peak cladding temperature must not ex ceed 220 0 ° F ( Ref . 1) ,
b . During a loss of f orced reactor coolant f low accident, there must b e at least 9 5 % prob ab ility at the 9 5 % conf idence lev el ( the 9 5 /9 5 departure f rom nucleate b oiling ( DNB) criterion) that the hot f uel rod in the core does not ex perience a DNB condition,
- c. During an ej ected rod accident, the energy deposition to the f uel 1 must not ex ceed 28 0 cal/gm ( Ref . 2) , and 20 0 Ref s. 3 and 4
- d. The control rods must b e capab le of shutting dow n the reactor w ith a minimum required SDM w ith the highest w orth control rod stuck f ully w ithdraw n ( Ref . 3) .
The L CO limits on the AF D, the Q PTR, the H eat F lux H ot Channel F actor
( F Q ( Z ) ) , the Nuclear Enthalpy Rise H ot Channel F actor ( F N H ) , and control b ank insertion are estab lished to preclude core pow er distrib utions that ex ceed the saf ety analy ses limits.
The Q PTR limits ensure that F N H and F Q ( Z ) remain b elow their limiting v alues b y prev enting an undetected change in the gross radial pow er distrib ution.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-1 Rev . 5 .0 2
Q PTR B 3.2.4 BASES APPL ICABL E SAF ETY ANAL Y SES ( continued)
In MODE 1, the F N H and F Q ( Z ) limits must b e maintained to preclude core pow er distrib utions f rom ex ceeding design limits assumed in the saf ety analy ses.
The Q PTR satisf ies Criterion 2 of 10 CF R 5 0 .36( c) ( 2) ( ii) .
L CO The Q PTR limit of 1.0 2, at w hich correctiv e action is required, prov ides a margin of protection f or b oth the DNB ratio and linear heat generation rate contrib uting to ex cessiv e pow er peak s resulting f rom X -Y plane pow er tilts. A limiting Q PTR of 1.0 2 can b e tolerated b ef ore the margin f or uncertainty in F Q ( Z ) and ( F N H ) is possib ly challenged.
APPL ICABIL ITY The Q PTR limit must b e maintained in MODE 1 w ith TH ERMAL POW ER
> 5 0 % RTP to prev ent core pow er distrib utions f rom ex ceeding the design limits.
Applicab ility in MODE 5 0 % RTP and in other MODES is not required b ecause there is either insuf f icient stored energy in the f uel or insuf f icient energy b eing transf erred to the reactor coolant to require the implementation of a Q PTR limit on the distrib ution of core pow er. The Q PTR limit in these conditions is, theref ore, not important. Note that the F N H and F Q ( Z ) L COs still apply , b ut allow progressiv ely higher peak ing f actors at 5 0 % RTP or low er.
ACTIONS A.1 W ith the Q PTR ex ceeding its limit, a pow er lev el reduction of 3% RTP f or each 1% b y w hich the Q PTR ex ceeds 1.0 0 is a conserv ativ e tradeof f of total core pow er w ith peak linear pow er. The Completion Time of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> allow s suf f icient time to identif y the cause and correct the tilt. Note that the pow er reduction itself may cause a change in the tilted condition.
The max imum allow ab le pow er lev el initially determined b y Required Action A.1 may b e af f ected b y sub sequent determinations of Q PTR.
Increases in Q PTR w ould require pow er reduction w ithin 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of Q PTR determination, if necessary to comply w ith the decreased max imum allow ab le pow er lev el. Decreases in Q PTR w ould allow increasing the max imum allow ab le pow er lev el and increasing pow er up to this rev ised limit.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-2 Rev . 5 .0 2
Q PTR B 3.2.4 BASES ACTIONS ( continued)
A.2 Af ter completion of Required Action A.1, the Q PTR alarm may still b e in its alarmed state. As such, any additional changes in the Q PTR are detected b y requiring a check of the Q PTR once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereaf ter.
