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Enclosure 2: Hope Creek Generating Station Improved Technical Specifications Conversion - Volume 7
	ML24142A435
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Site:	Hope Creek
Issue date:	05/20/2024
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To:	; Office of Nuclear Reactor Regulation
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ENCLOSURE 2 VOLUME 7 HOPE CREEK GENERATING STATION IMPROVED TECHNICAL SPECIFICATIONS CONVERSION ITS SECTION 3.2 POWER DISTRIBUTION LIMITS Revision 0

LIST OF ATTACHMENTS

1.

ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

2.

ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

3.

ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

4.

ISTS Not Adopted

ATTACHMENT 1 ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

3/4.2 POWER DISTRIBUTION LIMITS 3/4.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE LIMITING CONDITION FOR OPERATION 3.2.1 All AVERAGE PLANAR LINEAR HEAT GENERATION RATES (APLHGRs) shall be less than or equal to the limits specified in the CORE OPERATING LIMITS REPORT.

APPLICABILITY: OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER.

ACTION:

With an APLHGR exceeding the limits specified in the CORE OPERATING LIMITS REPORT, initiate corrective action within 15 minutes and restore APLHGR to within the required limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or reduce THERMAL POWER to less than 24% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.2.1 All APLHGRs shall be verified to be equal to or less than the limits specified in the CORE OPERATING LIMITS REPORT:

a.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter.

b.

Initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for APLHGR.

HOPE CREEK 3/4 2-1 Amendment No. 187 A01 ITS 3.2.1 ITS (APLHGR)

COLR RTP LCO 3.2.1 Applicability S

Any not within RTP ACTION A ACTION B (s)

SR 3.2.1.1 Verify are COLR.

RTP SR 3.2.1.1 Frequency L01 LA01 A02

POWER DISTRIBUTION LIMITS 3/4.2.2 DELETED HOPE CREEK 3/4 2-2 Amendment No. 163 A01 ITS 3.2.1

DISCUSSION OF CHANGES ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Hope Creek Page 1 of 2 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications-General Electric BWR/4 Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS Applicability states OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER. ITS Applicability states THERMAL POWER 24% RTP. This changes the CTS by not specifying Operational Condition 1 (ITS MODE 1) in the Applicability because the unit will be in MODE 1 when THERMAL POWER is 24% RTP.

The purpose of CTS 3.2.1 Applicability is to establish the Operational Condition (i.e., ITS MODE) in which the LCO is required. This change is acceptable because the Applicability of 24% RTP is not changed. This change is designated as an administrative change and is acceptable because it does not result a in technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.1 Action states, With an APLHGR exceeding the limits specified in the CORE OPERATING LIMITS REPORT, initiate corrective action within 15 minutes and restore APLHGR to within the required limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.2.1 ACTION A states that with any APLHGR not within limits, restore APLHGR(s) to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS does not include the requirement to initiate corrective action within 15 minutes. This changes the CTS by moving the procedural detail that prompt action should be taken to restore the APLHGRs to within the required limits to the ITS Bases.

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This

DISCUSSION OF CHANGES ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Hope Creek Page 2 of 2 change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural detail that prompt action should be taken to restore the APLHGRs to within the required limits is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation Of Surveillance Frequency) CTS 4.2.1.a and b state All APLHGRs shall be verified to be equal to or less than the limits specified in the CORE OPERATING LIMITS REPORT with Frequencies of Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter and Initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for APLHGR. ITS SR 3.2.1.1 states Verify all APLHGRs are less than or equal to the limits specified in the COLR once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 24% RTP AND In accordance with the Surveillance Frequency Control Program. This changes the CTS by deleting the Frequency requirement initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for APLHGR.

The purpose of ITS SR 3.2.1.1 is to verify all APLHGRs are less than or equal to the limits specified in the COLR. This change is acceptable because the deleted Surveillance Frequency is not necessary to verify the APLHGRS are within limits.

This surveillance has been evaluated to ensure that it provides an acceptable level of measurement to ensure the LCO is met. This change does not result in a reduction in the level of safety because a Limiting Control Rod Pattern is defined as a pattern which results in the core being on a thermal hydraulic limit (i.e.,

operating on a limiting value for APLHGR, LHGR, or MCPR). It is not evident that a Limiting Control Rod Pattern has been achieved until the Surveillance is performed.

Additionally, the core monitoring system (CMS) monitors core conditions including Thermal Limits. The CMS determines thermal limits when a calculation is initiated for a period report. The CMS generates a report at the time interval for automatic monitoring set by the operator (typically 30 minutes), or the report may be generated manually by the operator. The CMS is available in the Main Control Room. This change is designated as less restrictive because a Surveillance Frequency which is required in the CTS will not be required in the ITS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

APLHGR 3.2.1 General Electric BWR/4 STS 3.2.1-1 Rev. 5.0 CTS Hope Creek Amendment XXX 1

3.2 POWER DISTRIBUTION LIMITS 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

LCO 3.2.1 All APLHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY:

THERMAL POWER 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any APLHGR not within limits.

A.1 Restore APLHGR(s) to within limits.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to < 25% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 3/4.2.1 3.2.1 Applicability ACTION ACTION 3/4.2 24 24 3

3

APLHGR 3.2.1 General Electric BWR/4 STS 3.2.1-2 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify all APLHGRs are less than or equal to the limits specified in the COLR.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 25% RTP AND

[ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter OR In accordance with the Surveillance Frequency Control Program ]

4.2.1 2

24 3

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ITS 3.2.1 is changed to provide the proper plant specific THERMAL POWER value.

This is acceptable since the value is changed to reflect the current licensing basis.

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

APLHGR B 3.2.1 General Electric BWR/4 STS B 3.2.1-1 Rev. 5.0 Hope Creek Revision XXX 1

B 3.2 POWER DISTRIBUTION LIMITS B 3.2.1 AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

BASES BACKGROUND The APLHGR is a measure of the average LHGR of all the fuel rods in a fuel assembly at any axial location. Limits on the APLHGR are specified to ensure that the fuel design limits identified in Reference 1 are not exceeded during anticipated operational occurrences (AOOs) and that the peak cladding temperature (PCT) during the postulated design basis loss of coolant accident (LOCA) does not exceed the limits specified in 10 CFR 50.46.

APPLICABLE The analytical methods and assumptions used in evaluating the fuel SAFETY design limits are presented in References 1 and 2. The analytical ANALYSES methods and assumptions used in evaluating Design Basis Accidents (DBAs), anticipated operational transients, and normal operation that determine the APLHGR limits are presented in References 1, 2, 3, 4, 5, 6, and 7.

