point beach nuclear plant, units 1 and 2 - license ...sr 3.2.1.1 verifies via flux mapping that fae...

NEXTera" ENERGY€t ~

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001

RE: Point Beach Nuclear Plant, Units 1 and 2 Docl<et Nos. 50-266 and 50-301 Renewed Facility Operating Licenses DPR-24 and DPR-27

July 30, 2020 NRC 2020-0017

10 CFR 50.90

License Amendment Request 292, Resolve Non-Conservative Transient Heat Flux Hot Channel Factor (FaW(Z)} Requirements

NextEra Energy Point Beach, LLC (NextEra) hereby requests amendments to Renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach), respectively. The proposed license amendments modify the Point Beach Technical Specifications (TS) in order to resolve non-conservative surveillance requirements (SRs) associated with the nuclear transient heat flux hot channel factor, FaW(Z), as reported in Westinghouse Nuclear Safety Advisory Letter (NSAL) 15-01 , Heat Flux Hot Channel Factor Technical Specification Surveillance. Though the NSAL concludes there is no substantial safety hazard pursuant to 10 CFR 21, Point Beach is administratively implementing conservative interim actions consistent with the NSAL recommendations and NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are insufficient to Assure Plant Safety (NU DOCS Accession No. 9812280273). The proposed license amendments resolve the non-conservative SRs by implementing selected improvements in the surveillance formulations and Required Actions for FaW(Z) proposed in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC Fa Surveillance Technical Specifications (ADAMS Accession No. ML 18298A314).

The enclosure to this letter provides NextEra's evaluation of the proposed changes. Attachment 1 to the enclosure provides the Point Beach TS pages marked up to show the proposed changes. Attachment 2 provides the Point Beach TS pages retyped (clean copy) to show the proposed changes. Attachment 3 provides ~he existing Point Beach TS Bases pages marked up to show the proposed changes. Attachment 4 provides the Point Beach Core Operating Limit Report (COLR) revised sections to be consistent with the proposed TS changes. The TS Bases and COLR changes are provided for information only and will be incorporated in accordance with TS 5.5.13, Technical Specifications (TS) Bases Control Program, and TS 5.6.4, Core Operating Limit Report (COLR), upon Implementation of the approved amendments.

NextEra has determined that the proposed license amendments do not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and that there are no significant environmental impacts associated with the change. The Point Beach Onsite Review Group (ORG) has reviewed the enclosed amendment request. In accordance with 10 CFR 50.91(b)(1), a copy of this license amendment request is being forwarded to the designee for the State of Wisconsin.

NextEra requests that the proposed license amendments are processed as a normal license amendment request, with approval within one year and implementation within the following 90 days.

This letter contains no new regulatory commitments.

Should you have any questions regarding this submittal, please contact Mr. Eric Schultz, Licensing Manager, at 920-755-7854.

NextEra Energy Polnl Beach, LLC

6610 Nuclear Road, Two Rivers, WI 54241

Point Beach Nuclear Plant, Units 1 and 2 Docket Nos. 50-266 and 50-301

I declare under penally of perjury that the foregoing is true and correct.

Executed on lhe li day of July 2020.

Sincerely,

M~:/ti; = Site Director NextEra Energy Point Beach, LLC

Enclosure Attachments

cc: USN RC Regional Administrator, Region Ill Project Manager, USN RC, Point Beach Nuclear Plant Resident Inspector, USN RC, Point Beach Nuclear Plant Public Service Commission of Wisconsin

NRC 2020-0017 of 2


Evaluation of the Proposed Changes

Point Beach Units 1 and 2

License Amendment Request to Resolve Non-Conservative Transient Heat Flux Hot Channel Factor (FoW(Z)) Requirements

NRC 2020-0017 Enclosure

Page 1 or 50

1.0 SUMMARY DESCRIPTION .................................................................................................... ,, ...... . 2

2.0 DETAILED DESCRIPTION ........... ... .... ... ................ .. ....... ............ .. .. .................. ........ .. ........ ... ......... 2

2.1 System Design and Operation ... .. ..... .... .... ... .. ... .... ...... .... .. .... .... ................. ..... .. ... ...... .... .... ... 2

2.2 Current Requirements/ Description of the Proposed Change .... ..... .. ........ ..... .. .. ....... ......... 3

2.3 Reason for the Proposed Change .. ....... .. .. .... .. .. ... .... ... ..... ... .. .. ..... ... ...... ... .. ........ .. .... .. ... .. .. .. 4

3.0 TECHNICAL EVALUATION .......... .. ....... .. , .......... .. .... .............. .. .............. , ... ,,, .... , .. ... . , .... , .... ... . , ..... .. 4

4.0 REGULATORY EVALUATION ............................................. ........................................................... 9

4.1 Applicable Regulatory Requirements/Criteda .. ... .. ... ..... ... .. ..... .. .... ... .. .. ...... ... ...... .. .. .. ... .... .. .. 9

4.2 No Significant Hazards Consideration .. .............. ...... .... .. .. ...... ......... .. .. .. ..... : .. .. ... .. .... ....... .. 1 O

4.3 Conclusion .... .... ..... ...... .... ..... .... ........ ...... .. ...... .. .... .. .... ... ...... ... .. ...... .. ..... .... .... ...... .. ..... .. ..... . 11

5.0 ENVIRONMENTAL CONSIDERATION ........ .. ..... .. .. .... ....................... .. ................................. .. ...... 11

6,0 REFERENCES ..... .............................. ............ ........................................................... .... ...... .......... . 11

ATTACHMENTS

1. Technical Specifications pages (markup) 2. Technical Specifications pages (clean copy) 3. Technical Specifications Bases pages (markup) 4. Core Operating Limits Report (changed sections)



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1.0 SUMMARY DESCRIPTION

NextEra Energy Point Beach, LLC (NextEra) hereby requests amendments to Renewed Facility Operating Licenses DPR-24 and DPR-27 for Point Beach Nuclear Plant Units 1 and 2 (Point Beach), respectively. The proposed license amendments modify the Point Beach Technical Specifications (TS) in order to resolve non-conservative surveillance requirements (SRs) associated with the nuclear transient heat flux hot channel factor, FoW(Z), as reported in Westinghouse Nuclear Safety Advisory Letter (NSAL} 15-1, Heal Flux Hot Channel Factor Technical Specification Surveillance (Reference 6.1 ). Though the NSAL concludes there is no substantial safely hazard pursuant to 1 O CFR 21, Point Beach is administratively implementing conservative interim actions consistent with the NSAL recommendations and NRC Administrative Letter 98-10, Dispositioning ofTechnical Specifications that are Insufficient to Assure Plant Safety (Reference 6.2) . The proposed license amendments resolve the non-conservative SRs by implementing selected improvements in the surveillance formulations and Required Actions for FoW(Z) proposed in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC Fo Surveillance Technical Specifications (Reference 6.3).

2.0 DETAILED DESCRIPTION

2.1 System Design and Operation

The nuclear heat flux hot channel factor, Fo(Z), is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions. Fo(Z) is thereby a measure of the peak fuel pellet power within the reactor core. Limits on Fo(Z) ensure that the local peak power density assumed in the accident analyses remains valid . The Fo(Z) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA. Though the peak cladding temperature is typically the most limiting criteria, other criteria on maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long-term cooling must also be met. Calculations are performed in the core design process to confirm that the core can be controlled in such a manner during operation that it can stay within the LOCA Fa(Z) limits. The LOCA analyses provide the limits for Fo(Z), which typically remain conservative for other postulated analyses. Violating the Fo(Z) limits may produce unacceptable consequences if a design basis event occurs. If Fo{Z) cannot be maintained within limit, reduction of the core power is typically required .

The value of Fo(Z) varies along the axial height (Z) of the core and varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in the axial power distribution. Fa(Z) is determined using three-dimensional power distribution measurements (i.e. flux mapping) by means of the incore detector system, but the value represents an equilibrium condition and does not include variations present during non-equilibrium situations such as load following and power ascension. To account for such variations, the equilibrium value of Fa(Z), phrased FoC(Z), is adjusted to determine the transient heat flux hot channel factor, FaW(Z). FoW(Z), is the product of the FaC(Z) and W(Z), a weighting factor specified in the Core Operating Limits Report (COLR) which adjusts for the maximum expected power density increase under transient conditions at each axial location along the core height (Z). FaW(Z) represents the maximum, Fa(Z), calculated to occur In normal operation over the next surveillance interval and includes margin for fuel manufacturing tolerances, flux map measurement uncertainty, and operational transients anticipated over the next surveillance Interval. The Point Beach TS impose limits on both Fac(z) and FaW(Z).



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2.2 Current Requirements/ Proposed Changes

2.2.1 Fo(Z) Required Actions

• TS 3.2.1, Action A, requires for each 1 % that Foc(z) exceeds its limit (1) reducing THERMAL POWER ~1% RTP within 15 minutes after each Foc(z) determination, and (2) reducing the power range neutron flux - high and the overpower lff trip setpoints ~1% within 72 hours after each FoC(Z) determination. Additionally, Action A requires SR 3.2.1.1 and SR 3.2.1.2 performance prior to increasing THERMAL POWER above the Action A limit. Action A includes a Note requiring SR 3.2.1.1 and SR 3.2.1.2 completion whenever Action A ls entered .

• The proposed change revises the Note to exempt SR 3.2.1.2 performance if Action A is entered prior to THERMAL POWER exceeding 70% RTP after a refueling. The proposed change revises the Action A requirement to reduce the Power Range Neutron Flux - High and Overpower liT trip setpoints by ::'..1% for each 1% that FoC(Z) exceeds its limit to instead require trip setpolnt reductions of ~1% for each 1% that THERMAL POWER is limited below RTP by Action A.