A 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is suf f icient b ecause any additional change in Q PTR w ould b e relativ ely slow .
A.3 The peak ing f actors F Q ( Z ) , as approx imated b y F Q C
( Z ) and F Q W
( Z ) , and 1 F N H are of primary importance in ensuring that the pow er distrib ution remains consistent w ith the initial conditions used in the saf ety analy ses.
Perf orming SRs on F N H and F Q ( Z ) w ithin the Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter achiev ing equilib rium conditions f rom a Thermal Pow er reduction per Required Action A.1 ensures that these primary indicators of pow er distrib ution are w ithin their respectiv e limits. Equilib rium conditions are achiev ed w hen the core is suf f iciently stab le at intended 2 w ith equilib rium x enon operating conditions to support f lux mapping. A Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> af ter achiev ing equilib rium conditions f rom Thermal Pow er reduction per Required Action A.1 tak es into consideration the rate at w hich peak ing f actors are lik ely to change, and the time required to the appliab le L COs stab iliz e the plant and perf orm a f lux map. If these peak ing f actors are not w ithin their limits, the Required Actions of these Surv eillances prov ide 3 an appropriate response f or the ab normal condition. If the Q PTR remains ab ov e its specif ied limit, the peak ing f actor surv eillances are required each 7 day s thereaf ter to ev aluate F N H and F Q ( Z ) w ith changes in pow er distrib ution. Relativ ely small changes are ex pected due to either b urnup and x enon redistrib ution or correction of the cause f or ex ceeding the Q PTR limit.
A.4 Although F N H and F Q ( Z ) are of primary importance as initial conditions in the saf ety analy ses, other changes in the pow er distrib ution may occur as the Q PTR limit is ex ceeded and may hav e an impact on the v alidity of the saf ety analy sis. A change in the pow er distrib ution can af f ect such reactor parameters as b ank w orths and peak ing f actors f or rod Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-3 Rev . 5 .0 2
Q PTR B 3.2.4 BASES ACTIONS ( continued) malf unction accidents. W hen the Q PTR ex ceeds its limit, it does not necessarily mean a saf ety concern ex ists. It does mean that there is an indication of a change in the gross radial pow er distrib ution that requires an inv estigation and ev aluation that is accomplished b y ex amining the incore pow er distrib ution. Specif ically , the core peak ing f actors and the quadrant tilt must b e ev aluated b ecause they are the f actors that b est characteriz e the core pow er distrib ution. This re-ev aluation is required to ensure that, b ef ore increasing TH ERMAL POW ER to ab ov e the limit of Required Action A.1, the reactor core conditions are consistent w ith the assumptions in the saf ety analy ses.
A.5 is still ex ceeding If the Q PTR has ex ceeded the 1.0 2 limit and a re-ev aluation of the saf ety 5 analy sis is completed and show s that saf ety requirements are met, the shall b e ex core detectors are normaliz ed to restore Q PTR to w ithin limits prior to 5 increasing TH ERMAL POW ER to ab ov e the limit of Required Action A.1.
Normaliz ation is accomplished in such a manner that the indicated Q PTR f ollow ing normaliz ation is near 1.0 0 . This is done to detect any sub sequent signif icant changes in Q PTR.
shall not b e Required Action A.5 is modif ied b y tw o Notes. Note 1 states that the Q PTR is not restored to w ithin limits until af ter the re-ev aluation of the 2 b y ex core detector normaliz ation saf ety analy sis has determined that core conditions at RTP are w ithin the saf ety analy sis assumptions ( i.e., Required Action A.4) . Note 2 states that if Required Action A.5 is perf ormed, then Required Action A.6 shall b e perf ormed. Required Action A.5 normaliz es the ex core detectors to restore Q PTR to w ithin limits, w hich restores compliance w ith L CO 3.2.4.
Thus, Note 2 prev ents ex iting the Actions prior to completing f lux mapping to v erif y peak ing f actors, per Required Action A.6. These Notes are intended to prev ent any amb iguity ab out the required sequence of actions.