Fuel design evaluations are performed to demonstrate that the 1% limit on the fuel cladding plastic strain and other fuel design limits described in Reference 1 are not exceeded during AOOs for operation with LHGRs up to the operating limit LHGR. APLHGR limits are equivalent to the LHGR limit for each fuel rod divided by the local peaking factor of the fuel assembly. APLHGR limits are developed as a function of exposure and the various operating core flow and power states to ensure adherence to fuel design limits during the limiting AOOs (Refs. 5, 6, and 7). Flow dependent APLHGR limits are determined using the three dimensional BWR simulator code (Ref. 8) to analyze slow flow runout transients. The flow dependent multiplier, MAPFACf, is dependent on the maximum core flow runout capability. The maximum runout flow is dependent on the existing setting of the core flow limiter in the Recirculation Flow Control System.

Based on analyses of limiting plant transients (other than core flow increases) over a range of power and flow conditions, power dependent multipliers, MAPFACp, are also generated. Due to the sensitivity of the transient response to initial core flow levels at power levels below those at which turbine stop valve closure and turbine control valve fast closure scram trips are bypassed, both high and low core flow MAPFACp limits are provided for operation at power levels between 25% RTP and the previously mentioned bypass power level. The exposure dependent APLHGR limits are reduced by MAPFACp and MAPFACf at various operating conditions to ensure that all fuel design criteria are met for normal operation and AOOs. A complete discussion of the analysis code is provided in Reference 9.

1 1

1

APLHGR B 3.2.1 General Electric BWR/4 STS B 3.2.1-2 Rev. 5.0 Hope Creek Revision XXX 1

BASES APPLICABLE SAFETY ANALYSES (continued)

LOCA analyses are then performed to ensure that the above determined APLHGR limits are adequate to meet the PCT and maximum oxidation limits of 10 CFR 50.46. The analysis is performed using calculational models that are consistent with the requirements of 10 CFR 50, Appendix K. A complete discussion of the analysis code is provided in Reference 10. The PCT following a postulated LOCA is a function of the average heat generation rate of all the rods of a fuel assembly at any axial location and is not strongly influenced by the rod to rod power distribution within an assembly. The APLHGR limits specified are equivalent to the LHGR of the highest powered fuel rod assumed in the LOCA analysis divided by its local peaking factor. A conservative multiplier is applied to the LHGR assumed in the LOCA analysis to account for the uncertainty associated with the measurement of the APLHGR.

For single recirculation loop operation, the MAPFAC multiplier is limited to a maximum of 0.75 (Ref. 5). This maximum limit is due to the conservative analysis assumption of an earlier departure from nucleate boiling with one recirculation loop available, resulting in a more severe cladding heatup during a LOCA.

The APLHGR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The APLHGR limits specified in the COLR are the result of the fuel design, DBA, and transient analyses. For two recirculation loops operating, the limit is determined by multiplying the smaller of the MAPFACp and MAPFACf factors times the exposure dependent APLHGR limits. With only one recirculation loop in operation, in conformance with the requirements of LCO 3.4.1, "Recirculation Loops Operating," the limit is determined by multiplying the exposure dependent APLHGR limit by the smaller of either MAPFACp, MAPFACf, and 0.75, where 0.75 has been determined by a specific single recirculation loop analysis (Ref. 5).

APPLICABILITY The APLHGR limits are primarily derived from fuel design evaluations and LOCA and transient analyses that are assumed to occur at high power levels. Design calculations (Ref. 7) and operating experience have shown that as power is reduced, the margin to the required APLHGR limits increases. This trend continues down to the power range of 5% to 15% RTP when entry into MODE 2 occurs. When in MODE 2, the intermediate range monitor scram function provides prompt scram initiation during any significant transient, thereby effectively removing any APLHGR limit compliance concern in MODE 2. Therefore, at THERMAL POWER levels 25% RTP, the reactor is operating with substantial margin to the APLHGR limits; thus, this LCO is not required.

3 24 1

1 0.90 0.90 8

1 1

APLHGR B 3.2.1 General Electric BWR/4 STS B 3.2.1-3 Rev. 5.0 Hope Creek Revision XXX 1

BASES ACTIONS A.1 If any APLHGR exceeds the required limits, an assumption regarding an initial condition of the DBA and transient analyses may not be met.

Therefore, prompt action should be taken to restore the APLHGR(s) to within the required limits such that the plant operates within analyzed conditions and within design limits of the fuel rods. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is sufficient to restore the APLHGR(s) to within its limits and is acceptable based on the low probability of a transient or DBA occurring simultaneously with the APLHGR out of specification.

B.1 If the APLHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to in a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS APLHGRs are required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 25% RTP and periodically thereafter. They are compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

[ The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation.

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

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

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

]

4 4

2 3

3 3

3 24 24 24 24

APLHGR B 3.2.1 General Electric BWR/4 STS B 3.2.1-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES REFERENCES

1.

NEDO-24011-P-A "General Electric Standard Application for Reactor Fuel" (latest approved version).

2.

FSAR, Chapter [4].

3.

FSAR, Chapter [6].

4.

FSAR, Chapter [15].

5.

[Plant specific single loop operation].

6.

[Plant specific load line limit analysis].

7.

[Plant Specific Average Power Range Monitor, Rod Block Monitor and Technical Specification Improvements (ARTS) Program].

8.

NEDO-30130-A, "Steady State Nuclear Methods," May 1985.

9.

NEDO-24154, "Qualification of the One-Dimensional Core Transient Model for Boiling Water Reactors," October 1978.

10.

[Plant specific loss of coolant accident analysis].

2 2

GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident, Volume III, SAFER/GESTR Application Methodology, NEDE-23785-1-PA, General Electric Company, Revision 1, October 1984.

NEDC-33270P, GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II) (latest approved version).

NEDE-32906P Supplement 3-A, Migration to TRACG04 / PANAC11 from TRACG02 / PANAC10 for TRACG AOO and ATWS Overpressure Transients, Revision 1, April 2010.

NEDE-32906P-A, TRACG Application for Anticipated Operational Occurrences (AOO) Transient Analyses," Revision 3, September 2006.

UFSAR, Appendix 15D.4, Single Loop Operation.

U U

1 1

1

JUSTIFICATION FOR DEVIATIONS ITS 3.2.1 BASES, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ITS 3.2.1 is changed to provide the proper plant specific THERMAL POWER value.

This is acceptable since the value is changed to reflect the current licensing basis.

4. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Determination of No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.1, AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)

Hope Creek Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 2 ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

POWER DISTRIBUTION LIMITS 3/4.2.3 MINIMUM CRITICAL POWER RATIO LIMITING CONDITION FOR OPERATION 3.2.3 The MINIMUM CRITICAL POWER RATIO (MCPR) shall be equal to or greater than the MCPR limit specified in the CORE OPERATING LIMITS REPORT.

APPLICABILITY: OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER.

ACTION:

a.

