Text

North Anna, Units 1 and 2 - License Amendment Request to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev. 1 and NSAL-15-1
	ML15352A108
Person / Time
Site:	North Anna
Issue date:	12/10/2015
From:	Sartain M D; Virginia Electric & Power Co (VEPCO)
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	15-494
	Download: ML15352A108 (57)
	v • d • e

VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261December 10, 201510 CFR 50.90U.S. Nuclear Regulatory Commission Serial No. 15-494Attention:

Document Control Desk NLOS/DEA R0Washington, DC 20555 Docket Nos.: 50-338/339 License Nos.: NPF-4/7VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)

NORTH ANNA POWER STATION UNITS 1 AND 2LICENSE AMENDMENT REQUEST TO ADDRESS THE ISSUES IDENTIFIED INWESTINGHOUSE DOCUMENTS NSAL-09-5.

REV. 1 AND NSAL-1 5-IIn accordance with the provisions of 10 CFR 50.90, Virginia Electric and PowerCompany (Dominion) is submitting a license amendment request to revise the NorthAnna Power Station Units 1 and 2 Technical Specifications (TS). The proposedchanges would revise the TS to address the issues identified in two Westinghouse communication documents.

Specifically, the proposed changes will address the issues identified in:* Westinghouse Nuclear Safety Advisory Letter NSAL-09-5, Rev. 1 (Reference

1) by relocating required operating space reductions (power and AFD) to theCore Operating Limits Report, accompanied by verification for each reloadcycle* Westinghouse Nuclear Safety Advisory Letter NSAL-1 5-1, Rev. 0 (Reference

2) by defining TS surveillance requirements for steady-state and transient FQ(Z) and corresponding actions with which to apply an appropriate penaltyfactor to measured resultsAttachment 1 provides a discussion of the proposed change. The marked-up andproposed TS pages are included in Attachments 2 and 3, respectively.

The marked-up and proposed TS Bases changes are provided for NRC information only inAttachment 4.We have evaluated the proposed amendment and have determined that it does notinvolve a significant hazards consideration as defined in 10 CFR 50.92. The basis for thisdetermination is included in Attachment

1. We have also determined that operation withthe proposed change will not result in any significant increase in the amount of effluents that may be released offsite or any significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed amendment is eligible forcategorical exclusion from an environmental assessment as set forth in10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b),

no environmental impact statement orenvironmental assessment is needed in connection with the approval of the proposed_A4u6)

Serial No: 15-494Docket Nos.: 50-338/339 Page 2 of 3change. The proposed TS change has been reviewed and approved by the Facility SafetyReview Committee.

Dominion requests approval of the proposed amendment by May 31, 2017 to enableimplementation of the changes by the Unit 2 refueling outage in the fall of 2017.Should you have any questions inMs. Diane E. Aitken at (804) 273-2694.

Sincerely, Mark D. SartainVice President

-Nuclear Engineering regard to this submittal, please contactCOMMONWEALTH OF VIRGINIACOUNTY OF HENRICO)))The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today byMark D. Sartain, who is Vice President

-Nuclear Engineering of Virginia Electric and Power Company.

He has affirmedbefore me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that thestatements in the document are true to the best of his knowledge and belief.Acknowledged before me this ..L day of Lers' 2015.M y. ('.nm m ik F vn ir i .<4I 3)1 , "Z o LA rivl3 Notary Public Z) ~bl~Commonwealth of VirginiaReg. # 7629412 1My Commission Expires August 31, 20L2&

References:

1. Westinghouse Nuclear Safety Advisory Letter, NSAL-09-5, Rev. 1, "Relaxed AxialOffset Control EQ Technical Specification Actions,"

September 23, 2009.2. Westinghouse Nuclear Safety Advisory Letter, NSAL-1 5-1, Rev. 0, "Heat Flux HotChannel Factor Technical Specification Surveillance,"

February 6, 2015.Attachments:

1. Discussion of Change2. Marked-up Technical Specifications Pages3. Proposed Technical Specifications Pages4. Marked-up Technical Specifications Bases Pages (for information only)Commitments made in this letter: None Serial No: 15-494Docket Nos.: 50-338/339 Page 3 of 3cc: U.S. Nuclear Regulatory Commission

-Region IIMarquis One Tower245 Peachtree Center Avenue, NE Suite 1200Atlanta, GA 30303-1 257State Health Commissioner Virginia Department of HealthJames Madison Building

-7 th floor109 Governor StreetSuite 730Richmond, VA 23219Dr. V. Sreenivas NRC Project Manager -North AnnaU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 Ms. Karen Cotton-Gross NRC Project ManagerU.S. Nuclear Regulatory Commission One White Flint NorthMail Stop 08 G-9A11555 Rockville PikeRockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 1 of 16ATTACHMENT IDISCUSSION OF CHANGEVirginia Electric and Power Company(Dominion)

North Anna Power Station Units I and 2 Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and N SAL-i15-I, Rev. 0Attachment 1, Page 2 of 16Table of Contents1.0 DESCRIPTION

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32.0 PROPOSED TECHNICAL SPECIFICATIONS CHANGES ............................................

43.0 TECHNICALANALYSIS

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4.0 REGULATORY EVALUATION

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135.0 ENVIRONMENTAL CONSIDERATIONS

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1

66.0 REFERENCES

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16 Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. I and NSAL-15-1, Rev. 0Attachment 1, Page 3 of 161.0 DESCRIPTION In accordance with the provisions of 10 CFR 50.90, Virginia Electric and Power Company(Dominion) is submitting a request to amend the Technical Specifications (TS) for NorthAnna Power Station Units 1 and 2 (NAPS). The changes are intended to address theissues identified in Westinghouse communications NSAL-09-5, Rev. 1 (Reference

1) andNSAL-15-1 (Reference 2).Reference 1 notified Westinghouse customers of an issue associated with the RequiredActions for Condition B of TS 3.2.1B, "Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z)

Methodology),"

in Reference 3 for plants that have implemented the relaxed axial offsetcontrol (RAOC) methodology.

In certain situations where transient FQ, FQw(Z), is not withinits limit, the existing Required Actions may be insufficient to restore FQw(Z) to within thelimit. Revision 1 of Reference 1 provided clarification regarding the applicability of therecommended interim actions to address this issue and how they should be implemented, including potential inclusion in plant specific Technical Specification changes.

Dominion's evaluation of Reference I determined that it was applicable to NAPS, based on thesimilarities between the RAOC and Dominion's Relaxed Power Distribution Control (RPDC)methodologies.

Reference 2 notified Westinghouse customers of an issue associated with Surveillance Requirement (SR) 3.2.1.2 in TS 3.2.1B of Reference

3. For certain trends in measuredFQ(Z) and non-equilibrium factor W(Z), the existing SR may not ensure that the transient FQ,FQw(Z), limit will be met between the performance of the monthly flux map measurements, for those plants that use the W(Z) FQ surveillance methodology.

Dominion's evaluation ofReference 2 determined that it was also applicable to NAPS, based on the similarities between the RAOC and Dominion's Relaxed Power Distribution Control (RPDC)methodologies.

Dominion is proposing to change TS 3.2.1, "Heat Flux Hot Channel Factor (FQ(Z)),"

toenhance the required actions to be taken in the event that transient Fo(Z) surveillance limitsare not met. Changes are also proposed that define separate terms, action steps andsurveillance requirements for steady-state and transient FQ(Z), denoted as FQE(Z) andFQT(Z), respectively.

The use of separate surveillance requirements (SR) in this manner isconsistent with Westinghouse Standard Technical Specifications, NUREG-1431, Rev. 4(Reference 3). The revised surveillance requirements provide guidance for application of,and determining the magnitude of a penalty factor for the measured FQ(Z). The factor will beapplied if the trend in measured values indicates decreasing margin to the applicable limitsince performing the previous surveillance or if the trend in predicted values indicates decreasing margin to the applicable limit prior to the next required surveillance.

The Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 4 of 16changes specify that this factor will be defined in the Core Operating Limits Report (COLR),which allows specific numerical values of the factor to be evaluated for each reload core.The Bases for TS 3.2.1 are being modified to address the proposed changes to TS 3.2.1.The TS Bases changes are provided for information only. Changes to the TS Bases will beincorporated in accordance with the TS Bases Control Program (TS 5.5.13) upon approvalof this amendment request.2.0 PROPOSED TECHNICAL SPECIFICATIONS CHANGESThe proposed TS and SR changes are detailed below. To aid review, deleted text is struckthrough and added text is italicized and bolded. For more extensive

changes, reference ismade to the TS markups in Attachment 2 and TS Bases markups in Attachment 4.2.1 TS 3.2.1 -Heat Flux Hot Channel Factor (FQ(Z))TS 3.2.1 currently reflects use of the Dominion Relaxed Power Distribution Control (RPDC)power distribution control methodology (Reference 4). The proposed changes detailedbelow revise certain specification terminology, including relocation of some equations to theTS Bases, and revision of appropriate TS Required Actions to address the issues inReferences 1 and 2.The proposed changes follow:LCO 3.2.1*LCO 3.2.1 will be revised as follows:FQ(Z), as approximated by ,E{-- FQE(z) and FQT(Z), shall be within the limits specified in the COLR.TS 3.2.1 -CONDITION A. REQUIRED ACTIONS AND COMPLETION TIME* TS 3.2.1 CONDITION A will be revised as follows:-.......NOTE-------....

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

SR3.2.1.2 is not required to be performed if this Condition is entered prior toTHERMAL POWER exceeding 75% RTP after a refueling.