A.6 Once the f lux tilt is restored to w ithin limits ( i.e., Required Action A.5 is perf ormed) , it is acceptab le to return to f ull pow er operation. H ow ev er, as an added check that the core pow er distrib ution is consistent w ith the saf ety analy sis assumptions, Required Action A.6 requires v erif ication Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-4 Rev . 5 .0 2
Q PTR B 3.2.4 BASES ACTIONS ( continued) , as specif ied in the COL R, that F Q ( Z ) , as approx imated b y F Q C ( Z ) and F Q W ( Z ) , and F N H are w ithin 1 their specif ied limits w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of achiev ing equilib rium conditions at RTP. As an added precaution, if the core pow er does not reach equilib rium conditions at RTP w ithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, b ut is increased slow ly ,
then the peak ing f actor surv eillances must b e perf ormed w ithin 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> af ter increasing TH ERMAL POW ER ab ov e the limit of Required Action A.1. These Completion Times are intended to allow adequate time to increase TH ERMAL POW ER to ab ov e the limit of Required Action A.1, w hile not permitting the core to remain w ith unconf irmed pow er distrib utions f or ex tended periods of time.
Required Action A.6 is modif ied b y a Note that states that the peak ing f actor surv eillances may only b e done af ter the ex core detectors hav e b een normaliz ed to restore Q PTR to w ithin limits ( i.e., Required Action A.5 ) . The intent of this Note is to hav e the peak ing f actor surv eillances perf ormed at operating pow er lev els, w hich can only b e accomplished af ter the ex core detectors are normaliz ed to restore Q PTR to w ithin limits and the core returned to pow er.
B.1 If Required Actions A.1 through A.6 are not completed w ithin their associated Completion Times, the unit must b e b rought to a MODE or condition in w hich the requirements do not apply . To achiev e this status, TH ERMAL POW ER must b e reduced to < 5 0 % RTP w ithin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The 1 allow ed Completion Time of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is reasonab le, b ased on operating ex perience regarding the amount of time required to reach the reduced pow er lev el w ithout challenging plant sy stems.
SU RV EIL L ANCE SR 3.2.4.1 REQ U IREMENTS SR 3.2.4.1 is modif ied b y tw o Notes. Note 1 allow s Q PTR to b e calculated w ith three pow er range channels if TH ERMAL POW ER is 7 5 % RTP and the input f rom one Pow er Range Neutron F lux channel is inoperab le. Note 2 allow s perf ormance of SR 3.2.4.2 in lieu of SR 3.2.4.1.
This Surv eillance v erif ies that the Q PTR, as indicated b y the Nuclear Instrumentation Sy stem ( NIS) ex core channels, is w ithin its limits. [ The 6 F requency of 7 day s tak es into account other inf ormation and alarms av ailab le to the operator in the control room.
Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-5 Rev . 5 .0 2
Q PTR B 3.2.4 BASES SU RV EIL L ANCE REQ U IREMENTS ( continued) 6 OR The Surv eillance F requency is controlled under the Surv eillance F requency Control Program.
REV IEW ER S NOTE-----------------------------------
Plants controlling Surv eillance F requencies under a Surv eillance F requency Control Program should utiliz e the appropriate F requency 4 description, giv en ab ov e, and the appropriate choice of F requency in the Surv eillance Requirement.
6
]
Q PTR F or those causes of Q PT that occur quick ly ( e.g., a dropped rod) , there 5 ty pically are other indications of ab normality that prompt a v erif ication of core pow er tilt.
SR 3.2.4.2 This Surv eillance is modif ied b y a Note, w hich states that it is not required until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> af ter the input f rom one or more Pow er Range Neutron F lux channels are inoperab le and the TH ERMAL POW ER is > 7 5 % RTP.
W ith an NIS pow er range channel inoperab le, tilt monitoring f or a portion of the reactor core b ecomes degraded. L arge tilts are lik ely detected w ith the remaining channels, b ut the capab ility f or detection of small pow er tilts in some quadrants is decreased. [ Perf orming SR 3.2.4.2 at a F requency 6 of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prov ides an accurate alternativ e means f or ensuring that any tilt remains w ithin its limits.