With the end-of-cycle recirculation pump trip system inoperable per Specification 3.3.4.2, operation may continue provided that, within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , MCPR is determined to be greater than or equal to the EOC-RPT inoperable limit specified in the CORE OPERATING LIMITS REPORT.

b.

With MCPR less than the applicable MCPR limit specified in the CORE OPERATING LIMITS REPORT, initiate corrective action within 15 minutes and restore MCPR to within the required limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or reduce THERMAL POWER to less than 24% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.2.3 MCPR, shall be determined to be equal to or greater than the applicable MCPR limit specified in the CORE OPERATING LIMITS REPORT:

a.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter.

b.

Initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for MCPR.

HOPE CREEK 3/4 2-3 Amendment No. 187 A01 ITS 3.2.2 ITS 3.2 (MCPR)

LCO 3.2.2 Applicability ACTION A ACTION B SR 3.2.2.1 SR 3.2.2.1 Frequency S

RTP Any not within s

RTP LA01 L01 Verify all s

are s

COLR.

RTP Add proposed SR 3.2.2.2 SR 3.2.2.2 M01 2

All s

s operating COLR See ITS 3.3.4.1 A02 (s)

(s)

This page intentionally left blank HOPE CREEK 3/4 2-4 Amendment No. 126 A01 ITS 3.2.2

DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Hope Creek Page 1 of 3 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications-General Electric BWR/4 Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS Applicability states OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER. ITS Applicability states THERMAL POWER 24% RTP. This changes the CTS by not specifying Operational Condition 1 (ITS MODE 1) in the Applicability because the unit will be in MODE 1 when THERMAL POWER is 24% RTP.

The purpose of CTS 3.2.3 Applicability is to establish the Operational Condition (i.e., ITS MODE) in which the LCO is required. This change is acceptable because the Applicability of 24% RTP is not changed. This change is designated as an administrative change and is acceptable because it does not result a in technical change to the CTS.

MORE RESTRICTIVE CHANGES M01 CTS 3.2.3 does not contain an explicit requirement to determine MCPR limits following control rod scram time testing. ITS SR 3.2.2.2 requires MCPR limits be determined following scram time testing specified in ITS 3.1.4, Control Rod Scram Times. This changes the CTS by adding the ITS SR 3.2.2.2 requirement.

Because the transient analysis takes credit for conservatism in the scram speed performance, it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis. SR 3.2.2.2 determines the value of Tau (), which is a measure of the actual scram speed distribution compared with the assumed distribution. The MCPR operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4, Control Rod Scram Times) and Option B (realistic scram times) analyses. This change is acceptable because it determines the MCPR limits following scram time tests required by ITS SR 3.1.4.1, SR 3.1.4.2, and SR 3.1.4.4 because the effective scram speed distribution may change during the cycle or after maintenance that could affect scram times. This change is designated as more restrictive because it adds a Surveillance Requirement to the CTS.

RELOCATED SPECIFICATIONS None

DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Hope Creek Page 2 of 3 REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.3.b Action states With MCPR less than the applicable MCPR limits specified in the CORE OPERATING LIMITS REPORT, initiate corrective action within 15 minutes and restore MCPR to within the required limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.2.2 ACTION A states that with any MCPR not within limits, restore MCPR(s) to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS does not include the requirement to initiate corrective action within 15 minutes. This changes the CTS by moving the procedural detail that prompt action should be taken to restore MCPR to within the required limits to the ITS Bases.

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural detail that prompt action should be taken to restore MCPR to within the required limits is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation Of Surveillance Frequency) CTS 4.2.3.a and b state MCPR shall be determined to be equal to or greater than the applicable MCPR limit specified in the CORE OPERATING LIMITS REPORT with Frequencies of Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is greater than or equal to 24%

of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter and Initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for MCPR. ITS SR 3.2.2.1 states Verify all MCPRs are greater than or equal to the limits specified in the COLR once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 24% RTP AND In accordance with the Surveillance Frequency Control Program. This changes the CTS by deleting the Frequency requirement initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for MCPR.

The purpose of ITS SR 3.2.2.1 is to verify all MCPRs are greater than or equal to the limits specified in the COLR. This change is acceptable because the deleted Surveillance Frequency is not necessary to verify the MCPRs are within limits.

This surveillance has been evaluated to ensure that it provides an acceptable level of measurement to ensure the LCO is met. This change does not result in a reduction in the level of safety because a Limiting Control Rod Pattern is defined as a pattern which results in the core being on a thermal hydraulic limit (i.e.,

operating on a limiting value for APLHGR, LHGR, or MCPR). It is not evident that

DISCUSSION OF CHANGES ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Hope Creek Page 3 of 3 a Limiting Control Rod Pattern has been achieved until the Surveillance is performed.

Additionally, the core monitoring system (CMS) monitors core conditions including Thermal Limits. The CMS determines thermal limits when a calculation is initiated for a period report. The CMS generates a report at the time interval for automatic monitoring set by the operator (typically 30 minutes), or the report may be generated manually by the operator. The CMS is available in the Main Control Room. This change is designated as less restrictive because a Surveillance Frequency which is required in the CTS will not be required in the ITS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

MCPR 3.2.2 General Electric BWR/4 STS 3.2.2-1 Rev. 5.0 CTS Hope Creek Amendment XXX 1

3.2 POWER DISTRIBUTION LIMITS 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

LCO 3.2.2 All MCPRs shall be greater than or equal to the MCPR operating limits specified in the COLR.

APPLICABILITY:

THERMAL POWER 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any MCPR not within limits.

A.1 Restore MCPR(s) to within limits.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to < 25% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify all MCPRs are greater than or equal to the limits specified in the COLR.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 25% RTP AND

[ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter OR In accordance with the Surveillance Frequency Control Program ]

3/4.2.3 3.2.3 Applicability ACTION ACTION 24 24 4.2.3.a 2

24 3

3 3

MCPR 3.2.2 General Electric BWR/4 STS 3.2.2-2 Rev. 5.0 CTS Hope Creek Amendment XXX 1

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.2.2.2 Determine the MCPR limits.

Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.1 AND Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.2 AND Once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each completion of SR 3.1.4.4 M01

JUSTIFICATION FOR DEVIATIONS ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ITS 3.2.2 is changed to provide the proper plant specific THERMAL POWER value.

This is acceptable since the value is changed to reflect the current licensing basis.

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

MCPR B 3.2.2 General Electric BWR/4 STS B 3.2.2-1 Rev. 5.0 Hope Creek Revision XXX 1

B 3.2 POWER DISTRIBUTION LIMITS B 3.2.2 MINIMUM CRITICAL POWER RATIO (MCPR)

BASES BACKGROUND MCPR is a ratio of the fuel assembly power that would result in the onset of boiling transition to the actual fuel assembly power. The operating limit MCPR is established to ensure that no fuel damage results during anticipated operational occurrences (AOOs), and that 99.9% of the fuel rods are not susceptible to boiling transition if the limit is not violated.