A. F-QM-Z-)

FQE(Z) not within limit.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 5 of 16* Delete TS 3.2.1 REQUIRED ACTION A.1 and renumber remaining REQUIREDACTIONS as REQUIRED ACTION A.1, A.2, A.3, and A.4* New TS 3.2.1 REQUIRED ACTION A.1 reads as follows:Reduce THERMAL POWER > 1% RTP for each 1% FQE(Z) exceeds limit.A.1 COMPLETION TIME15 minutes after each FQM(-Z-)

FQE(Z) determination

New TS 3.2.1 REQUIRED ACTION A.2 reads as follows:Reduce Power Range Neutron Flux-High trip setpoints

> 1% for each 1% .FQM(-Z--

eee-litthat THERMAL POWER is limited below RTP by RequiredAction A. 1.A.2 COMPLETION TIME72 hours after each .FQM(-Z-)

FQE(Z) determination

New TS 3.2.1 REQUIRED ACTION A.3 reads as follows:Reduce Overpower AT trip setpoints

> 1% for each 1 % = Z)-e ....ee-li,;ii thatTHERMAL POWER is limited below RTP by Required Action A. 1.A.3 COMPLETION TIME72 hours after each .FQM(-Z-)

FQE(Z) determination

New TS 3.2.1 ACTION A.4 reads as follows:Perform SR 3.2.1.1 and SR 3.2.1.2A.4 COMPLETION TIMEPrior to increasing THERMAL POWER above the limit of Required Action A.21 Serial No: 15-494Docket Nos.: 50-338/339 LAR- NSAL-09-5, Rev. 1 and NSAL-15-1, Rev. 0Attachment 1, Page 6 of 16TS 3.2.1 -CONDITION B. REQUIRED ACTIONS and COMPLETION TIME* New TS 3.2.1 CONDITION B will be added, to read as follows:ACTIONSCONDITION

] REQUIRED ACTIONj COMPLETION TIMEB.----NOTE-.....

Required Action B.5shall be completed whenever thisCondition is entered.FQT (z) not withinlimit.8.1 Reduce AFD limitsas specified in theCOLR.ANDB.2 Reduce THERMALPOWER as specified inthe COLR.ANDB.3 Reduce PowerRange Neutron Flux-High trip setpoints

> 1%for each 1% thatTHERMAL POWER islimited below RTP byRequired Action 8.2.ANDB.4 Reduce Overpower AT trip setpoints

> 1%for each 1% thatTHERMAL POWER islimited below RTP byRequired Action 8.2.AND8.5 Perform SR 3.2.1.1and SR 3.2.1.2.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after eachFQT (Z) determination 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after eachFQT (Z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after eachFQT (z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after eachFQT (Z) determination Prior to increasing THERMAL POWERand AFD limits abovethe limits of RequiredActions 8.1 and 8.2* Renumber existing TS 3.2.1 CONDITION B, REQUIRED ACTION, as follows:BC. Required Action and associated Completion Time not met.BC.1 Be in MODE 2.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 7 of 162.2 SR 3.2.1.1, SR 3.2.1.2 [new] -Heat Flux Hot Channel Factor (FQ(Z))The changes to SR 3.2.1.1 and the addition of SR 3.2.1.2 conform with the introduction ofsteady-state, FQE(Z), and transient, FQT(Z), in TS 3.2.1. These changes define separatesurveillance requirements for the two representations of FQ(Z).The proposed changes follow:SR 3.2.1.1* The Note before SR 3.2.1 .1 is deleted since it pertains to transient limits.* SR 3.2.1.1 is revised to read as follows:Verify FQE(Z) is within limit.SR 3.2.1.1 [FREQUENCY]

(the 2nd clause):Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by -- 10%RTP, the THERMAL POWER at which FQM(-Z-)

FQE(Z) was last verified Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. I and NSAL-1 5-1, Rev. 0Attachment 1, Page 8 of 16*New SR 3.2.1.2 will be added, to read as follows:S UR VEILLA NCEFREQUENCY SR 3.2.1.2----..............NOTE.........

If measurements indicate that either the[K(Z) Imaximum over zORK(z) ]maximum over zhas increased since the previous evaluation of FQ(Z)or is expected to increase prior to the nextevaluation:

A. Increase FQT(Z) by the appropriate factor, asspecified in the COLR, and verify FQT(Z) isstill within limits orB. Repeat SR 3.2.1.2 once perT7 EFPD untila. Above (A) is met orb. Two successive flux maps indicate that the[~¶21LKzJmaximum over zANDK(Z)].maximum over zOnce after eachrefueling within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions afterTHERMAL POWERexceeds 75% RTPANDOnce within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions after exceeding, by> 10% RTP, theTHERMAL POWER atwhich FQT(Z) was last verifiedANDIn accordance with theSurveillance Frequency Control Programhas not increased.

Verify FQT (Z) is within limit.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 9 of 162.3 TS Bases 3.2.1 -Heat Flux Hot Channel Factor (FQ(Z))Several changes to the Bases will be required which reflect the terminology changes andrelocation of items from the specific TS sections noted in the description above.Summary list of key changes (see markup in Attachment 4):* Revise terminology throughout to reflect use of FQ(Z), FQE(Z) and FQT(Z) as appropriate

Changes to conform with deletion and renumbered Condition A REQUIRED ACTIONSin TS 3.2.1* Insert 4 describes the relation for FQT(Z), including the N(Z) factor* Insert 5 describes actions to reduce core power and AFD limits if FQE(Z) and FQT(Z)cannot be maintained within LCO limits* Insert 6 describes the Condition B REQUIRED ACTIONS added in TS 3.2.1 for FaT(Z)* Insert 7 describes the steady-state peaking factor, FQE(Z) for SR 3.2.1.1* Insert 8 describes the frequency conditions for the transient peaking factor, FQT(Z) forSR 3.2.1.2* Insert 9 describes expressions for both FQE (Z) and FQT(z) that are evaluated todetermine whether to apply the appropriate penalty factor or increase the frequency ofsurveillance Based on Dominion's analytical assessment of internal and external operating experiences (e.g. Westinghouse Communication 06-IC-03, Reference 5), the magnitudes of the lowerand upper core regions excluded from FQ surveillances had been proactively andconservatively reduced (in approximately 2006) from what was and is currently described inthe North Anna Technical Specification Bases. An update to the Technical Specification Bases to expand the FQ axial surveillance regions is being tracked by Dominion's corrective action system.3.0 TECHNICAL ANALYSISThe proposed TS changes identified in Section 2.0 are evaluated for technical adequacy in thefollowing sections.

3.1 TS 3.2.1 -Heat Flux Hot Channel Factor (FQ(Z))The proposed changes involve additions, deletions and revisions to existing TS content thatare associated with LCO 3.2.1. These changes provide resolution of issues documented inWestinghouse notification documents NSAL-09-5, Rev. 1 (Reference

1) and NSAL-15-1 (Reference 2). NAPS is currently operating with compensatory actions which address theissues identified in References 1 and 2. Evaluation of the specific proposed changes isprovided below.

Serial No: 15-494Docket Nos.: 50-338/339 LAR,- NSAL-09-5, Rev. I and NSAL-1 5-1, Rev. 0Attachment 1, Page 10 of 16LCO 3.2.1The existing LCO 3.2.1 specifies that FQ(Z) is approximated by F0M(Z), which is described inthe Bases as the steady-state measured value for FQ(Z). The COLR limit to which FQM(z) iscompared is adjusted by the factor, N(Z), which accounts for the calculated worst casetransient core conditions.

The N(Z) factor is calculated in accordance with the approvedDominion RPDC methodology (Reference 4). The proposed changes specify that Fo(Z) isapproximated by F0E(z) and FQT(Z), denoted as the steady-state and transient quantities, respectively.

Separate surveillance requirements are specified for FQE(Z) and FQT(Z), whichis consistent with the comparable terms F0c(Z) and F0w(Z) in Standard Technical Specifications for Westinghouse plants (Reference 3).A Note is inserted before LCO 3.2.1 Condition A to explain that Action A.4 is alwaysrequired to be performed unless SR 3.2.1.2 is performed prior to exceeding 75% RTP aftera refueling outage. This note is consistent with language proposed for this LCO condition inresponse to an NRC Request for Additional Information during review of WCAP-1 7661-P(Reference 6).Required Action A.1 in existing LCO 3.2.1 is deleted, since the revised Condition A nowapplies to steady-state FQE(Z), for which this action does not apply, per the comparable Reference 3 actions for TS 3.2.IB. The remaining actions for LCO 3.2.1 Condition A areretained, with changes to each action that reflect use of FQE(Z) versus FQM(Z).A new Condition B with corresponding Required Actions is added to address the situation inwhich FQT(Z) is not within its limit. Proposed Required Actions B.1 through B.5 are amodified version of the interim actions identified in NSAL-09-5, Rev. 1 (Reference 1), forthis situation.

These changes are proposed as the resolution for the issues identified inReference 1.Westinghouse's proposal for the long term resolution of NSAL-09-5, Rev. 1 is to seek NRCapproval for the methods described in WCAP-17661-P (Reference 6). WCAP-17661-P isintended to revise the existing RAOC and Constant Axial Offset Control (CAOC) F0Surveillance Technical Specifications to address several outstanding issues, one of whichwas NSAL-09-5.

