Text

Non-Voluntary License Amendment Request to Modify Watts Bar Nuclear Plant Units 1 and 2 Technical Specifications 3.2.1, Fq(Z), to Implement Methodology from WCAP-17661, Revision 1, Improved RAOC and CAOC Fq Surveillance Technical Specificat
	ML20062F243
Person / Time
Site:	Watts Bar
Issue date:	03/02/2020
From:	Polickoski J; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CNL-19-115, WBN-TS-19-08
	Download: ML20062F243 (102)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-19-115 March 2, 2020 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391

Subject:

Non-Voluntary License Amendment Request to Modify Watts Bar Nuclear Plant Units 1 and 2 Technical Specifications 3.2.1, FQ(Z), to Implement Methodology from WCAP-17661, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, (WBN-TS-19-08)

References:

1.

NRC Letter to PWROG, Verification Letter of the Approval Version of the Pressurized Water Reactor Owners Group Topical Report WCAP-17661, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, dated August 23, 2019 (ML19225D179)

2.

WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, dated February 2019 (ML19225C079)

3.

NUREG-1431, Revision 4, Volume 1, Standard Technical Specifications Westinghouse Plants, Revision 4.0 Volume 1, Specifications, dated April 2012

4.

NUREG-0847 Supplement 29, Safety Evaluation Report: Related to the Operation of Watts Bar Nuclear Plant, Unit 2, dated October 2015 (ML15282A051)

5.

Westinghouse Nuclear Safety Advisory Letter (NSAL-09-05), Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, dated September 23, 2009

6.

Westinghouse Nuclear Safety Advisory Letter (NSAL-15-1), Heat Flux Hot Channel Factor Technical Specification Surveillance, dated February 3, 2015 In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license, construction permit, or early site permit," Tennessee Valley Authority (TVA) is submitting a request for an amendment to the Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant (WBN)

Units 1 and 2, respectively.

U.S. Nuclear Regulatory Commission CNL-19-115 Page 2 March 2, 2020 The proposed amendment revises the WBN Units 1 and 2 Technical Specification (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), to implement the methodology in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, (References 1 and 2). The proposed revised WBN Units 1 and 2 TS 3.2.1 are also consistent with NUREG-1431, Revision 4, Standard Technical Specifications Westinghouse Plants, (Reference 3). Additionally, this license amendment request (LAR) modifies the WBN Unit 1 and Unit 2 TS 5.9.5 to include Reference 2 in the list of the Nuclear Regulatory Commission (NRC) approved methodologies used to develop the cycle specific Core Operating Limits Report (COLR). The proposed change also deletes WBN Unit 2 Operating License (OL) Condition 2.C.10, which is documented in Section 1.9.6 of NUREG-0847 Supplement 29 (Reference 4).

Nuclear Safety Advisory Letter (NSAL) 09-05, Revision 1, (Reference 5) and NSAL-15-1, (Reference 6) noted there are non-conservatisms in the methodology in Westinghouse Standard TS (STS) 3.2.1B, Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z)

Methodology), for plants that have implemented the Relaxed Axial Offset Control (RAOC) methodology. Therefore, in accordance with the guidance in NRC Administrative Letter 98-10, Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety, this LAR is required to resolve non-conservative TS and is not a voluntary request from a licensee to change its licensing basis. Therefore, this request is not subject to forward fit considerations as described in the letter from S. Burns (NRC) to E. Ginsberg (NEI), dated July 14, 2010 (ML101960180). TVA has implemented compensatory measures in accordance with References 5 and 6.

The enclosure to this submittal provides a description and assessment of the proposed change, including technical analyses, regulatory analyses, and environmental considerations. Attachments 1 and 2 to the enclosure provide the existing WBN Units 1 and 2 TS pages marked-up to show the proposed changes. Attachment 3 to the enclosure provides the existing WBN Unit 2 OL Condition 2.C.10 marked-up to show the proposed change. Attachments 4 and 5 to the enclosure provide the existing WBN Units 1 and 2 TS pages retyped to show the proposed changes. Attachment 6 to the enclosure provides the existing WBN Unit 2 OL Condition 2.C.10 retyped to show the proposed change.

Attachments 7 and 8 to the enclosure provide the existing WBN Units 1 and 2 TS Bases pages marked-up to show the proposed changes. Changes to the existing TS Bases are provided for information only and will be implemented under the Technical Specification Bases Control Program.

TVA determined that there are no significant hazard considerations associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). In accordance with 10 CFR 50.91, Notice for Public Comment; State Consultation, TVA is sending a copy of this letter and the enclosure to the Tennessee Department of Environment and Conservation.

TVA requests approval of the proposed non-voluntary license amendment within one year from the date of this submittal. Due to the core design and safety analysis evaluation needed to support each core design using the methodology in WCAP-17661-P-A, Revision 1, implementation of this amendment for each unit will coincide with the start of the

U.S. Nuclear Regulatory Commission CNL-19-115 Page 3 March 2, 2020 fuel cycles for WBN Unit 1 Cycle 18 (Fall 2021) and WBN Unit 2 Cycle 5 (Spring 2022), but no later than November 30, 2021 for WBN Unit 1 and May 15, 2022 for WBN Unit 2.

There are no new regulatory commitments associated with this submittal. Please address any questions regarding this request to Kimberly D. Hulvey, Fleet Licensing Manager, at 423-751-3275.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 2'"'day of March 2020.

Respectfully, J^es T. Polickoski Director, Nuclear Regulatory Affairs

Enclosure:

Evaluation of Proposed Change cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager-Watts Bar Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation

Enclosure CNL-19-115 E1 of 19 Evaluation of Proposed Change

Subject:

Non-Voluntary License Amendment Request to Modify Watts Bar Nuclear Plant Units 1 and 2 Technical Specifications 3.2.1, FQ(Z), to Implement Methodology from WCAP-17661, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications (WBN-TS-19-08)

TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION............................................................................................. 2 2.0 DETAILED DESCRIPTION.............................................................................................. 2 2.1 Background.................................................................................................................. 2 2.2 Description of the Proposed Change............................................................................ 3 2.3 Reason for the Proposed Change................................................................................ 4

3.0 TECHNICAL EVALUATION

............................................................................................. 4 3.1 Process Parameter Limitations.................................................................................... 4 3.1.1 Heat Flux Hot Channel Factor (FQ(Z))................................................................... 4 3.1.2 AFD...................................................................................................................... 4 3.1.3 Control Bank Insertion Limits................................................................................ 5 3.2 Evaluation of Proposed TS Changes........................................................................... 6 3.2.1 TS 3.2.1................................................................................................................ 6 3.2.2 Approval Limitations.............................................................................................13 3.3 Conclusion..................................................................................................................14

4.0 REGULATORY ANALYSIS

............................................................................................14 4.1 Applicable Regulatory Requirement Criteria................................................................14 4.2 Precedent...................................................................................................................16 4.3 No Significant Hazards Consideration Determination..................................................16

4.0 ENVIRONMENTAL CONSIDERATION

..........................................................................19

5.0 REFERENCES

...............................................................................................................19 ATTACHMENTS

1. Proposed TS Changes (Mark-Ups) for WBN Unit 1

2. Proposed TS Changes (Mark-Ups) for WBN Unit 2

3. Proposed WBN Unit 2 OL Condition 2.C.10 (Mark-Ups)

4. Proposed TS Changes (Final Typed) for WBN Unit 1

5. Proposed TS Changes (Final Typed) for WBN Unit 2

6. Proposed WBN Unit 2 OL Condition 2.C.10 (Final Typed)

7. Proposed TS Bases Page Changes (Mark-Ups) for WBN Unit 1 (For Information Only)

8. Proposed TS Bases Page Changes (Mark-Ups) for WBN Unit 2 (For Information Only)

Enclosure CNL-19-115 E2 of 19 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, "Application for amendment of license, construction permit, or early site permit," Tennessee Valley Authority (TVA) is requesting a non-voluntary license amendment to the Watts Bar Nuclear Plant (WBN) Unit 1 and Unit 2 Technical Specifications (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), to implement the improved FQ Surveillance TS methodology. This non-voluntary license amendment request (LAR) proposes to revise WBN Units 1 and 2 TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z), to implement the methodology in WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, (References 1 and 2), without deviation. The proposed revised WBN Units 1 and 2 TS 3.2.1 are also consistent with NUREG-1431, Revision 4, Standard Technical Specifications Westinghouse Plants, (Reference 3). Additionally, this LAR modifies the WBN Unit 1 and Unit 2 TS 5.9.5 to include Reference 2 in the list of Nuclear Regulatory Commission (NRC)-approved methodologies used to develop the cycle specific Core Operating Limits Report (COLR). The proposed change also deletes WBN Unit 2 Operating License (OL) Condition 2.C.10, which is documented in Section 1.9.6 of NUREG-0847, Supplement 29 (Reference 4).

