ML11217A020

LGS Unit 1 Summary Report for Mur Power Change

ML11217A020
Person / Time
Site:	Limerick
Issue date:	07/29/2011
From:	Maguire W Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11217A020 (18)

Text

T Exelkn Limerick Generating Station www.exeloncorp.com Nuclear 3146 Sanatoga Road Pottstown, PA 19464 T.S. 6.9.1.1 July 29, 2011 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Limerick Generating Station, Unit 1 Facility Operating License Nos. NPF-39 NRC Docket No. 50-352

Subject:

LGS Unit 1 Summary Report for MUR Power Change The LGS Unit 1 Summary Report for Measurement Uncertainty Recapture (MUR)

Project which was implemented on May 1 for Unit 1 following receipt of NRC License Amendment dated 4/8/11. Power level for Unit 1 was raised from 3458 MWt to 3515 MWt (1.65%).

There are no commitments contained in this letter.

If you have any questions or require additional information, please do not hesitate to contact us.

Sincerely, William F. Maguire Vice President - LGS Exelon Generation Company, LLC

Enclosure:

Limerick Generating Station Units 1 Summary Report for MUR Power Change cc: W. M. Dean, Administrator, Region I, USNRC E. DiPaolo, LGS USNRC Senior Resident Inspector 4oof

bcc: J. Grimes- KSA 3N (w/o attachments)

P. Gardner - GML 5-1 (w/o attachments)

K. Jury - Cantara (w/o attachments)

W. Maguire - GML 5-1 (w/o attachments)

M. Jesse- KSA 2N (w/o attachments)

D. Helker - KSA 2N (w/o attachments)

J. Hunter - SSB 2-4 w/o attachments D Doran - SSB 3-1 (w/o attachments)

S. Bobyock - SSB 3-1 (w/o attachments)

A. Olsen- KSA (w/o attachments)

C. Hoffman- SSB 4-2 (w/attachments)

M. Thomas-SSB 4-2 (w/attachments)

A. Columbus - SMB 1-2 (w/attachments)

S. Gamble - SSB 2-4 (w/attachments)

R. Janati - Commonwealth of PA DEP (w/attachments)

M. Murphy - (PABRP) SSB 2-4 (w/o attachments)

Limerick Generating Station UNIT 1 CYCLE 14 STARTUP REPORT SUBMITTED TO THE U.S. NUCLEAR REGULATORY COMMISSION PURSUANT TO FACILITY OPERATING LICENSE NPF-39 July 2011 Page 1

TABLE OF CONTENTS Section Title Page 1.0 Summary 3 1.1 Purpose 3 1.2 Acceptance Criteria 3 1.3 Testing Requirements 4 2.0 UFSAR Chapter 14.2 Tests Not Required 4 2.1 STP-3, Fuel Loading 4 2.2 STP-4, Full Core Shutdown Margin 4 2.3 STP-5, Control Rod Drive System 4 2.4 STP-6, SRM Performance and Control Rod Sequence 4 2.5 STP-9, Water Level Reference Leg Temperature 4 2.6 STP- 10, IRM Performance 4 2.7 STP- 11, Local Power Range Monitoring Calibration 5 2.8 STP- 13, Process Computer Performance Verification 5 2.9 STP-14, Reactor Core Isolation Cooling system Performance 5 2.10 STP- 15, High Pressure Coolant Injection System Performance Verification 5 2.11 STP- 16, Selected Process Temperatures Verification 5 2.12 STP- 17, System Expansion 5 2.13 STP- 18, TIP Uncertainty 5 2.14 STP-20, Steam Production 6 2.15 STP-24, Main Turbine Valves Surveillance Test 6 2.16 STP-25, Main Steam Isolation Valves Performance Verification 6 2.17 STP-26, Main Steam Relief Valves Performance 6 2.18 STP-27, Turbine Trip and Generator Load Rejection Demonstration 6 2.19 STP-28, Shutdown from Outside the Main Control Room Demonstration 6 2.20 STP-29, Recirculation Flow Control Demonstration 7 2.21 STP-30, Recirculation System 7 2.22 STP-3 1, Loss of Turbine-Generator and Offsite Power 7 2.23 STP-32, Essential HVAC System Operation and Containment Hot Penetration 7 Temperature Verification 2.24 STP-33, Piping Steady-State Vibration Measurements 7 2.25 STP-34, Offgas System Performance Verification 8 2.26 STP-35, Recirculation Flow Calibration 8 2.27 STP-36, Piping Dynamic Transient 8 2.28 STP-70, Reactor Water Cleanup System Performance Verification 8 2.29 STP-71, Residual Heat Removal System Performance Verification 8 3.0 UFSAR Chapter 14.2 Tests Required 9 3.1 STP- 1, Chemical and Radiochemical 9 3.2 STP-2, Radiation Measurements 10 3.3 STP- 12, APRM Calibration 10 3.4 STP- 19, Core Performance 11 3.5 STP-22, Pressure Regulator 12 3.6 STP-23, Feedwater System 14 4.0 Tests Not Described in UFSAR Section 14.2 15 4.1 STP- 1B, Steam Dryer/Separator Performance 15 4.2 STP-101, Plant Parameter Monitoring and Evaluation 16 Page 2

1.0 Summary This Startup Test Report is submitted to the Nuclear Regulatory Commission (NRC) in accordance with the requirements of Limerick Generating Station (LGS) Technical Specifications (TS) 6.9. 1. 1 through 6.9.1.3. The report summarizes the startup testing performed on LGS Unit I following implementation of MUR Thermal Power Optimization (TPO) Uprate during Cycle 14. The uprate was implemented in accordance with Ammendment 201 of the Facility Operating License No. NPF-39.

The result of MUR Uprate is an increase in reactor power equal to 1.64% of the original rated thermal power.

All testing identified within the LGS Updated Final Safety Analysis Report (UFSAR) Chapter 14.2 is addressed and evaluated for applicability to the change to the licensed thermal power as required by Technical Specifications. Test applicability was determined in accordance with Project Task Report "Exelon Nuclear Limerick Units I and 2 Thermal Power Optimization" Task T 1005: Startup Test Specifications, Rev 0.

The new 100% power (3515 MWth/ 1175 MWe) was first achieved on May 2, 2011.

There was one Special Procedure (SP) written and performed in combination with various Surveillance Tests (STs) described in this report, to successfully achieve the new rating. No adjustments were required to control systems. All systems performed in a stable manner during the transient testing. The unit is operating well at rerated conditions.

1.1 Purpose This Startup Test Report summarized the testing performed on Limerick Generating Station (LGS) Unit 1 following the implementation of MUR Uprate. The result of MUR Uprate is an increase in reactor power equal to 1.64% of the original rated thermal power. All testing identified within the LGS Updated Final Safety Analysis Report (UFSAR) Chapter 14.2 was addressed and evaluated for applicability to this increased licensed power rating as required by Technical Specification 6.9.1. 1. The Uprated Startup Test Program Plan documents these evaluations and describes in detail the tests performed for MUR TPO Uprate. Each test performed for MUR TPO Uprate is described herein, including the test purpose, description, acceptance criteria and results.

This report is submitted in accordance with the requirements of Technical Specification 6.9. 1.1.

1.2 Acceptance Criteria Level I Acceptance Criteria is associated with plant safety. If a Level I criteria is not satisfied, the plant will be put in a suitable hold condition judged to be satisfactory and safe until resolution is obtained. Tests compatible with this hold condition may be continued. Following resolution, applicable tests must be repeated to verify that the requirements of Level I criteria are now satisfied.

Level 2 criteria are associated with expectations relating to the performance of systems. If a level 2 criterion is not satisfied, operating and test plans would not necessarily be altered. Investigation of the measurements and the analytical techniques used for predictions would be started.

Any acceptance criteria failure must be documented on a Test Exception Report (TER).

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1.3 Testing Requirements Each of the tests listed in LGS UFSAR Chapter 14.2 were evaluated for applicability for the MUR TPO Uprate as designated in the UFSAR. Testing was performed and results were evaluated in accordance with the Project Task report "Exelon Nuclear Limerick Units I and 2 Thermal Power Optimization" Task T 1005: Startup Test Specifications, Rev. 0.

2.0 UFSAR Chapter 14.2 Tests Not Required 2.1 STP-3, Fuel Loading The test objective is to load fuel safely and efficiently to the full core size.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.2 STP-4, Full Core Shutdown Margin The objective of this test is to demonstrate the reactor is sufficiently subcritical throughout the fuel cycle, with any single control rod withdrawn.

Shutdown margin for Cycle 14 has been calculated per normal plant procedures during initial startup following 1R13 and is satisfactory. The MUR Power Uprate does not affect Full Core Shutdown Margin.

2.3 STP-5, Control Rod Drive System The objectives to this test are (1) to demonstrate that the Control Rod Drive (CRD) System operates properly over the full range of primary coolant operating temperatures and pressures, and (2) to determine the initial operating characteristics of the CRD system.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.4 STP-6, SRM Performance and Control Rod Sequence The objective of this test is to determine that the operational neutron sources, Source Range Monitoring instrumentation, and control rod withdrawal sequences provide adequate information to achieve criticality and power increases in a safe and efficient manner.

The MiUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.5 STP-9, Water Level Reference Leg Temperature The objective of this test is to demonstrate the calibration and agreement of the installed reactor vessel water level instrumentation at normal operating pressure and temperature.

The MTUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.6 STP-10, IRM Performance The objective of this test is to demonstrate IRM system response to neutron flux and IRM overlap with the SRM and APRM systems.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

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2.7 STP-11, Local Power Range Monitoring Calibration The objective of this test is to calibrate the LPRM system.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.8 STP-13, Process Computer Performance Verification The objective of this test is to verify the performance of the process computer to provide accurate information pertaining to plant process variables under operating conditions.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.9 STP-14, Reactor Core Isolation Cooling system Performance The objectives of this test are (1) to verify the proper operation of the Reactor Core Isolation Cooling (RCIC)

System over its expected operating pressure range, (2) to demonstrate reliability in automatic starting without the aid of ac power with the exception of the RCIC dc/ac inverters, and (3) to verify the operation of RCIC beyond its design basis of operation with extended loss of ac power.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.10 STP-15, High Pressure Coolant Injection System Performance Verification The objectives of this test are (1) to verify the proper operation of the High Pressure Coolant Injection (HPCI)

System over its expected operating pressure and flow ranges, and (2) to demonstrate reliability in automatic starting from cold standby when the reactor is at rated pressure conditions.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.11 STP-16, Selected Process Temperatures Verification The objective of this test is to assure that the measured bottom head drain temperature corresponds to bottom head coolant temperature during normal operation.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.12 STP-17, System Expansion This test verifies that safety related piping systems and other piping systems as identified in the FSAR expand in an acceptable manner during plant heat-up and power escalation. Specific objectives are to verify that: (1) piping thermal expansion is as predicted by design calculations; (2) snubbers and spring hangers remain within operating travel ranges at various piping temperatures; and (3) piping is free to expand without interference.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.13 STP-18, TIP Uncertainty The objective of this test is to determine the reproducibility of the traversing in-core probe system readings.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

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2.14 STP-20, Steam Production The objective of this test is to demonstrate that the Nuclear Steam Supply System (NSSS) can provide steam sufficient to satisfy all appropriate warranties as defined in the NSSS contract.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.15 STP-24, Main Turbine Valves Surveillance Test The objectives of this test are to demonstrate acceptable procedures and maximum power levels of periodic surveillance testing of the main turbine control, stop, and bypass valves without producing a reactor scram.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

Procedures have been updated to perform the tests 2% lower in power than prior to the MUR Uprate implementation. Valve testing is now performed at a lower thermal power than prior to the Uprate allowing for additional margin to scram set-points.

2.16 STP-25, Main Steam Isolation Valves Performance Verification The objectives of this test are (1) to functionally check the Main Steam Isolation Valves (MSIVs) for proper operation at selected power levels, (2) to determine the MSIV closure times, and (3) to determine the maximum power level at which full closure of a single MSIV can be performed without causing a reactor scram. The full isolation is performed to determine the reactor transient behavior that results from the simultaneous full closure of all MSIVs at high power level.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.17 STP-26, Main Steam Relief Valves Performance The objectives of this test are (1) to verify that the relief valves function properly (can be manually opened and closed), (2) to verify that the relief valves reseat properly after actuation, (3) to verify that there are no major blockages in the relief valve discharge piping and (4) to demonstrate system stability to relief valve operation.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.18 STP-27, Turbine Trip and Generator Load Rejection Demonstration The objectives of this test are (1) to determine the response of the reactor system to a turbine trip or generator load rejection; and (2) to evaluate the response of the bypass, SRV, and the reactor protection systems.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.19 STP-28, Shutdown from Outside the Main Control Room Demonstration The objectives of this test are to demonstrate that the reactor (1) can be safely shutdown from outside the Main Control Room (MCR), (2) can be maintained in a Hot Standby condition from outside the MCR and (3) can be safely cooled from hot to cold shutdown from outside the MCR. In addition, it will provide an opportunity to demonstrate that the procedures of Remote Shutdown are clear and comprehensive and that the operational personnel are familiar with their application.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

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2.20 STP-29, Recirculation Flow Control Demonstration The objectives of this test are (1) to demonstrate the flow control capability of the plant over the entire pump speed range and (2) to determine that the controllers are set for the desired system performance and stability.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.21 STP-30, Recirculation System The objectives of this test are to:

Determine transient responses and steady-state conditions following recirculation pump trips at selected power levels Obtain jet pump performance data Demonstrate that no recirculation system cavitation occurs in the operation region of the power/flow map.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.22 STP-31, Loss of Turbine-Generator and Offsite Power This test objective is to demonstrate the performance of the reactor and plant electrical equipment and systems, during the loss of auxiliary power transient.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.23 STP-32, Essential HVAC System Operation and Containment Hot Penetration Temperature Verification The objectives of this test are (1) to demonstrate, under normal operating conditions, satisfactory performance of the HVAC systems in the following areas:

Drywell Control Enclosure Control Room Reactor Enclosure Radwaste Enclosure And (2) to verify that concrete temperatures surrounding hot penetrations remain within specified limits.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.24 STP-33, Piping Steady-State Vibration Measurements The objective of this test is to verify that the steady state vibration of NSSS, Main Steam, Reactor Recirculation and selected BOP piping systems is within acceptable limits.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

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2.25 STP-34, Offgas System Performance Verification The objective of this test is to verify that the Offgas System operates within the TS limits and expected operating conditions.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.26 STP-35, Recirculation Flow Calibration The objective of this test is to perform a complete calibration of the recirculation system flow instrumentation, including specific signals to the plant monitoring system.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.27 STP-36, Piping Dynamic Transient The objectives of this test are to verify that the following piping systems are adequately designed and restrained to withstand the following transient loading conditions:

Main Steam - Main Turbine Stop Valve/Control Valve closures at approximately 20-25%, 60-80%, and 95-100% of rated thermal power.

Main Steam and Relief Valve Discharge - Main Steam Relief Valve actuation.

Recirculation - Recirculation Pump trips and restarts.

HPCI steam supply - HPCI turbine trips.

Feedwater - Reactor feed pump trips/coastdowns.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.28 STP-70, Reactor Water Cleanup System Performance Verification The objective of this test is to demonstrate specific aspects of the mechanical operability of the Reactor Water Cleanup System.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

2.29 STP-71, Residual Heat Removal System Performance Verification The objective of this test is to demonstrate the ability of the Residual Heat Removal (RHR) System to remove residual and decay heat from the nuclear system so that the refueling and nuclear servicing can be performed.

Additionally, this test will demonstrate the ability of the RHR System to remove heat from the suppression pool.

The MUR Power Uprate does not affect the performance of systems needed to satisfy the objectives of this test.

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3.0 UFSAR Chapter 14.2 Tests Required 3.1 STP-1, Chemical and Radiochemical Objectives The objectives of this test are to maintain control of and knowledge about the quality of the reactor coolant chemistry and radiochemistry at TPO conditions.

Description Samples will be taken and measurements made at TPO test conditions to determine 1) the chemical and radiochemical quality of reactor water and reactor feedwater and 2) gaseous release.

Acceptance Criteria Level I a) Chemical factors defined in the Technical Specifications (Technical requirements Manual, COLR, or Fuel Warranty, as applicable) must be maintained within the limits specified.

b) The activities of gaseous and liquid effluents must be known and must conform to license limitations.

Level 2 Water quality must be known at all times and must remain with in guidelines of the station's chemistry program.

Results During LGS Unit I Cycle 14, following the MUR TPO Uprate, reactor coolant chemistry parameters as well as radioactive gaseous waste releases and radioactive liquid waste releases were maintained within the limits set forth in the LGS Unit I TS. The following is a list of chemistry related surveillance tests (ST) satisfactorily performed since operating at the new TPO power level.

ST-5-041-800- 1, ST-5-041-885- 1, ST-5-061-570- 1, ST-5-070-885- 1, ST-5-076-8 10- 1, ST-5-076-815-1 In addition to the surveillance tests, routine tests and normal analysis were performed. Results are as follows:

PARAMETER ACTUAL DATA ACTUAL DATA ACCEPTANCE (100% CLTP) (TPO) CRITERIA Primary Rx Coolant Iodine 2.39 x 10 6 IaCi/gm 6.4948 x 10-6 pCi/gm <._0.2ýiCi/gm Primary Rx Coolant .130 ýtmhos/cm .130 gmhos/cm <1.0 gmhos/cm Conductivity _

Primary Rx Coolant Chloride < 0.31 ppb < 0.31 ppb <200 ppb Fuel Warranty Appendix I - Water Quality Requirements are all met. A comparison of data recorded at 100%

CLTP and TPO conditions is provided below.

Parameter 100% CLTP TPO Continual Limit (max)

Total Feedwater Copper Concentration 0.003 ppb 0.004 ppb 0.5 ppb I Insoluble 0.241 ppb 0.248 ppb 10 ppb Feedwater Iron Concentration Soluble 0.002 ppb 0.002 ppb I ppb Total Metals 0.633 ppb 0.650 ppb 15 ppb Page 9

3.2 STP-2, Radiation Measurements Objective The objective of this test is to monitor radiation at the TPO conditions to assure that personnel exposures are maintained ALARA, that radiation survey maps are accurate, and that radiation zones are properly posted.

Acceptance Criteria Level 1 The radiation doses of plant origin and occupancy times of personnel in radiation zones shall be controlled consistent with the guidelines of the standards for protection against radiation outlined in IOCFR20.

Level 2 None Results Plant surveys were performed at the TPO power level. Spot checks were performed to validate routine surveys.

Postings at steam-affected areas were updated as necessary to reflect the new TPO conditions. Based on the observed results, no additional surveys were determined to be necessary. Affected postings and survey maps were updated as necessary. Radiation doses and occupancy times of personnel are consistent with the guidelines of the Standard for Protection Against Radiation outlined in IOCFR20.

3.3 STP-12, APRM Calibration Objective The objective of this test is to calibrate the Average Power Range Monitor (APRM) system to the TPO power level.

Acceptance Criteria Level I a) The APRM channels must be calibrated consistent with Technical Specifications.

b) Technical Specifications (Technical Requirements Manual, COLR, or Fuel Warranty, as applicable) limits on APRM scram and rod block set-points shall not be exceeded.

Level 2 None Results APRM Calibrations or Gain Adjustments were performed at the new TPO power level. ST-6-107-887-1, APRM Gain Determination and Adjustment, was completed satisfactorily and the APRM scram and rod block set-points were not exceeded.

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3.4 STP-1 9, Core Performance Objectives The objective of this test is to evaluate the core thermal power and core flow and evaluate whether core performance parameters are within limits to ensure a careful, monitored approach to the TPO power level.

Descriptio!1 Routine measurements of reactor and system parameters are taken near 95% and 100% of CLTP along the constant rod pattern line that will be used to increase to maximum TPO power. Core thermal power measurements will be performed using the more accurate heat balance methods indicated in the NRC approved TPO submittal. Core performance parameters are calculated using accepted methods to ensure current licensed and operational practice are maintained. Fuel thermal margin and other core performance parameters will be projected to the TPO power level from the 100% CLTP test conditions. Power increase above CLTP is along a constant rod pattern line in one progression to TPO power level following the station's standard power ascension practices. Measured reactor parameters and calculated core performance parameters at TPO power level are evaluated by comparison to limits specified in Technical Specifications and projected values.

Acceptance Criteria Level I a) All core performance parameters shall be within the limits specified in Technical Specifications

1. CMIFLPD (Core Maximum Fraction of Limiting Power Density)

2. CMFCPR (Core Maximum Fraction of Critical Power Ratio)

3. CMAPRAT (Core Maximum Average Planar Ratio) b) Steady state reactor power shall be limited to maximum value of the lesser of either the TPO power level or the MELLLA Boundary as indicated on the Power/Flow Map.

c) Core flow shall not exceed its maximum value depicted on the Power/Flow Map.

Level 2 None Results Core monitor cases were run at each power level to monitor core performance parameters, ensuring they remained within the Technical Specifications throughout the approach to the TPO power level. Values for each of the core performance parameters at each of the test plateaus are given below and are to be maintained less than or equal to 1.0 per Technical Specifications.

Core Performance Reactor Power (MWth)

Parameter 3285 3458 3487 3515 CMFLPD 0.889 0.916 0.917 0.922 CMFCPR 0.932 0.933 0.930 0.929 CMAPRAT 0.741 0.786 0.792 0.799 Steady state reactor power and core flow are maintained within the bounds of the Power/Row map in accordance with plant operating procedures. During power ascension testing, maximum core flow was 94.4 Mlbm/hr with a maximum allowable core flow of 110 Mlbm/hr.

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3.5 STP-22, Pressure Regulator Objective The objective of this test is to confirm the adequacy of the pressure control settings for TPO operations by inducing transients in the reactor pressure control system using the pressure regulators and gather data to determine incremental regulation.

Description Turbine Pressure Controller Set-point Prior to commencing TPO baseline testing (in the 95% CLTP test condition), the turbine pressure controller set-point will be adjusted to achieve desired reactor pressure when projected to TPO uprate conditions and then held constant throughout the TPO power ascension. This provides the most meaningful evaluation of turbine steam flow margin at TPO conditions.

Note: With the small TPO power change, holding the turbine pressure controller set-point constant establishes a consistent basis for measuring the performance of the reactor and especially TCVs as they open during the TPO power ascension. Achieving normal operating reactor dome pressure in the TPO test condition permits direct evaluation between CLTP and TPO operating conditions.

Description of Pressure Regulator Testing Note: This testing may produce core power excursions due to the vessel pressure changes.

The power levels of these operational transients have the potential to exceed the steady-state power level of the test condition. A margin to licensed thermal power should be established to avoid exceeding the licensed thermal power limit.

In each test condition, testing of the pressure control system response to pressure set-point step changes is accomplished by first making a down set-point step change, followed by an up set-point step change after conditions stabilize, in accordance with the following set-point change sequence.

1. -3 psi

2. +3 psi When testing is completed for one pressure regulator, the other pressure regulator is selected and the pressure set-point step testing is repeated. For the testing performed at TPO conditions, power is established with margin to the licensed thermal power limit to ensure the licensed thermal power is not exceeded.

Incremental Regulation Data Collection Average main steam line flow versus pressure regulator output is taken in increments of 2% of uprated power or less during ascension to TPO power. Collect data from Generator minimum load to TPO power or from 95% of CLTP, if data already exists up to this power level. Subsequent to the TPO power ascension, the variation in the slope of a curve plotted on linear graph paper must show that the incremental regulation meets the Level 2 criteria.

Level I The transient response of any pressure control system related variable to any test input must not diverge.

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Level 2 a) Pressure control system-related variables may contain oscillatory modes of response. In these cases, the decay ratio of each controlled mode of response must be _<0.25.

b) Pressure control system deadband, delay, etc., shall be small enough that steady state limit cycles, if any, shall produce turbine steam flow variations no larger than +/- 0.5% of rated flow.

c) The variation in incremental regulation (ratio of the maximum to the minimum value of the quantity, "incremental change in pressure control signal/incremental change in steam flow," for each flow range) shall meet the following:

% of Steam Flow Obtained with Valves Wide Open Variation 0 to 85% <4:1 85 to 97% <2:1 97 to 99% <5:1 Results Pressure regulator stability testing was performed at 95% CLTP, 100% CLTP, and TPO power levels. The data obtained during each test condition is summarized below. The system responded to the pressure transients as expected with no signs of divergence or oscillations. Decay ratios were zero for all step changes on both pressure regulators. Pressure response time and margin to scram set-points were satisfactory in all cases. No limit cycles were observed. All Level I and Level 2 acceptance criteria were satisfied.

The Pressure Regulator Incremental Regulation Determination was performed previously from Generator Synchronization to 100% CLTP in 2% power increments and was satisfactory. Data was collected for the TPO uprate at each of the test plateaus from 95 % CLTP to TPO conditions. The variation in incremental regulation was verified to be within the acceptance criteria for all test conditions.

"A" Pressure Regulator Step Change Data Power Step Size Peak Pressure Peak Steady Decay Level (+/-) Pressure Response Power (%) State Ratio (MWth) _psi_*_ Time Cycles 3285 -3 psi 1028.3 10 sec. 93.2 0 0 3285 +3 psi 1032.6 10 sec. 94.4 0 0 3458 -3 psi 1038.5 6 sec. 97.8 0 0 3458 +3 psi 1043.1 5 sec. 99.0 0 0 3515 -3 psi 1038.0 5 sec. 98.3 0 0 3486 +3 psi 1042.4 6 sec. 99.2 0 0 "B" Pressure Re ulator Step Change Data Power Step Size Peak Pressure Peak Steady Decay Level (+/-) Pressure Response Power (%) State Ratio (MWth) _psi__) Time Cycles 3285 -3 psi 1028.7 7 sec 93.3 0 0 3285 +3 psi 1033.0 7 sec 94.4 0 0 3458 -3 psi 1042.0 7 sec 98.5 0 0 3458 +3 psi 1038.5 7 sec 97.6 0 0 3486 -3 psi 1037.0 5 sec 98.0 0 0 3486 +3 psi 1041.8 6.5 sec 99.0 0 0 Page 13

3.6 STP-23, Feedwater System Objectives The purpose of this test is to verify the feedwater control system has been adjusted to provide acceptable reactor water level control for TPO operating conditions.

Description Feedwater Control System Testin2 Note: This testing may produce core power excursions due to the feedwater addition. The power levels of these operational transients have the potential to exceed the steady-state power level of the test condition. A margin to licensed thermal power should be established to avoid exceeding the licensed thermal power limit.

At each test condition reactor water level set-point changes are introduced into the feedwater control system in accordance with the following set-point change sequence: -4 in., + 1 in., -2 in., + 2 in., -3 in., + 3 in.

The normal feedwater control system mode is three-element control, with single element control only being used for temporary backup situations. The feedwater control system in three-element control mode should be adjusted, not only for stable operational transient level control (i.e., decay ratio), but also for stable steady-state level control (i.e., minimize water level limit cycles). In single element control mode, the system adjustments must achieve the operational transient level control criteria, but for steady state level control the temporary backup nature of this mode should be considered.

Acceptance Criteria Level I The transient response of any feedwater level control system- related variable to any test input must not diverge.

Level 2 a) Level control system-related variables may contain oscillatory modes of response. In these cases, the decay ratio of each controlled mode of response must be _<0.25.

b) The turbine speed regulation variation between the three feedpumps must match within +/- 6% of rated speed.

Results Feedwater Stability Testing was performed at 95% CLTP, 100% CLTP, and TPO power level. One, two, and three inch positive and negative level set-point changes were input and system response was monitored. These step changes were performed in three element control. The -3 inch level change at 95% CLTP is the only test that produced a non-zero decay ratio. The decay ratio was 0.13, which is within the level 2 criteria of decay ratio < 0.25. No tuning or adjustments were necessary. Previous testing of the Feedwater Level Control System is sufficient to demonstrate control capability of the control system in single element control mode through 100% TPO power level, so no single element testing was performed. All acceptance criteria related to system stability were satisfied.

Speed regulation variation between the three reactor feed pumps was verified to match to within +/-6% of each other at each test plateau from 95% CLTP to TPO conditions.

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4.0 Tests Not Described in UFSAR Section 14.2 4.1 STP-1B, Steam Dryer/Separator Performance Objective The objective of this test is to evaluate steam dryer/separator performance at TPO conditions by measuring main steam line (MSL) moisture content.

Note: Task T0306, Steam Dryer/Separator Performance, performs a specific evaluation of Limerick steam dyer/separator performance at TPO conditions. T0306 provides confirmation of the steam dryer moisture content functional performance specification for the TPO. Steam dryer/separator performance testing is recommended to confirm the T0306 analytical results and demonstrate acceptable performance at TPO.

Description Steam dryer/separator performance (i.e., moisture carryover) is determined by performing a tracer test similar to that performed in the original startup test program or by other equivalent plant procedure. Refer to SIL-639 (Ref. 4) for information on MSL moisture content measurement in operating BWRs. For this testing, MSL moisture content is considered equivalent to the steam dryer moisture carryover. Testing at 100% TPO satisfies this testing recommendation. Optional testing at 100% TPO on the MELLLA Boundary permits the T0306 analytical prediction to be confirmed acceptable at the limiting operating conditions of low core flow at high thermal power. Optional testing at the 100% TPO and ICF comer testing allows MSL moisture content to be compared to the steam dryer performance at the limiting operating condition of high core flow at high thermal power. Other test condition power/flow operating points may be tested as deemed appropriate prior to achieving the 100% TPO power test conditions to demonstrate the test methodology or confirm acceptable steam moisture content at operating conditions prior to achieving 100% TPO.

Level I None Level 2 MSL moisture content shall not be in excess of the steam dryer functional performance design specification for long-term operations.

Results Moisture carryover readings were taken at both 100% CLTP and TPO power levels. At 100% CLTP, moisture carryover was measured to be 0.021% and at TPO power level, moisture carryover was 0.032%. The design limit for moisture carryover is to be less than or equal to 0.1%.

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4.2 STP-101, Plant Parameter Monitoring and Evaluation Objective The objective of this test is to evaluate that power-dependent parameters remain within limits to ensure a careful, monitored approach to the TPO level. The power-dependent parameters monitored are those of systems and equipment affected by the TPO power increase.

Description Routine measurements of the power-dependent parameters (i.e., pressures, temperatures, flows, vibration) of systems and equipment affected by the TPO, are taken at 95% and 100% of CLTP. Parameters will be calculated using accepted methods to ensure current licensed and operational practices are maintained.

Measured and calculated power-dependent parameters are used to project those values in the TPO test condition prior to increasing power above CLTP. Once the TPO power test condition is achieved, each actual value will be evaluated against operational limits and its predicted value to confirm the change as expected with the TPO power increase is acceptable.

Level 1 All power-dependent parameters shall be within the limits specified in Technical Specifications (TRM, COLR, or Fuel Warranty, as applicable).

Level 2 None Results:

System monitoring was performed at each of the test plateaus. All power-dependent parameters were confirmed to be within the limits specified in Technical Specifications (Technical Requirements Manual, COLR, or Fuel Warranty as applicable) at each power level. All acceptance criteria related to power-dependent systems parameters was satisfactory.

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