Dominion has strategically chosen not to adopt WCAP-17661-P and itssubsequent Technical Specification Task Force (TSTF) traveler for North Anna.This alternate approach was determined by Dominion evaluation to most appropriately address the issues in NSAL-09-5, Rev. 1 for NAPS. The Dominion approach has thesedesirable aspects:

1) it addresses directly the issues of NSAL-09-5, Rev. 1; 2) it retains theexisting TS surveillance scheme and structure; and 3) it retains the existing axial controlcalculational methodology (RPDC). By relocating the numerical values to the COLR, Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 11 of 16Dominion's proposed resolution of NSAL-09-5 allows the required RPDC operating space(THERMAL POWER and AFD) reductions to be evaluated and modified on a cycle-specific basis. This proposed resolution is supported by current Dominion RPDC methods.Specifically, the allowable operating space that applies to Required Action B.1 and 8.2 isrelocated to the COLR. A new table, entitled "Required Operating Space Reductions forFQT(Z) Exceeding Its Limits,"

will be added to the COLR to quantify the required THERMALPOWER and AFD limits associated with different amounts of FQT(Z) margin improvement (1%, 2%, etc.). If LCO 3.2.1, Condition B is entered, the operating space as defined in thenew COLR table will ensure that sufficient margin exists. COLR Table 3.2-3 below presentsa sample of the proposed table to be included in the COLR.The values provided in the sample table below are only intended to provide a representative example of typical reload values. The determination and verification of the required FQT(Z)margin improvements and the corresponding required reductions in the THERMAL POWERLimit and AFD Bands will be performed on a reload specific basis in accordance with theapproved methodology of VEP-NE-1-A listed in Technical Specification 5.6.5.b.COLR Table 3.2-3Required Operating Space Reductions for FQT(Z) Exceeding Its LimitsRequired FQT(z) Margin THERMAL POWER Negative AFD Positive AFDImprovement Reduction Band Reduction Band Reduction

(% RTP) (% AFD) (% AFD)< %>3% >2.0% > 2.0%> 1% and<2% >5% > 3.0% > 3.0%> 2% and <3% ___8% __.3.5% >3.5%> 3% _50% N/A N/A3.2 SR 3.2.1.1, SR 3.2.1.2 [new] -Heat Flux Hot Channel Factor (FQ(Z))The proposed changes to SR 3.2.1.1 address surveillance for FQE(Z), and the addition ofnew SR 3.2.1.2 addresses surveillance for FQT(Z). Specifying separate requirements forFQE(Z) and FQT(Z), iS consistent with treatment of the comparable terms F0c(Z) and FQw(Z)in Standard Technical Specifications for Westinghouse plants (Reference 3).The Note preceding SR 3.2.1.1 is deleted since it is not applicable to surveillance for thesteady-state parameter FQE(z). It relates to considerations that apply only to conducting surveillance for the transient FQ(Z) limits.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 12 of 16Insert 3 describes proposed new SR 3.2.1.2 for FQT(Z), including a Note preceding SR3.2.1.2 that describes the actions for the situation in which either FQE(Z) or FQT(Z) haveincreased since the last evaluation of FQ(Z) or are expected to increase prior to the nextevaluation.

Required Action A of the Note involves increasing FQT(Z) by the appropriate factor, as specified in the COLR, if the conditions concerning either FQE(Z) or FQT(Z) aremet. This approach, although different in the details of application from that recommended in Reference 2, has been deemed to be more suitable for use with Dominion methods.

Theproposed SR 3.2.1 .2 has been confirmed by analysis with Dominion methods forrepresentative NAPS reload cores to ensure that FQE(Z) and FQT(Z) will satisfy theirrespective limits and to resolve the issue -of undetected loss of margin identified inReference 2.As applied by Dominion, SR 3.2.1.2 involves looking for increases in steady-state andtransient, measured and predicted FQ(Z) to determine if the penalty factor should beapplied.

The application of the appropriate penalty factor will be required if any of thefollowing conditions are met:1. Increase in measured maximum FoE(Z,) I K(Z) from the previous surveillance,

2. Increase in measured maximum FQT(Z) I K(Z) from the previous surveillance,

3. Increase in predicted maximum FQE(Z) I K(Z) over the next surveillance period, or4. Increase in predicted maximum FQT(Z) I K(Z) over the next surveillance period.Cycle-specific analyses will be performed to determine the appropriate penalty factorrequired to accommodate potential increases in FQ(Z) over the surveillance period. SR3.2.1.2 notes that the 'appropriate factor' will be specified in the COLR. This allows for thedetails of the appropriate penalty factors to be evaluated and modified on a cycle-specific basis. This revised surveillance requirement will ensure an appropriate analytical penaltyfactor is applied during performance of SR 3.2.1.2, which addresses the issues identified inNSAL-15-1 (Reference 2).A new table, entitled "Penalty Factors for Flux Map Analysis,"

will be added to the COLR.Table 3.2-2 below presents a sample of the proposed table to be included in the COLR. Thevalues provided in the sample table below are only intended to provide a representative example of typical reload values. The determination and verification of the appropriate penalty factor will be performed on a reload specific basis in accordance with the approvedmethodology of VEP-NE-1-A listed in Technical Specification 5.6.5.b.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. I and NSAL-1 5-1, Rev. 0Attachment 1, Page 13 of 16COLR Table 3.2-2Penalty Factors for Flux Map AnalysisBurnup Surveillance (MWD/MTU)

Factor0 -999 4.00%1000 -1999 3.50%2000 -2999 2.00%3000 -3999 2.00%4000 -4999 2.00%5000 -6999 2.00%7000 -8999 2.00%9000 -10999 2.00%11000 -12999 2.00%13000 -14999 2.00%15000 -16999 2.00%17000 -18999 2.00%19000 -EOR 2.00%Subsequent to approval of this LAR, Dominion intends to process appropriate conforming

changes, in the form of a modification (denoted VEP-NE-1, Rev. 0.2-A) to the RPDC topicalreport. These changes will reflect the adjustments discussed herein to address the issues inReferences 1 and 2. This modification will be prepared in accordance with Dominion's topical modification

process, as provided for in our reload methods topical report VEP-FRD-42-A (Reference 7).4.0 REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements and Criteria10 CFR 50, Appendix B, General Design Criterion 10, which states:The reactor core and associated

coolant, control, and protection systems shall be designedwith appropriate margin to assure that specified acceptable fuel design limits are notexceeded during any condition of normal operation, including the effects of anticipated operational occurrences.

10 CFR 50.36, Technical Specifications, paragraph (c)(2) states that technical specifications will include limiting conditions for operation.

Paragraph (c)(3) states that technical specifications will include surveillance requirements.

Both of these paragraphs areapplicable to the proposed change.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-15-1, Rev. 0Attachment 1, Page 14 of 16Section (c)(2)(ii)(B) provides that LCOs must be established for each item meeting one ormore criteria.

For the power distribution items affected by the proposed change, thefollowing criterion applies:(B) Criterion

2. A process variable, design feature, or operating restriction that is an initialcondition of a design basis accident or transient analysis that either assumes the failure ofor presents a challenge to the integrity of a fission product barrier.

The association with therelevant design basis accident analysis is described below.10 CFR 50.46, Acceptance Criteria For Emergency Core Cooling Systems For Light-Water Nuclear Power Reactors, establishes acceptable limits for the performance of emergency core cooling systems (ECCS), and requirements for the analytical models used to validatethe performance.

The analyses of ECOS performance use various inputs and assumptions that reflect the conditions and features of a given plant. In accordance with North Anna TS5.6.5.b, Core Operating Limits Report, the ECCS analysis establishes limits for FQ(Z), HeatFlux Hot Channel Factor, which is the subject of the proposed TS changes.The proposed change maintains compliance with these requirements.

4.2 No Significant Hazards Consideration Dominion has evaluated whether a significant hazards consideration is involved with theproposed amendment by addressing the three standards set forth in 10 CFR 50.92,"Issuance of Amendment,"

as discussed below:1. Does the proposed change involve a significant increase in the probability orconsequences of an accident previously evaluated?

Response:

No.The proposed change for resolution of Westinghouse notification documents NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0 is intended to address deficiencies identified within theexisting NAPS Technical Specifications and to return them to their as-designed function.

Operation in accordance with the revised TS ensures that the assumptions for initialconditions of key parameter values in the safety analyses remain valid and does notresult in actions that would increase the probability or consequences of any accidentpreviously evaluated.

Therefore, the proposed amendment does not involve a significant increase in theprobability or the consequences of any accident previously evaluated.

Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 15 of 162. Does the proposed change create the possibility of a new or different kind of accidentfrom any accident previously evaluated?

Response:

No.Operation in accordance with the revised TS and its limits precludes new challenges toSSCs that might introduce a new type of accident.

All design and performance criteriawill continue to be met and no new single failure mechanisms will be created.

Theproposed change for resolution of Westinghouse notification documents NSAL-09-5, Rev. 1 and NSAL-15-1, Rev. 0 does not involve the alteration of plant equipment orintroduce unique operational modes or accident precursors.

It thus does not create thepotential for a different kind of accident.

Therefore, the proposed amendment does not create a new or different kind of accidentfrom any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?Response:

No.Operation in accordance with the revised TS and its limits preserves the marginsassumed in the initial conditions for key parameters assumed in the safety analysis.

Thisensures that all design and performance criteria associated with the safety analysis willcontinue to be met and that the margin of safety is not affected.

Therefore, the proposed amendment does not involve a significant reduction in a marginof safety.Based on the above information, Dominion concludes that the proposed license amendment involves no significant hazards consideration under the criteria set forth in 10 CFR 50.92(c)and, accordingly, a finding of no significant hazards consideration is justified.

4.3 Precedents

The proposed changes to the North Anna Units 1 and 2 TS are fundamentally the same asthose in the following submittal associated with previous application of Dominion methods:1. Letter from Mark D. Sartain (Dominion) to USNRC, "Millstone Power Station Unit 3License Amendment Request to Adopt Dominion Core Design and Safety AnalysisMethods and to Address the Issues Identified in Westinghouse Documents NSAL-09-5, Rev. 1, NSAL-1 5-1 and 06-1C-03,"

May 8, 2015 (ADAMS Accession No. ML1 51 34A244).Precedent 1 included proposed TS changes that address each of the issues identified inReferences 1 and 2 in a comparable manner to those enclosed in this LAR. For both Serial No: 15-494Docket Nos.: 50-338/339 LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Attachment 1, Page 16 of 16Precedent 1 and this LAR, the proposed TS changes are compatible with Dominion reloadcore design methods.5.0 ENVIRONMENTAL CONSIDERATIONS Dominion has reviewed the proposed license amendment for environmental considerations.