Although fuel damage does not necessarily occur if a fuel rod actually experienced boiling transition (Ref. 1), the critical power at which boiling transition is calculated to occur has been adopted as a fuel design criterion.

The onset of transition boiling is a phenomenon that is readily detected during the testing of various fuel bundle designs. Based on these experimental data, correlations have been developed to predict critical bundle power (i.e., the bundle power level at the onset of transition boiling) for a given set of plant parameters (e.g., reactor vessel pressure, flow, and subcooling). Because plant operating conditions and bundle power levels are monitored and determined relatively easily, monitoring the MCPR is a convenient way of ensuring that fuel failures due to inadequate cooling do not occur.

APPLICABLE

REVIEWER'S NOTE -------------------------------

SAFETY Incorporate the MCPR95/95 discussion if applicable.

ANALYSES The analytical methods and assumptions used in evaluating the AOOs to establish the operating limit MCPR are presented in References 2, 3, 4, 5, 6, 7, and 8. To ensure that the MCPR Safety Limit (SL) is not exceeded during any transient event that occurs with moderate frequency, limiting transients have been analyzed to determine the largest reduction in critical power ratio (CPR). The types of transients evaluated are loss of flow, increase in pressure and power, positive reactivity insertion, and coolant temperature decrease. The limiting transient yields the largest change in CPR (CPR). When the largest CPR is combined with the

[SL] MCPR[99.9%], the required operating limit MCPR is obtained.

[MCPR99.9% is determined to ensure more than 99.9% of the fuel rods in the core are not susceptible to boiling transition using a statistical model that combines all the uncertainties in operating parameters and the procedures used to calculate critical power. The probability of the occurrence of boiling transition is determined using the approved Critical 4

4 2

MCPR B 3.2.2 General Electric BWR/4 STS B 3.2.2-2 Rev. 5.0 Hope Creek Revision XXX 1

BASES APPLICABLE SAFETY ANALYSES (continued)

Power correlations. Details of the MCPR99.9% calculation are given in Reference 2. Reference 2 also includes a tabulation of the uncertainties and the nominal values of the parameters used in the MCPR99.9%

statistical analysis.]

The MCPR operating limits are derived from [the MCPR99.9% value and]

the transient analysis, and are dependent on the operating core flow and power state (MCPRf and MCPRp, respectively) to ensure adherence to fuel design limits during the worst transient that occurs with moderate frequency (Refs. 6, 7, and 8). Flow dependent MCPR limits are determined by steady state thermal hydraulic methods with key physics response inputs benchmarked using the three dimensional BWR simulator code (Ref. 9) to analyze slow flow runout transients. The operating limit is dependent on the maximum core flow limiter setting in the Recirculation Flow Control System.

Power dependent MCPR limits (MCPRp) are determined by approved transient analysis models (Ref. 10). Due to the sensitivity of the transient response to initial core flow levels at power levels below those at which the turbine stop valve closure and turbine control valve fast closure scrams are bypassed, high and low flow MCPRp operating limits are provided for operating between 25% RTP and the previously mentioned bypass power level.

The MCPR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

LCO The MCPR operating limits specified in the COLR [(MCPR99.9% value, MCPRf values, and MCPRp values)] are the result of the Design Basis Accident (DBA) and transient analysis. The operating limit MCPR is determined by the larger of the MCPRf and MCPRp limits[, which are based on the MCPR99.9% limit specified in the COLR.]

APPLICABILITY The MCPR operating limits are primarily derived from transient analyses that are assumed to occur at high power levels. Below 25% RTP, the reactor is operating at a minimum recirculation pump speed and the moderator void ratio is small. Surveillance of thermal limits below 25% RTP is unnecessary due to the large inherent margin that ensures that the MCPR SL is not exceeded even if a limiting transient occurs.

Statistical analyses indicate that the nominal value of the initial MCPR expected at 25% RTP is > 3.5. Studies of the variation of limiting transient behavior have been performed over the range of power and flow conditions. These studies encompass the range of key actual plant operation 24% RTP. Critical power test data indicates that sufficient margin to critical power exists below 24% RTP 24 24 3

3 3

3 1

4 2

MCPR B 3.2.2 General Electric BWR/4 STS B 3.2.2-3 Rev. 5.0 Hope Creek Revision XXX 1

BASES APPLICABILITY (continued) parameter values important to typically limiting transients. The results of these studies demonstrate that a margin is expected between performance and the MCPR requirements, and that margins increase as power is reduced to 25% RTP. This trend is expected to continue to the 5% to 15% power range when entry into MODE 2 occurs. When in MODE 2, the intermediate range monitor provides rapid scram initiation for any significant power increase transient, which effectively eliminates any MCPR compliance concern. Therefore, at THERMAL POWER levels

< 25% RTP, the reactor is operating with substantial margin to the MCPR limits and this LCO is not required.

ACTIONS A.1 If any MCPR is outside the required limits, an assumption regarding an initial condition of the design basis transient analyses may not be met.

Therefore, prompt action should be taken to restore the MCPR(s) to within the required limits such that the plant remains operating within analyzed conditions. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is normally sufficient to restore the MCPR(s) to within its limits and is acceptable based on the low probability of a transient or DBA occurring simultaneously with the MCPR out of specification.

B.1 If the MCPR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER must be reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.2.1 REQUIREMENTS The MCPR is required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 25% RTP and periodically thereafter. It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

[ The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation.

3 3

24 24 3

3 3

3 2

24 24 24 24

MCPR B 3.2.2 General Electric BWR/4 STS B 3.2.2-4 Rev. 5.0 Hope Creek Revision XXX 1

BASES SURVEILLANCE REQUIREMENTS (continued)

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

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

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

]

SR 3.2.2.2 Because the transient analysis takes credit for conservatism in the scram speed performance, it must be demonstrated that the specific scram speed distribution is consistent with that used in the transient analysis.

SR 3.2.2.2 determines the value of, which is a measure of the actual scram speed distribution compared with the assumed distribution. The MCPR operating limit is then determined based on an interpolation between the applicable limits for Option A (scram times of LCO 3.1.4, "Control Rod Scram Times") and Option B (realistic scram times) analyses. The parameter must be determined once within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after each set of scram time tests required by SR 3.1.4.1, SR 3.1.4.2, and SR 3.1.4.4 because the effective scram speed distribution may change during the cycle or after maintenance that could affect scram times. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is acceptable due to the relatively minor changes in expected during the fuel cycle.

REFERENCES

1.

NUREG-0562, June 1979.

2.

NEDO-24011-P-A, "General Electric Standard Application for Reactor Fuel" (latest approved version).