• TS 3.2.1, Action B, requires reducing THERMAL POWER ~1 % RTP within 4 hours, and reducing the power range neutron flux - high and overpower t,. T trip setpoints .:::1% within 72 hours for each 1% that FoW(Z) exceeds its limit. Additionally, Action B requires SR 3.2.1.1. and SR 3.2.1.2 performance prior to increasing THERMAL POWER above the Action B limit. Action B includes a Note requiring SR 3.2.1.1 and SR 3.2.1.2 completion whenever Action B is entered.

The proposed change replaces the Action B requirements and preceding Note with an Action 8.1 requirement to implement within 4 hours a new CAOC operating space, if specified in the COLR, that restores FoW(Z) to within limits and perform -SR 3.2.1.1 and SR 3.2.1.2 if control rod motion is required to comply with the new CAOC operating space. As an alternative to Action B.1, the proposed change creates an Action B.2 requirement to limit THERMAL POWER to less than RTP as specified in the COLR within 4 hours, reduce the power range neutron flux - high and overpower 6T trip setpoints by ::'..1% for each 1% that THERMAL POWER is limited below RTP within 72 hours and perform SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the Action 8.2° limit. Action B.2 is preceded by a Note requiring SR 3.2.1.1 and SR 3.2.1.2 performance prior to increasing THERMAL POWER above the limit of Action 8.2.

2.2.2 Fo(Z) Surveillance Requirements (SRs)

• SR 3.2.1.1 and SR 3.2.1.2 are preceded by a Note which states that THERMAL POWER may be Increased during power escalation at the beginning of cycle until an equilibrium power level is achieved, at which time a power distribution map is obtained.

The proposed change deletes the Note preceding SR 3.2.1.1 and SR 3.2.1.2.

• SR 3.2.1.1 requires that foC(Z) is verified within limit (1) prior to exceeding 75% RTP after each refueling, (2) within 12 hours of achieving equilibrium conditions after exceeding by ~10% RTP since the previous FoC(Z) verification, and (3) in accordance with the Surveillance Frequency Control Program (SFCP), currently every 31 Effective Full Power Days (EFPD).



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2.3

The proposed change extends the verification time from 12 hours to 24 hours after achieving equilibrium conditions after exceeding by :::10% RTP since the previous FoC(Z) verification.

• SR 3.2.1.2 requires verification that FoW(Z) is within limit (1) prior to exceeding 75% RTP after each refueling, (2) within 12 hours of achieving equilibrium after exceeding by ~10% RTP since the previous FaW(Z) verification, and (3) in accordance with the SFCP (currently every 31 EFPD). In addition, SR 3.2.1.2 contains a Note applicable whenever the ratio (aka maximum over z) of Fac(Z)/l((Z) has increased since the previous evaluation of FaC(Z) (i.e. per SR 3.2.1.1 ), where l((Z) represents the axial dependence of the total heat flux hot channel factor, Fa. For this condition, the Note requires increasing Fow(z) by the greater of a 2% penalty or by a penalty factor specified in the COLR, and reverifying the increased FoW(Z) is within limit, or performing SR 3.2.1.2 every 7 EFPD until either Faw(z) is met with the application of the penalty or two successive flux maps indicate that the ratio of FaC(Z)/l((Z) has not increased.

' The proposed change modifies th!;! requirement to verify FaW(Z) is within limit prior to exceeding 75% RTP after each refueling to instead verify FoW(Z) is within limit within 24 hours after exceeding 70% RTP after each refueling. The proposed change also extends the verification time from 12 hours to 24 hours after achieving equilibrium conditions after exceeding by ?:10% RTP since the previous FaW(Z) verification. The proposed change additionally deletes the Note related to the penalty factor applicable whenever the maximum over z of Foc(Z)/K(Z) has increased since the previous Fac(z) evaluation.

Reason for the Proposed Change

The proposed license amendments resolve the non-conservative SRs reported in NSAL 15-1 (Reference 6.1) by implementing selected improvements in the surveillance formulations and Required Actions for FaW(Z) proposed in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC Fa Surveillance Technical Specifications (Reference 6.3) .

3.0 TECHNICAL EVALUATION

3.1 Background

Westinghouse NSAL 15-1 (Reference 6.1) reported that one aspect of SR 3.2.1 .2 for the transient heat flux hot channel factor (Fow(z)) determination may not be sufficient to assure that the peaking factor assumed in the licensing basis analysis is maintained under all conditions between flux map measurements conducted in accordance with SR 3.2.1.2. As a result, the total heat flux hot channel factor (aka total core peaking factor, Fa), could potentially exceed that assumed in plant safety analyses without being identified. SR 3.2.1.2 is performed In MODE 1 In accordance with the Surveillance Frequency Control Program (SFCP), currently every 31 effective full power days (EFPD).

NSAL 15-1 applies to facilities employing the constant axial offset control (CAOC) methodology for determining Faw(z) specified in WCAP 10217-P-A (Reference 6.4), such as Point Beach. The methodology applies a pre-calculated, cycle dependent allowance factor, W(Z), to the steady-state heat flux hot channel factor, Fac(z), to determine the transient heat flux hot channel factor, FaW(Z). W(Z) adjusts for the maximum expected power density increases under transient conditions at each axial location along the core. height (Z). W(Z) is specified in the COLR.



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SR 3.2.1.1 verifies via flux mapping that Fae (Z) is within limit in accordance with the SFCP, currently every 31 EFPD, whereas SR 3.2.1.2 verifies FaW(Z) is within limit by applying the W(Z) factors to the FaC(Z) flux map results and then comparing the maximum FaW(Z) to the LCO limit. SR 3.2.1.2 also features a Note which requires a penally factor to be applied to Faw(z) whenever the steady-state Fac(z) has increased since the previous surveillance. Alternatively, the Note requires an increased surveillance frequency of once every 7 EFPD until two successive flux maps indicate FaC(Z) is no longer Increasing. The penalty factor, which is meant to assure FaW(Z), remains conservative between flux map surveillances, assumes that variations in FaW(Z} will follow similarly with variations in Fac(z). NSAL 15-1 reports that the variations may not always follow similarly and that under some plant circumstances, FaW(Z) may actually increase as Fac(z) is decreasing. The NSAL concludes that the penalty factor of SR 3.2.1.2 may not be sufficiently conservative to assure the LCO limit for FaW(Z) is satisfied during periods between flux map surveillances. The NSAL also concludes that the Note does not represent a substantial safety hazard pursuant to 10 CFR 21 as a result of the significant conservatisms present in the methodology, as further described in the· NSAL. Consistent with NRC Administrative Letter 98-10 (Reference 6.2) regarding TS requ irements that do not assure safety, Point Beach has.administratively implemented interim measures, which are more conservative than the recommendations of NSAL 15-1. Specifically, Point Beach procedures direct application of the penalty factor for all FaW(Z) surveillances to cover any potential increases in FoW(Z) between surveillance intervals. Based on the station's operating margin to the Fa limit, conservatively applying the penalty factor for all surveillances would still provide sufficient margin to assure the Fa limit assumed in Point Beach safety analyses is satisfied.

The proposed license amendments resolve the non-conservative SRs by implementing selected improvements In the surveillance formulations and Required Actions for FaW(Z) proposed in WCAP-17661-P-A, Revision 1, (Reference 6.3). Specifically, this amendment request is for the resolution of issues identified in NSAL 15-1 that are applicable to Point Beach. As such, optional improvement changes that provide additional input to the FaW(Z) surveillance, such as the implementation of WCAP featured function, Aa(Z), are not being pursued due to the low likelihood of a FaW(Z) exceedance. The methodologies used in supporting the Fa limit and operating space W(Z) parameters thus remain unchanged. Thereby, it Is not necessary to add WCAP-17661-P-A, Revision 1, to the TS 5.6.4.b listing of analytical methods used to determine the core operating limits.

3.2 Fa(Z) Required Actions

3.2.1 The proposed change revises the Note to Action A by exempting SR 3.2.1.2 performance in accordance with Action A.4 whenever Action A is entered prior to THERMAL POWER exceeding 70% RTP following a refueling. The proposed change Is reasonable since during power ascensions, FaW(Z) determinations are not reliable below 70% RTP. The proposed Note clarifies that only SR 3.2.1.1 performance is required if Action A is entered below 70% RTP whereas SR 3.2.1.1 and SR 3.2.1.2 performance is required otherwise.

The proposed change revises the Action A.2 and Action A.3 requirements to reduce the Power Range Neutron Flux - High and the Overpower{). T trip setpoints by :.::1 % for each 1 % that Fac(z) exceeds its limit to Instead require trip setpoint reductions of~1% for each 1% that THERMAL POWER is limited below RTP. The proposed change provides a conservative reduction of the Power Range Neutron Flux - High and Overpower LiT trip setpoints since they must be reduced by the percentage that THERMAL. POWER is limited below RTP by Action A.1 . Hence, if thermal power is 75% of RTP during the surveillance and Fac(z) exceeds Its limit by 1%, the THERMAL POWER will be limited to S74% and the subject trip setpoints must be reduced ~26%. In contrast, the trip setpoints would presently


NRG 2020-0017 Enclosure

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be reduced by only ;?:1 % since the current Action(s) A.2 and A.3 do not account for surveillances conducted at lower power levels. The proposed change· is reasonable since the magnitude of the trip setpoint reductions is increased as a conservative action for protection against the consequences of transients with unanalyzed power distributions and no changes are proposed to the Completion Times to reduce THERMAL POWER within 15-minutes in accordance with Action A.1 or reduce the trip setpoints within 72-hours in accordance with Actions A.2 and A.3.

The proposed changes are largely consistent with the changes to TS 3.2.1 C, Action A, of NUREG-1431 (Reference 6.5) that were evaluated in Reference 6.3. The proposed change deviates in exempting SR 3.2.1.2 performance after a refueling and prior to THERMAL POWER exceeding 70%, rather than 75% RTP. The proposed 70% RTP threshold is reasonable since it is conservative and consistent with the proposed SR 3.2.1.2 surveillance frequency requirements.