The proposed license amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluentthat may be released

offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets theeligibility criterion for categorical exclusion from an environmental assessment as set forthin 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51 .22(b), no environmental impactstatement or environmental assessment need be prepared in connection with the proposedamendment.

6.0 REFERENCES

1. Westinghouse Nuclear Safety Advisory Letter, NSAL-09-5, Rev. 1, "Relaxed AxialOffset Control EQ Technical Specification Actions,"

September 23, 2009.2. Westinghouse Nuclear Safety Advisory Letter, NSAL-15-1, Rev. 0, "Heat Flux HotChannel Factor Technical Specification Surveillance,"

February 3, 2015.3. NUREG-1431, Revision 4, Vol. 1 and 2, "Standard Technical Specifications

-Westinghouse Plants."4. Topical Report, VEP-NE-1, Rev. 0.1-A, "VEPCO Relaxed Power Distribution ControlMethodology and Associated FQ Surveillance Technical Specifications,"

August 2003.5. Westinghouse Notice 06-1C-03, "FQ and Fxy, Surveillance Zone Issue," February 21,2006.6. WCAP-17661-P, Revision 1, "Improved RAOC and CAOC FQ Surveillance Technical Specifications,"

November 2013.7. Topical Report, VEP-FRD-42, Rev. 2.1-A, "Reload Nuclear Design Methodology,"

August 2003.

Serial No. 15-494LAR -NSAL-09-5, Rev. I and NSAL-1 5-1, Rev. 0Docket Nos. 50-338/339 ATTACHMENT 2MARKED-UP TECHNICAL SPECIFICATIONS PAGESVirginia Electric and Power Company(Dominion)

North Anna Power Station Units 1 and 2 FQ(Z)3.2.13.2 POWER DISTRIBUTION LIMITS3.2.1 Heat Flux Hot Channel Factor (FQ(Z)) ,,- FQE(Z)and FQ'(Z)1kLCO 3.2.1FQ(Z), as approximated by , shall be within the limitsspecified in the COLR.APPLICABILITY:

MODE 1.ACTIONSCONDITIONNSRT"1']A. not withinlimit.REQUIRED ACTIONCOMPLETION TIMEA1eADlimits

_> 1% 15 mi er"foreac-M(Z)FQ(Z) exeesliidetermi nat ionReduce THERMAL POWER1% RTP for each 1%ANDA.-2-.2 Reduce Power RangeNeutron Flux-High tripsetpoints 1% foreach 1% MANDA.f-..3 Reduce Overpower ATtrip setpoints 1%for each 1%-F/-,,,-

cxcd limit.ANDA.-2-.4 Perform SR 3.2.1.1land SR 3.2.1.215 minutes aftereach -F~-+Z 4-determi nationIFQE(Z)72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months aftereach -F --~----determi nation72 hours aftereach 4-determination that THERMAL POWERis limited below RTP byRequired Action A.1Prior toincreasing THERMAL POWERabove the limitof RequiredAction A.f-..INorth Anna Units 1 and 2 3211Aedet 3/13.2.1-I FQ(Z)3.2.1ACTIONSCONDITION REQUIRED ACTION COMPLETION TIME---Required Action and -B-.I Be in MODE 2. 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months sassociated Completions SURVEILLANCE REQUIREMENTS

NOTE- ---------During power escalation, THERMAL POWER may be increased until a power levelfor extended operation has been achieved, at which a power distribution map isobtai ned.North Anna Units 1 and 2 3212Aedet 3/13.2.1-2 FQ(Z)3.2.1SURVEILLANCE REQUIREMENTS SURVE IL LANCEFREQUENCY SR 3.2.1.1IFoE(Z)-...NOTE----

--I F(Z) measurements indicatemaximu over z LK-(Z)has increas ,d since the p iueval uation o Za. Increase by he appropriate factor and-verf F(Z) is stillwithin limits;b. Repeat SR .21. ce per 7 EFPDuntil two cesv lux mapsindicatemaxium verz [ K~(Z)j]__as not Veri fy> --(ji swithin limit.Once after eachrefueling prior toTHERMAL POWERexceeding 75% RTPANDOnce within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions after exceeding, by10% RTP, the THERMALPOWER at waslat erifed~ANDIn accordance with theSurveil11ance Frequency Control ProgramNorth Anna Units 1 and 2 3.2.1-3 Aedet 6/4 INSERT "1"-~NOTE---

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

SR 3.2.1.2 isnot required to beperformed if thisCondition is enteredprior to THERMALPOWER exceeding 75%RTP after a refueling.

INSERT "2"ACTIONSCONDITION

[REQUIRED ACTION ]COMPLETION TIMEB.----NOTE----...

Required Action B.5shall be completed whenever thisCondition is entered.FQT(Z) not withinlimit.B.1ANDB.2ANDB.3ANDB.4ANDB.5Reduce AFD limits as specified inthe COLR.Reduce THERMAL POWER asspecified in the COLR.Reduce Power Range NeutronFlux-High trip setpoints

> 1 % foreach 1 % that THERMAL POWERis limited below RTP by RequiredAction B.2.Reduce Overpower AT tripsetpoints

> 1 % for each 1 % thatTHERMAL POWER is limitedbelow RTP by Required ActionB.2.Perform SR 3.2.1.1 and SR3.2.1.2.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after eachFaT(Z) determination 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after eachFaT(Z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after eachFaT(Z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after eachFQT(z) determination Prior to increasing THERMAL POWERand AFD limits abovethe limits of RequiredActions B.1 and B.2 INSERT "3"SURVEILLANCE FREQUENCY SR 3.2.1.2-~~~NOTE-----------

If measurements indicate that either themaximum over z [n()]1ORmaximum over z [ K(z)].has increased since the previous evaluation of FQ(Z)or is expected to increase prior to the nextevaluation:

A. Increase FQT(Z) by the appropriate factor, asspecified in the COLR, and verify FQT(z) is stillwithin limits orB. Repeat SR 3.2.1.2 once per 7 EFPD untila. Above (A) is met orb. Two successive flux maps indicate that themaximum over z [FK(Z)]JANDmaximum over z [nK~)has not increased.

Verify FQT(Z) is within limit.Once after eachrefueling within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions afterTHERMAL POWERexceeds 75% RTPANDOnce within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions after exceeding, by> 10% RTP, theTHERMALPOWER at which FoT(z)was last verifiedANDIn accordance with theSurveillance Frequency Control Program Serial No. 15-494LAR -NSAL-09-5, Rev. 1 and NSAL-15-1 Docket Nos. 50-338/339 ATTACHMENT 3PROPOSED TECHNICAL SPECIFICATIONS PAGESVirginia Electric and Power Company(Dominion)

North Anna Power Station Units 1 and 2 FQ(Z)3.2.13.2 POWER DISTRIBUTION LIMITS3.2.1 Heat Flux Hot Channel Factor (FQ(Z))LCO 3.2.1APPLICABILITY:

FQ(Z) , as approximated by FQE (Z) and FQT (Z), shall be withinthe limits specified in the COLR.MODE 1.ACTIONSCONDITION

] REQUIRED ACTION TCOMPLETION TIMEA.------NOTE---

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

SR 3.2.1.2is not required to beperformed if thisCondition is enteredprior to THERMAL POWERexceeding 75% RTP aftera refueling.

FQE (7) not withinlimit.A.IReduce THERMAL POWER1% RTP for each 1%FQE (Z) exceeds limit.15 minutes aftereach FeE (7)determi nati onANDA.2 Reduce Power RangeNeutron Flux-High trip setpoints 1%for each 1% thatTHERMAL POWER islimited below RTP byRequired Action A.I.ANDA.3 Reduce Overpower ATtrip setpoints 1%for each 1% thatTHERMAL POWER islimited below RTP byRequired Action A.1.ANDA.4 Perform SR 3.2.1.1and SR 3.2.1.2.72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months afteYFQE (Z)determi nati onr each72 hours after eachFQE (Z)determi nati onPrior to increasing THERMAL POWER abovethe limit ofRequired Action A.IINorth Anna Units 1 and 2 3211Aedet 3.2.1-1Amendments FQ(Z)3.2.1ACTIONSCONDITION

]R EQUIRED ACTION COMPLETION TIMEB.------NOTE-

---Required Action B.5shall be completed whenever this Condition is entered.B.IReduce AFD limits asspecified in theCOLR,FQT (Z) not withinlimit.ANDB,2 Reduce THERMAL POWERas specified in theCOLR.ANDB.3 Reduce Power RangeNeutron Flux-High trip setpoints

> 1%for each 1% thatTHERMAL POWER islimited below RTP byRequired Action B.2ANDB,4 Reduce Overpower ATtrip setpoints

> 1%for each 1% thatTHERMAL POWER islimited below RTP byRequired Action B.2.ANDB.5 Perform SR 3.2.1.1and SR 3.2.1.2.4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after eachFQT (7)determi nati on4 hours after eachFQT (Z)determi nati on72 hours after eachFQT (Z)determi nati on72 hours after eachFQT (Z)determi nati onPrior to increasing THERMAL POWER andAFD limits abovethe limits ofRequired ActionsB.I and B.2.C. Required Action and }C.1 Be in MODE 2. 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months sassociated Completion Time not met.,______________

_________

North Anna Units 1 and 2 3212Aedet 3,2.1-2Amendments FQ(Z)3.2.1SURVEILLANCE REQUIREMENTS

-- ------------------ NOTE ----------During power escalation, THERMAL POWER may be increased until a power levelfor extended operation has been achieved, at which a power distribution map isobtained.