3.

FSAR, Chapter [4].

4.

FSAR, Chapter [6].

2 5

2 2

NEDC-33270P, GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II) (latest approved version).

U 1

MCPR B 3.2.2 General Electric BWR/4 STS B 3.2.2-5 Rev. 5.0 Hope Creek Revision XXX 1

BASES REFERENCES (continued)

5.

FSAR, Chapter [15].

6.

[Plant specific single loop operation].

7.

[Plant specific load line limit analysis].

8.

[Plant specific Average Power Range Monitor, Rod Block Monitor and Technical Specification Improvements (ARTS) Program].

9.

NEDO-30130-A, "Steady State Nuclear Methods," May 1985.

10.

NEDO-24154, "Qualification of the One-Dimensional Core Transient Model for Boiling Water Reactors," October 1978.

U 2

NEDE-32906P Supplement 3-A, Migration to TRACG04 / PANAC11 from TRACG02 / PANAC10 for TRACG AOO and ATWS Overpressure Transients, Revision 1, April 2010.

UFSAR, Appendix 15D.4, Single Loop Operation.

1 NEDE-32906P-A, TRACG Application for Anticipated Operational Occurrences (AOO) Transient Analyses," Revision 3, September 2006.

GESTR-LOCA and SAFER Models for the Evaluation of the Loss-of-Coolant Accident, Volume III, SAFER/GESTR Application Methodology, NEDE-23785-1-PA, General Electric Company, Revision 1, October 1984.

1

JUSTIFICATION FOR DEVIATIONS ITS 3.2.2 BASES, MINIMUM CRITICAL POWER RATIO (MCPR)

Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ITS 3.2.2 is changed to provide the proper plant specific THERMAL POWER value.

This is acceptable since the value is changed to reflect the current licensing basis.

4. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal. License Amendment 219, dated September 19, 2019 (ADAMS Accession No. ML19218A305) modified the MCPR safety limit based on the use 95/95 criterion (i.e., 95% probability at a 95%

confidence level that the hot rod does not experience transition boiling). As part of approval for this amendment, the MPCR operating limits are required to be based on the MCPR 99.9% value. The ISTS Bases bracketed text associated with use of the MCPR 99.9% value applies to the Hope Creek Generating Station.

5. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Determination of No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.2, MINIMUM CRITICAL POWER RATIO (MCPR)

Hope Creek Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 3 ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Current Technical Specifications (CTS) Markup and Discussion of Changes (DOCs)

POWER DISTRIBUTION LIMITS 3/4.2.4 LINEAR HEAT GENERATION RATE LIMITING CONDITION FOR OPERATION 3.2.4 The LINEAR HEAT GENERATION RATE (LHGR) shall not exceed the limit specified in the CORE OPERATING LIMITS REPORT.

APPLICABILITY: OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER.

ACTION:

With the LHGR of any fuel rod exceeding the limit specified in the CORE OPERATING LIMITS REPORT, initiate corrective action within 15 minutes and restore the LHGR to within the limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months or reduce THERMAL POWER to less than 24% of RATED THERMAL POWER within the next 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

SURVEILLANCE REQUIREMENTS 4.2.4 LHGR's shall be determined to be equal to or less than the limit specified in the CORE OPERATING LIMITS REPORT:

a.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter.

b.

Initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating on a LIMITING CONTROL ROD PATTERN for LHGR.

HOPE CREEK 3/4 2-5 Amendment No. 187 A01 ITS 3.2.3 ITS 3.2 3

All s

s be less than or equal to COLR RTP Any not within s

RTP LCO 3.2.3 Applicability ACTION A ACTION B SR 3.2.3.1 SR 3.2.3.1 Frequency LA01 A02 L01 RTP s

Verify all s

COLR.

are less than or equal to (LHGR)

(s)

DISCUSSION OF CHANGES ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Hope Creek Page 1 of 2 ADMINISTRATIVE CHANGES A01 In the conversion of the Hope Creek Generating Station (HCGS) Current Technical Specifications (CTS) to the plant specific Improved Technical Specifications (ITS), certain changes (wording preferences, editorial changes, reformatting, revised numbering, etc.) are made to obtain consistency with NUREG-1433, Rev. 5.0, "Standard Technical Specifications-General Electric BWR/4 Plants" (ISTS).

These changes are designated as administrative changes and are acceptable because they do not result in technical changes to the CTS.

A02 CTS Applicability states OPERATIONAL CONDITION 1, when THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER. ITS Applicability states THERMAL POWER 24% RTP. This changes the CTS by not specifying Operational Condition 1 (ITS MODE 1) in the Applicability because the unit will be in MODE 1 when THERMAL POWER is 24% RTP.

The purpose of CTS 3.2.4 Applicability is to establish the Operational Condition (i.e., ITS MODE) in which the LCO is required. This change is acceptable because the Applicability of 24% RTP is not changed. This change is designated as an administrative change and is acceptable because it does not result a in technical change to the CTS.

MORE RESTRICTIVE CHANGES None RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 3 - Removing Procedural Details for Meeting TS Requirements or Reporting Requirements) CTS 3.2.4 Action states, With the LHGR of an fuel rod exceeding the limit specified in the CORE OPERATING LIMITS REPORT, initiate corrective action within 15 minutes and restore the LHGR to within the limit within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS 3.2.3 Action A states that with any LHGR not within limits, restore LHGR(s) to within limits within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . ITS does not include the requirement to initiate corrective action within 15 minutes. This changes the CTS by moving the procedural detail that prompt action should be taken to restore the LHGRs to within limits to the ITS Bases.

The removal of these details from the Technical Specifications is acceptable because this type of information is not necessary to be included in the Technical Specifications to provide adequate protection of public health and safety. This

DISCUSSION OF CHANGES ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Hope Creek Page 2 of 2 change is acceptable because the removed information will be adequately controlled in the ITS Bases. Changes to the Bases are controlled by the Technical Specifications Bases Control Program in Chapter 5. This program provides for the evaluation of changes to the Bases to ensure the Bases are properly controlled. This change is designated as a less restrictive removal of detail change because procedural detail that prompt action should be taken to restore the LHGRs to within limits is being removed from the Technical Specifications.

LESS RESTRICTIVE CHANGES L01 (Category 7 - Relaxation Of Surveillance Frequency) CTS 4.2.4.a and b state All LHGRs shall be determined to be equal to or less than the limits specified in the CORE OPERATING LIMITS REPORT with Frequencies of Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is greater than or equal to 24% of RATED THERMAL POWER and in accordance with the Surveillance Frequency Control Program thereafter and Initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN for LHGR. ITS SR 3.2.3.1 states Verify all LHGRs are less than or equal to the limits specified in the COLR once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 24% RTP AND In accordance with the Surveillance Frequency Control Program. This changes the CTS by deleting the Frequency requirement initially and in accordance with the Surveillance Frequency Control Program when the reactor is operating with a LIMITING CONTROL ROD PATTERN.