3.2.2 The proposed change deletes the Note to Action B requiring SR 3.2.1.1 and SR 3.2.1.2 completion whenever Action B is entered and replaces it with a new Action imposing SR 3.2.1.1 and SR 3.2.1.2 performance depending on the method of restoring FaW(Z) to within limit. This proposed change is reasonable as described below.

The proposed change replaces the Action 8.1 requirement to reduce THERMAL POWER by :?:1 % RTP for each 1 % that FaW(Z) exceeds its limit with a new Action B.1 .1 requirement to implement within 4 hours a CAOC operating space, if specified in the COLR, that restores FoW(Z) to within limit and a new Action 8.1.2 requirement to perform SR 3.2.1.1 and SR 3.2.1.2 within 72 hours if control rod motion is required to satisfy new Action B.1.1 . The proposed change aligns with proposed changes to the Point Beach COLR (Attachment 4), which provides for options to define more restrictive CAOC operating spaces, if needed, that further limit the range of non-equilibrium power shapes by implementing smaller axial flux deviation (AFD) bands and/or shallower control rod insertion limits. The COLR changes are based on CAOC analysis methodologies that have been approved for use by the NRC staff and are consistent with the COLR recommendations evaluated jn Reference 6.3. New Action B.1.1 and the 4-hour Completion Time are appropriate since a more restrictive CAOC operating space is imposed to assure sufficient FoW(Z) margin. New Action 8.1 .2 and the 72-hour Completion Time are appropriate since control rod adjustments can change the fundamental measured power distribution and warrant SR 3.2.1 .1 and SR 3.2.1.2 performance. The 72-hour Completion Time ensures that the plant has time to restore equilibrium conditions in the event that control rod motions result In transient conditions . The proposed changes are reasonable since the restrictive operating margins imposed in response to FoW(Z) not within limit enhance overall safety.

The proposed change provides an alternative to new Action(s) B.1.1 and B.1.2, by replacing existing Action(s) B.1, B.2, B.3 and B.4 with new Action(s) B.2.1, B.2.2, B.2.3 and B.2.4. New Action B.2.1 limits the THERMAL POWER to less than RTP as specified in the COLR within 4 hours. New Actions B.2.2 and B.2.3 reduce within 72 hours the Power Range Neutron Flux - High and Overpower lff trip setpoints by ;?:1% for each 1% that THERMAL POWER is limited below RTP, respectively. New Action B.4 requires SR 3.2.1 .1 and SR 3.2.1.2 performance prior to increasing THERMAL POWER above the limit required by Action B.2.1 . New Action B.2.1 is preceded by a Note requiring Action B.2.4 performance prior to increasing THERMAL POWER above the Action B.2:1 limit. New Action B.2.1 and its preceding NOTE are appropriate since they reduce THERMAL POWER to



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3.3

a value which aligns with the COLR specified condition for safe operation and assure foC(Z) and foW(Z) are within limit before resuming power operation above the THERMAL POWER reduction imposed by Action B.2.1. Should none of the COLR specified options provide sufficient FoW(Z) margin, the COLR requires THERMAL POWER be reduced to.'.:: 50% RTP, or as specified in cycle-specific · COLR, to assure additional margin to the transient Fa. New Action(s) B.2.2 and B.2.3 are appropriate since they conservatively reduce the Power Range Neutron Flux - High and Overpower lff trip setpoints as a conservative action for protection against the consequences of transients with unanalyzed power distributions. New Action B.2.4 is appropriate since it assures FaC(Z) and Faw(z) are within limit before increasing power above the THERMAL POWER reduction imposed by ACTION B.2.1. The proposed changes are reasonable since they reduce THERMAL POWER in accordance with the COLR in response to FaW(Z) being not within limit.

The proposed changes to Action Bare consistent with the changes to TS 3.2.1C, Action B, of NUREG-1431 (Reference 6.5) that were evaluated in Reference 6.3.

Fo(Z) Surveillance Requirements (SRs)

3.3.1 The proposed change deletes the Note preceding SR 3.2.1.1 and SR 3.2.1.2. The Note states that THERMAL POWER may be increased during power escalation at the beginning of cycle until an equilibrium power level Is achieved, at which time a power distribution map is obtained. The Note is proposed for deletion since, as discussed in Reference 6.3, it was a source of confusion and interpreted differently by different utilities implementing the requirement.

The proposed changes to SR 3.2.1.1 and SR 3.2.1.2 are consistent with the changes to TS 3.2.1C, SRs 3.2.1.1 and 3.2.1.2 of NUREG-1431 (Reference 6.5) that were evaluated in Reference 6.3.

3.3 .2 The proposed change modifies SR 3.2.1.1 by extending the surveillance time from 12 hours to 24 hours after achieving equilibrium conditions after exceeding by ~10% RTP since the previous foC(Z) verification. SR 3.2.1 .1 requires FaC(Z) to be verified within limit (1) prior to exceeding 75% RTP after each refueling, (2) within 12 hours of achieving equilibrium after exceeding by ~10% RTP since the previous foC(Z) verification, and (3) in accordance with the Surveillance Frequency Control Program (SFCP), currently every 31 EFPD. Extending the foC(Z) surveillance time from 12 hours to 24 hours is not a reduction in the surveillance frequency since the condition requiring the surveillance is unchanged. When the unit increases THERMAL POWER by 10% or more since the previous surveillance, SR 3.2.1.1 requires FoC(Z) to be verified within limit after reaching equilibrium conditions. Hence, the proposed change merely extends the time allotted to complete the surveillance. The .proposed change is reasonable given the low likelihood of a limiting core condition occurring since the last FaC(Z) surveillance, the results of which provide reasonable assurance that continued power ascension will not create conditions that challenge safety analysis limits.

The proposed change to SR 3.2.1.1 is consistent with the changes to TS 3.2.1 C, SR 3.2.1 .1 of NUREG-1431 (Reference 6.5) that were evaluated in Reference 6.3.

3.3.3 The proposed change modifies SR 3.2.1.2 by revising the requirement to verify FoW(Z) is within limit prior to exceeding 75% RTP after each refueling to instead require FaW(Z) verification within limit within 24 hours after exceeding 70% RTP after each refueling. The proposed change additionally extends the surveillance



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time from 12 hours to 24 hours after achieving equilibrium conditions after exceeding by ;::10% RTP since the previous FaW(Z) verification. The proposed change additionally deletes the Note applicable whenever the ratio of FaC(Z)/l<(Z) has increased since the previous Fac(z) evaluation, where K(Z) represents the axial dependence of the total heat flux hot channel factor, Fa.

The proposed change to replace the requirement to verify after each refueling that Faw(z) is within limit prior to exceeding 75% RTP with a requirement to verify Faw(z) within limit within 24 hours after exceeding 70% RTP is in recognition that FaW(Z) determinations are not reliable at lower powers levels. Moreover, power levels of _90% RTP are non-limiting for minimum transient FaW(Z) margin. In addition, initial startups do not typically result in non-equilibrium power shapes and core power distribution measurements at these power levels provide ample indication of core performance. The proposed change is reasonable since performing the surveillance within 24 hours after thermal power exceeds 70% RTP assures FaW(Z) is within limit prior to extended, non-equilibrium operation at power levels which could challenge the maximum peak linear heat rate limits.

The proposed surveillance time extension from 12 hours to 24 hours is reasonable since, as described in Section 3.3.2 above, the extension is not a reduction In the surveillance frequency but merely extends the time allotted to complete the surveillance. The condition requiring the surveillance is unchanged and the previous Fac(z) surveillance provides reasonable assurance that continued power ascension will not create conditions that challenge safely analysis limits.

The proposed change deletes the Note for SR 3.2.1.2 that applies whenever the ratio of FaC(Z)/K(Z) has Increased since the previous FaC(Z) evaluation, where K(Z) represents the axial dependence of the total heat flux hot channel factor, Fa. The existing Note requires increasing FaW(Z) by the greater of 2% (or as specified in the COLR) and verifying the increased Faw(z) Is within limit or performing SR 3.2.1.2 every 7 EFPD until either FaW(Z) is met with the penalty or two successive flux maps indicate that the ratio of FaC(Z)/K(Z) has not increased. The proposed change deletes the Note because a penally factor, referred to as R1, is embedded in the surveillance equations proposed in the COLR, consistent with the improved methodology of WCAP-17661-P-A, Revision 1 (Reference 6.3). The proposed COLR ties this burnup-dependent penally factor, R1, to the predicted decrease in the actual transient Fa margin during the period prior to the next SR 3.2.1.2 surveillance rather than the measured Increase in FaC(Z)/K(Z) over the previous surveillance period. Hence, the penalty factor relies solely on the predicted transient Fa margin, thereby resolving the non-conservatism reported in NSAL 15-1 (Reference 6.1 ); namely that variations in FaW(Z) may not similarly follow variations in Fac(z), and In fact, FaW(Z) may increase as Fac(z) is decreasing under some plant circumstances. When the transient Fa margin is predicted to decrease, the proposed COLR specifies an appropriate Ri factor based on the predicted margin trend. When the transient Fa margin is predicted to increase, the R1 factor becomes unity (i.e.1.0) thereby imposing no penalty on the surveillance results. The proposed change is reasonable since it provides an acceptable confirmation that FaW(Z) remains within analyzed limits, including cases where the surveillance indicates trends of reduced margin to FaW(Z) limits.