SURVEILLANCE REQUIREMENTS

_____________

SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQ (Z) is within limit. Once after eachrefueling prior toTHERMAL POWERexceeding 75% RTPANDOnce within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions after exceeding, by10% RTP, the THERMALPOWER at which FQE (Z)was last verifiedANDIn accordance with theSurveillance Frequency Control ProgramNorth Anna Units 1 and 2 3213Aedet 3.2.1-3Amendments FQ(Z)3.2.1SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

+SR 3.2.1.2-NOTE-If measurements indicate that eitherthemaximum over zORmaximum over z1LK(Z) j1has increased since the previousevaluation of FQ (7) or is expectedto increase prior to the nextevaluation:

A. Increase FQT (7) by theappropriate factor, as specified in the COLR, and verify FQT (7)is still within limits orB. Repeat SR 3.2.1.2 once per 7 EFPDuntil1a. Above (A) is met orb. Two successive flux mapsindicate that themaximum over zANDmaximum over zSFQ(Z)]K(Z) jhas not increased.

(conti nued)North Anna Units 1 and 2 3214Aedet 3.2.1-4Amendments FQ(Z)3.2.1SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.2(conti nued)Verify FQT (Z) is within limit.Once after eachrefueling within12 hours afterachieving equilibrium conditions afterTHERMAL POWER exceeds75% RTPANDOnce within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions after exceeding, by10% RTP, the THERMALPOWER at which FQT (Z)was last verifiedANDIn accordance with theSurveillance Frequency Control ProgramNorth Anna Units 1 and 2 3215Aedet 3.2.1-5Amendments Intentionally Blank Serial No. 15-494LAR -NSAL-09-5, Rev. 1 and NSAL-1 5-1, Rev. 0Docket Nos. 50-338/339 ATTACHMENT 4MARKED-UP AND PROPOSEDTECHNICAL SPECIFICATIONS BASES PAGES(for information only)Virginia Electric and Power Company(Dominion)

North Anna Power Station Units 1 and 2 FQ(Z)B 3.2.1B 3.2 POWER DISTRIBUTION LIMITSB 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))BASESBACKGROUND FQ(Z) is approximated byFQE(Z) and FaT(Z). FQE(Z)is defined as themeasured value of FQ(Z),incorporating manufacturing tolerances and measurement uncertainties.

FaT(Z) isdefined as the FQE(Z)incorporating a non-equilibrium factor thataccounts for possiblepower distribution transients during normaloperation.

The purpose of the limits on the values of FQ(Z) is to limitthe local (i.e., pellet) peak power density.

The value ofFQ(Z) varies along the axial height (Z) of the core.FQ(Z) is defined as the maximum local fuel rod linear powerdensity divided by the average fuel rod linear powerdensity, assuming nominal fuel pellet and fuel roddimensions.

Therefore, FQ(Z) is a measure of the peak fuelpellet power within the reactor core.During power operation, the global power distribution islimited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," andLCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR),"

which aredirectly and continuously measured process variables.

TheseLCOs, along with LCO 3.1.6, "Control Bank Insertion Limits,"maintain the core limits on power distributions on acontinuous basis.FQ(Z) varies with fuel loading patterns, control bankinsertion, fuel burnup, and changes in axial powerdistribution.

FQ(Z) is measured periodically using the incore detectorsystem. These measurements are generally taken with the coreat or near steady state conditions.

Using the measured three dimensional power distributions, itIsteady-state F0(Z),I is possible to derive a measure val1 foFQ)rt\IFQE(Z)I

However, because this value represents a steady statecondition, it does not encompass the variations in the valueof FQ(Z) that are present during nonequilibrium situations, such as load changes.To account for these possible variations, the steady state.........

e\ is" adjusted by an elevation dependent factor-.that accounts for the calculated worst case transient conditions itO derive FaT(Z) Ii Core monitoring and control under nonsteady state conditions are accomplished by operating the core within the limits ofthe appropriate LC~s, including the limits on AFD, QPTR, andcontrol rod insertion.

North Anna Units 1 and 2 B3211Rvso B 3.2.1-1Revision 0

FQ(Z)B 3.2.1BASESAPPLICABLE This LCO precludes core power distributions that violate theSAFETY ANALYSES following fuel design criteria:

a. During a loss of coolant accident (LOCA), the peakcladding temperature during a small break LOCA must notexceed 2200°F, and there must be a high level ofprobability that the peak cladding temperature does notexceed 22000F for the large breaks (Ref. 1);b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95%confidence level (the 95/95 DNB criterion) that the hotfuel rod in the core does not experience a departure fromnucleate boiling (DNB) condition;

c. During an ejected rod accident, the energy deposition tounirradiated fuel is limited to 225 cal/gm and irradiated fuel is limited to 200 cal/gm (Ref. 2); andd. The control rods must be capable of shutting down thereactor with a minimum required SDM with the highestworth control rod stuck fully withdrawn (Ref. 3).Limits on Fo(7) ensure that the value of the initial totalpeaking factor assumed in the accident analyses remainsvalid. Other criteria must also be met (e.g., maximumcladding oxidation, maximum hydrogen generation, coolablegeometry, and long term cooling).

However, the peak claddingtemperature is typically most limiting.

Fo (Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the FQ(Z) limitassumed in safety analyses for other postulated accidents.

Therefore, this LCO provides conservative limits for otherpostulated accidents.

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

(2) (ii).North Anna Units 1 and 2B321-Reion 3B 3.2.1-2Revision 13 FQ(Z)B 3.2.1BASESNE[CO Heat Flux Hot Channel Factor, f-Ft), shall belimited by the following relationships, asu=, dec ....badIforwhere: CFQ is the FQ(Z) limit at RTP provided in the COLR,K(Z) is the normalized F (Z) as a function of coreheight provided in the CObLR,cedependent function thas ra " nonteredI o " included in theFQ(Z) is approximated byFQE(Z) and FQT(Z). Thus, bothFQE(Z) and FQT(Z) must meetthe preceding limits on FQ(Z).P is the fraction of RATED THERMAL POWER definedas=THERMAL POWER--The actual values of CF, K(Z), an ()aegven in the\COLR; however, CFQ is normally approximately

2. (Z) s ar-\ function that looks like the one provided inI FQ(Z) evluaionrequires obtaining an incore flux map inMEI.From the incore flux map results we obtain the aumeasured value of FQ(Z). Then, the measured increased by 1.03 which is a factor that accounts for fuelmanufacturing tolerances and 1.05 which accounts for fluxI NER 4" measurement unetit o banFEZThe FQ(Z) limits define limiting values for core powerpeaking that precludes peak cladding temperatures above2200°F during a small break LOCA and assures with a highlevel of probability that the peak cladding temperature doesnot exceed 2200°F for large breaks (Ref. 1).This LCO requires operation within the bounds assumed in thesafety analyses.

Calculations are performed in the coredesign process to confirm that the core can be controlled in(conti nued)North Anna Units 1 and 2B321-Reion3 B 3.2.1-3Revision 13 FQ(Z)B 3.2.1BASESLCO(conti nued)such a manner during operation that it can stay within theLOCA "Ft'cQ/(

limits..

.= If FQ(Z ......~ i^ ma-inta-.^d

,.,ih-n th..r::::r:r7

III~2r'i~ rcguir~u.

Violating the LCO limits for FQ(Z) produces unacceptable consequences if a design basis event occurs while FQ(Z) isoutside its specified limits.APPLICABILITY The FQ(Z) limits must be maintained in MODE 1 to prevent corepower distributions from exceeding the limits assumed in thesafety analyses.

Applicability in other MODES is notrequired because there is either insufficient stored energyin the fuel or insufficient energy being transferred to thereactor coolant to require a limit on the distribution ofcore power.ACTIONSoccurred, oepain r r texceeded.

The maximumAFD limits initil by Req d Action A.1 maybe affce euntdtriains o MZ)and wouldrequire rdcin ih1 iue fteF-~i. AP--1R~ducing THERMAL POWER by 1% RTP for each 1% by which4r,-fZ-)-exceeds its limit, maintains an acceptable absolutepower density.

The percent the limit can-l1.O}x100 for P > 0.5100 for P 0.5(conti nued)North Anna Units 1 and 2B3.1-Reion 3B 3.2.1-4Revision 13 FQ(Z)B3.2.1BASESACTIONS A.-1. (continued)

QE(ZI- -......->-F~-*)is the measured FQ(Z) multiplied by factors accounting for manufacturing tolerances and measurement uncertainties.

FM(Z) t,,e ,,=ou= ,ahe u, ,(Z). The Completion Time of15 minutes provides an acceptable time to reduce power in anorderly manner and without allowing the unit to remain in anunacceptable condition for an extended period of time. Themaximum allowable power level initially determined byRequired Action A.-t.I may be affected by subsequent determinations would require power reductions within 15 minutegof if necessary to comply with the decr~ased maximum allowable power level.Decreases iricF-(*)would allow increasing the maximumallowable po~ler level and increasing power up to thisrevised limit.Ithat THERMAL POWER is limitedA.--f.2 Ibelow RTP by Required Action A.1A reduction of the Power Range Neutron Flux-High tripsetpoints by > 1% for each 1% by ,which .....d liz _.--im-it, is a conservative action for protection against theconsequences of severe transients with unanalyzed powerdistributions.

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient inthis time period and the preceding prompt reduction inTHERMAL POWER in accordance with Required Action Themaximum allowable Power Range Neutron Flux-High tripsetpoints initially determined by Required Action A.-2-,2 maybe affected by subsequent determinations of-.zF-~-and wouldrequire Power Range Neutron Flux-High trip setpointreductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of ifnecessary to comply with the decr'6ased maximum allowable Power Range Neutron Flux-High trip setpoints.

Decreases in>_-FZ-(-_4 would allow increasing the maximum allowable PowerRange Neutron Flux-High trip setpoints.