The purpose of ITS SR 3.2.3.1 is to verify all LHGRs are less than or equal to the limits specified in the COLR. This change is acceptable because the deleted Surveillance Frequency is not necessary to verify the LHGRS are within limits.

This surveillance has been evaluated to ensure that it provides an acceptable level of measurement to ensure the LCO is met. This change does not result in a reduction in the level of safety because a Limiting Control Rod Pattern is defined as a pattern which results in the core being on a thermal hydraulic limit (i.e.,

operating on a limiting value for APLHGR, LHGR, or MCPR). It is not evident that a Limiting Control Rod Pattern has been achieved until the Surveillance is performed.

Additionally, the core monitoring system (CMS) monitors core conditions including Thermal Limits. The CMS determines thermal limits when a calculation is initiated for a period report. The CMS generates a report at the time interval for automatic monitoring set by the operator (typically 30 minutes), or the report may be generated manually by the operator. The CMS is available in the Main Control Room. This change is designated as less restrictive because a Surveillance Frequency which is required in the CTS will not be required in the ITS.

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

LHGR (Optional) 3.2.3 General Electric BWR/4 STS 3.2.3-1 Rev. 5.0 Hope Creek Amendment XXX CTS 1

3.2 POWER DISTRIBUTION LIMITS 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) (Optional)

LCO 3.2.3 All LHGRs shall be less than or equal to the limits specified in the COLR.

APPLICABILITY:

THERMAL POWER 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Any LHGR not within limits.

A.1 Restore LHGR(s) to within limits.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to < 25% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify all LHGRs are less than or equal to the limits specified in the COLR.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 25% RTP AND

[ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter OR In accordance with the Surveillance Frequency Control Program ]

24 24 24 2

3 3

3 1

3/4.2.4 3.2.4 Applicability ACTION ACTION 4.2.4 4.2.4.a 1

JUSTIFICATION FOR DEVIATIONS ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ITS 3.2.3 is changed to provide the proper plant specific THERMAL POWER value.

This is acceptable since the value is changed to reflect the current licensing basis.

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

LHGR (Optional)

B 3.2.3 General Electric BWR/4 STS B 3.2.3-1 Rev. 5.0 Hope Creek Revision XXX 1

1 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.3 LINEAR HEAT GENERATION RATE (LHGR) (Optional)

BASES BACKGROUND The LHGR is a measure of the heat generation rate of a fuel rod in a fuel assembly at any axial location. Limits on LHGR are specified to ensure that fuel design limits are not exceeded anywhere in the core during normal operation, including anticipated operational occurrences (AOOs).

Exceeding the LHGR limit could potentially result in fuel damage and subsequent release of radioactive materials. Fuel design limits are specified to ensure that fuel system damage, fuel rod failure, or inability to cool the fuel does not occur during the anticipated operating conditions identified in Reference 1.

APPLICABLE The analytical methods and assumptions used in evaluating the fuel SAFETY system design are presented in References 1 and 2. The fuel assembly ANALYSES is designed to ensure (in conjunction with the core nuclear and thermal hydraulic design, plant equipment, instrumentation, and protection system) that fuel damage will not result in the release of radioactive materials in excess of the guidelines of 10 CFR, Parts 20, 50, and 100.

The mechanisms that could cause fuel damage during operational transients and that are considered in fuel evaluations are:

a.

Rupture of the fuel rod cladding caused by strain from the relative expansion of the UO2 pellet and

b.

Severe overheating of the fuel rod cladding caused by inadequate cooling.

A value of [1%] plastic strain of the fuel cladding has been defined as the limit below which fuel damage caused by overstraining of the fuel cladding is not expected to occur (Ref. 3).

Fuel design evaluations have been performed and demonstrate that the

[1%] fuel cladding plastic strain design limit is not exceeded during continuous operation with LHGRs up to the operating limit specified in the COLR. The analysis also includes allowances for short term transient operation above the operating limit to account for AOOs, plus an allowance for densification power spiking.

The LHGR satisfies Criterion 2 of 10 CFR 50.36(c)(2)(ii).

2 2

1 and 1

1

LHGR (Optional)

B 3.2.3 General Electric BWR/4 STS B 3.2.3-2 Rev. 5.0 Hope Creek Revision XXX 1

1 BASES LCO The LHGR is a basic assumption in the fuel design analysis. The fuel has been designed to operate at rated core power with sufficient design margin to the LHGR calculated to cause a 1% fuel cladding plastic strain.

The operating limit to accomplish this objective is specified in the COLR.

APPLICABILITY The LHGR limits are derived from fuel design analysis that is limiting at high power level conditions. At core thermal power levels < 25% RTP, the reactor is operating with a substantial margin to the LHGR limits and, therefore, the Specification is only required when the reactor is operating at 25% RTP.

ACTIONS A.1 If any LHGR exceeds its required limit, an assumption regarding an initial condition of the fuel design analysis is not met. Therefore, prompt action should be taken to restore the LHGR(s) to within its required limits such that the plant is operating within analyzed conditions. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is normally sufficient to restore the LHGR(s) to within its limits and is acceptable based on the low probability of a transient or Design Basis Accident occurring simultaneously with the LHGR out of specification.

B.1 If the LHGR cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER is reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER TO < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.3.1 REQUIREMENTS The LHGR is required to be initially calculated within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 25% RTP and periodically thereafter. It is compared to the specified limits in the COLR to ensure that the reactor is operating within the assumptions of the safety analysis. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to operating limits at lower power levels.

[ The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slow changes in power distribution during normal operation.

3 3

2 24 24 24 24 24 24

LHGR (Optional)

B 3.2.3 General Electric BWR/4 STS B 3.2.3-3 Rev. 5.0 Hope Creek Revision XXX 1

1 BASES SURVEILLANCE REQUIREMENTS (continued OR The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

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

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

]

REFERENCES

1.

FSAR, Section [ ].

2.

FSAR, Section [ ].

3.

NUREG-0800,Section II.A.2(g), Revision 2, July 1981.

4 2

2 2

NEDO-24011-P-A, General Electric Standard Application for Reactor Fuel (latest approved version)

NEDC-33270P, GNF2 Advantage Generic Compliance with NEDE-24011-P-A (GESTAR II) (latest approved version)

JUSTIFICATION FOR DEVIATIONS ITS 3.2.3 BASES, LINEAR HEAT GENERATION RATE (LHGR)

Hope Creek Page 1 of 1

1. Changes are made (additions, deletions, and/or changes) to the ISTS that reflect the plant specific nomenclature, number, reference, system description, analysis, licensing basis, or licensing basis description.

2. The ISTS contains bracketed information and/or values that are generic to all General Electric BWR/4 vintage plants. The brackets are removed, and the proper plant specific information/value is provided. This is acceptable since the information/value is changed to reflect the current licensing basis.

3. ITS 3.2.3 is changed to provide the proper plant specific THERMAL POWER value.

This is acceptable since the value is changed to reflect the current licensing basis.

4. The Reviewers Note has been deleted. This information is for the NRC reviewer to be keyed into what is needed to meet this requirement. This Note is not meant to be retained in the final version of the plant specific submittal.

Determination of No Significant Hazards Considerations (NSHCs)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS ITS 3.2.3, LINEAR HEAT GENERATION RATE (LHGR)

Hope Creek Page 1 of 1 There are no specific No Significant Hazards Considerations for this Specification.

ATTACHMENT 4 ISTS Not Adopted

Improved Standard Technical Specifications (ISTS) Markup and Justification for Deviations (JFDs)

APRM Gain and Setpoints (Optional) 3.2.4 General Electric BWR/4 STS 3.2.4-1 Rev. 5.0 3.2 POWER DISTRIBUTION LIMITS 3.2.4 Average Power Range Monitor (APRM) Gain and Setpoints (Optional)

LCO 3.2.4

a.

MFLPD shall be less than or equal to Fraction of RTP, or

b.

Each required APRM setpoint specified in the COLR shall be made applicable, or

c.

Each required APRM gain shall be adjusted such that the APRM readings are 100% times MFLPD.

APPLICABILITY:

THERMAL POWER 25% RTP.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Requirements of the LCO not met.

A.1 Satisfy the requirements of the LCO.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months B. Required Action and associated Completion Time not met.

B.1 Reduce THERMAL POWER to < 25% RTP.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1

APRM Gain and Setpoints (Optional) 3.2.4 General Electric BWR/4 STS 3.2.4-2 Rev. 5.0 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1

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

Not required to be met if SR 3.2.4.2 is satisfied for LCO 3.2.4 Item b or c requirements.

Verify MFLPD is within limits.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after 25% RTP AND

[ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter OR In accordance with the Surveillance Frequency Control Program ]

SR 3.2.4.2

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

Not required to be met if SR 3.2.4.1 is satisfied for LCO 3.2.4 Item a requirements.

Verify APRM setpoints or gains are adjusted for the calculated MFLPD.

[ 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Surveillance Frequency Control Program ]

1

JUSTIFICATION FOR DEVIATIONS ISTS 3.2.4, AVERAGE POWER RANGE MONITOR (APRM) GAIN AND SETPOINTS (OPTIONAL)

Hope Creek Page 1 of 1

1. ISTS 3.2.4, Average Power Range Monitor (APRM) Gain and Setpoints (Optional) is not included in the Hope Creek ITS because the Hope Creek CTS do not include a Specification for the Average Power Range Monitor (APRM) Gain and Setpoints.

Improved Standard Technical Specifications (ISTS) Bases Markup and Justification for Deviations (JFDs)

APRM Gain and Setpoints (Optional)

B 3.2.4 General Electric BWR/4 STS B 3.2.4-1 Rev. 5.0 B 3.2 POWER DISTRIBUTION LIMITS B 3.2.4 Average Power Range Monitor (APRM) Gain and Setpoints (Optional)

BASES BACKGROUND The OPERABILITY of the APRMs and their setpoints is an initial condition of all safety analyses that assume rod insertion upon reactor scram.

Applicable GDCs are GDC 10, "Reactor Design," GDC 13, "Instrumentation and Control," GDC 20, "Protection System Functions,"

and GDC 23, "Protection against Anticipated Operation Occurrences" (Ref. 1). This LCO is provided to require the APRM gain or APRM flow biased scram setpoints to be adjusted when operating under conditions of excessive power peaking to maintain acceptable margin to the fuel cladding integrity Safety Limit (SL) and the fuel cladding 1% plastic strain limit.

The condition of excessive power peaking is determined by the ratio of the actual power peaking to the limiting power peaking at RTP. This ratio is equal to the ratio of the core limiting MFLPD to the Fraction of RTP (FRTP), where FRTP is the measured THERMAL POWER divided by the RTP. Excessive power peaking exists when:

FRTP MFLPD > 1, indicating that MFLPD is not decreasing proportionately to the overall power reduction, or conversely, that power peaking is increasing. To maintain margins similar to those at RTP conditions, the excessive power peaking is compensated by a gain adjustment on the APRMs or adjustment of the APRM setpoints. Either of these adjustments has effectively the same result as maintaining MFLPD less than or equal to FRTP and thus maintains RTP margins for APLHGR and MCPR.

The normally selected APRM setpoints position the scram above the upper bound of the normal power/flow operating region that has been considered in the design of the fuel rods. The setpoints are flow biased with a slope that approximates the upper flow control line, such that an approximately constant margin is maintained between the flow biased trip level and the upper operating boundary for core flows in excess of about 45% of rated core flow. In the range of infrequent operations below 45%

of rated core flow, the margin to scram is reduced because of the nonlinear core flow versus drive flow relationship. The normally selected APRM setpoints are supported by the analyses presented in References 1 and 2 that concentrate on events initiated from rated conditions. Design experience has shown that minimum deviations occur within expected margins to operating limits (APLHGR and MCPR), at 1

APRM Gain and Setpoints (Optional)

B 3.2.4 General Electric BWR/4 STS B 3.2.4-2 Rev. 5.0 BASES BACKGROUND (continued) rated conditions for normal power distributions. However, at other than rated conditions, control rod patterns can be established that significantly reduce the margin to thermal limits. Therefore, the flow biased APRM scram setpoints may be reduced during operation when the combination of THERMAL POWER and MFLPD indicates an excessive power peaking distribution.

The APRM neutron flux signal is also adjusted to more closely follow the fuel cladding heat flux during power transients. The APRM neutron flux signal is a measure of the core thermal power during steady state operation. During power transients, the APRM signal leads the actual core thermal power response because of the fuel thermal time constant.

Therefore, on power increase transients, the APRM signal provides a conservatively high measure of core thermal power. By passing the APRM signal through an electronic filter with a time constant less than, but approximately equal to, that of the fuel thermal time constant, an APRM transient response that more closely follows actual fuel cladding heat flux is obtained, while a conservative margin is maintained. The delayed response of the filtered APRM signal allows the flow biased APRM scram levels to be positioned closer to the upper bound of the normal power and flow range, without unnecessarily causing reactor scrams during short duration neutron flux spikes. These spikes can be caused by insignificant transients such as performance of main steam line valve surveillances or momentary flow increases of only several percent.

APPLICABLE The acceptance criteria for the APRM gain or setpoint adjustments are SAFETY that acceptable margins (to APLHGR and MCPR) be maintained to the ANALYSES fuel cladding integrity SL and the fuel cladding 1% plastic strain limit.

FSAR safety analyses (Refs. 2 and 3) concentrate on the rated power condition for which the minimum expected margin to the operating limits (APLHGR and MCPR) occurs. LCO 3.2.1, "AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR)," and LCO 3.2.2, "MINIMUM CRITICAL POWER RATIO (MCPR)," limit the initial margins to these operating limits at rated conditions so that specified acceptable fuel design limits are met during transients initiated from rated conditions. At initial power levels less than rated levels, the margin degradation of either the APLHGR or the MCPR during a transient can be greater than at the rated condition event. This greater margin degradation during the transient is primarily offset by the larger initial margin to limits at the lower than rated power levels. However, power distributions can be hypothesized that would result in reduced margins to the pre-transient operating limit. When combined with the increased severity of certain transients at other than rated conditions, the SLs could be approached.

At substantially reduced power levels, highly peaked power distributions 1

APRM Gain and Setpoints (Optional)

B 3.2.4 General Electric BWR/4 STS B 3.2.4-3 Rev. 5.0 BASES APPLICABLE SAFETY ANALYSES (continued) could be obtained that could reduce thermal margins to the minimum levels required for transient events. To prevent or mitigate such situations, either the APRM gain is adjusted upward by the ratio of the core limiting MFLPD to the FRTP, or the flow biased APRM scram level is required to be reduced by the ratio of FRTP to the core limiting MFLPD.

Either of these adjustments effectively counters the increased severity of some events at other than rated conditions by proportionally increasing the APRM gain or proportionally lowering the flow biased APRM scram setpoints, dependent on the increased peaking that may be encountered.

The APRM gain and setpoints satisfy Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii).

LCO Meeting any one of the following conditions ensures acceptable operating margins for events described above:

a.

Limiting excess power peaking,

b.

Reducing the APRM flow biased neutron flux upscale scram setpoints by multiplying the APRM setpoints by the ratio of FRTP and the core limiting value of MFLPD, or

c.

Increasing APRM gains to cause the APRM to read greater than 100 times MFLPD (in %). This condition is to account for the reduction in margin to the fuel cladding integrity SL and the fuel cladding 1% plastic strain limit.

MFLPD is the ratio of the limiting LHGR to the LHGR limit for the specific bundle type. As power is reduced, if the design power distribution is maintained, MFLPD is reduced in proportion to the reduction in power.

However, if power peaking increases above the design value, the MFLPD is not reduced in proportion to the reduction in power. Under these conditions, the APRM gain is adjusted upward or the APRM flow biased scram setpoints are reduced accordingly. When the reactor is operating with peaking less than the design value, it is not necessary to modify the APRM flow biased scram setpoints. Adjusting APRM gain or setpoints is equivalent to MFLPD less than or equal to FRTP, as stated in the LCO.

For compliance with LCO Item b (APRM setpoint adjustment) or Item c (APRM gain adjustment), only APRMs required to be OPERABLE per LCO 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," are required to be adjusted. In addition, each APRM may be allowed to have its gain or setpoints adjusted independently of other APRMs that are having their gain or setpoints adjusted.

1

APRM Gain and Setpoints (Optional)

B 3.2.4 General Electric BWR/4 STS B 3.2.4-4 Rev. 5.0 BASES APPLICABILITY The MFLPD limit, APRM gain adjustment, and APRM flow biased scram and associated setdowns are provided to ensure that the fuel cladding integrity SL and the fuel cladding 1% plastic strain limit are not violated during design basis transients. As discussed in the Bases for LCO 3.2.1 and LCO 3.2.2, sufficient margin to these limits exists below 25% RTP and, therefore, these requirements are only necessary when the reactor is operating at 25% RTP.

ACTIONS A.1 If the APRM gain or setpoints are not within limits while the MFLPD has exceeded FRTP, the margin to the fuel cladding integrity SL and the fuel cladding 1% plastic strain limit may be reduced. Therefore, prompt action should be taken to restore the MFLPD to within its required limit or make acceptable APRM adjustments such that the plant is operating within the assumed margin of the safety analyses.

The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time is normally sufficient to restore either the MFLPD to within limits or the APRM gain or setpoints to within limits and is acceptable based on the low probability of a transient or Design Basis Accident occurring simultaneously with the LCO not met.

B.1 If MFLPD cannot be restored to within its required limits within the associated Completion Time, the plant must be brought to a MODE or other specified condition in which the LCO does not apply. To achieve this status, THERMAL POWER is reduced to < 25% RTP within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The allowed Completion Time is reasonable, based on operating experience, to reduce THERMAL POWER to < 25% RTP in an orderly manner and without challenging plant systems.

SURVEILLANCE SR 3.2.4.1 and SR 3.2.4.2 REQUIREMENTS The MFLPD is required to be calculated and compared to FRTP or APRM gain or setpoints to ensure that the reactor is operating within the assumptions of the safety analysis. These SRs are only required to determine the MFLPD and, assuming MFLPD is greater than FRTP, the appropriate gain or setpoint, and is not intended to be a CHANNEL FUNCTIONAL TEST for the APRM gain or flow biased neutron flux scram circuitry. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months allowance after THERMAL POWER 25% RTP is achieved is acceptable given the large inherent margin to operating limits at low power levels.

1

APRM Gain and Setpoints (Optional)

B 3.2.4 General Electric BWR/4 STS B 3.2.4-5 Rev. 5.0 BASES SURVEILLANCE REQUIREMENTS (continued)

[ The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency of SR 3.2.4.1 is chosen to coincide with the determination of other thermal limits, specifically those for the APLHGR (LCO 3.2.1). The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Frequency is based on both engineering judgment and recognition of the slowness of changes in power distribution during normal operation. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Frequency of SR 3.2.4.2 requires a more frequent verification than if MFLPD is less than or equal to fraction of rated power (FRP). When MFLPD is greater than FRP, more rapid changes in power distribution are typically expected.

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

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

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

]

REFERENCES

1.

10 CFR 50, Appendix A, GDC 10, GDC 13, GDC 20, and GDC 23.

2.

FSAR, Section [ ].

3.

FSAR, Section [ ].

1

JUSTIFICATION FOR DEVIATIONS ISTS 3.2.4 BASES, AVERAGE POWER RANGE MONITOR (APRM) GAIN AND SETPOINTS (OPTIONAL)

Hope Creek Page 1 of 1

1. ISTS 3.2.4, Average Power Range Monitor (APRM) Gain and Setpoints (Optional) is not included in the Hope Creek ITS because the Hope Creek CTS do not include a Specification for the Average Power Range Monitor (APRM) Gain and Setpoints.

ML24142A435

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