The proposed changes to SR 3.2.1.2 are largely consistent with the changes to TS 3.2.1 C, SR 3.2.1.2 of NUREG-1431 (Reference 6.5) that were evaluated in Reference 6.3. The proposed change deviates in requiring FaW(Z) to be verified within limit within 24 hours after a refueling and after THERMAL PIOWER exceeds 70%, rather than 75% RTP. The proposed 70% RTP threshold is reasonable since



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it provides increased flexibility for the flux map power level without significantly impacting accuracy.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria

• 10 CFR 60.36(c)(2)(i) states that when a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

• 10 CFR 60.36(c)(3) states that surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

• 10 CFR 50.46 states, in part, that ECCS shall be designed such that an evaluation performed using an acceptable evaluation model demonstrates that acceptance criteria, set forth in 10 CFR 60.46(b), including peak cladding temperature. cladding oxidation, hydrogen generation, maintenance of coolable core geometry, and long-term cooling are met for a variety of hypothetical loss-of-co~lant accidents (LOCAs). including the most severe hypothetical LOCA.

[The Point Beach General Design Criteria (GDCs) are similar in content to the Atomic Industrial Forum (AIF) version of the Proposed 1967 GDCs.]

• Point Beach GDC 6 states that the reactor core with its related controls and protection systems shall be designed to function throughout its design lifetime without exceeding acceptable fuel damage limits which have been stipulated and justified. The core and related auxiliary system designs shall provide this integrity under all expected conditions of normal operation with appropriate margins for uncertainties and for specified transient situations which can be anticipated.

• Point Beach GDC 7 states that the design of the reactor core with its related controls and protection systems shall ensure that power oscillations, the magnitude of which could cause damage in excess of acceptable fuel damage limits, are not possible or can be readily suppressed.

• Point Beach GDC 13 states that means shall be provided for monitoring or otherwise measuring and maintaining control over the fission process throughout core life under all conditions that can reasonable be anticipated to cause variations in reactivity of the core.

• Point Beach GDC 14 states that core protection systems, together with associated equipment, shall be designed to prevent or to suppress conditions that could result in exceeding acceptable fuel damage limits.

• Point Beach GDC 30 states that the reactivity control systems provided shall be capable of making the core subcritical under credible accident conditions with appropriate margins for contingencies and limiting any subsequent return to power such that there will be no undue risk to the health and safety of the public.



Page 10 of 50

4.2

The proposed change complies with the requirements of 10 CFR 50.36(c), 10 CFR 50.46, and Point Beach GDCs 6, 7, 13, 14, and 30. All regulatory requirements will continue to be satisfied as a result of the proposed license amendments.

No Significant Hazards Consideration

The proposed license amendments modify the Point Beach licensing basis to resolve nonconservative surveillance requirements (SRs) associated with the transient heat flux hot channel factor, FoW(Z), as reported in Westinghouse Nuclear Safety Advisory Letter (NSAL) 15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance. The proposed license amendments resolve the non-conservative SRs by implementing selected improvements in the surveillance formulations and Required Actions for FoW(Z) proposed in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC Fo Surveillance Technical Specifications. As required by 10 CFR 50.91 (a), Next Era evaluated the proposed changes using the criteria in 10 CFR 50.92 and determined that the proposed changes do not involve a significant hazards consideration . An analysis of the issue of no significant hazards consideration is presented below:

(1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

The proposed change resolves the non-conservative TS requirements reported in Westinghouse NSAL 15-1 by incorporating selected surveillance formulations and required actions for the transient heat flux hot channel factor, FoW(Z) , proposed in WCAP-17661-P-A, Revision 1. The proposed change enhances predicted trends in FoW(Z) and includes an option for implementing more restrictive operating spaces which will assure the total peak power density remains within analyzed limits. No changes to the reactor protection or engineered safety feature actuation systems' protective features will result from the proposed change. All plant equipment will continue to perform consistent with applicable requirements and safely analysis assumptions. Thereby, the proposed change cannot affect any accident initiators or precursors or alter the design, conditions, or configuration of the facility as currently analyzed.

Therefore, the proposed license amendments would not involve a significant increase in the probability or c·onsequences of an accident previously evaluated.

(2). Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed change resolves non-conservative TS requirements by implementing selected surveillance formulations and required actions for FoW(Z) proposed in WCAP-17661-P-, Revision 1. The proposed change does neither modify plant equipment nor introduce unique operational modes or failure mechanisms. The proposed change does not alter the types or increase the amounts of fission product effluents and no increase in individual or cumulative occupational exposure will result. All design and performance criteria will continue to be met and the nuclear units will continue to be operated within the limits of their design and licensing basis. The proposed change aligns with the applicable regulations and NRC endorsed industry guidance for safe operation.



Page 11 of 50

5.0

Thereby, no new accident scenarios, transient precursors or limiting single failures can result.

Therefore, the proposed license amendments would not create the possibility of a new or different kind of accident from any previously evaluated.

(3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

The proposed change resolves non-conservative TS requirements by implementing selected surveillance formulations and required actions for FaW(Z) proposed in WCAP-17661-P-, Revision 1. No equipment functions, response times or acceptance criteria associated with any accident analyses are affected by the proposed change. No new or altered methods of assessing plant performance are introduced and all accident analysis assumptions remain unaffected. Thereby, no safety limits or limiting safety settings are challenged by the proposed change.

Therefore, the proposed license amendment would not involve a significant reduction in the margin of safety. ·

Based upon the above analysis, NextEra concludes that the proposed amendments do not Involve a significant hazards consideration under the standards set forth in 1 O CFR 50.92(c), and accordingly, a finding of no significant hazards consideration Is justified.

4.3 Conclusion

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

ENVIRONMENTAL CONSIDERATION

The proposed amendment modifies a regulatory requirement with respect lo ~he installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or changes an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordirigly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 1 O CFR 51 .22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 Westinghouse Nuclear Safety Advisory Letter (NSAL) 15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance, February 3, 2015.



Page 12 of 50

6.2 NRC Administrative Letter 98-10, Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety, December 29, 1998 (NUDOCS Accession No. 9812280273) .

6.3 Westinghouse WCAP-17661 -P-A, Revision 1, Improved RAOC and CAOC Fa Surveillance Technical Specifications, February 2019 (ADAMS Accession No. ML 18298A314).

6.4 Westinghouse WCAP-10217-A, Revision 1A, Relaxation of Constant Axial Offset ControlFQ Surveillance Technical Specification, February 1994.

6.5 NUREG-1431 , Standard Technical Specifications - Westinghouse Plants, Revision 4.0, Volume 1, Specifications (ADAMS Accession No. ML 121 00A222)


ATTACHMENT 1

PROPOSED TECHNICAL SPECIFICATION PAGES (MARKUP)

(6 pages follow)


Page 13 of 50

3.2 POWER DISTRIBUTION LIMITS

F0 (Z) 3.2.1'

3.2.1 Heat Flux Hot Channel Factor (F0 (Z))

LCO 3.2.1 F0 (Z), as approximated by F~(Z) and F~{Z), shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS

CONDITION

------------NOTE----------- - A .1 Required Action A.4 shall be completed whenever .this Condition

is_ enter•, ---------------_ AND

A. Fi(Z) not 'th in limit. A.2

prior to Increasing THERMAL POWER above the limit of Required Action A.1. SR 3.2.1.2 is

AND

not required to be A.3 performed if this condition is entered prior to TH ER MAL POWER exceeding 70% RTP after a refueling AND

Point Beach

REQUIRED ACTION COMPLETION TIME

Reduce THERMAL 15 minutes POWER ~ 1 % RTP for after each Fi(z) each 1 % Fi(Z) exceeds determination limit.

Reduce Power Range 72 hours Neutron Flux - High trip after each F~(Z) setpoints ~ 1 % for each determination 1 % F~(Z) exseods ~ that THERMAL POWER is limited

below RATED THERMAL POWER by Required Action A.1

I Reduce Overpower 6. ;./ 72 hours

after each F~(Z) trip setpoints ~ 1 % for each 1 <¾ .-c ,..,, - ,~ deterrn ination

0 Q\~/ - --

fun+t .

(continued)

3.2.1 -1 Unit 1 - Amendment No. M-4 Unit 2 - Amendment No. -2e&

ACTIONS

CONDITION

A. (continued) B.1.1 Implement a CAOC operating space if specified In the COLR that restores FQW(Z) to within limits. (Completion time is 4 hours)

AND 8.1.2 Perform SR 3.2.1.1 and SR 3.2.1.2 if control rod motion is required to comply ' with the new operating space. (Completion time is 72 hours)

--,- - - ~. shall be completed

.L - - - - ~ • 1-,. '. - r" - .•• I,.•, -is eRtered .

8. F~(Z) not within limits . /

OR B. 2 .1 ----------NOTE-----------·--Required Action B.2.4 shall be completed whenever Required Action B.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action B.2.1 --------------------------------------

Limit THERMAL POWER to less than RATED THERMAL POWER as specified in the COLR. (Completion time is 4 hours)

Point Beach

REQUIRED ACTION

A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

~

&4 Reduce THERMAL POWER ~ 1 % RTP for

I each 1 %-4~(Z) exceeds Mm,.

~~ Bt

Reduce Power Range Neutron Flux-High trip

[D setpoints ~ 1 % for each O ltil ./ 11/o F 0 (2} exceeds ......

J.iwts.

~ ~

F0 (Z) 3.2.1

COMPLETION TIME

Prior to increasing THERMAL POWER above the lim it of Required Action A.1

4 hours

72 hours

that THERMAL PO WER ATED by 2.1

Is limited below R THERMAL POWER Required Action 8.

(continued)

3.2.1-2 Unit 1 - Amendment No. -241 Unit 2 - Amendment No. -245

ACTIONS

CONDITION

B. (continued) 3

[]

C. Required Action and C.1 associated Completion Time not met.

Point Beach

REQUIRED ACTION

Reduce the Overpower 6 T trip setpoints ~ 1 % for each 1 % F'i(Z) exceeds limits .

Perform SR 3.2.1.1 and SR 3.2 .1.2.