OR The Surv eillance F requency is controlled under the Surv eillance F requency Control Program.
REV IEW ER S NOTE-----------------------------------
Plants controlling Surv eillance F requencies under a Surv eillance F requency Control Program should utiliz e the appropriate F requency 4
description, giv en ab ov e, and the appropriate choice of F requency in the Surv eillance Requirement.
] 6 Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-6 Rev . 5 .0 2
Q PTR B 3.2.4 BASES SU RV EIL L ANCE REQ U IREMENTS ( continued)
, or b y incore thermocouple map F or purposes of monitoring the Q PTR w hen one pow er range channel is inoperab le, the mov eab le incore detectors are used to conf irm that the 1 normaliz ed sy mmetric pow er distrib ution is consistent w ith the indicated Q PTR and any prev ious data indicating a tilt. The incore detector monitoring is perf ormed w ith a f ull incore f lux map or tw o sets of f our thimb le locations w ith quarter core sy mmetry . The tw o sets of f our sy mmetric thimb les is a set of eight unique detector locations. These locations are C-8 , E-5 , E-11, H -3, H -13, L -5 , L -11, and N-8 f or three and 2 f our loop cores.
The sy mmetric thimb le f lux map can b e used to generate sy mmetric thimb le " tilt." This can b e compared to a ref erence sy mmetric thimb le tilt, f rom the most recent f ull core f lux map, to generate an incore Q PTR.
Theref ore, incore monitoring of Q PTR can b e used to conf irm that Q PTR is w ithin limits.
W ith one NIS channel inoperab le, the indicated tilt may b e changed f rom the v alue indicated w ith all f our channels OPERABL E. To conf irm that no change in tilt has actually occurred, w hich might cause the Q PTR limit to b e ex ceeded, the incore result may b e compared against prev ious f lux maps either using the sy mmetric thimb les as describ ed ab ov e or a complete f lux map. Nominally , quadrant tilt f rom the Surv eillance should b e w ithin 2% of the tilt show n b y the most recent f lux map data.
REF ERENCES 1. 10 CF R 5 0 .46.
U F SAR Section14.2.6
- 2. Regulatory G uide 1.7 7 , Rev [ 0 ] , May 19 7 4.
19 67 AEC Proposed G eneral Design Criteria, G DC 27 2
- 4. U F SAR, Section 3.1.2 Turk ey Point U nit 3 and U nit 4 Rev ision X X X W estinghouse STS B 3.2.4-7 Rev . 5 .0 2
JUSTIFICATION FOR DEVIATIONS ITS 3.2.4 BASES, QUADRANT POWER TILT RATIO (QPTR)
- 1. Changes are made to be consistent with changes made to the Specification.
- 2. Changes are made (additions, deletions, and/or changes) to the Improved Standard Technical Specifications (ISTS) Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.
- 3. ISTS 3.2.4 Bases Required Action A.3 refers to the Required Actions of the referenced Surveillances. There are no Required Actions in the Turkey Point Nuclear Generating Station (PTN) Plant Improved Technical Specifications (ITS) 3.2.1 or ITS 3.2.2 Surveillances. This reference has been corrected to refer to the Required Actions of the applicable Limiting Conditions for Operation (LCOs).
- 4. The Reviewer's Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.
- 5. Typographical/grammatical error corrected.
- 6. The ISTS contains bracketed information and/or values that are generic to Westinghouse vintage plants. The brackets are removed and the proper plant specific information/value is inserted to reflect the current licensing basis.
Turkey Point Unit 3 and Unit 4 Page 1 of 1
Specific No Significant Hazards Considerations (NSHCs)
DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.4, QUADRANT POWER TILT RATIO There are no specific No Significant Hazards Considerations for this Specification.
Turkey Point Unit 3 and Unit 4 Page 1 of 1