2.0 DETAILED DESCRIPTION

2.1 BACKGROUND

The purpose of the FQ Surveillance TS is to provide assurance that the heat flux hot channel factor FQ(Z), will remain within the limits assumed in the plant safety analyses when the core is operated within its allowed operating space. Key operating space limits include the Rated Thermal Power (RTP), the control bank Rod Insertion Limits (RILs),

and the Axial Flux Difference (AFD) limits. Together, these operating space limits restrict the range of potential non-equilibrium core power shapes during normal operation, thereby limiting the maximum non-equilibrium FQ(Z).

The current FQ Surveillance formulation relies on a combination of analytical factors and periodic measurements to provide assurance that core operation within the allowed operating space will be acceptable. When an FQ surveillance is performed, the equilibrium FQ(Z) is measured at or near steady-state conditions. FQ(Z) is then multiplied by an analytical factor, W(Z), which characterizes the increase in FQ(Z) for non-equilibrium operation. The result, when uncertainties are included, is the maximum postulated transient FQ(Z), which is then compared to the FQ(Z) limit.

The above formulation has been shown to be problematic for Relaxed Axial Offset Control (RAOC) plants. The accuracy of the analytically derived W(Z) values is sensitive to how well the surveillance axial power shape is predicted. While the predicted axial power shape can be inaccurate under nominal full power conditions, the accuracy of predicting the axial power shape for part-power surveillances is even more problematic.

Additionally, the current Required Action of WBN Units 1 and 2 TS 3.2.1, to reduce the AFD limits if the transient FQ limit is not met, may be insufficient to ensure that the peaking factor basis assumed in the licensing basis analysis is maintained under all conditions.

Nuclear Safety Advisory Letter (NSAL) 09-5 and NSAL-15-1 (References 5 and 6, respectively) document specific issues with regards to these general problems with the

Enclosure CNL-19-115 E3 of 19 current TS. Reference 5 notified Westinghouse customers of an issue associated with the Required Actions for Condition B of Standard TS (STS) 3.2.1B, Heat Flux Hot Channel Factor (FQ(Z) (RAOC-W(Z) Methodology), for plants that have implemented the RAOC methodology. In certain situations where transient FQW(Z) is not within its limit, the existing Required Actions may be insufficient to restore FQW(Z) to within its limit.

Reference 5 provided clarification regarding the applicability of the recommended interim actions to address this issue in accordance with NRC Administrative Letter (AL) 98-10, Dispositioning of Technical Specifications That Are Insufficient to Assure Plant Safety.

Reference 6 notified Westinghouse customers of an issue associated with STS 3.2.1B and 3.2.1C (Heat Flux Hot Channel Factor (FQ(Z)). Specifically, STS Surveillance Requirement (SR) 3.2.1.2 in STS 3.2.1B and 3.2.1C may not ensure that the transient FQ meets the limiting condition for operation (LCO) limit between the performance of the 31 effective full power days (EFPD) flux map measurements, under some conditions, for those plants that use the W(Z) FQ surveillance methodology.

Therefore, because of the issues identified in References 5 and 6, TVA determined that WBN Units 1 and 2 TS 3.2.1 constitute a non-conservative TS and entered this into the corrective action program. TVA implemented the References 5 and 6 recommended actions procedurally for WBN Unit 1. The WBN Unit 2 TS also incorporated these recommended actions with the restriction that WBN Unit 2 OL Condition 2.C.10 was adopted to verify that the Reference 5 recommended actions are sufficient for each WBN Unit 2 operating cycle.

The improved FQ surveillance methodology in Reference 2 resolves the above issues.

The new surveillance methodology requires the measurement of FXY(Z), which is then multiplied by factors that characterize the maximum transient P(Z) values postulated to occur during non-equilibrium operation. This formulation essentially eliminates the sensitivity of the surveillance to the surveillance axial power shape. Additionally, the improved FQ surveillance methodology incorporates various RAOC operating spaces, consisting of combinations of control bank rod insertion, AFD, and thermal power limits that provides sufficient FQ margin for future operation.

2.2 DESCRIPTION

OF THE PROPOSED CHANGE The LAR proposes changes to WBN Unit 1 and Unit 2 TS 3.2.1 and TS 5.9.5 that implement the methodology and TS changes in Reference 2 without deviation.

Additionally, the LAR deletes WBN Unit 2 OL Condition 2.C.10, which is documented in Section 1.9.6 of Reference 4. Further description of the proposed changes is provided in Section 3.2 to this enclosure.

Attachments 1 and 2 to this enclosure provide the existing WBN Units 1 and 2 TS pages marked-up to show the proposed changes. Attachment 3 to this enclosure provides the existing WBN Unit 2 OL Condition 2.C.10 marked-up to show the proposed change.

Attachments 4 and 5 to this enclosure provide the existing WBN Units 1 and 2 TS pages retyped to show the proposed changes. Attachment 6 to this enclosure provides the existing WBN Unit 2 OL Condition 2.C.10 retyped to show the proposed change.

Attachments 7 and 8 to this enclosure provide the existing WBN Units 1 and 2 TS Bases pages marked-up to show the proposed changes. Changes to the existing TS Bases

Enclosure CNL-19-115 E4 of 19 are provided for information only and will be implemented under the Technical Specification Bases Control Program 2.3 REASON FOR THE PROPOSED CHANGE In accordance with the guidance in NRC AL 98-10, this LAR is required to resolve a non-conservative TS and is not a voluntary request from a licensee to change its licensing basis. The proposed LAR is needed to resolve the issues discussed in References 5 and 6 and align the WBN Units 1 and 2 TS with the STS changes in Reference 2. Additionally, the requested change is needed for Unit 2 because OL Condition 2.C.10 requires special cycle specific evaluations to be performed that are beyond the routine evaluations performed for a fuel cycle. The new FQ formulation will remove the surveillance sensitivity to the predicted axial power shapes and remove the potential non-conservatism in TS 3.2.1.

3.0 TECHNICAL EVALUATION

3.1 PROCESS PARAMETER LIMITATIONS 3.1.1 Heat Flux Hot Channel Factor (FQ(Z))

FQ(Z) is defined as the maximum local fuel rod linear power density divided by the average fuel rod linear power density and is a measure of the peak fuel pellet power within the reactor core. The values of FQ vary along the axial height (Z) of the core.

FQ(Z) also varies with fuel loading patterns, control bank insertion, fuel burnup, and changes in axial power distribution. The purpose of the limits on the values of FQ(Z) is to limit the local (i.e. pellet) peak power density.

FQ(Z) is measured periodically using either the movable incore detector system (MIDS) or the power distribution monitoring system (PDMS). Because these measurements are generally taken with the core at or near equilibrium conditions, the measured FQ(Z) does not include the variations which would be present during non-equilibrium situations, such as load following or power ascension.

To account for these possible variations, the equilibrium values of FQ(Z) are adjusted by elevation dependent factors that account for the expected maximum values postulated to occur during RAOC operation.

The proposed changes to TS 3.2.1 involve a re-formulation of these elevation dependent factors, designated as [T(Z)]COLR. The proposed TS 3.2.1 incorporates various RAOC Operation Spaces (ROS) that define the corresponding elevation dependent factors,

[T(Z)]COLR. Each ROS is composed of corresponding COLR limits associated with TS 3.2.3, AXIAL FLUX DIFFERENCE (AFD), and TS 3.1.7, CONTROL BANK Insertion Limits, assumed in the calculation of each particular [T(Z)]COLR function.

3.1.2 AFD The purpose of TS 3.2.3 is to establish limits on the values of AFD in order to limit the amount of axial power distribution skewing to either the top or bottom of the core. By limiting the amount of power distribution skewing, core peaking factors are consistent with the assumption used in the safety analyses. Limiting power distribution skewing over time also minimizes the xenon distribution skewing, which is a significant factor in axial power distribution control.

Enclosure CNL-19-115 E5 of 19 AFD is the difference in normalized flux signals between the top and bottom halves of a two-section excore neutron detector. AFD is a measure of the axial power distribution skewing to either the top or bottom half of the core. AFD is sensitive to many core related parameters such as control bank positions, core power level, axial burnup, axial xenon distribution, and, to a lesser extent, reactor coolant temperature and boron concentration.

The allowed range of AFD is used in the nuclear design process to confirm that operation within these limits produces core peaking factors and axial power distributions that meet safety analysis requirements. The limits on AFD ensure that FQ(Z) is not exceeded during either normal operation or in the event of xenon redistribution following power changes. The limits on AFD also restrict the range of power distributions that are used as initial conditions in the analyses of Condition II, III, or IV events as described in Chapter 15 of the WBN dual-unit Updated Final Safety Analysis Report.