Be in MODE 2.

F0(Z) 3.2.1

COMPLETION TIME

72 hours

that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1

Prior to increasing THERMAL POWER above the limit of

{ Required Action B . .:h ~ 12.1.1 6 hours

3.2.1-3 Unit 1 - Amendment No. "244 Unit 2 - Amendment No. -245

SURVEILLANCE REQUIREMENTS

F0 (Z) 3.2.1

NOTE • WWUWWM MUM M

During power escalation at the beg+R-H-i-Ag of each cycle , THERMAL POWER may be increas.ed until an equi librium p~-e.vel has been achieved , at-WA-i-Gf:l..-a-powe-i: distribution map is obtained.

SURVEILLANCE

SR 3.2.1.1 Verify Fi(z) is within limit.

I Point Beach 3.2.1-4

FREQUENCY

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

AND 124 I OnrA4" ~~~~~·~fter achieving equilibrium conditions after exceeding, by ;;,; 10% RTP, the THERMAL POWER at which Fi(Z) was last verified

In accordance with the Surveillance Frequency Control Program

(continued)

Unit 1 - Amendment No. -253-Unit 2 -Amendment No.~

F0 (Z) 3.2.1

SURVEILLANCE REQUIREMENTS (continued)

SR 3.2.1.2

Point Beach

SURVEILLANCE

NOTE U-F~(Z) maasmamants indicate that tha

ma•imYm ovo,z [ I has increased sines tha previous evaluation of ~tfl-f-a.. ~~(Z) by the graatar of a factor

of 1.02 or by an appropriate factor specified in the COLR and reverify ~{Z} is within limits ; Gf

b-. Repeat SR 3.2.1 .2 ones par 7 EFPO until aithar a. abova is mat, or two successive flux maps indicate that the

ma•imYm ovor a [

has not incraasad.

Verify F~(Z) is within limit.

I

/' .-----------, within 24 hours after THERMAL POWER exceeds 70% RTP

FREQUENCY

Once after each refueling~ THERMAL POVIJER ~~ 75% RTP_A_

( continued)

3.2.1-5 Unit 1 - Amendment No. z&tUnit 2 - Amendment No. -200-


SURVEILLANCE

SR 3.2.1.2 (continued)

I Point Beach 3.2.1-6

Fq(Z) 3.2.1

FREQUENCY

Once within 42 hours after achieving equilibrium conditions after exceeding, by ~ 10% RTP, the THERMAL POWER at which F~(Z) was last verified.


Unit 1 - Amendment No. 253-Unit 2 - Amendment No. 2e-7


ATTACHMENT 2

PROPOSED TECHNICAL SPECIFICATION PAGES (CLEAN COPY)

(6 pages follow)


Page 20 of 50

3.2 POWER DISTRIBUTION LIMITS

F0(Z) 3.2.1

3.2 .1 Heat Flux Hot Channel Factor (F0 (Z))

LCO 3.2.1 F0 (Z), as approximated by Fcf(Z) and Fow(z), shall be within the limits specified in the COLR.

APPLICABILITY: MODE 1.

ACTIONS

CONDITION

-------- ---- NOTE------------ A .1

Required Action A.4 shall be completed whenever this Condition is entered prior to AND increasing THERMAL POWER above the limit A .2 of Required Action A.1. SR 3.2.1.2 is not required to be performed if this condition is entered prior to THERMAL POWER exceeding 70% RTP after a refueling.

A. Foc(z) not within limit.

Point Beach

AND

A.3

REQUIRED ACTION

Reduce THERMAL POWER 2 1 % RTP for each 1 % F 0c(Z) exceeds limit.

Reduce Power Range Neutron Flux- High trip setpoints 2 1 % for each 1 % that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

Reduce Overpower ~ T trip setpoints 2 1 % for each 1 % that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A .1.

COMPLETION TIME

15 minutes after each Foc(Z) determination

72 hours after each Foc(z) determination

72 hours after each Foc(Z) determination

(continued)

3.2.1-1 Unit 1 - Amendment No. xxx Unit 2 - Amendment No. xxx

ACTIONS

CONDITION

A. (continued) A.4

B.1 .1

B. FaW(Z) not within limits .

B.1.2

OR

8 .2.1

/

8 .2.2

Point Beach

REQUIRED ACTION

. Perform SR 3.2.1.1 and SR 3.2.1.2 .

Implement a CAOC operating space if specified in the COLR that re.stores F0W(Z) to within limits .

AND

Perform SR 3.2.1 .1 and SR 3.2.1.2 if control rod motion is required to comply with the new operating space.

----------NOTE---- ------Required Action 8 .2.4 shall be completed whenever Required Action 8.2.1 is performed prior to increasing THERMAL POWER above the limit of Required Action 8 .2.1. -----------------------------

Limit THERMAL POWER to less than RATED THERMAL POWER as specified in the COLR.

AND

Reduce Power Range Neutron Flux-High trip setpoints ~ 1 % for each 1 % that THERMAL POWER is limited below RATED THERMAL POWER by Requ ired Action 8.2 .1

F0 (Z) 3.2.1

COMPLETION TIME

Prior to increasing THERMAL POWER above the limit of Required Action A.1

4 hours

72 hou rs

4 hours

72 hours

(continued)

3.2.1-2 Unit 1 - Amendment No. xxx Unit 2 - Amendment No. xxx

ACTIONS

CONDITION

B. (continued)

8 .2.3

8.2.4

C. Required Action and C.1 associated Completion Time not met.

Point Beach

REQUIRED ACTION

AND

Reduce the Overpower /J. T trip setpoints ~ 1 % for each 1 % that THERMAL POWER is limited below RA TED THERMAL POWER by Required Action 8 .2.1

AND

Perform SR 3.2.1 .1 and SR 3.2 .1.2.

Be in MODE 2.

Fo(Z) 3.2.1

COMPLETION TIME

72 hours

Prior to increasing THERMAL POWER above the limit of Required Action 8.2 .1.

6 hours

3.2.1 -3 Unit 1 - Amendment No. xxx Unit 2 - Amendment No. xxx


SURVEILLANCE

SR 3.2 .1.1 Verify F0C(Z) is within limit.

Point Beach 3.2.1-4

F0(Z) 3.2.1

FREQUENCY

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

AND

Once within 24 hours after achieving equilibrium conditions after exceeding, by ~ 10% RTP, the THERMAL POWER at which Foc(Z) was last verified

AND


(continued)

Unit 1 - Amendment No. xxx Unit 2 - Amendment No. xxx

SURVEILLANCE REQUIREMENTS -(continued)

SURVEILLANCE

SR 3.2.1.2 Verify Faw(Z) is within limit.

Point Beach 3.2.1-5

F0(Z) 3.2.1

FREQUENCY

Once after each refueling within 24 hours after THERMAL POWER exceeds 70% RTP

AND Once within 24 hours after achieving equilibrium conditions after exceed ing, by ~ 10% RTP, the THERMAL POWER at which Fcf(Z) was last verified.

AND




SURVEILLANCE

Point Beach 3.2.1-6

F0(Z) 3.2.1

FREQUENCY



ATTACHMENT 3


Page 27 of 50

PROPOSED TECHNICAL SPECIFICATION BASES PAGES (MARKUP)

(19 pages follow)

Fa(Z) B 3.2.1

B 3.2 POWER DISTRIBUTION LIMITS

B 3.2.1 Heat Flux Hot Channel Factor (Fa(Z))

BASES

BACl<GROUND

Point Beach

The purpose of the limits on the values of F0 (Z) is to limit the local (i.e ., pellet) peak power density. The value of F0 (Z) varies along the axial height (Z) of the core.

F 0 (Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density, assuming nominal fuel pellet and fuel rod dimensions. Therefore, F0 (Z)is a measure of the peak fuel pellet power within the reactor core.

During power operation, the global power distribution is limited by LCO 3.2.3, "AXIAL FLUX DIFFERENCE (AFD), 11 and LCO 3.2.4, "QUADRANT POWER TILT RATIO (QPTR)," which are directly and continuously measured process variables . These LCOs, along with LCO 3.1.6, "Control Bank Insertion Limits," maintain the core limits on power distributions on a continuous basis .

F 0 (Z) varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution.

F0 (Z) is measured periodically using the incore detector system. These measurements are generally taken with the core at or near equilibrium conditions.

Using the measured three dimensional power distributions, it is possible to derive a measured value for F0 (Z). However, because this value represents an equilibrium condition, it does not include the variations in the value of F0 (Z) which are present during non-equilibrium situations, such as load following or power ascension.

To account for these possible variations, the equilibrium value of F0 (Z) is adjusted as Fwo(Z) by an elevation dependent factor 0/1/(Z)) that accounts for the calculated worst case transient conditions.

Core monitoring and control under non-equilibrium conditions are accomplished by operating the core within the limits of the appropriate LCOs, including the limits on AFD, QPTR, and control rod insertion.

B 3.2.1-1 Unit 1 - Amendment No.--2&1-Unit 2 - Amendment No:--266-

BASES

Fa(Z) B 3.2.1

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

Point Beach

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

b. During a loss of forced reactor coolant flow accident, there must be at least 95% probability at the 95% confidence level (the 95/95 DNB criterion) that the hot fuel rod in the core does not experience a . departure from nucleate boiling (DNB) condition;

c. During an ejected rod accident, the energy deposition to the fuel must not exceed 225 cal/gm for unirradiated fuel and 200 cal/gm for irradiated fuel (Ref. 2); and

d. The control rods must be capable of shutting down the reactor with a minimum required SOM with the highest worth control rod stuck fully withdrawn (Ref. 3).

Limits on F0(Z) ensure that the value of the initial total peaking factor assumed in the accident analyses remains valid. Other criteria must also be met (e.g., maximum cladding oxidation, maximum hydrogen generation, coolable geometry, and long term cooling) . However, the peak cladding temperature is typically most limiting.