A .-4-. 3Reduction in the Overpower AT trip setpoints (value of K4) by1% (in AT span) for each 1% by which exceeds itz<-++w+t, is a conservative action for protection against theconsequences of severe transients with unanalyzed powerdistributions.

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient inthis time period, and the preceding prompt reduction inTHERMAL POWER in accordance with Required Action A.-2..1.

The(conti nued)North Anna Units 1 and 2B3.1-Reion 3B 3.2.1-5 FQ(Z)B 3.2.1BASESACTIONS[FoE(Z)IA.-2-.3 (continued) maximum allowable Overpower AT trip setpoints initially determined by Required Action may be affected bysubsequent determinations o~f~ftand would requireOverpower AT trip setpoint r~ductions within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of thedetermination, if necessary to comply with thedecreased maximum allowable Overpower AT trip setpoints.

Decreases i -.{)would allow increasing the maximumOverpower AT trip setpoints.

A f.A i-tA/-and SR 3.2121Verification thatl.F-,)-has bee rerestored, to within, itslimit, by perforrifng SR 3.2.1.1 prior to increasing THERMALPOWER above the limit imposed by Required Action A."Z1.,ensures that core conditions during operation at higherpower levels are consistent with safety analysesassumptions.

-_--1 I--A. 1 through A.4 and B. 1 through B.5IIf Required Actions A.I, A.2.1, A.2.2, A.2.3, or A.2.1 arenot met within their associated Completion Times, the unitmust be placed in a MODE or condition in which the LCOrequirements are not applicable.

This is done by placing theunit in at least MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .This allowed Completion Time is reasonable based onSURVEILLANCE SR 3.2.1.1 4-modified by a Note. It states that THERMALREQUIREMENTS POWER may be increased until a power level for extendedoperation has been achieved at which a power distribution map can be obtained.

This allowance is modified,

however, byone of the Frequency conditions that requires verification FQZ tha f+-is within its specified limit after a power riseIFQ~z I I of ore than 10% RTP over the THERMAL POWER at which it wasI last verified to be within specified limits. In the absenceI of this Frequency condition, it is possible to increaseI power to RTP and operate for 31 days without verification of44..*. The Frequency condition is not intended to require"verification of these parameters after every 10% increase inpower level above the last verification.

It only requires(continued)

North Anna Units 1 and 2B321-Reion3 B 3.2.1-6Revision 13 FQ(Z)B 3.2.1BASESSURVEILLANCE verification after a power level is achieved for extendedREQUIREMENTS operation that is 10% higher than that power at which FQ was(continued) last measured.

SR 3.2.1.1I INSR~i111I The nuclear design process includes calculations performed to determine that the core can be operated within theFQ(Z) limits. Because flux maps are taken in steady stateconditions, the variations in power distribution resulting from normal operational maneuvers are not present in theflux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers innormal operation.

The maximum peaking factor increase oversteady state values, calculated as a function of coreelevation, Z, is called N(Z).The limit with which-~-~

is compared varies inversely withpower above 50% RTP~and N(Z) and directly with a functioncalled K(Z) provided in the COLR. IINSERT,"8",

If THERMAL POWER has been increased by 10% RTP since thelast determination o0 , another evaluation of thisfactor is required 12hours after achieving equilibrium conditions at this higher power level (to ensure thakc-F~()-

values are being reduced sufficiently with power increase tostay within the LCO limits).The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.Flux map data are taken for multiple core elevations

..A+evaluations are not applicable for the following coreregions, measured in percent of core height:a. Lower core region, from 0 to 15% inclusive; andb. Upper core region, from 85 to 100% inclusive.

North Anna Units 1 and 2B321-Reion4 B 3.2.1-7Revision 46 FQ(Z)B 3.2.1BASESSR -3.2.1. (continued)

SURVE ILLANCEREQUIREMENTS The top and bottom 15% of the core are excluded from theevaluation because of the low probability that these regionswould be more limiting in the safety analyses and because ofthe difficulty of making a precise measurement in theseThis Surveillce has been modified by a Note that mayrequire that mor requent surveillances be performed.

AnFQ()evaluation of the eG 3required to accountIFTZ or any increase t )that may occur and__cause th ~r~limit to be exceeded before the next require(e evaluation.

atwo most recent evaluations show an incriit is required to m e l im ith the last increased by apepropriate factor, or to uate more fr~pm lly, each 7 EFPD. These alternative r rementsFQ(Z) from exceeding its limit without detectliREFERENCES

1. 10 CFR 50.46.2. VEP-NFE-2-A, "VEPCO Evaluation of the Control RodEjection Transient."

3. UFSAR, Section 3.1.22.4. VEP-NE-I-A, "VEPCO Relaxed Power Distribution ControlMethodology and Associated FQ Surveillance Technical Specifications."

North Anna Units 1 and 2B321-Reion3 B 3.2.1-8Revision 13 INSERT "4"FQE(Z) is an excellent approximation for FQ(Z) when the reactor is at the steady-state power at which the incore flux map was taken.The expression for FQT(Z) is:FQT(Z) "- FQE(Z) N(Z)Where:N(Z) is a cycle dependent function that accounts for powerdistribution transients encountered during normal operation.

N(Z) isincluded in the COLR. The FQT(Z) is calculated as described inReference 4.INSERT "5"If FQE(Z) cannot be maintained within the LCO limits, reduction of core power is requiredand if FQT(Z) cannot be maintained within the LCO limits, reduction of the AFD limits isalso required.

INSERT "6"B.1If it is found that the maximum calculated value of FQ(Z) that can occur during normalmaneuvers, FQT(Z) , exceeds its specified limits, there exists a potential for FQE(Z) tobecome excessively high if a normal operational transient occurs. Reducing the AFDLimit by the amount specified in the COLR within the allowed Completion Time of 4hours, restricts the axial flux distribution such that even if a transient

occurred, corepeaking factors are not exceeded.

INSERT "6" (Continued)

B.2If it is found that the maximum calculated value of FQ(Z) that can occur during normalmaneuvers, FQT(Z) , exceeds its specified limits, there exists a potential for FQE(Z) tobecome excessively high if a normal operational transient occurs. Reducing THERMALPOWER by the amount specified in the COLR within the allowed Completion Time of 4hours, restricts the absolute power density such that even if a transient

occurred, corepeaking factors are not exceeded.

The percent that FQT(Z) exceeds the limit can bedetermined from:{maximum over Z ('C;-Q(-Z))!

1 xl00forP>0.5 tmaximum overZ CFQKZ~)'

1} x100 for P<O.5B.3A reduction of the Power Range Neutron Flux-High trip setpoints by > 1 % for each 1 %by which the maximum allowable power is reduced, is a conservative action forprotection against the consequences of severe transients with unanalyzed powerdistributions.

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the smalllikelihood of a severe transient in this time period and the preceding prompt reduction inTHERMAL POWER and AFD limits in accordance with Required Actions B.1 and B.2.B.4Reduction in the Overpower AT trip setpoints (value of K4) by > 1 % for each 1% bywhich the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions.

TheCompletion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severetransient in this time period, and the preceding prompt reduction in THERMAL POWERand AFD limits in accordance with Required Actions B.1 and B.2.

INSERT "6" (Continued)

B.5Verification that FQT(z) has been restored to within its limit, by performing SR 3.2.1.1and SR 3.2.1.2 prior to increasing THERMAL POWER and AFD limits above themaximum allowable power and AFD limits imposed by Required Actions B.1 and B.2ensures that core conditions during operation at higher power levels and futureoperation are consistent with safety analyses assumptions.

C.1INSERT "7"Verification that FQE(Z) is within its specified limits involves increasing FQ(Z) to allow formanufacturing tolerance and measurement uncertainties in order to obtain FQE(z).Specifically, FQE(Z) is the measured value of FQ(Z) obtained from incore flux map resultsmultiplied by manufacturing and measurement uncertainties (1.05 x 1.03 = 1.0815).FQE(Z) is then compared to its specified limits.The limit with which FQE(z) is compared varies inversely with power above 50% RTPand directly with a function called K(Z) provided in the COLR.Performing this Surveillance in MODE 1 prior to exceeding 75% RTP ensures that theFQE(Z) limit is met when RTP is achieved, because peaking factors generally decreaseas power level is increased.

If THERMAL POWER has been increased by > 10% RTP since the last determination ofFQE(Z), another evaluation of this factor is required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions at this higher power level (to ensure that FQE(Z) values are being reducedsufficiently with power increase to stay within the LCO limits).SR 3.2.1.2 INSERT "8"SR 3.2.1.2 requires a Surveillance of FQT(Z) during the initial startup following eachrefueling within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding 75%RTP. THERMAL POWER levels below 75% are typically non-limiting with respect to thelimit for FQT(Z). Also, initial startups following a refueling are slow and well controlled due to startup ramp rate limitations and fuel conditioning requirements.

Furthermore, startup physics testing and flux symmetry measurements, also performed at low power,provide confirmation that the core is operating as expected.

Consequently, the initialstartup following a refueling will not result in non-equilibrium power shapes that couldchallenge the FQT(Z) limit. This Frequency ensures that verification of FaT(Z) isperformed prior to extended operation at high power levels where the maximumpermitted peak LHR could be challenged by non-equilibrium operation.

If a previous Surveillance of FQT(Z) was performed at part power conditions (belowRTP), SR 3.2.1.2 also requires that FoT(Z) be verified at power levels -> 10% RTP abovethe THERMAL POWER of its last verification within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions.

This ensures that FQT(Z) is within its limit using radial peaking factorsmeasured at the higher power level.INSERT "9"If the two most recent FQ(Z) evaluations show that either themaximum over Z [ K()]ORmaximum over Z/ ()Jhas increased or is expected to increase prior to the next evaluation then it is requiredto increase the FQT(Z) by the appropriate factor, as specified in the COLR, and verifyFQT(z) is still within limits or evaluate FQ(Z) every 7 EFPD until SR 3.2.1 .2 is satisfied.