RAOC, as described in WCAP-10216-P-A, Revision 1A, Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification, (Reference 7), is a calculational procedure that defines the allowed operational space of the AFD versus THERMAL POWER. AFD limits are selected by considering a range of axial xenon distributions that may occur as a result of large variations of AFD. Subsequently, power peaking factors and power distributions are examined to ensure that the loss of coolant accident (LOCA), loss of flow accident, and anticipated transient limits are met. Violation of the AFD limits invalidates the conclusions of the accident and transient analyses with regard to fuel cladding integrity.

The RAOC methodology establishes a xenon distribution library with tentatively wide AFD limits. One-dimensional axial power distribution calculations are then performed to demonstrate that normal operation power shapes are acceptable for LOCA and loss of flow accident and for initial conditions of anticipated transients. The tentative limits are adjusted as necessary to meet the safety analysis requirements.

3.1.3 Control Bank Insertion Limits The insertion of the control rods directly affect core power and fuel burnup distributions and assumptions of available ejected rod worth, shutdown margin (SDM), and initial reactivity insertion rate. RILs are established and rod positions are monitored against the RILs and controlled during power operation to ensure that the power distribution and reactivity limits defined by the design power peaking and SDM limits are preserved.

The rod cluster control assemblies (RCCAs) are divided among control banks and shutdown banks. Each bank may be further subdivided into two groups to provide for precise reactivity control (shutdown banks C and D have only one group each). A group consists of two or more RCCAs that are electrically paralleled to step simultaneously.

Except for shutdown banks C and D, a bank of RCCAs consists of two groups that are moved in a staggered fashion, but always within one-step of each other. There are four control banks and four shutdown banks.

TS 3.1.6 requires each shutdown bank to be within the insertion limits as specified in the COLR. TS 3.1.7 requires the control banks to be within the insertion, sequence, and overlap limits as specified in the COLR. The control banks are operated in sequence by

Enclosure CNL-19-115 E6 of 19 withdrawal of Bank A, Bank B, Bank C, and then Bank D. The control banks are sequenced in reverse order upon insertion.

Overlap is the distance travelled together by two control banks. Upon initiation of control bank withdrawal, control bank A is withdrawn by itself. At a predetermined position, control bank B begins withdrawing, resulting in both banks withdrawing simultaneously until control bank A is fully withdrawn. Control bank B will continue withdrawing until, at a subsequent predetermined position, control bank C begins withdrawing. This process continues until control bank D is fully withdrawn or the demand for rod withdrawal ceases. As such, each banks overlap is the number of steps that each bank travelled from the following banks predetermined position to the fully withdrawn position.

The power density at any point in the core must be limited so that the fuel design criteria are maintained. Together, TS 3.1.5, Rod Group Alignment Limits, TS 3.1.6, TS 3.1.7, TS 3.2.3, and TS 3.2.4, QUADRANT POWER TILT RATIO (QPTR), provide limits on control component operation and on monitored process variables, which ensure that the core operates within the fuel design criteria. The shutdown and control bank insertion and alignment limits, AFD, and QPTR are process variables that together characterize and control the three dimensional power distribution of the reactor core.

3.2 EVALUATION OF PROPOSED TS CHANGES The current WBN Unit 1 and Unit 2 TS 3.2.1 differ due to the extended period of time between the approval of each units OL (i.e., February 7, 1996 for Unit 1 and October 22, 2015 for Unit 2). The WBN Unit 1 TS 3.2.1 reflects the original RAOC methodology contained in Reference 7. The WBN Unit 1 TS 3.2.1 reflects the recommended action from References 5 and 6, which supplement the original Reference 7 methodology The WBN Unit 2 OL Condition 2.C.10 was imposed because the recommended actions from Reference 6 were largely based on engineering judgement. The cycle specific evaluation required by WBN Unit 2 OL Condition 2.C.10 ensure these actions are bounded for the given fuel cycle.

Furthermore, the formulations for FQW(Z) differ between WBN Units 1 and 2 due to the systems available to obtain an incore power measurement system between each unit.

WBN Unit 1 utilizes the movable incore detector system (MIDS) and a power distribution monitoring system (PDMS) using core exit thermocouples. Whereas, WBN Unit 2 utilizes a PDMS with fixed self-powered incore detectors. The measurement uncertainty factor [i.e., FQMU or (1+UQ/100)] is dependent on the method used to measure either FQM(Z) or FXYM(Z).

Further description of the proposed TS changes in this LAR is provided below.

3.2.1 TS 3.2.1 A. LCO While the LCO remains unchanged, the underlying formulation of the approximation, FQW(Z), is changed. The current formulations for FQW(Z) are:

Unit 1 FQW(Z) = 1.03 FQM(Z) FQMU W(Z)/P

[MIDS]

Enclosure CNL-19-115 E7 of 19 or FQW(Z) = 1.03 FQM(Z) (1+UQ/100) W(Z)/P

[PDMS]

Unit 2 FQW(Z) = 1.03 FQM(Z) (1+UQ/100) W(Z)/P The new formulations for FQW(Z) are:

Unit 1 FQW(Z) = 1.03 FXYM(Z) FQMU AXY(Z) Rj [T(Z)]COLR/P

[MIDS]

or FQW(Z) = 1.03 FXYM(Z) (1+UQ/100) AXY(Z) Rj [T(Z)]COLR/P

[PDMS]

Unit 2 FQW(Z) = 1.03 FXYM(Z) (1+UQ/100) AXY(Z) Rj [T(Z)]COLR/P In the new formulations, the measured parameter is FXY(Z), which is the planar peaking factor. The new factor, AXY(Z), accounts for differences between the reference and surveillance conditions. The newly defined factor, Rj, is used to account for the expected decrease in margin due to operation over the allowed period of time before the next performance of SR 3.2.1.2. This factor exists in the current TS as the appropriate factor specified in the COLR in the Note to SR 3.2.1.2. The factor, W(Z), is replaced by the new factor, [T(Z)]COLR. This new formulation reduces the sensitivity of the FQW(Z) evaluation to the prediction of the axial power shape at the time of the surveillance.

B. Condition A The proposed Condition A is modified by a note in accordance with Reference 2, which requires the performance of SR 3.2.1.1 and SR 3.2.1.2 (Required Action A.4) whenever Condition A is entered prior to increasing thermal power above the thermal power limit imposed by Required Action A.1. This new requirement ensures FQ(Z) is properly evaluated even if plant conditions change such that Condition A may be exited. The note clarifies further that SR 3.2.1.2 is not required to be performed if Condition A is entered prior to thermal power exceeding 75% RTP after a refueling.

This latter clarification makes the note consistent with the changes in the other Required Actions and Surveillance Requirements.

The Completion Time for Required Action A.1 is modified by a statement to ensure Required Action A.1 is re-performed after each FQC(Z) determination. Otherwise, Required Action A.1 would only have to be performed within 15 minutes of Condition A initial entry.

Enclosure CNL-19-115 E8 of 19 Required Action A.2 is revised to change the NIS setpoint reductions when FQC(Z) is not within limits. Instead of reducing the setpoints > 1% for each 1% FQC(Z) exceeds limit, the setpoints are reduced > 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1. The change will require a greater setpoint reduction if the surveillance was performed at reduced power.

The Completion Time for Required Action A.2 is modified in two ways. The Completion Time is relaxed from eight to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This relaxation is necessary in light of the activities needing to be performed on all four power range channels. This relaxation is reasonable 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 second change ensures Required Action A.2 is re-performed after each FQC(Z) determination. Otherwise, Required Action A.2 would only have to be performed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of Condition A initial entry.

Required Action A.3 is revised to change the Overpower (OP)T setpoint reductions when FQC(Z) is not within limits. Instead of reducing the setpoints > 1% for each 1%

FQC(Z) exceeds limit, the setpoints are reduced > 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1. The change will require a greater setpoint reduction if the surveillance was performed at reduced power.

The Completion Time for Required Action A.3 is modified by a statement that ensures Required Action A.3 is re-performed after each FQC(Z) determination.

Otherwise, Required Action A.3 would only have to be performed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of Condition A initial entry.

Required Action A.4 is revised to require performance of SR 3.2.1.2 in addition to SR 3.2.1.1. This ensures that future operation is evaluated prior to increasing thermal power above the limit of Required Action A.1.

C. Condition B Unit 1 The current Unit 1 TS 3.2.1 only contains Required Action B.1 to reduce AFD limits

> 1% for each 1% FQW(Z) exceeds limit, which contains the non-conservatisms documented in Reference 5. The current Required Action B.1 is being replaced with a number of new Required Actions, in accordance with Reference 2, as described below.

The proposed Required Action B.1.1 requires another ROS, as specified in the COLR, be implemented that restores FQW(Z) to within limits. Implicit in this action to implement a ROS that restores FQW(Z) to within limits is the verification that the previously obtained measurement has sufficient FQW(Z) margin using the [T(Z)]COLR factors associated with the new ROS being implemented. This action is better than the current Required Action B.1, because Reference 5 documents that the > 1%

AFD limit reduction for each 1% FQW(Z) exceeded its limit and may not provide sufficient FQW(Z) margin in all situations.

Enclosure CNL-19-115 E9 of 19 Proposed Required Action B.1.2 requires SR 3.2.1.1 and SR 3.2.1.2 be performed if control rod motion is required to comply with the new ROS. Because changed control rod positions affect peaking factors, this ensures FQ(Z) is evaluated under the new operating conditions.

The proposed Required Action B.2.1 is modified by a Note, which requires the performance of Required Action B.2.4 (i.e., perform SR 3.2.1.1 and SR 3.2.1.2) whenever Required Action B.2.1 is performed prior to increasing thermal power above the thermal power limit imposed by Required Action B.2.1. Proposed Required Action B.2.1 requires thermal power to be limited to less than RTP and to reduce AFD limits as specified in the COLR. This proposed Required Action is equivalent to implementing an alternate ROS that restricts thermal power as opposed to the RILs in addition to the reduction of the AFD Limits.

Proposed Required Action B.2.2 requires the Power Range Neutron Flux-High trip setpoints to be reduced > 1% for each 1% that thermal power is limited below RTP by Required Action B.2.1. This action retains the same margin between the highest level of allowed thermal power and the power level at which the Power Range trip would be initiated.

Proposed Required Action B.2.3 requires the OPT trip setpoints to be reduced

> 1% for each 1% that thermal power is limited below RTP by Required Action B.2.1.

This action retains the same margin between the highest level of allowed thermal power and the power level at which the OPT trip would be initiated.

Proposed Required Action B.2.4 requires SR 3.2.1.1 and SR 3.2.1.2 be performed prior to increasing thermal power above the limit of Required Action B.2.1. This ensures that FQ(Z) is properly evaluated prior to increasing thermal power above the limit of Required Action B.2.1.

Unit 2 The current Required Action B.1 to reduce AFD limits > 1% for each 1% FQW(Z) exceeds limit is replaced by proposed Required Action B.1.1, which requires another ROS be implemented that restores FQW(Z) to within limits. Implicit in this proposed action to implement a ROS that restores FQW(Z) to within limits is the verification that the previously determined measurement has sufficient FQW(Z) margin using the

[T(Z)]COLR factors associated with the new ROS being implemented. This action is superior to the current Required Action B.1, because Reference 5 documents that the > 1% AFD limit reduction for each 1% FQW(Z) exceeded its limit and may not provide sufficient FQW(Z) margin in all situations.

Proposed Required Action B.1.2 requires SR 3.2.1.1 and SR 3.2.1.2 be performed if control rod motion is required to comply with the new ROS. Because changed control rod positions affect peaking factors, this ensures FQ(Z) is evaluated under the new operating conditions.

The current note modifying Required Action B.2.1 is replaced by a new note. The current note allows for Required Actions B.2.1, B.2.2, B.2.3, and B.2.4 to not be performed if SR 3.2.1.2 was performed at < 75% RTP. The proposed note requires the performance of Required Action B.2.4 (i.e., SR 3.2.1.1 and SR 3.2.1.2) whenever Required Action B.2.1 is performed prior to increasing thermal power above the

Enclosure CNL-19-115 E10 of 19 thermal power limit imposed by Required Action B.2.1. This new requirement ensures FQ(Z) is properly evaluated even if plant conditions change such that Condition B may be exited or Required Action B.1 is subsequently performed.

The current Required Action B.2.1 to reduce the maximum allowable power > 3%

RTP for each 1% FQW(Z) exceeds the limit is replaced by the requirement to limit thermal power to less than RTP and to reduce AFD limits as specified in the COLR.

This proposed Required Action is equivalent to implementing an alternate ROS that restricts thermal power as opposed to the RILs in addition to the reduction of the AFD Limits.

Required Action B.2.2 is revised to change the Power Range Neutron Flux-High trip setpoints reductions when FQW(Z) is not within limits. Instead of reducing the setpoint 1% for each 1% the maximum allowable power is reduced, the setpoint is reduced 1% for each 1% that thermal power limited below RTP by Required Action B.2.1. The proposed action retains the same margin between the highest level of allowed thermal power and the power level at which the Power Range trip would be initiated if the surveillance was performed at a part power condition.

Required Action B.2.3 is revised to change the OPT setpoint reductions when FQW(Z) is not within limits. Instead of reducing the setpoint 1% for each 1% the maximum allowable power is reduced, the setpoint is reduced 1% for each 1% that thermal power limited below RTP by Required Action B.2.1. The proposed action retains the same margin between the highest level of allowed thermal power and the power level at which the OPT trip would be initiated if the surveillance was performed at a part power condition.

Required Action B.2.4 requires SR 3.2.1.1 and SR 3.2.1.2 be performed prior to increasing thermal power above the limit of Required Action B.2.1. This ensures that FQ(Z) is properly evaluated prior to increasing thermal power above the limit of Required Action B.2.1.

D. Surveillance Requirements The Note modifying all surveillance requirements is deleted. The Note stated, During power escalation at the beginning of each cycle, thermal power may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained. This Note has been the source of confusion within the industry. The new surveillance Frequency requirements are unambiguous and the Bases have been enhanced with the explanation of the equilibrium conditions necessary for surveillance performance.

The first surveillance Frequency for SR 3.2.1.1 is modified by the removal of initial fuel loading and. The initial fuel loading was completed a number of fuel cycles ago and this wording is now moot.

The second surveillance Frequency for SR 3.2.1.1 is changed from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by > 10% RTP, the thermal power at which FQC(Z) was last verified.

The Note modifying SR 3.2.1.2 is deleted. Reference 6 documents potential non-conservatisms with the application of this note. Removal of this Note allows for the

Enclosure CNL-19-115 E11 of 19 application of the appropriate factor accounting for expected decreases in FQW(Z) margin in future surveillances regardless of the trend of FQW(Z) margin in the past.

Additionally, this change removes the option to perform SR 3.2.1.2 at an increased frequency of 7 EFPD without the factor applied. The formulation of FQW(Z) will include the appropriate factor whenever margin is expected to decrease.

The first surveillance Frequency for SR 3.2.1.2 is modified in two ways. The requirement to perform the surveillance after initial fuel loading and is removed.

The initial fuel loading was completed a number of fuel cycles ago and this wording is now moot. Additionally, the requirement to perform the surveillance prior to thermal power exceeding 75% RTP is replaced with the requirement to perform the surveillance within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after thermal power exceeds 75% RTP. Power levels of < 75% RTP are non-limiting for minimum transient FQW(Z) margin. Performing this initial verification after exceeding 75% RTP ensures that the surveillance will be performed with more appropriate steady state peaking factors measured at or near the power level where future non-equilibrium operation could be limiting.

The second surveillance Frequency for SR 3.2.1.2 is changed from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by > 10% RTP, the thermal power at which FQW(Z) was last verified.

The value of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in SRs 3.2.1.1 and 3.2.1.2 is bracketed in Reference 2, meaning it is a site-specific value. As noted in Reference 2, the 24-hour time frame is a reasonable time period in which to perform this verification given the extremely small likelihood of limiting power shapes or limiting design basis events occurring prior to completion of the surveillance. The change from 12 to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months will provide a more accurate measurement of FQC(Z) and FQW(Z) by allowing sufficient time to achieve equilibrium conditions and obtain the power distribution measurement.

E. TS 5.9.5 - COLR The reference to TS 3.2.1 is removed from TS 5.9.5 Reference b.3 with respect to WCAP-10216-P-A, Revision 1A, because the new FQW(Z) formulation is no longer applicable to the methodology in WCAP-10216-P-A, Revision 1A, but rather to WCAP-17661-P-A. The AFD limits associated with TS 3.2.3, however, remain applicable to the WCAP-10216-P-A methodology.

TS 5.9.5 Reference b.11 was added to include a reference to WCAP-17661-P-A.

The new FQW(Z) formulation and surveillance requirements are directly related to this newly approved topical.

F. Deletion of Unit 2 OL Condition 2.C.10 Unit 2 OL Condition 2.C.10 states, TVA will verify for each core reload that the actions taken if FQW(Z) is not within limits will assure that the limits on core power peaking FQ(Z) remain below the initial total peaking factor assumed in the accident analyses. The basis for this OL condition was Section 1.9.6 of Reference 4, which states:

The NRC staff proposed a license condition discussed in Section 15.3.1, of SSER 29. The operating license for WBN, Unit 2 will include a license condition similar to the following.

Enclosure CNL-19-115 E12 of 19 Core Reload License Condition:

TVA will verify for each core reload that the actions taken if FQ W(Z) is not within limits will assure that the limits on core power peaking FQ(Z) remain below the initial total peaking factor assumed in the accident analyses.

Section 15.3.1 of Reference 4 addresses the issues in References 5 and 6 and states:

On October 9, 2015, in response to the NRC staffs questions associated with how TVA addressed the issues identified in the NSALs, TVA (1) provided a license condition where the margins provided in TS 3.2.1 will be evaluated each fuel cycle to assure that the related assumptions in the accident analyses are maintained, and (2) submitted a summary of a Westinghouse margin assessment report for Cycle 1 providing additional information related to the proposed TS 3.2.1.

The proposed license condition requires TVA to perform cycle-specific evaluations of the margins of the Required Actions in TS 3.2.1 Condition B, and states:

TVA will verify for each core reload that the actions taken if FQW(Z) is not within limits will assure that the limits on core power peaking FQ(Z) remain below the initial total peaking factor assumed in the accident analyses.

The results of this verification are documented in the final Reload Safety Evaluation that the vendor provides WBN, Unit 2 for each core reload, which will be reviewed by TVA, and is a quality assurance record as defined in 10 CFR 50, Appendix B, and available for NRC inspection.

While the NRC staff has not come to a final decision on any actions required for already-licensed plants using different versions of TS 3.2.1 that are impacted by the NSALs, the NRC staff has reached a decision for WBN, Unit 2. Specifically, as detailed in Section 16 of this SSER, the proposed TS, which include provisions to address the NSALs, are acceptable. Further, the additional analyses imposed though the new license condition will provide additional assurances that the actions taken under TS 3.2.1 are appropriate.

TVA has complied with the above license condition. However, based on the proposed TS changes in this LAR and based on Reference 2, WBN Unit 2 OL Condition 2.C.10 is no longer needed because the implementation of the methodology in Reference 2 renders this license condition moot. The current WBN Unit 2 TS 3.2.1 is based on the Reference 7 methodology. References 5 and 6 documented non-conservatisms in the Reference 7 methodology, which was the basis for the WBN Unit 2 OL Condition 2.C.10.

Because the Reference 2 methodology replaces the Reference 7 methodology and eliminates the non-conservatisms, the compensatory actions of WBN Unit 2 OL Condition 2.C.10 are no longer needed.

Enclosure CNL-19-115 E13 of 19 3.2.2 Approval Limitations In Reference 2, the NRC stipulated two limitations for the implementation of the proposed Technical Specifications.

Limitation 1: Use of AXY and AQ Methods 1 and 2 are acceptable for calculating AXY and AQ when performing RAOC and CAOC W(Z) surveillances, subject to the following limitations:

1. The NRC-approved methods provided in the response to RAI 15.b must be used to perform the surveillance-specific AXY or AQ calculations. Newer methods with similar capabilities may be considered acceptable provided the NRC staff specifically approves them for calculating AXY and AQ factors.

2. The depletion calculation used to determine the numerator and denominator of the AXY or AQ factor must be performed similarly to the original design calculation, as described in the response to RAI 15.c.

3. The use of Method 1 for calculating AQ is only acceptable subject to the constraints discussed in the response to RAI 15.a. The surveillance Axial Offset must be within 1.5-percent of the target AO, and there must be assurance that the limiting FQW(Z) location does not lie within a rodded elevation at the time of surveillance. Note that the use of Method 1 remains acceptable when surveillance-specific W(Z) functions are used.

TVA Response WCAP-17661-P-A and the Technical Specification Bases were revised to limit the methods to calculate AXY to Methods 1 and 2. Method 1 sets AXY(Z) to 1.0. Method 2 calculates AXY(Z) for the conditions existing at the time of the surveillance. The NRC approved methods provided in the response to RAI 15.b are ANC and BEACON, which uses the same neutronic methodology as the design ANC model that was used as the base model for calculating the FQ surveillance factors. There are no plans at this time to add an additional method to calculate the AXY(Z) values, but doing so would require a revision to the TS, which would require NRC approval.

When BEACON is used to calculate surveillance condition specific AXY(Z) values, the calculation will be performed without using nodal calibration factors and the core depletion assumptions will be the same as used in the original core model to generate the T(Z) factors.

When ANC is used to calculate the surveillance condition specific AXY(Z) values, the calculation will use the same nuclear model and depletion basis that was used to generate the original T(Z) factors.

Item 3 of the limitation is not applicable because AQ is applicable to the CAOC methodology, whereas WBN used the used the RAOC methodology.

Limitation 2: Power Level Reduction to 50 Percent RTP As noted in Section 4.3.2 of this SE, the use of 50 percent as the final power level reduction in the event of failed FQ surveillance is not included in the TS, but rather in the BASES and in the COLR. As such, this final power level, 50 percent, must be

Enclosure CNL-19-115 E14 of 19 implemented on a plant-specific basis and included in COLR input generated, using this methodology, in order to use this TR.

TVA Response WCAP-17661-P-A provides sample COLR input, which specifies 50% RTP as the final power level reduction in the event of a failed FQ surveillance. All COLR input for WBN Units 1 and 2 fuel cycles will also specify 50% RTP as the final power level reduction in the event of a failed FQ surveillance.

3.3 CONCLUSION

This evaluation concludes that the changes to the FQ(Z) surveillance methodology in TS 3.2.1, to implement the methodology in Reference 2, are acceptable. The changes provide a more robust means of performing the FQW(Z) surveillance. A bounding ROS, selected from a set of previously evaluated ROSs, is implemented if FQW(Z) does not meet the FQ(Z) limit. The SRs and Required Actions are more clearly defined. The changes also provide reasonable assurance that a core operated in accordance with the new requirements will remain within the power distribution limits assumed in the safety analyses.

4.0 REGULATORY ANALYSIS

4.1 APPLICABLE REGULATORY REQUIREMENT CRITERIA General Design Criteria WBN Units 1 and 2 were designed to meet the intent of the "Proposed General Design Criteria for Nuclear Power Plant Construction Permits" published in July, 1967. The Watts Bar construction permit was issued in January 1973. The dual-unit UFSAR, however, addresses the NRC General Design Criteria (GDC) published as Appendix A to 10 CFR 50 in July 1971, including Criterion 4 as amended October 27, 1987.

Each criterion listed below is followed by a discussion of the design features and procedures that meet the intent of the criteria.

Criterion 10, Reactor Design The reactor core and associated coolant, control, and protection systems shall be designed with appropriate margin to assure that specified acceptable fuel design limits are not exceeded during any conditions of normal operation, including the effects of anticipated operational occurrences.

Conformance with GDC 10 is described in Section 3.1.2.2 of the WBN dual-unit UFSAR.

The reactor core with its related coolant, control, and protection systems is designed to function throughout its design lifetime without exceeding acceptable fuel damage limits.

The reactor trip system is designed to actuate a reactor trip for any anticipated combination of plant conditions when necessary to ensure that fuel design limits are not exceeded. The core design, together with reliable process and decay heat removal systems, provides for this capability under all expected conditions of normal operation with appropriate margins for uncertainties and anticipated transient situations, including

Enclosure CNL-19-115 E15 of 19 the effects of loss of reactor coolant flow, trip of the turbine-generator, loss of normal feedwater and loss of both normal and preferred power sources.

Criterion 13 - Instrumentation and control Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems.

Conformance with GDC 13 is described in Section 3.1.2.2 of the WBN dual-unit UFSAR.

Instrumentation and controls are provided to monitor and control neutron flux, control rod position, temperatures, pressures, flows, and levels as necessary to assure that adequate plant safety can be maintained. Instrumentation is provided in the reactor coolant system, steam and power conversion system, the containment, engineered safety features systems, radiological waste systems, and other auxiliaries. Parameters that must be provided for operator use under normal operating and accident conditions are indicated in the control room in proximity with the controls for maintaining the indicated parameter in the proper range. The quantity and types of process instrumentation provided measures safe and orderly operation of all systems over the full design range of the plant.

Criterion 20 - Protection System Functions The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

Conformance with GDC 20 is described in Section 3.1.2.3 of the WBN dual-unit UFSAR.

A fully automatic protection system (with appropriate redundant channels) is provided to cope with transients where insufficient time is available for manual corrective action.

The design basis for all protection systems is in accord with IEEE Standard 279-1971.

The reactor trip system automatically initiates a reactor trip when any appropriate monitored variable or combination of variables exceed the normal operating range.

Setpoints are chosen to provide an envelope of safe operating conditions with adequate margin for uncertainties to ensure that fuel design limits are not exceeded.

Reactor trip is initiated by removing power to the rod drive mechanisms of all the full-length rod cluster control assemblies. This will allow the assemblies to free fall into the core, rapidly reducing reactor power output.

The engineered safety features actuation system automatically initiates emergency core cooling, and other safeguards functions, by sensing accident conditions using redundant process protection system channels measuring diverse parameters. Manual actuation of safeguards is relied upon where ample time is available for operator action. The ESF actuation system also provides a reactor trip on manual or automatic safety injection (S) signal generation.

Enclosure CNL-19-115 E16 of 19 Criterion 26 - Reactivity Control System Redundancy and Capability Two independent reactivity control systems of different design principles shall be provided. One of the systems shall use control rods, preferably including a positive means for inserting the rods, and shall be capable of reliably controlling reactivity changes to assure that under conditions of normal operation, including anticipated operational occurrences, and with appropriate margin for malfunctions such as stuck rods, specified acceptable fuel design limits are not exceeded. The second reactivity control system shall be capable of reliably controlling the rate of reactivity changes resulting from planned, normal power changes (including xenon burnout) to assure acceptable fuel design limits are not exceeded. One of the systems shall be capable of holding the reactor core subcritical under cold conditions.

Conformance with GDC 20 is described in Section 3.1.2.3 of the WBN dual-unit UFSAR.

Two reactivity control systems are provided. These are rod cluster control assemblies (RCCAs) and chemical shim (boric acid). The RCCAs are inserted into the core by the force of gravity. During operation, the shutdown rod banks are fully withdrawn. The full-length control rod system automatically maintains a programmed average reactor temperature compensating for reactivity effects associated with scheduled and transient load changes. The shutdown rod banks along with the full-length control banks are designed to shutdown the reactor with adequate margin under conditions of normal operation and anticipated operational occurrences thereby ensuring that specified fuel design limits are not exceeded. The most restrictive period in core life is assumed in all analyses and the most reactive rod cluster is assumed to be in the fully withdrawn position.

The boron system will maintain the reactor in the cold shutdown state independent of the position of the control rods and can compensate for xenon burnout transients.

4.2 PRECEDENT There are no applicable regulatory precedents regarding the changes proposed in this LAR.

4.3 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION The proposed change revises the TS 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), and associated references in TS 5.9.5, Core Operating Limits Report (COLR), to implement the new FQ(Z) surveillance methodology of WCAP-17661-P-A, Revision 1. The proposed changes will re-formulate the FQW(Z) approximation for FQ(Z), revise the surveillance requirements, and revise the required actions when FQ(Z) is not within limits. These changes remove the potential non-conservatisms documented in Westinghouse Nuclear Safety Advisory Letter (NSAL-15-1), "Heat Flux Hot Channel Factor Technical Specification Surveillance," and NSAL-09-05, Revision 1, "Relaxed Axial Offset Control FQ Technical Specification Actions."

Tennessee Valley Authority (TVA) has evaluated the proposed changes to the TS using the criteria in Section 50.92 to Title 10 of the Code of Federal Regulations (10 CFR) and has determined that the proposed changes do not involve a significant hazards

Enclosure CNL-19-115 E17 of 19 consideration. As required by 10 CFR 50.91(a), the TVA analysis of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of any accident previously evaluated?

Response: No The proposed change will re-formulate the FQW(Z) approximation for FQ(Z), revise the surveillance requirements, and revise the required actions when FQ(Z) is not within limits. This change does not result in any physical changes to plant safety-related structures, systems, or components (SSC).

As such, the proposed change does not involve an increase in the probability of any accident previously evaluated.

The proposed changes affect the Surveillance Requirements performed to ensure the Heat Flux Hot Channel Factor, FQ(Z), is within the limits assumed in the safety analyses for previously evaluated accidents. The new surveillance activity involves a reformulation of the transient hot channel factor approximation, FQW(Z), and a more conservative application of applied factors to ensure FQW(Z) remains within limit during subsequent operation up until the next surveillance performance. Both of these changes to the surveillance activity provide assurance that the FQW(Z) remains within the accident analyses assumptions.

The proposed changes also affect the Required Actions and Completion Times should FQ(Z) be found to not be within limit. The new Required Actions and Completion Times ensure the plant is placed in a condition whereby FQ(Z) is restored to within limit in a timely manner. Should FQC(Z) be found not within limit, thermal power is reduced and the NIS and OPT reactor trip setpoints are reduced a conservative amount that retains the margin between the nominal thermal power and reactor trip setpoints. Should FQW(Z) be found not within limit, the core power distribution is constrained by reduced AFD limits, more limiting Rod Insertion Limits, and/or thermal power reductions. These changes to the Required Actions and Completion Times restore FQ(Z) to within the safety analyses assumptions in a timely manner.

Therefore, the proposed change does not involve a significant increase in the consequences of an accident previously evaluated.

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

Response: No The proposed change will re-formulate the FQW(Z) approximation for FQ(Z), revise the surveillance requirements, and revise the required actions when FQ(Z) is not within limits. This change does not result in any physical changes to plant safety-related structures, systems, or components (SSCs). Neither does this change alter the modes of plant operation in a manner that is outside the bounds of those previously evaluated.

Enclosure CNL-19-115 E18 of 19 Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No The proposed change will re-formulate the FQW(Z) approximation for FQ(Z), revise the surveillance requirements, and revise the required actions when FQ(Z) is not within limits. This change does not result in any physical changes to plant safety-related structures, systems, or components (SSCs)

The proposed changes affect the Surveillance Requirements performed to ensure the Heat Flux Hot Channel Factor, FQ(Z), is within the limits assumed in the safety analyses for previously evaluated accidents. The new surveillance activity involves a reformulation of the transient hot channel factor approximation, FQW(Z), and a more conservative application of applied factors to ensure FQW(Z) remains within limit during subsequent operation up until the next surveillance performance. Both of these changes to the surveillance activity provide assurance that the FQW(Z) remains within the accident analyses assumptions.

The proposed changes also affect the Required Actions and Completion Times should FQ(Z) be found to not be within limit. The new Required Actions and Completion Times ensure the plant is placed in a condition whereby FQ(Z) is restored to within limit in a timely manner. Should FQC(Z) be found not within limit, thermal power is reduced and the NIS and OPT reactor trip setpoints are reduced a conservative amount that retains the margin between the nominal thermal power and reactor trip setpoints. Should FQW(Z) be found not within limit, the core power distribution is constrained by reduced AFD limits, more limiting Rod Insertion Limits, and/or thermal power reductions. These changes to the Required Actions and Completion Times restore FQ(Z) to within the safety analyses assumptions in a timely manner.

The proposed changes do not affect the FQ(Z) limit to which the FQC(Z) and FQW(Z) approximations are compared. Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, TVA concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and accordingly, a finding of no significant hazards consideration is justified.

Conclusions 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 Commissions 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.

Enclosure CNL-19-115 E19 of 19

4.0 ENVIRONMENTAL CONSIDERATION

The proposed TS change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR Part 20, and would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed TS change meets the eligibility criterion for categorical exclusion set forth in 10 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 TS change.

5.0 REFERENCES

1.

NRC Letter to PWROG, Verification Letter of the Approval Version of the Pressurized Water Reactor Owners Group Topical Report WCAP-17661, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, dated August 23, 2019 (ML19225D179)

2.

WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, dated February 2019 (ML19225C079)

3.

NUREG-1431, Revision 4, Volume 1, Standard Technical Specifications Westinghouse Plants, Revision 4.0 Volume 1, Specifications, dated April 2012

4.

NUREG-0847 Supplement 29, Safety Evaluation Report: Related to the Operation of Watts Bar Nuclear Plant, Unit 2, dated October 2015 (ML15282A051)

5.

Westinghouse Nuclear Safety Advisory Letter (NSAL-09-05), Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, dated September 23, 2009

6.

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

7.

WCAP-10216-P-A, Revision 1A, Relaxation of Constant Axial Offset Control/FQ Surveillance Technical Specification, dated February 1994

Enclosure CNL-19-115 Proposed TS Changes (Mark-Ups) for WBN Unit 1

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-1 Amendment XX 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ (Z))

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

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

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

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit 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 75% RTP after a refueling.

FQCQ(Z) not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% FQC (Z) exceeds limit.

AND A.2 Reduce Power Range Neutron FluxHigh trip setpoints > 1%

for each 1% FCQ(Z) exceeds limit. that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

AND A.3 Reduce Overpower T trip setpoints 1% for each 1% FCQ(Z) exceeds limit. that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

AND 15 minutes after each FQC (Z) determination 872 hours0.0101 days 0.242 hours 0.00144 weeks 3.31796e-4 months after each FQC (Z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (Z) determination

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-2 Amendment XX (continued)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

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

FQW (Z) not within limits.

B.1 Reduce AFD limits 1% for each 1% FWQ(Z) exceeds limit.

B.1.1 Implement a RAOC operating space specified in the COLR that restores FQW (Z) to within limits.

AND B.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.

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 and reduce AFD limits as specified in the COLR.

AND B.2.2 Reduce Power Range Neutron Flux - High trip setpoints > 1%

for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1.

AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-3 Amendment XX CONDITION REQUIRED ACTION COMPLETION TIME ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2.3 Reduce Overpower T trip setpoints > 1 % for each 1%

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

AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 C.

Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-4 Amendment XX SURVEILLANCE REQUIREMENTS

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

During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.

SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQC (Z) is within limit.

Once after initial fuel loading and each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 24 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC (Z) was last verified AND 31 EFPD thereafter (continued)

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-4 Amendment 11, 82, XX SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2

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

If FWQ(Z) is within limits and measurements indicate Maximum over z

K(Z)

(Z)

FC Q

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

a.

Increase FWQ(Z) by the appropriate factor specified in the COLR and reverify FWQ(Z) is within limits; or b.

Repeat SR 3.2.1.2 once per 7 EFPD using either the movable incore detectors or the PDMS until two successive power distribution measurements indicate Maximum over z

K(Z)

(Z)

FC Q

has not increased.

Verify FQW (Z) is within limit.

Once after initial fuel loading and each refueling prior to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER exceeding exceeds 75% RTP AND (continued)

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-5 Amendment 11, 82, XX SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.2 (continued)

Once within 12 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQW (Z) was last verified AND 31 EFPD thereafter

Reporting Requirements 5.9 (continued)

Watts Bar-Unit 1 5.0-30 Amendment 7, 11, 20, 31, 46, 127, XXX 5.9 Reporting Requirements 5.9.5 CORE OPERATING LIMITS REPORT (COLR) (continued) 3.

WCAP-10216-P-A, Revision 1A, RELAXATION OF CONSTANT AXIAL OFFSET CONTROL F(Q) SURVEILLANCE TECHNICAL SPECIFICATION, February 1994 (W Proprietary). (Methodology for Specifications 3.2.1 - Heat Flux Hot Channel Factor (W(Z) Surveillance Requirements For F(Q) Methodology) and 3.2.3 - Axial Flux Difference (Relaxed Axial Offset Control).)

4.

WCAP-12610-P-A, VANTAGE + FUEL ASSEMBLY REFERENCE CORE REPORT, April 1995. (W Proprietary). (Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor).

5.

WCAP-15088-P, Rev. 1, Safety Evaluation Supporting A More Negative EOL Moderator Temperature Coefficient Technical Specification for the Watts Bar Nuclear Plant, July 1999, (W Proprietary), as approved by the NRC staffs Safety Evaluation accompanying the issuance of Amendment No. 20 (Methodology for Specification 3.1.4 - Moderator Temperature Coefficient.).

6.

Caldon, Inc. Engineering Report-80P, Improving Thermal Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM' System, Revision 0, March 1997; and Caldon, Inc. Engineering Report-160P, Supplement to Topical Report ER-80P: Basis for a Power Uprate With the LEFM', Revision 0, May 2000; as approved by the NRC staffs Safety Evaluation accompanying the issuance of Amendment No. 31.

7.

WCAP-11397-P-A, Revised Thermal Design Procedure, April 1989.

(Methodology for Specification 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor).

8.

WCAP-15025-P-A, Modified WRB-2 Correlation, WRB-2M, for Predicting Critical Heat Flux in 17 x 17 Rod Bundles with Modified LPD Mixing Vane Grids, April 1999. (Methodology for Specification 3.2.2

- Nuclear Enthalpy Rise Hot Channel Factor).

9.

WCAP-14565-P-A, VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis, October 1999. (Methodology for Specification 3.2.2 -

Nuclear Enthalpy Rise Hot Channel Factor).

10.

WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO'.

11.

WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019 (Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor (T(Z) Surveillance Requirements for FQ Methodology).)

Reporting Requirements 5.9 (continued)

Watts Bar-Unit 1 5.0-30a Amendment 7, 11, 20, 31, 46, 127, XXX 5.9 Reporting Requirements (continued) 5.9.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

c.

The core operating limits shall be determined such that all applicable limits (e.g.,

fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

Enclosure CNL-19-115 Proposed TS Changes (Mark-Ups) for WBN Unit 2

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-1 Amendment XX 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ (Z))

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

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NOTE----------------

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit 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 75% RTP after a refueling.

FQC (Z) not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% FQC (Z) exceeds limit.

15 minutes after each FQCQ (Z) determination AND A.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% FQC (Z) exceeds limit.

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

872 hours0.0101 days 0.242 hours 0.00144 weeks 3.31796e-4 months after each FQC (Z) determination AND

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-2 Amendment XX ACTIONS (continued)

A. (continued)

A.3 Reduce Overpower T trip setpoints 1% for each 1% FQC (Z) exceeds limit. that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (Z) determination AND A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

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

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-3 Amendment XX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. FQW (Z) not within limits.

B.1 B.1.1 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 4 hours B.1.2 Reduce AFD limits 1%

for each 1% FQW (Z) exceeds limit.

Implement a RAOC operating space specified in the COLR that restores FQW (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.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND OR

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-4 Amendment XX CONDITION REQUIRED ACTION COMPLETION TIME B.2.1

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

Required Actions B.2.1, B.2.2, B.2.3, and B.2.4 not required if SR 3.2.1.2 was performed at < 75%

RTP.

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.

Reduce maximum allowable power 3%

RTP for each 1% FQW (Z) exceeds limit. Limit THERMAL POWER to less than RATED THERMAL POWER and reduce AFD limits as specified in the COLR.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND B.2.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% the maximum allowable power is reduced that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-5 Amendment XX CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2.3 Reduce Overpower T trip setpoints 1% for each 1% the maximum allowable power is reduced that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-6 Amendment XX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months SURVEILLANCE REQUIREMENTS

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

During power escalation at the beginning of each cycle, THERMAL POWER may be increased until an equilibrium power level has been achieved, at which a power distribution map is obtained.

SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQC (Z) is within limit.

Once after initial fuel loading and each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 24 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC (Z) was last verified AND 31 EFPD thereafter (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-7 Amendment XX SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2

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

If FQW (Z), increased by the appropriate factor specified in the COLR, is not within limits:

Repeat SR 3.2.1.2 once per 7 EFPD using the Power Distribution Monitoring System (PDMS) until two successive incore power distribution measurements indicate Maximum over z

()

AND Maximum over z

()()

()

have not increased.

Verify FQW (Z) is within limit.

Once after initial fuel loading and each refueling prior to within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER exceeding exceeds 75% RTP AND (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-8 Amendment XX SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.2 (continued)

Once within 24 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 FQW (Z) was last verified AND 31 EFPD thereafter

Reporting Requirements 5.9 5.9 Reporting Requirements (continued)

Watts Bar - Unit 2 5.0-31 Amendment XX 5.9.5 CORE OPERATING LIMITS REPORT (COLR) (continued) 1.

WCAP-9272-P-A, WESTINGHOUSE RELOAD SAFETY EVALUATION METHODOLOGY, July 1985 (W Proprietary). (Methodology for Specifications 3.1.4 - Moderator Temperature Coefficient, 3.1.6 -

Shutdown Bank Insertion Limit, 3.1.7 - Control Bank Insertion Limits, 3.2.1 - Heat Flux Hot Channel Factor, 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor, 3.2.3 - Axial Flux Difference, and 3.9.1 - Boron Concentration).

2a. WCAP-16009-P-A, Realistic Large-Break LOCA Evaluation Methodology Using the Automated Statistical Treatment of Uncertainty Method (ASTRUM), January 2005 (W Proprietary).(Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor, and 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor).

2b. WCAP-10054-P-A, Small Break ECCS Evaluation Model Using NOTRUMP Code, August 1985. Addendum 2, Rev. 1: Addendum to the Westinghouse Small Break ECCS Evaluation Model using the NOTRUMP Code: Safety Injection into the Broken Loop and COSI Condensation Model, July 1997. (W Proprietary). (Methodology for Specifications 3.2.1 - Heat Flux Hot Channel Factor, and 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor).

3.

WCAP-10216-P-A, Revision 1A, RELAXATION OF CONSTANT AXIAL OFFSET CONTROL F(Q) SURVEILLANCE TECHNICAL SPECIFICATION, February 1994 (W Proprietary). (Methodology for Specifications 3.2.1 - Heat Flux Hot Channel Factor (W(Z) Surveillance Requirements For F(Q) Methodology) and 3.2.3 - Axial Flux Difference (Relaxed Axial Offset Control).)

4.

WCAP-12610-P-A, VANTAGE + FUEL ASSEMBLY REFERENCE CORE REPORT, April 1995. (W Proprietary). (Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor).

Reporting Requirements 5.9 5.9 Reporting Requirements 5.9.5 CORE OPERATING LIMTS REPORT (COLR) (continued)

(continued)

Watts Bar - Unit 2 5.0-33 Amendment XX

11. WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019 (Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor (T(Z) Surveillance Requirements for FQ Methodology).)

c.

The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

Enclosure CNL-19-115 Proposed WBN Unit 2 OL Condition 2.C.10 (Mark-Ups)

Amendment 19, XX TVA may make changes to the approved fire protection program without prior approval of the Commission, only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

(9)

By May 31, 2018, TVA shall report that a listing organization acceptable to the NRC (as the Authority Having Jurisdiction) has determined that the fire detection monitoring panel in the main control room either meets the appropriate designated standards or has been tested and found suitable for the specified purpose.

(10)

TVA will verify for each core reload that the actions taken if FQW(Z) is not within limits will assure that the limits on core power peaking FQ(Z) remain below the initial total peaking factor assumed in the accident analyses.Deleted (11)

TVA will implement the compensatory measures described in Section 3.4, Additional Compensatory Measures, of TVA Letter CNL-18-012, dated January 17, 2018, during the timeframe the temperature indicator for RCS hot let 3 is not required to be operable for the remainder of Cycle 2. If the RCS hot leg 3 temperature indicator is returned to operable status prior to the end of Cycle 2, then these compensatory measures are no longer required.

D.

The licensee shall have and maintain financial protection of such types and in such amounts as the Commission shall require in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.

E.

This license is effective as of the date of issuance and shall expire at midnight on October 21, 2055.

FOR THE NUCLEAR REGULATORY COMMISSION William M. Dean, Director Office of Nuclear Reactor Regulation Appendices: 1. Appendix A -

Technical Specifications

2. Appendix B -

Environmental Protection Plan Date of Issuance: October 22, 2015

Enclosure CNL-19-115 Proposed TS Changes (Final Typed) for WBN Unit 1

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-1 Amendment XX 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ(Z))

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

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

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

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit 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 75% RTP after a refueling.

FQC (Z) not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% FQC (Z) exceeds limit.

AND A.2 Reduce Power Range Neutron FluxHigh trip setpoints > 1%

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

AND A.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

AND 15 minutes after each FQC (Z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (Z) determination 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (Z) determination (continued)

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-2 Amendment XX CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

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

FQW (Z) not within limits.

B.1.1 Implement a RAOC operating space specified in the COLR that restores FQW (Z) to within limits.

AND B.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.

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 and reduce AFD limits as specified in the COLR.

AND B.2.2 Reduce Power Range Neutron Flux - High trip setpoints > 1%

for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 72 hours ACTIONS (continued)

(continued)

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-3 Amendment XX CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2.3 Reduce Overpower T trip setpoints > 1 % for each 1%

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

AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 C.

Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ACTIONS (continued)

(continued)

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-4 Amendment XX SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQC (Z) is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC (Z) was last verified AND 31 EFPD thereafter (continued)

FQ(Z) 3.2.1 Watts Bar-Unit 1 3.2-5 Amendment 11, 82, XX SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.1.2 Verify FQW (Z) is within limit.

Once after each refueling within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER exceeds 75% RTP AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQW (Z) was last verified AND 31 EFPD thereafter

Reporting Requirements 5.9 (continued)

Watts Bar-Unit 1 5.0-30 Amendment 7, 11, 20, 31, 46, 127, XXX 5.9 Reporting Requirements 5.9.5 CORE OPERATING LIMITS REPORT (COLR) (continued) 3.

WCAP-10216-P-A, Revision 1A, RELAXATION OF CONSTANT AXIAL OFFSET CONTROL F(Q) SURVEILLANCE TECHNICAL SPECIFICATION, February 1994 (W Proprietary). (Methodology for Specification 3.2.3 - Axial Flux Difference (Relaxed Axial Offset Control).)

4.

WCAP-12610-P-A, VANTAGE + FUEL ASSEMBLY REFERENCE CORE REPORT, April 1995. (W Proprietary). (Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor).

5.

WCAP-15088-P, Rev. 1, Safety Evaluation Supporting A More Negative EOL Moderator Temperature Coefficient Technical Specification for the Watts Bar Nuclear Plant, July 1999, (W Proprietary), as approved by the NRC staffs Safety Evaluation accompanying the issuance of Amendment No. 20 (Methodology for Specification 3.1.4 - Moderator Temperature Coefficient.).

6.

Caldon, Inc. Engineering Report-80P, Improving Thermal Accuracy and Plant Safety While Increasing Operating Power Level Using the LEFM' System, Revision 0, March 1997; and Caldon, Inc.

Engineering Report-160P, Supplement to Topical Report ER-80P:

Basis for a Power Uprate With the LEFM', Revision 0, May 2000; as approved by the NRC staffs Safety Evaluation accompanying the issuance of Amendment No. 31.

7.

WCAP-11397-P-A, Revised Thermal Design Procedure, April 1989.

(Methodology for Specification 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor).

8.

WCAP-15025-P-A, Modified WRB-2 Correlation, WRB-2M, for Predicting Critical Heat Flux in 17 x 17 Rod Bundles with Modified LPD Mixing Vane Grids, April 1999. (Methodology for Specification 3.2.2 - Nuclear Enthalpy Rise Hot Channel Factor).

9.

WCAP-14565-P-A, VIPRE-01 Modeling and Qualification for Pressurized Water Reactor Non-LOCA Thermal-Hydraulic Safety Analysis, October 1999. (Methodology for Specification 3.2.2 -

Nuclear Enthalpy Rise Hot Channel Factor).

10.

WCAP-12610-P-A and CENPD-404-P-A, Addendum 1-A, Optimized ZIRLO'.

11.

WCAP-17661-P-A, Revision 1, Improved RAOC and CAOC FQ Surveillance Technical Specifications, February 2019 (Methodology for Specification 3.2.1 - Heat Flux Hot Channel Factor (T(Z)

Surveillance Requirements for FQ Methodology).)

Reporting Requirements 5.9 (continued)

Watts Bar-Unit 1 5.0-30a Amendment 7, 11, 20, 31, 46, 127, XXX 5.9 Reporting Requirements (continued) 5.9.5 CORE OPERATING LIMITS REPORT (COLR) (continued) c.

The core operating limits shall be determined such that all applicable limits (e.g.,

fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.

d.

The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC.

Enclosure CNL-19-115 Proposed TS Changes (Final Typed) for WBN Unit 2

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-1 Amendment XX 3.2 POWER DISTRIBUTION LIMITS 3.2.1 Heat Flux Hot Channel Factor (FQ (Z))

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

APPLICABILITY:

MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------NOTE----------------

Required Action A.4 shall be completed whenever this Condition is entered prior to increasing THERMAL POWER above the limit 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 75% RTP after a refueling.

FQC (Z) not within limit.

A.1 Reduce THERMAL POWER 1% RTP for each 1% FQC (Z) exceeds limit.

15 minutes after each FC (Z) determination AND A.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (Z) determination AND (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-2 Amendment XX ACTIONS (continued)

A. (continued)

A.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action A.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each FQC (Z) determination AND A.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

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

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-3 Amendment XX ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. FQW (Z) not within limits.

B.1.1 Implement a RAOC operating space specified in the COLR that restores FQW (Z) to within limits.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND B.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.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 and reduce AFD limits as specified in the COLR.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND B.2.2 Reduce Power Range Neutron Flux - High trip setpoints 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-4 Amendment XX CONDITION REQUIRED ACTION COMPLETION TIME B. (continued)

B.2.3 Reduce Overpower T trip setpoints 1% for each 1% that THERMAL POWER is limited below RATED THERMAL POWER by Required Action B.2.1.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND B.2.4 Perform SR 3.2.1.1 and SR 3.2.1.2.

Prior to increasing THERMAL POWER above the limit of Required Action B.2.1 C. Required Action and associated Completion Time not met.

C.1 Be in MODE 2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (continued)

ACTIONS (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-5 Amendment XX SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify FQC (Z) is within limit.

Once after each refueling prior to THERMAL POWER exceeding 75% RTP AND Once within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after achieving equilibrium conditions after exceeding, by 10% RTP, the THERMAL POWER at which FQC (Z) was last verified AND 31 EFPD thereafter (continued)

FQ (Z) 3.2.1 Watts Bar - Unit 2 3.2-5a Amendment XX SURVEILLANCE REQUIREMENTS (continued)