F0 (Z) limits assumed in the LOCA analysis are typically limiting relative to (i.e., lower than) the F0(Z) limit assumed in safety analyses for other postulated accidents. Therefore, this LCO provides conservative limits for other postulated accidents.

F0(Z) satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

B 3.2.1-2 Unit 1 11/01/2004 Unit 2 11/01/2004

BASES

LCO

Fo(Z) B 3.2.1

The Heat Flux Hot Channel Factor, F0 (Z), shall be limited by the following relationships ;

where:

Fa(Z):,; CFa K(Z) forP>0.5 p

Fa(Z) :,; CFa K(Z) forP ~ 0.5 0.5

CF0 is the F0 (Z) limit at RTP provided in the COLR,

K(Z) is the normalized F0(Z)~ s ~ lion of core height provided in the COLR, and ~

p = THERMAL POWER RTP

For this facility, the actual values of CF0 and K(Z) are given in the Y COLR; however, Cfa is normally a number on the order of 2.60, and I K(Z) is a function that looks like the one provided in Figure B 3.2.1-1.

For Constant Axial Offset Control operation, F0 (Z) is approximated by f Fe a(Z) and Fw 0 (Z). Thus, both Fe 0 (2) and Fw 0 (2) must meet the preceding limits on F0 (Z).

An Fe 0 (Z) evaluation requires obtaining an incore flux map in MODE 1. From the incore flux map results we obtain the measured value (~(Z)) of F0 {Z). Then,

Fi(Z} = F~(Z) 1.08

where 1.08 is a factor that accounts for fuel manufacturing tolerances and flux map measurement uncertainly.

Fe 0 (Z) is an excellent approximation for F0 (Z) when the reactor is at the steady state power at which the incore flux map was taken.

v-1r-[W- (Z-)]...,....CO:-,-L--R -R-1 -,I !Replace with INSERT 1 ~ The expression for F~(Z} is: F~(Z) = Fi(Z) Wflt - I p

'i'there W(Z) is a oycle dependent function that aooounts f.or powei: distribution transients encountered during normal operation. W(Z) is included in the GOLR. The F0(Z) is calculated at equil ibrium conditions .

Point Beach

The f 0(2) limits define limiting values for core power peaking that precludes peak cladding temperatures above 2200°F during either a large or small break LOCA.

B 3.2.1-3 Unit 1 -Amendment No. ~ Unit 2 - Amendment No. --246

BASES

LCO (continued)

APPLICABILITY

ACTIONS

!INSERT B

Point Beach

Fo{Z) B 3.2.1

This LCO requires operation within the bounds assumed in the safety analyses. Calculations are performed in the core design process to confirm t t the core can be controlled in such a manner during operation hat it can stay within the LOCA F0 (Z) limits. If Fe 0 (2) cannot

· · ·n the LGO limits, Feduotion of the core power is

Violating the LCO limits for F0(Z) produces unacceptable consequences if a design basis event occurs while F0 (Z) is outside its specified limits.

The F0 {Z) limits must be maintained in MODE 1 to prevent core power distributions from exceeding the limits assumed in the safety analyses. Applicability in other MODES is not required because there is either insufficient stored energy in the fuel or insufficient energy being transferred to the reactor coolant to require a limit on the distribution of core power.

Reducing THERMAL POWER by~ 1 % RTP for each 1 % by which Fe 0 (Z) exceeds its limit, maintains an acceptable absolute power density. Fe 0(Z) is FM 0 (Z) multiplied by a factor accounting for manufacturing tolerances and measurement uncertainties. ~ 0 (Z) is the measured value of F0 (Z). The Completion Time of 15 minutes provides an acceptable time to reduce power in an orderly manner and without allowing the plant to remain in an unacceptable condition for an extended period of time. The maximum allowable power level initially determined by Required Action A.1 may be affected by subsequent determinations of Fe O (Z) and would require power reductions within 15 minutes of the Fe 0 (Z) determination if necessary to comply with the decreased maximum allowable power level. Decreases in ~ 0 (Z) would allow increasing the maximum allowable power level and increasing power up to this revised limit.

..----- ----------------, 1-----)~ that THERMAL POWER is limited below RATED

A.2 THERMAL POWER by Required Action A.1

A reduction of the Po Range Neutron Flux - High trip set points by ~ 1 % for each 1 % -by-which F\(Z} e:i<eeeds its limit, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is

B 3.2.1-4 Unit 1 - Amendment No.~ Unit 2 - Amendment No.~

BASES

ACTIONS (continued}

Point Beach

Fo(Z) B 3.2.1

sufficient considering the small likelihood of a severe transient in this time period and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1 . The maximum allowable Power Range Neutron Flux-High trip setpoints initially determined by Required Action A.2 may be affected by subsequent determinations of Y Fe 0 (2} and would require Power Range Neutron Flux-High trip setpoint reductions within 72 hours of the Fe 0 (Z} determination, if necessary to comply with the decreased maximum allowable Power Range Neutron Flux-High trip setpoints. Decreases in ~ 0 (2) would allow increasing the maximum allowable Power Range Neutron Flux-High trip setpoints.

that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1

the Overpower /J. T trip setpoints (value qf l(i} by ~ 1 % for each 1 % e · · , is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is sufficient considering the small likelihood of a severe transient in this time period, and the preceding prompt reduction in THERMAL POWER in accordance with Required Action A.1 . The maximum allowable Overpower /J. T trip setpoints initially determined by Required Action A.3 may be affected by subsequent determinations of~ 0(2} and would require Overpower /J. T trip setpoint reductions within 72 hours of the Fe 0 (2) determination, if necessary to comply with the decreased maximum allowable Overpower /J. T trip setpoints. Decreases in Ft(Z} would allow increasing the maximum Overpower /J. T trip setpoints.

Verification that Fe 0 (2) has been restored to within its limit, by performing SR 3.2.1 .1 and SR 3. 2.1.2 prior to increasing THERMAL POWER above the limit imposed by Required Action A.1, ensures that { core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions .

.....------11 NSE RT C Condition A is modified by a Note that requires equired Action A.4 to be performed whenever the Condition is entere . This ensures that SR 3.2.1 .1 and SR 3.2.1.2 will be performed prior to increasing THERMAL POWER abov he limit of Required Action A.1 even when Condition A is exited prior o performing Required Action A.4. Performance of SR 3.2.1. and SR 3.2.1.2 are necessary to assure Fa(Z} is properly evaluate prior to increasing THERMAL POWER.

(if required)

B 3.2.1-5 Unit 1 - Amendment No. -244-Unit 2 - Amendment No. --24-5-

BASES

Fo(Z) B 3.2.1

ACTIONS (continued) .&-1:'~

If it is found that the maximum calculated value of F0 (Z) that can occur during normal maneuvers, Fw 0 (Z), exceeds its specified limits, there exists a potential for Fe 0 (Z) to become excessively high if a normal operational transient occurs. Reducing the THERMAL PO\IVER by

~ z 1 % RTP for each 1 % by-which rw0 (Z) e:xceeds its limit-withift-the-aH&wed Cmrtpletion Time of 4 hours, mainlaifls an acceptable absolute -power density such that e·1efl if a transient ooourred, oore peaking. facto, s a, e 11ot exceeded.

!INSERT 3 (B.1.2, B.2.1) p ,_th_a_t T_H_E_R_M_A_L-PO_W_E_R_i_s -lim-i-te_d_b_e_lo_w_R_A_T_E__,D

~~ THERMAL POWER by Required Action A.1

Point Beach

A reduction of the P er Range Neutron Flux-High trip setpoints by f" ~ 1 % for each 1 %-ey---whieh the maximum allowable power is reduoed , is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion

,--- -, Time of 72 hours is sufficient considering the small likelihood of a B.2.1 severe transient in this time period and the preceding prompt r ction in ~ HE~ L ~ RJfln accordance with Required Action -84.

~ fil.~ ~ - that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1

Reduction in the Ove ower /J. tnp setpomt va ue o y ~ 1 ° o or each 1 % by which Fa\''(Z) exceeds its limits, is a conservative action for protection against the consequences of severe transients with unanalyzed power distributions. The Completion Time of 72 hours is sufficient considering the small likelihood of a severe transient in this .r time period , and the preceding prompt reduction inJ H~ AL ~ R,1\I in accordance with Required Act ion 8.1. ~ ~

~ M B.2.1

Verificatio that Fw 0 (Z) has been restored to within its limit, by performin SR 3.2.1.1 and SR 3.2.1.2 prior to increasing THERMAL POWER bove the maximum allowable limit imposed by Required Action 8,4- ensures that core conditions during operation at higher power levels and future operation are consistent with safety analyses assumptions.

83.2.1-6 Unit 1 - Amendment No. -2-44 Unit 2 - Amendment No. -245-

BASES

Fo(Z) B 3.2.1

ACTIONS (continued) -GeAattion Bis modified by a Note that requires Required Action B.4 to be performed whenever the Condition is entered. This ensures that SR 3.2. 1. 1 ai 1d SR 3.2.1.2 wil l be performe~fier to increosin§-


Point Beach

TI IERMAL POWER--abeve-tfte--limit of Required Action B.1, even wheAGondition B is e~ited i:,rior to performing Required Action B.4. ~rformance of SR 3.2.1.1 and SR 3.2.1.2 are necessary to ossureF0(Z) is properly evaluated prior to inernosing THERMAL POWER.

c.1 ~A or B, as applicable, I If Required Actions A.1 through A.4 or B.1 throu~ are not met within their associated Completion Times, the plant must be placed in a mode or condition in which the LCO requirements are not applicable . This is done by placing the plant in at least MODE 2 within 6 hours.

This allowed Completion Time is reasonable based on operating experience regarding the amount of time it takes to reach MODE 2 from full power operation in an orderly manner and wiihout challenging plant systems.

3.2.1.1 and SR 3.2.1.2 are modified by a Note. The Note applies du · g the first power ascension after a refueling. It states that THE AL POWER may be increased until an equilibrium power vel has bee chieved at which a power distribution map can be ained. This allowa e is modified, however, by one of the Freque conditions tha quires verification that Fe O (Z) and Fw are within their specified lim after a power rise of more than 1 1/o RTP over the THERMAL POWER which they were last verifie to be within specified limits. Becau Fe 0 (2) and Fw 0 (Z) co a not have previously been measured in this relo core, there is second Frequency condition, applicable only for oad core , hat requires determination of these parameters before exce in 5% RTP. This ensures that some determination of Fe 0 (2) and (Z) are made at a lower power level at which adequate margin· avaI le before going to 100% RTP. Also, this Frequency conditio , together · h the Frequency condition requiring verification of Fe ) and Fw 0 (2) fo wing a power increase of more than 10%, ensur that they are verified a soon as RTP (or any other level for exten d operation) is achieved. In e absence of these Frequency condi · ns, it is possible to increase powe o RTP and operate for 31 ays without verification of Fe a(Z} and F O ). The Frequency ondition is not intended to require verification o hose para me rs after every 10% increase in power level above the st verifi tion. It only requires verification after a power level is ach1 ed fo xtended operation that is 10% higher than that power at which

0 (2) was last measured.

B 3.2.1-7 Unit 1 - Amendment No. -244-Unit 2 - Amendment No. 245-

BASES

SURVEILLANCE REQUIREMENTS ( continued)

SR 3.2.1 .1

Fo(Z) B 3.2.1

Verification that Fi(Z) is within its specified limits involves increasing FM 0(Z) to allow for manufacturing tolerance and measurement uncertainties in order to obtain Fc0 (Z). Specifically, FM0 (Z) is the measured value of F0 (Z) obtained from incore flux map results and Fi(Z) = F~(Z) 1.08 (Ref. 4). Fi(Z) is then compared to its specified limits .

The limit with which Fc0 (Z) is compared varies inversely with power above 50% RTP and directly with a function called K(Z) provided in the

COLR. INSERT D !following a refueling outage St, Performing t ·s Surveillance in MODE 1 prior to exceeding 75% RTP ensures that the Fc0(Z) limit is met when RTP is aohievec:I , beoa1:1se

· •peal(ing feelers generally c:leorease as power level is inoreasec:I.

If THERMAL POWER has been increased by ~ 10% RTP since the fast determination of Fe 0 (Z), another evaluation of this factor is required .-. - .1-. ...... ,----.

~ ,1-2' hours after achieving equilibrium conditions at this higher power 1111 18 or level (to ensure that Fe 0 (Z) values are being reduced sufficient! with most recent power increase to stay within the LCO limits). INSERT E

~ The Surveillance Frequency is controlled under the Surveillance L,

Point Beach

Frequency Control Program. 1

Unit 1 • Amendment No. ~ Unit 2 • Amendment No. -25-7-

BASES


W(Z)COLR

SR 3.2.1.2

The nuclear design process includes calculations performed to determine that the core can be operated within the F0(Z) limits.

Fa(Z) B 3.2.1

Because flux maps are taken in steady state conditions , the variations in power distribution resulting from normal operational maneuvers are not present in the flux map data. These variations are, however, conservatively calculated by considering a wlde range of unit maneuvers in normal operation. The maximum peaking factor increase o t ady state values, calculated as a function of core elevation, Z, is call ~ . Multiplying the measured total peaking factor, P: 0(2), by~ gives the maximum F0 (Z) calculated to occur in normal

~ J>¢ation, F~(Z). ~ -

The limit with which Fw 0 (2) is compared varies inversely with power above 50% RTP and directly with the function K(Z) provided in the COLR.

IW(Z)coLR factors are~ The W(Z) cuP.ie is provided in the COLR for discrete core elevations. Flux map data are typically taken for 30 to 75 core elevations.

These regions of the core are

F~(Z) evaluations are not applicable for all a><ial core regions. ~INSERT GI Depefldiflg 0fl aflalyses, the top and boUom regiofls of the eorc may be

----excluded from the evaluation because of the low probability that these regions would be more limiting in the safety analyses and because of the difficulty of making a precise measurement in these regions (usually the top and bottom 10% or 15%).

ID.ELETE I )

!INSERT 4 I >

Point Beach

equired F0 (Z) e

B 3.2.1-9 Unit 1 02.'19/2002 Unit 2 02/10/2002-

BASES

SURVEILLANCE REQUIREMENTS ( continued)

REFERENCES

[ r:g(Z) ] K(Z)

Fo(Z) B 3.2.1

hen Fw0(Z) must be in a factor of 1.02, or by n appropriate factor speci ef. 5), or F0 (Z) must be valuated more frequently, ese alternative equirements prevent F limit for any significant eriod of time without

erforming th ce in MODE 1 prio · g 75% RTP nsures t nit is met when RTP i ecause

generally decreased as powe sed. ower levels ~ 10% RTP abov erification, 12 hours after achi that F (Z) is within its limit

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

1. 10 CFR 50.46, 1974.

2. FSAR, Section 14.2.6.

3. FSAR, Chapter 3.

4. WCAP - 7308-L-P-A, "Evaluation of Nuclear Hot Channel Factor Uncertainties," June 1988.

5. WCAP-8403 (nonproprietary), Power Distribution Control and Load Following Procedures, Westinghouse Electric Corporation,

~ September 1974.

Point Beach B 3.2.1-10 Unit 1 - Amendment No. ~ Unit 2 - Amendment No. 2-5r

Replace with INSERT 5

1.0

(0.0

0.8

- 0.6

0.4

0.2

0.0

Point Beach

I 1,0)

(6.0, 1.0)

THIS FIGURE IS FOR ILLUSTRATION ONLY

DO NOT USE FOR OPERATION

0 'D ' I) n . CORE HE IGHT (FT)

Figure 8 3.2.1-1 (page 1 of 1)

-(12.0,

10 1

Fo(Z) 8 3.2.1

0.92)

2

K(Z) - Normalized F0 (Z) as a Function of Core Height

B3.2.1-11 Unit 1 - Amendment No. ~ Unit 2 - Amendment No. -z-06-

Note to TS Bases Reviewers:

To assist the reviewer, two sets of TS Bases INSERTS are provided. INSERTS labeled by number (1, 2, etc.) are enumerated the same as WCAP 17661. INSERTS labeled by alphabet (A, 8, etc.,) were created due to lack of room on PBN's Bases pages.

INSERT A

In the unlikely event that measurements indicate that the limit for F0W(Z) could be exceeded during future non-equilibrium operation, a more restrictive Constant Axial Offset Control (CAOC) operating space specified in the Core Operating Limits Report (COLR) may be implemented to restore margin to the FoW(Z) limit. A CAOC operating space is a unique combination of an allowable AFD band and Control Bank Insertion Limits. A more restrictive CAOC operating space would employ a narrower AFD band, shallower Control Bank Insertion Limits, or a combination of the two. W(z) functions for each CAOC operating space are specified in the COLR. If none of the CAOC operating spaces provide adequate margin to the Fow(z) limit, then THERMAL POWER must be limited to less than RATED THERMAL POWER.

INSERT 1

[W(z)]COLR is the cycle and burnup dependent function , specified in the COLR, which accounts for power distribution transients encountered during non-equilibrium normal operation. [W(z)}coLR functions are specified for each analyzed CAOC operating space (i.e., each unique combination of AFD band and Control Bank lnseriion Limits). The [W(z)] coLR functions account for the limiting non-equilibrium axial power shapes postulated to occur during normal operation for each CAOC operating space. Limiting power shapes at both full and reduced power operation are considered in determining the maximum values of [W(z)jCOLR. The [W(z)]CoLR functions also account for the following effects: (1) the increase in radial peaking in rodded core planes due to the presence of control rods during non-equilibrium normal operation, (2) the increase in radial peaking that occurs during part-power operation due to reduced fuel and moderator temperatures, and (3) the increase in radial peaking due to non-equilibrium xenon effects. The [W(z)]coLR functions are normally calculated assuming that the Surveillance is performed at the Target Axial Offset core condi tions. Surveillance specific [W(z)] coLR values may be generated for a given surveillance core condition.

Pis the THERMAL POWER/ RTP. R1 is a cycle and burnup dependent analytical factor specified in the COLR that accounts for potential increases in F0W(Z) between surveillances. R1 values are provided for each CAOC operating space.

INSERT B

If an Fa surveillance is performed at 100% RTP conditions, and both Fac(Z) and Faw(z) exceed their limits, the option to reduce the THERMAL POWER limit in accordance with Required Action 8 .2.1 instead of implementing a new operating space in accordance with Required Action 8.1,1, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours. In the event the evaluated THERMAL POWER reduction in the COLR for Required Action B.2.1 did not result in a further power reduction {for example, if both Condition A and Condition B were entered at less than 100% RTP conditions) , then the THERMAL POWER level established as a result of completing Required Action A.1 will take precedence, and will establish the effective operating power level limit for the unit until both Conditions A and B are exited ..

INSERT C

.. . prior to increasing THERMAL POWER above the limit of Required Action A.1 . The Note also states that SR 3.2.1.2 is not required to be performed if this Condition is entered prior to THERMAL POWER exceeding 70% RTP after a refueling.

INSERT 2

Implementing a more restrictive CAOC operating space, specified in the COLR, within the allowed Completion Time of 4 hours will restrict the AFD such that core peaking factor limits will not be exceeded during non-equilibrium . normal operation. Several CAOC operating spaces, representing successively smaller AFD bands and, optionally, shallower Control Bank Insertion Limits, may be specified in the COLR. The corresponding [W(z)]C0 LR functions for these operating spaces can be used to determine which CAOC operating space would result in acceptable nonequilibrium operation within the Fow(Z) limit.

INSERT 3

B.1 .2

If it is found that the maximum calculated value of Fo(Z) that can occur during normal maneuvers, Faw(Z), exceeds its specified limits, there exists a potential for Fac(z) to become excessively high if a normal operational transient occurs. As discussed above, Required Action 8.1 .1 requires that a new CAOC operating space be implemented to restore Faw(Z) to within its limits. Required Action 8.1.2 requires that SR 3.2.1.1 and SR 3.2.1.2 be performed if control rod motion occurs as a result of implementing the new CAOC operating space in accordance with Required Action 8.1.1. The performance of SR 3.2.1.1 and SR 3.2.1.2 is necessary to assure Fa(Z) is properly evaluated after any rod motion resulting from the implementation of a new CAOC operating space in accordance with Required Action 8. 1.1.

8.2.1

When F0W(Z) exceeds its limit, Required Action 8.2.1 may be implemented instead of Required Action 8.1. Required Action 8 .2.1 limits THERMAL POWER to less than RATED THERMAL POWER by the amount specified in the COLR. This maintains an acceptable absolute power density relative to the maximum power density value assumed in the safety analyses.

If the required Faw(z) margin improvement exceeds the margin improvement available from the pre-analyzed THERMAL POWER and AFD reductions provided in the COLR, then THERMAL POWER must be further reduced to less than or equal to 50% RTP or as specified in the COLR. In this. case, reducing THERMAL POWER to less than or equal to this power level will provide additional margin in the transient Fo by the required change in THERMAL POWER and the increase in the Fo limit. This will ensure that the Fa limit is met during transient operation that may occur at or below this power level.

The Completion Time of 4 hours provides an acceptable time to reduce power in an orderly manner to preclude entering an unacceptable condition during future nonequilibrium operation. The limit on THERMAL POWER initially determined by Required Action 8.2.1 may be affected by subsequent determinations of FaW(Z) and would require power reductions within 4 hours of the Fow{z) determination if necessary to comply with the decreased THERMAL POWER limit. Decreases in Faw(z) would allow increasing the THERMAL POWER limit and increasing THERMAL POWER up to this revised limit.

INSERT 3, can't.

Required Action 8.2.1 is modified by a Note that states Required Action 8.2.4 shall be completed whenever Required Action 8 .2.1 is periormed prior to increasing THERMAL POWER above the limit of Required Action 8.2. 1. Required Action 8.2.4 requires the performance of SR 3.2.1 .1 and SR 3.2.1.2 prior to increasing THERMAL POWER above the limit established by Required Action 8.2.1. The Note ensures that the SRs will be performed even if Condition 8 may be exited prior to performing Required Action 8 .2.4. The performance of SR 3.2.1.1 and SR 3.2.1 .2 is necessary to assure Fa(Z) is properly evaluated prior to increasing THERMAL POWER.

If an Fa surveillance is performed at 100% RTP conditions. and both Fac(Z) and FaW(Z) exceed their limits, the option to reduce the THERMAL POWER limit in accordance with Required Action 8 .2.1 instead of implementing a new operating space in accordance with Required Action 8 .1.1, will result in a further power reduction after Required Action A.1 has been completed. However, this further power reduction would be permitted to occur over the next 4 hours. In the event the evaluated THERMAL POWER reduction in the COLR for Required Action 8.2.1 did not result in a further power reduction (for example, if both Condition A and Condition B were entered at less than 100% RTP conditions), then the THERMAL POWER level established as a result of completing Required Action A.1 will take precedence, and will establish the effective operating power level limit for the unit until both Conditions A and 8 are exited.

INSERT D

... some determination of Fac(z) is made prior to achieving a significant power level where the peak linear heat rate could approach the limits assumed in the safety analyses.

INSERT E

Equilibrium conditions are achieved when the core is sufficiently stable at the intended operating conditions required to perform the Surveillance.

The allowance of up to 24 hours after achieving equilibrium conditions at the increased THERMAL POWER level to complete the next Fac(z) surveillance applies to situations where the Fac(z) has already been measured at least once at a reduced THERMAL POWER level. The observed margin in the previous surveillance will provide assurance that increasing power up to the next plateau will not exceed the Fa limit, and that the core is behaving as designed.

INSERT F

This Frequency condition Is not intended to require verification of these parameters after every 10% increase in RTP above the THERMAL POWER at which the last verification was performed. It only requires verification after a power level is achieved for extended operation that Is 10% higher than the THERMAL POWER at which Fac(z) was last measured.

INSERTG

6. Westinghouse WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC Fa Surveillance Technical Specifications, February 2019

INSERT 4

SR 3.2.1.2 requires a surveillance of Fow(Z) during the initial startup following each refueling within 24 hours after exceeding 70% RTP. THERMAL POWER levels below 70% are typically non-limiting with respect to the limit for Fow(z). Furthermore, startup physics testing and flux symmetry measurements, also performed at low power, provide confirmation that the core is operating as expected. This frequency ensures that verification of F0W(Z) is performed prior to extended operation at power levels where the maximum permitted peak LHR could be challenged and that the first required performance of SR 3.2.1.2 after a refueling is performed at a power level high enough to provide a high level of confidence in the accuracy of the Surveillance result.

Equilibrium conditions are achieved when the core is sufficiently stable at the intended operating conditions required to perform the Surveillance.

If a previous Surveillance of F0W(Z) was performed at pari power conditions, SR 3.2.1.2 also requires that F0W(Z) be verified at power levels~ 10% RTP above the THERMAL POWER of its last verification within 24 hours after achieving equilibrium conditions. This ensures that FoW(Z) is within its limit using radial peaking factors measured at the higher power level. The allowance of up to 24 hours after achieving equilibrium conditions will provide a more accurate measurement of F0W(Z) by allowing sufficient time to achieve equilibrium conditions and obtain the power distribution measurement.

INSERT 5

I 00 NOT OPERATE IN THIS AREA I 1 .

(0, l .0) (6, 1.0) -(12, 0.925)

0.8

e ;::i

,eo.6

i l 0

z 0.4

THIS FIGURE IS FOR ILLUSTRATION ONLY.

00 NOT USE FOR 0.1 OPERATION.

0 0 1 4 6 8 JO n

Helghl (fl)


ATTACHMENT 4

PROPOSED CORE OPERATING LIMITS REPORT CHANGED SECTIONS

(3 pages follow)


Page 47 of 50

2.5 Control Bank Insertion Limits (TS 3.1.6)

The control banks shall b\;3 within the insertion, sequence and overlap limits specified in Figure 3 for the Operating Space of Figure 6.

2.6 Nuclear Heat Flux Hot Channel Factor (Fg(Z)) (TS 3.2.1)

The Heat Flux Hot Channel Factor shall be within the following limits:

Fa (Z) ~ CFa * K(Z) / P for P > 0.5

Fa (Z) $ CFo * K(Z) / 0.5 for P ~ 0.5

Where P is the fraction of Rated Power at which the core is operating .

Fo (Z) is both:

• Steady State Foc(z) = Fa(Z) * 1.08

• Transient

CPq = 2.60

FoW(Z) = FoC(Z) * W(Z) / p *RO)

FaW(Z) = FaC(Z) * W(Z) / 0.5 *RO)

K(Z) is the function in Figure 4

for P > 0.5

for P $ 0.5

W(Z) is the function in Figures 5 and 5A (applicable to Operating Space of Figure 6).

RO) is the function in Figure 7 for the Operating Space o_f Figure 6 and accounts for the potential decrease in transient Fo margin between surveillances.

Figure 8 provides the required limits on THERMAL POWER for the Operating Space defined in Figure 8 in the event that additional margin is required.

2.8 Axial Flux Difference (AFD) (TS 3.2.3)

The AFD target band is specified in Figure 6.

The AFD Acceptable Operation Limits are provided in Figure 6.

Cycle Dnrnnp <MWD/MTU)

<150 367 585 802 1019 1236 1454 1671 1888 2106 2323 2540 2757 2975 3192 3409 3626

3844 <BU< 8407 8624 884 l 9058 9276 9493 9710 9928 10145 10362 10579 10797 11014 11231 11449 11666 11883 12100 12318

Figure 7

R(j) Margin Decrease Factors

Example

RO) Cycle Bnrnnp <MWD/MTU

1.046 12535 1.050 12752 1.052 12969 1.051 13187 1.049 13404 1.046 13621 1.041 13839 1.036 14056 1.030 14273 1.025 14490 1.019 14708 1.015 14925 1.011 151 42 1.008 15360 1.005 15577 1.003 15794 1.001 16011 1.000 16229 1.001 16446 1.002 16663 1.003 16880 1.004 17098 1.004 17315 1.005 17532 1.005 17750 1.006 17967 1.006 18184 1.007 18401 1.007 18619 1.007 18836 1.007 19053 1.007 19271 1.007 19,(88 1.008 19705 1.008 19922 1.008 BU:?::20140

Values may be interpolated to the surveillance cycle bumup.

RU)

1.007 1.007 1.007 1.007 1.007 1.006 ·1.006 1.005 1.006 1.006 1.007 1.008 1.009 1.010 1.010 1.011 1.011 I.Oil 1.011 1.010 1.010 1.009 1.008 1.007 1.006 1.006 1.006 1.005 1.005 1.004 1.003 1.003 1.002 1.001 1.001 1.000

CAOC Operating Space

Figure 6

Figure 8

Required THERMAL POWER Limits

Example

Required FQ W(z) Required THERMAL

Margin Improvement POWER Limit (¾RTP)

{%)

:5 1 :5 99

> 1.0 ands 3.0 :5 97

> 3.0 < 50

point beach nuclear plant, units 1 and 2 - license ...sr 3.2.1.1 verifies via flux mapping that fae...

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