These alternate requirements prevent FQ(Z) from exceeding its limit without detection.

FQ(Z)B 3.2.1B 3.2 POWER DISTRIBUTION LIMITSB 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))BASESBACKGROUND The purpose of the limits on the values of FQ(Z) is to limitthe local (i.e., pellet) peak power density.

The value ofFQ(Z) varies along the axial height (Z) of the core.FQ(Z) is defined as the maximum local fuel rod linear powerdensity divided by the average fuel rod linear powerdensity, assuming nominal fuel pellet and fuel roddimensions.

Therefore, FQ(Z) is a measure of the peak fuelpellet power within the reactor core.FQ(Z) is approximated by FQE (Z) and FQT (Z). FeE (7) isdefined as the measured value of FQ(Z), incorporating manufacturing tolerances and measurement uncertainties.

FQT (Z) i s defined as the FQE (Z) incorporating anon-equilibrium factor that accounts for possible powerdistribution transients during normal operation.

During power operation, the global power distribution islimited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD)," andLCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR),"

which aredirectly and continuously measured process variables.

TheseLCOs, along with LCO 3.1.6, "Control Bank Insertion Limits,"maintain the core limits on power distributions on acontinuous basis.FQ(Z) varies with fuel loading patterns, control bankinsertion, fuel burnup, and changes in axial powerdistribution.

FQ(Z) is measured periodically using the incore detectorsystem. These measurements are generally taken with the coreat or near steady state conditions.

Using the measured three dimensional power distributions, itis possible to derive a measured value for steady stateFQ(Z), FQE (Z). However, because this val ue represents asteady state condition, it does not encompass the variations in the value of FQ(Z) that are present during nonequilibrium situations, such as load changes.(conti nued)North Anna Units 1 and 2B32.-Reionx B 3.2.1-iRevision xx FQ(Z)B 3.2.1BASESBACKGROUND To account for these possible variations, the steady state(continued)

FeE (Z) is adjusted by an elevation dependent factor thataccounts for the calculated worst case transient conditions to derive FQT (Z).Core monitoring and control under nonsteady state conditions are accomplished by operating the core within the limits ofthe appropriate LCOs, including the limits on AFD, QPTR, andcontrol rod insertion.

lIAPPLICABLE SAFETY ANALYSESThis LCO precludes core power distributions that violate thefollowing fuel design criteria:

a. During a loss of coolant accident (LOCA), the peakcladding temperature during a small break LOCA must notexceed 22000F, and there must be a high level ofprobability that the peak cladding temperature does notexceed 2200°F for the large breaks (Ref. 1);b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95%confidence level (the 95/95 DNB criterion) that the hotfuel rod in the core does not experience a departure fromnucleate boiling (DNB) condition;

c. During an ejected rod accident, the energy deposition tounirradiated fuel is limited to 225 cal/gm and irradiated fuel is limited to 200 cal/gm (Ref. 2); andd. The control rods must be capable of shutting down thereactor with a minimum required SDM with the highestworth control rod stuck fully withdrawn (Ref. 3).Limits on F (Z) ensure that the value of the initial totalpeaking factor assumed in the accident analyses remainsvalid. Other criteria must also be met (e.g., maximumcladding oxidation, maximum hydrogen generation, coolablegeometry, and long term cooling).

However, the peak claddingtemperature is typically most limiting.

FQ(Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the FQ(Z) limitassumed in safety analyses for other postulated accidents.

Therefore, this LCO provides conservative limits for otherpostulated accidents.

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

(2) (ii).North Anna Units 1 and 2B3212Reionx B 3.2.1-2 FQ(Z)B 3.2.1BASESLCO The Heat Flux Hot Channel Factor, FQ(Z), shall be limited bythe following relationships:

FQ(Z) < CFQ K(Z) for P > 0.5FQ(Z) < CFQ K(Z) for P 0.5where: CFQ is the FQ(Z) limit at RTP provided in the COLR,K(Z) is the normalized F (Z) as a function of coreheight provided in the COLR andP is the fraction of RATED THERMAL POWER definedasTHERMAL POWERRTPThe actual values of CFQ and K(Z) are given in the COLR;however, CFQ is normally approximately 2 and K(Z) is aIfunction that looks like the one provided inFigure B 3.2.1-1.is approximated by FeE (Z) and FQT (Z). Thus, bothFQ (z) and FQT (Z) must meet the preceding limits on FQ(Z).An FQE (Z) evaluation requires obtaining an incore flux mapin MODE 1. From the incore flux map results we obtain themeasured value of FQ(Z). Then, the measured value isincreased by 1.03 which is a factor that accounts for fuelmanufacturing tolerances and 1.05 which accounts for fluxmap measurement uncertainty to obtain FQE (Z) (Ref. 4).FeE (Z) is an excellent approximation for FQ(Z) when thereactor is at the steady state power at which the i ncore fluxmap was taken.The expression for FQT (Z) is:FQT (Z)= =FQE (Z) N(Z)Where: N(Z) is a cycle dependent function that accountsfor power distribution transients encountered duringnormal operation.

N(Z) is included in the COLR. TheFQT (Z) is calculated as described in Reference 4.(conti nued)North Anna Units 1 and 2B32.-Reionx B3.2.1-3Revision xx FQ(Z)B 3.2.1BASESLCO(conti nued)The FQ(Z) limits define limiting values for core powerpeaking that precludes peak cladding temperatures above2200°F during a small break LOCA and assures with a highlevel of probability that the peak cladding temperature doesnot exceed 2200°F for large breaks (Ref. 1).This LCO requires operation within the bounds assumed in thesafety analyses.

Calculations are performed in the coredesign process to confirm that the core can be controlled insuch a manner during operation that it can stay within theLOCA FQ(Z) limits. If FQE (Z) cannot be maintained within theLCO limits, reduction of core power is required and ifFQT (Z) cannot be maintained within the LCO limits, reduction of the AFD limits is also required.

Violating the LCO limits for FQ(Z) produces unacceptable consequences if a design basis event occurs while FQ(Z) isoutside its specified limits.APPLICABILITY The FQ(Z) limits must be maintained in MODE 1 to prevent corepower distributions from exceeding the limits assumed in thesafety analyses.

Applicability in other MODES is notrequired because there is either insufficient stored energyin the fuel or insufficient energy being transferred to thereactor coolant to require a limit on the distribution ofcore power.ACTIONSA.IRedJucing THERMAL POWER by _> 1%0 RTP for each 1%o byFQ (Z) exceeds its limit, maintaips an acceptable power density.

The percent that FQ (Z) exceeds thebe determined from:{maximum over z C.Q_ Z)J-i.0 xlO0 for P > 0.5{maximum over z x1i00 for P <0.50.whichabsol utelimit can(conti nued)North Anna Units 1 and 2B321-Reionx B 3.2.1-4Revision xx FQ(Z)B 3.2.1BASESACTIONS(conti nued)A.1 (continued)

FQE (Z) is the measured FQ(Z) multiplied by factorsaccounting for manufacturing tolerances and measurement uncertainties.

The Completion Time of 15 minutes provides anacceptable time to reduce power in an orderly manner andwithout allowing the unit to remain in an unacceptable condition for an extended period of time. The maximumallowable power level initially determined by RequiredAction A.1 may be affected by subsequent determinations ofFQE (Z) and would require power reductions within .15 minutesof the FQE (Z) determination, if necessary to comply with thedecreased maximum allowable power level. Decreases in FeE (Z)would allow increasing the maximum allowable power level andincreasing power up to this revised limit.A.2A reduction of the Power Range Neutron Flux-High tripsetpoints by >_ 1% for each 1%o that THERMAL POWER is limitedbelow RTP by Required Action A.I, is a conservative actionfor protection against the consequences of severe transients with unanalyzed power distributions.

The Completion Time of72 hours is sufficient considering the small likelihood of asevere transient in this time period and the preceding prompt reduction in THERMAL POWER in accordance withRequired Action A.1. The maximum allowable Power RangeNeutron Flux-High trip setpoints initially determined byRequired Action A.2 may be affected by subsequent determinations of FQE (Z) and would require Power RangeNeutron Flux-High trip setpoint reductions within 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months sof the FeE (Z) determination, if necessary to comply with thedecreased maximum allowable Power Range Neutron Flux-High trip setpoints.

Decreases in FeE (Z) would allow increasing the maximum allowable Power Range Neutron Flux-High tripsetpoi nts.A.3Reduction i n the Overpower AT trip setpoints (value of K4) by>_ 1% (in AT span) for each 1% that THERMAL POWER is limitedbelow RTP by Required Action A.1, is a conservative action(conti nued)North Anna Units 1 and 2B321-Reionx B 3.2.1-5Revision xx FQ(Z)B 3.2.1BASESACTIONS A.3 (continued)

(contnued) for protection against the consequences of severe transients with unanalyzed power distributions.

The Completion Time of72 hours is sufficient considering the small likelihood of asevere transient in this time period, and the preceding prompt reduction in THERMAL POWER in accordance withRequired Action A.I. The maximum allowable Overpower AT tripsetpoints initially determined by Required Action A.3 may beaffected by subsequent determinations of FQE (Z) and wouldrequire Overpower AT trip setpoint reductions within72 hours of the FQE (Z) determination, if necessary to complywith the decreased maximum allowable Overpower AT tripsetpoints.

Decreases in FQE (Z) would allow increasing themaximum Overpower AT trip setpoints.

A.4Verification that FQE(Z) has been restored to within itslimit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior toincreasing THERMAL POWER above the limit imposed by RequiredAction A.1, ensures.that core conditions during operation athigher power levels are consistent with safety analysesassumptions.

B.1If it is found that the maximum calculated value of FQ(Z)that can occur during normal maneuvers, FQT (Z), exceeds itsspecified limits, there exists a potential for FQE (Z) tobecome excessively high if a normal operational transient occurs. Reducing the AFD Limit by the amount specified in theCOLR within the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ,restricts the axial flux distribution such that even if atransient

occurred, core peaking factors are not exceeded.

B.2If it is found that the maximum calculated value of FQ(Z)that can occur during normal maneuvers, FQT (Z), exceeds itsspecified limits, there exists a potential for FQE (Z) tobecome excessively high if a normal operational transient occurs. Reducing THERMAL POWER by the amount specified inthe COLR within the allowed Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ,(conti nued)North Anna Units 1 and 2B321-Reionx B 3.2.1-6 FQ(Z)B 3.2.1BASESACTIONS B.2 (continued)

(conti nued)restricts the absolute power density such that even if atransient

occurred, core peaking factors are not exceeded.

The percent that FQT (Z) exceeds the limits can be determined from:F r FQIZ)1maximum over Z 1FQK(Z)J-1}

xlO0 for P > 0.5maximum over Z -1xli00 for P 0.50.5B.3A reduction of the Power Range Neutron Flux-High tripsetpoints by >1% for each 1% by which the maximum allowable power is reduced, is a conservative action for protection against the consequences of severe transients withunanalyzed power distributions.

The Completion Time of72 hours is sufficient considering the small likelihood of asevere transient in this time period and the preceding prompt reduction in THERMAL POWER and AFD limits inaccordance with Required Actions B.1 and B.2.B.4Reduction in the Overpower AT trip setpoints (value of K4) by>1% for each 1% by which the maximum allowable power isreduced, is a conservative action for protection against theconsequences of severe transients with unanalyzed powerdistributions.

The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is sufficient considering the small likelihood of a severe transient inthis time period, and preceding prompt reduction.in THERMALPOWER and AFD limits in accordance with Required Actions B.1and B.2.(conti nued)North Anna Units 1 and 2B321-Reionx B 3.2.1-7 FQ(Z)B 3.2.1BASESACTIONS(conti nued)B.5Verification that FQT (Z) has been restored to within itslimit, by performing SR 3.2.1.1 and SR 3.2.1.2 prior toincreasing THERMAL POWER and AFD limits above the maximumallowable power and AFD limits imposed by Required ActionsB.1 and B.2 ensures that core conditions during operation athigher power levels and future operation are consistent withsafety analyses assumptions.

C.'If Required Actions A.I through A.4 and B.I through B.5 arenot met within their associated Completion Times, the unitmust be placed in a MODE or condition in which the LCOrequirements are not applicable.

This is done by placing theunit in at least MODE 2 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .This allowed Completion Time is reasonable based onoperating experience regarding the amount of time it takesto reach MODE 2 from full power operation in an orderlymanner and without challenging unit systems.SURVEILLANCE REQU IREMENTSSR 3.2.1.1 and SR 3.2.1.2 are modified by a Note. It statesthat during power escalation, THERMAL POWER may be increased until a power level for extended operation has been achievedat which a power distribution map can be obtained.

Thisallowance is modified,

however, by one of the Frequency conditions that requires verification that FQ(Z) is withinits specified limit after a power rise of more than 10% RTPover the THERMAL POWER at which it was last verified to bewithin specified limits. In the absence of this Frequency condition, it is possible to increase power to RTP andoperate for 31 days without verification of FQ(Z). TheFrequency condition is not intended to require verification of these parameters after every 10% increase in power levelabove the last verification.

It only requires verification after a power level is achieved for extended operation thatis 10% higher than that power at which FQ was last measured.

(continued)

IINorth Anna Units 1 and 2B321-Reionx B 3.2.1-8Revision xx FQ(Z)B 3.2.1BASESSURVEILLANCE REQU IREMENTS(continued)

SR 3.2.1.1Verification that FQE (Z) is within its specified limitsinvolves increasing FQ(Z) to allow for manufacturing tolerance and uncertainties in order to obtainFQ (Z). Specifically, FQ (Z) is the measured value of FQ(Z)obtained from incore flux map results multiplied bymanufacturing and measurement uncertainties (1.05 x 1.03 = 1.0815).

FQ (Z) is then compared to itsspecified limits.The limit with which FQE (Z) is compared varies inversely with power above 50%0 RTP and directly with a function calledK(Z) provided in the COLR.Performing this in MODE 1 prior to exceeding 75% RTP ensures that the FQ (Z) limit is met when RTP isachieved, because peaking factors generally decrease aspower level is increased.

If THERMAL POWER has beep increased by > 10% RTP since thelast determination of FQ (Z) , another evaluation of thisfactor is required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions at this higher power level (to ensure that FeE (Z)values are being reduced sufficiently with power increase tostay within the LCO limits).SR 3.2.1.2The nuclear design process includes calculations performed to determine that the core can be operated within theFQ(Z) limits. Because flux maps are taken in steady stateconditions, the variations in power distribution resulting from normal operational maneuvers are not present in theflux map data. These variations are, however, conservatively calculated by considering a wide range of unit maneuvers innormal operation.

The maximum peaking factor increase oversteady state values, calculated as a function of coreelevation, Z, is called N(Z).The limit with whichwith power above 50%function called K(Z)FQT (Z) is compared varies inversely RTP and N(Z) and directly with aprovided in the COLR.SR 3.2.1.2 requires a Surveillance of FQT (Z) during theinitial startup following each refueling within 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months safter achieving equilibrium conditions after exceeding 75%(continued)

North Anna Units 1 and 2B321-Reionx B 3.2.1-9Revision xx FQ(Z)B 3.2.1BASESSURVEILLANCE REQUIREMENTS (conti nued)SR 3.2.1.2 (continued)

RTP. THERMAL POWER levels below 75% are typically non-limiting with respect to the limit for FQT (Z) .Also,initial startups following a refueling are slow and wellcontrolled due to startup ramp rate limitations and fuelconditioning requirements.

Furthermore, startup physicstesting and flux symmetry measurements, also performed atlow power, provide confirmation that the core is operating as expected.

Consequently, the initial startup following arefueling will not result in non-equilibrium power shapesthat could challenge the FQT (Z)T limit. This Frequency ensures that verification of FQT (Z) is performed prior toextended operation at high power levels where the maximumpermitted peak LHR could be challenged by non-equilibrium operation.

If a previous Surveillance of FqT (Z) was performed at partpower conditions (below RTP), SR 3.2.1.2 also requires thatFQT (Z) be yenifi ed at power level s_> 10% RTP above theTHERMAL POWER of its last verification within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months afterachieving equilibrium conditions.

This ensures that FQT (7)is within its limit using radial peaking factors measured atthe higher power level.If THERMAL POWER has been increased by 10% RTP since thelast determination of FQT (Z), another evaluation of thisfactor is required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions at this higher power level (to ensure that FQT (Z)values are being reduced sufficiently with power increase tostay within the LCO limits).The Surveillance Frequency is based on operating experience, equipment reliability, and plant risk and is controlled under the Surveillance Frequency Control Program.Flux map data are taken for multiple core elevations.

FQT (Z)evaluations are not applicable for the following axial coreregions, measured in percent of core height:a. Lower core region, from 0 to 15% inclusive; andb. Upper core region, from 85 to 100% inclusive.

(conti nued)North Anna Units 1 and 2 B3211 eiinxB 3.2.1-10Revision xx FQ(z)B 3.2.1BASESSURVEILLANCE REQUIREMENTS (conti nued)SR 3.2.1.2 (continued)

The top and bottom 15% of the core are excluded from theevaluation because of the low probability that these regionswould be more limiting in the safety analyses and because ofthe difficulty of making a precise measurement in theseregions.This Surveillance has been modified by a Note that mayrequire that more frequent surveillances be performed.

Anevaluation of the expressions below are required to accountfor any increase to FqT (Z) that may occur and cause theFQT (Z) limit to be exceeded before the next required FQT (Z)eval uati on.If the two most recent FQ(Z) evaluations show that either themaximum over zORL 1FQ(Z)K(Z)-maximum over zhas increased or is expected to increase prior to the nextevaluation then it is required to increase the FeT (Z) by theappropriate factor, as specified in the COLR, and verify(Z) is still within limits or evaluate FQ(Z) every 7 EFPDuntil SR 3.2.1.2 is satisfied.

These alternate requirements prevent FQ(Z) from exceeding its limit without detection.

REFERENCES

1. 10 CFR 50.46.2. VEP-NFE-2-A, "VEPCO Evaluation of the Control RodEjection Transient."

3. UFSAR, Section 3.1.22.4. VEP-NE-1-A, "VEPCO Relaxed Power Distribution ControlMethodology and Associated FQ Surveillance Technical Specifications."

North Anna Units 1 and 2 B3211 eiinx FQ(Z)B3.2.11.21.11.00.90.80.7._. 0.60.50.40.30.20.10.0DO NO IPRT IN TIS AREADONO OPRT NHSAE(6, 1.0)(12, .925)THIS FIGURE FOR-ILLUSTRATION ONLY. DONOT USE FOR OPERATION FT. 0 1 2 3 4 5 6 7 8 9 10 11 1216.633.3 50.066.783.3100CORE HEIGHT* FOR CORE HEIGHT OF 12 FEETFigure B 3.2.1-1 (page 1 of 1)K(Z)-Normalized FQ(Z) as a Function of Core HeightNorth Anna Units 1 and 2 B3211 eiinxB 3,2.1-12Revision xx VIRGINIA ELECTRIC AND POWER COMPANYRICHMOND, VIRGINIA 23261December 10, 201510 CFR 50.90U.S. Nuclear Regulatory Commission Serial No. 15-494Attention: