Text

Supplemental Information Supporting Request for License Amendment Request - Extended Power Uprate - Supplement No. 5
	ML13182A025
Person / Time
Site:	Peach Bottom
Issue date:	06/27/2013
From:	Borton K; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML13182A025 (61)
	v • d • e

AmwExelon Generation.

10 CFR 50.90 June 27, 2013 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Supplemental Information Supporting Request for License Amendment Request -

Extended Power Uprate - Supplement No. 5

References:

1. Letter from K. F. Borton (Exelon Generation Company, LLC) to U. S. Nuclear Regulatory Commission, "License Amendment Request - Extended Power Uprate," dated September 28, 2012. (ML122860201)

2. U.S. Nuclear Regulatory Commission to Exelon Generation dated April 26, 2013; Peach Bottom Atomic Power Station - Units 2 and 3 - Request for Additional Information for Extended Power Uprate (TAC Nos. ME9631 and ME9632). (ML13106A126)

In Reference 1, Exelon Generation Company, LLC (EGC) requested an amendment to Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS),

Units 2 and 3, respectively. Specifically, the proposed changes revise the Operating License and Technical Specifications (TS) to implement an increase to 3951 MWt from the current licensed reactor thermal power (CLTP) of 3514 MWt.

In this supplement, EGC proposes changes to the proposed TS submitted in Reference 1.

These changes include 1) new TS surveillance requirements (SR) to verify the capability to transfer power sources for selected valves and 2) revisions to TS related to the Oscillating Power Range Monitors (OPRM).

The original license amendment request (LAR) described modifications to enable PBAPS to eliminate the need to credit containment accident pressure (CAP) in its evaluation of net positive suction head for the emergency core cooling system (ECCS) pumps. During the detailed design, it was determined that certain changes to the modifications described in Reference 1 that support CAP credit elimination are necessary. The Residual Heat Removal (RHR) Heat Exchanger Cross-Tie Modification ("RHR Modification"), as described in Enclosure 9c of Reference 1, will be changed to provide the control room operator with the capability to transfer power for certain selected valves from a normal source to an alternate source in the event of a loss of offsite power and failure of an emergency AC electrical power source. This change requires additional SRs to ensure this function.

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U.S. Nuclear Regulatory Commission License Amendment Request - Extended Power Uprate - Supplement No. 5 June 27, 2013 Page 2 The revisions to the proposed OPRM TS affect the Reactor Protection System Instrumentation TS changes included in Reference 1. The revision proposes to align the operability requirement for the OPRM Upscale function with the requirement for the calibration of the Average Power Range Monitors (APRM) at EPU conditions.

A design change will also be made to allow the operator to prevent the automatic swapover of the suction of the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) pumps for certain events including fires in certain fire areas.

This supplement includes a description of these changes, including changes to related descriptions from Attachments 4, 6, and 9 of Reference 1.

Finally, this supplement provides additional editorial corrections and clarifications to the Reference 1, Attachments 4 and 6.

The attachments to this supplement are summarized as follows:

Provides proposed TS changes and a description of the changes to the modifications described in Reference 1 supporting CAP credit elimination, OPRM TS changes, revisions to the human factors evaluation and minor editorial changes to Reference 1.

Provides replacement marked up pages of the affected TS indicating the changes proposed in this supplement. They are shaded to distinguish them from the changes proposed in Reference 1.

Provides replacement marked up pages of the affected TS Bases indicating the changes proposed in this supplement. They are shaded to distinguish them from the changes proposed in Reference 1. These pages are provided for information only and do not require NRC approval.

Provides a revision to Reference 1, Attachments 4 and 6, Section 2.11, Human Performance, reflecting the results of a human factors evaluation due to the changes. This attachment also provides additional information requested by the Health Physics and Human Performance Branch (Reference 2).

EGC has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration in Reference 1. The additional information provided in this supplement does not affect the bases for concluding that no significant hazards consideration is involved with the proposed EPU license amendment. Further, the additional information provided in this supplement does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the Commonwealth of Pennsylvania and the State of Maryland of this supplement by transmitting a copy of this letter to the designated State Officials.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact David B. Neff at (610) 765-5631.

U.S. Nuclear Regulatory Commission License Amendment Request - Extended Power Uprate - Supplement No. 5 June 27, 2013 Page 3 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of June 2013.

Respectfully, Kevin F. Borton Manager, Licensing - Power Uprate Attachments:

1. Evaluation of Proposed Changes

2. Replacement Markups of Technical Specification Pages for Units 2 and 3

3. Replacement Markups of Technical Specification Bases Pages for Units 2 and 3

4. Replacement Text for Section 2.11 in Attachments 4 and 6 of PBAPS EPU LAR Submitted September 28, 2012 cc:

USNRC Region I, Regional Administrator wlattachments USNRC Senior Resident Inspector, PBAPS w/attachments USNRC Project Manager, PBAPS w/attachments R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland Peach Bottom Atomic Power Station Units 2 and 3 Supplement No. 5 to Extended Power Uprate License Amendment Request NRC Docket Nos. 50-277 and 50-278 Evaluation of Proposed Changes

TABLE OF CONTENTS

SUBJECT:

Supplement 5 to Extended Power Uprate License Amendment Request

1.0 INTRODUCTION

2.0 CHANGES TO SUPPORT CAP CREDIT ELIMINATION 2.1 Description of Changes to RHR Heat Exchanger Cross-Tie Modification 2.2 Proposed Changes to RHR and HPSW Technical Specifications 2.3 Revision to Enclosure 9c, RHR Cross-Tie Heat Exchanger Modification 2.4 Risk Assessment of Changes to RHR Heat Exchanger Cross-Tie Modification 2.5 Description of Changes to Inhibit HPCI/RCIC Pump Inadvertent Suction Swap 3.0 HUMAN PERFORMANCE REVIEWS 3.1 Revision to PUSAR Section 2.11, Human Performance 3.2 Update to Health Physics and Human Performance (AHPB) Branch RAI's 4.0 OSCILLATION POWER RANGE MONITOR (OPRM) TS CHANGE 4.1 Proposed Changes to RPS Instrumentation Technical Specification 3.3.1.1 4.2 Technical Evaluation for Proposed Changes to TS 3.3.1.1 5.0 MISCELLANEOUS CHANGES AND CORRECTIONS TO THE EPU LAR

6.0 REFERENCES

TABLE 1-1 NEW OR CHANGED OPERATOR ACTIONS THAT IMPACT EMERGENCY OR ABNORMAL PROCEDURES Enclosure la:

Figure 9c RESIDUAL HEAT REMOVAL SYSTEM CURRENT CONFIGURATION WITH RHR MODIFICATION CHANGES - FOR INFORMATION ONLY Figure 9c RHR AND HPSW MODIFICATIONS SINGLE LINE ELECTRICAL DIAGRAM - FOR INFORMATION ONLY

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 1

1.0 INTRODUCTION

Exelon Generation Company, LLC (EGC) submitted a License Amendment Request (LAR) for an Extended Power Uprate (EPU) for the Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3 on September 28, 2012 (Reference 1). During the detailed design process, changes to the modifications described in Reference 1 that support Containment Accident Pressure (CAP) credit elimination were identified. These include the need to provide the operator with the capability to transfer the source of power for the motor-operated valves required to establish the Residual Heat Removal (RHR) system in a cross-tied configuration from a normal to an alternate source and the ability to inhibit the automatic swapover of the suction of the High Pressure Coolant Injection (HPCI) and Reactor Core Isolation Cooling (RCIC) pumps from the Condensate Storage Tank to the suppression pool for certain events. These changes necessitated additional Technical Specifications (TS) changes. A change to the Oscillation Power Range Monitor (OPRM) TS to provide coordination with related TS requirements was also identified. Finally, minor corrections and clarifications to Attachments 4 and 6 of the EPU LAR (i.e., the Power Uprate Safety Analysis Report, PUSAR) were identified. This supplement provides the additional information related to these changes necessary to support the U.S. Nuclear Regulatory Commission's (NRC) review of the EPU LAR.

The safety analyses included in the EPU LAR support the elimination of reliance on CAP credit in demonstrating Net Positive Suction Head (NPSH) for the Emergency Core Cooling System (ECCS) pumps. The EPU LAR described certain modifications that will accomplish the elimination of CAP credit. Among these modifications is the RHR Heat Exchanger Cross-Tie Modification (RHR Modification) as described in Enclosure 9c to of Reference 1. Since the submittal of Reference 1, the detailed design process identified the need to provide the Control Room operator with the capability to transfer the power supply of the motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger High Pressure Service Water (HPSW) outlet valves from a safety-related normal source to a safety-related alternate source in the event of a loss of offsite power and the failure of an emergency AC electrical source. These changes are described in Section 2.1 below and include the proposed additional changes to the TS Surveillance Requirements (SR) that will verify operability of the alternate power transfer switch function; a revision to Enclosure 9c of Attachment 9 reflecting these changes; and the results of an evaluation of their impact on overall plant risk.

The EPU LAR described modifications supporting the elimination of CAP credit that include establishing the Condensate Storage Tank (CST) as the only suction source for HPCI and RCIC pumps during certain special events. This modification is described in e, Condensate Storage Tank Modifications, of Attachment 9 of Reference 1.

The detailed design process also identified the need to provide key-lock switches that will allow the operator to inhibit the automatic swapover of the suction source for these

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 2 pumps for a fire in certain fire areas. This modification change is described in Section 2.5 below.

The changes to the RHR Modification and the use of key-lock switches for inhibiting automatic swapover of the suctions for the HPCI and RCIC pumps impact operator actions. The resulting revisions to the procedures governing affected operator actions are addressed in Section 3.0 below and are incorporated into a revision of PUSAR Section 2.11, Human Performance, provided as Attachment 4 to this supplement. The effects of the changes described in this supplement on the responses provided in Requests for Additional Information (RAI) AHPB-RAI-1, 2 and 3 provided in Reference 5 are also addressed in Section 3.0 below.

Section 4.0 of this supplement proposes a revision to TS 3.3.1.1, Reactor Protection System Instrumentation, that would revise the power level at which the OPRM Upscale function is required to be operable in order to align with the calibration of the Average Power Range Monitors (APRMs) at EPU conditions.

Finally, Section 5.0 provides additional minor corrections and clarifications to the PUSAR as submitted in the EPU LAR.

2.0 CHANGES TO SUPPORT CAP CREDIT ELIMINATION 2.1 Description of Changes to RHR Heat Exchangier Cross-tie Modification The proposed EPU design basis analysis assumes that the RHR system is placed into a cross-tied configuration consisting of one RHR pump with flow balanced through two heat exchangers at one hour into the event. In order to place the RHR system in the cross-tied configuration, certain motor-operated valves are needed to function even if the normal safety-related emergency AC electrical power source fails. The RHR Heat Exchanger Cross-Tie Modification, as described in Enclosure 9c to Attachment 9 of Reference 1, has been changed to ensure that these valves are provided with the capability of receiving power from either their normal source or from an alternate safety-related power supply. This will ensure that the failure of one emergency electrical AC source will not result in the loss of the RHR containment cooling function. Specifically, control switches in the Control Room will allow the operator to manually transfer power from a normal source to an alternate safety related source for the following valves, if necessary, in order to establish cross-tied RHR operation:

RHR Cross-Tie Valves MO-2-10-23452A,B MO-3-10-33452A,B RHR Flow Control Valves CV-2-10-2677A,B,C,D CV-3-10-3677A, B,C,D RHR Heat Exchanger HPSW MO-2-10-089A,B,C,D MO-3-10-089A,B,C,D Outlet Valves

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 3 This will be accomplished by powering each of these valves through a motor control center (MCC) compartment with a transfer switch that can provide a redundant source of power within the same division. This modification will allow the operator to select the power supply and transfer power manually with control switches in the Control Room as required. There will be two new MCC compartments per division or a total of four for each unit.

In order to ensure that the fire safe shutdown requirements of Appendix R are met, control and transfer/isolation switches will be installed outside the Control Room that will allow the operator to prevent spurious operation of the 'B' RHR cross-tie valves (MO 10-23452B for Unit 2 and MO-3-10-33452B for Unit 3) and inadvertent switching of power sources in the event of a fire in the Control Room requiring shutdown from the alternative shutdown panel (ASD) panel. This will ensure that flow is not diverted from the protected 2B (Unit 2 'B' RHR pump and 'B' RHR heat exchanger) and 3D (Unit 3 'D' RHR pump and 'D' RHR heat exchanger) RHR trains.

All new RHR cross-tie components will meet PBAPS safety-related and seismic requirements applicable to the RHR system. The physical separation criteria as described in Chapter 8 of the UFSAR will be applied to the changes to the RHR Modification.

In accordance with the proposed surveillance requirements, the valves powered by the new MCC compartments will be tested while powered from their normal power supply during quarterly RHR surveillance testing. The capability to transfer from the normal to the alternate supply will also be tested on a frequency established in accordance with the Surveillance Frequency Control Program.

2.2 Proposed Changes to RHR and HPSW Technical Specifications This supplement to the EPU LAR proposes three TS Surveillance Requirements (SR) associated with the changes to the RHR Modification which provide the Control Room operator with the capability to transfer the power supply to the motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves from the safety-related normal source to a safety-related alternate source.

2.2.1 RHR Suppression Pool Cooling TS Control switches in the Control Room will provide the operator with the capability to transfer power for the motor-operated RHR cross-tie and RHR flow control valves from the normal source to the alternate source. The following new SR is proposed to be conducted in accordance with the Surveillance Frequency Control Program:

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 4 "SR 3.6.2.3.3 Verify manual transfer capability of power supply for the RHR motor-operated flow control valve and the RHR cross-tie motor-operated valve from the normal to the alternate source."

The ability to provide power to each motor-operated RHR flow control valve and RHR cross-tie valve from either of two independent 4kV emergency buses ensures that a single failure of an emergency AC electrical source will not result in failure of these valves.

2.2.2 RHR Suppression Pool Spray TS The capability to transfer power for the motor-operated RHR cross-tie and RHR flow control valves described in Section 2.1.1 above for the Suppression Pool Cooling mode of RHR is also relied upon in the Suppression Pool Spray mode of RHR. The following new SR is proposed to be conducted in accordance with the Surveillance Frequency Control Program:

"SR 3.6.2.4.3 Verify manual transfer capability of power supply for the RHR motor-operated flow control valve and the RHR cross-tie motor-operated valve from the normal to the alternate source."

The ability to provide power to each motor-operated RHR flow control valve and RHR cross-tie valve from either of two independent 4kV emergency buses ensures that a single failure of an emergency AC electrical source will not result in failure of these valves.

2.2.3 HPSW System TS The proposed TS changes in the EPU LAR (Attachment 2 to Reference 1) include a proposed SR for the transfer capability of the motor-operated HPSW cross-tie valves.

This supplement proposes to revise that proposed SR to also include the motor-operated RHR heat exchanger HPSW outlet valves. The following SR is proposed to be conducted in accordance with the Surveillance Frequency Control Program:

"SR 3.7.1.2 Verify manual transfer capability of power supply for the HPSW cross-tie motor operated valve and the RHR heat exchanger HPSW outlet motor operated valve from the normal to the alternate source."

The ability to provide power to the motor-operated HPSW cross-tie valve and each motor-operated RHR heat exchanger HPSW outlet valve from either of two independent 4kV emergency buses ensures that a single failure of an emergency AC electrical source will not result in failure of a required HPSW system flow path.

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 5 2.3 Revision to Enclosure 9c, RHR Cross-Tie Heat Exchanqer Modification Certain sections of Enclosure 9c of Attachment 9 to the EPU LAR, which provided a description of the RHR Modification, are being revised to reflect the capability to provide both a normal and an alternate power source for each motor-operated RHR cross-tie, RHR flow control, and RHR heat exchanger HPSW outlet valve. An update of the affected text of Enclosure 9c is presented below. Additions are indicated by bolded characters and deletions are indicated with stiketl;Feugh markers. Gray highlighted sections are changes included in Supplement 1 (Reference 2).

The revision includes an update to Figure 9c-1, RESIDUAL HEAT REMOVAL SYSTEM CURRENT CONFIGURATION WITH RHR MODIFICATION CHANGES, which shows the configuration changes being made to the RHR system as a result of EPU including those discussed in this supplement. It is provided in Enclosure la to this Attachment.

The revision to Enclosure 9c also includes a new Figure 9c-2, RHR AND HPSW MODIFICATIONS SINGLE LINE ELECTRICAL DIAGRAM that is also provided in Enclosure la. Figure 9c-2 updates the sketch provided in the response to EEEB RAI-1 1 (Reference 5) by showing the alternate power supply capability that will be provided to the motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves. c, Section 4.1.2 Electrical, page 8 In order to ensure that the capability to provide an RHR subsystem with two heat exchangers cross-tied to one RHR pump is maintained following a design basis accident with a loss of offsite power and the single failure of one emergency AC electrical power source, the motor-operators on the RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves are capable of being powered from a safety-related normal and safety-related alternate electrical bus, within the same electrical division, backed by separate Emergency Diesel Generators.

The moadification inldcte olwn ew Safety related loads:-

QA Onene RHR crosES tie MOV per division.

A nAeW motoF r F roperated floW conGtrol ValVe -n the discharge of each RHR pump.

G#0 Cotol F

room ontol and indications.

The installation of new MCC compartments with remote manual transfer switches will provide the diverse power sources. Remote manual control switches will be installed in the Control Room to allow the operator to transfer power from the normal to the alternate power supply. Electrical separation of power, instrumentation and control cables associated with the RHR heat exchanger cross-tie modification shall will conform to physical separation criteria as described in Chapter 8 of the UFSAR.

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 6 Sigeo-the The RHR heat exchanger cross-tie MOVs and the new flow instrumentation are not credited to achieve and maintain safe shutdown during an Appendix R fire for EPU but the valves must remain closed for postulated fires in areas that they are credited for in their associated loop so flow is not diverted.,-pProtection of the these cross-tie MOVs and associated cables from fire damage for the purpose of maintaining remote er-manual gontrel capability for safe shutdo,-wn is not required to maintain the valve in a closed position will, therefore, be provided..-However, the The four new RHR flow control valve cables and power supplies will Ferwiae proteGtFGR also be protected from fire damage so that they can be controlled from the Control Room to support LPCI injection for Shutdown Method C (see PUSAR 2.5.1.4.2 for a description of the four Appendix R Shutdown Methods) and to support alternate shutdown cooling and suppression pool cooling as required for Shutdown Methods A, B, C, and D.

The RHR pumps are each powered from separate 4 KV emergency auxiliary buses and EDGs. The c-ress-tie NOVs motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves in each RHR loop will be capable of being powered from normal and alternate safety-related power sources through separate 4KV buses from;-an backed by EDGs in the same division such that the failure of one EDG emergency AC electrical power source will not result in the loss of the RHR containment cooling function ef the cross tie in both loops. The new control.MOV's wil be powered from, the c Frn EDG ar s the4 a+ks*o,-

RHR pump-Th, e These Rew-RHR aress-tie MOVs are not oesideied included in the EDG loading calculations suioe the because their stroke times is are limited and they are an intermittent load that occurs after all the immediate actions in the first 10 minutes have been completed. Refer to section 5.0, Operating with the RHR Heat Exchanger oCross-tie, for operation of the RHR heat exchanger cross-tie MOVs.

Figure 9c-2 is a schematic that shows the electrical one-line arrangement of the power sources for the motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves as well as for the motor-operated HPSW cross-tie valves described in Enclosure 9d. c, Section 4.1.3, Instrumentation, page 9 RHR Cross-Tie Isolation MOV This valve is normally closed, and will need to be m'R'all, opened to enter the RHR heat exchanger cross-tie mode of operation. Control room operators will be provided with manual controls for the RHR heat exchanger cross-tie isolation MOV with full open and full closed indicating lights. When the valve is in mid-travel, both the red and green lights will be illuminated. New hand switches and indicating lights are being provided in the Control Room for manually controlling the transfer of power to the MOV from the Normal to Alternate source or vice versa. The indicating lights indicate if power is available on the Normal and Alternate sources. All controls

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 7 associated with the RHR heat exchanger cross-tie isolation MOV are classified as safety-related.

RHR Heat Exchanger Flow Control Valves Manual controls are provided for the RHR flow control valves located downstream of the RHR pumps allowing the operator to throttle the valve position. Full travel indicating red and green lights are provided for the full open and full closed positions. These valves will be verified in the proper alignment for LPCI operation during RHR system surveillance testing (See Section 5.0, Operating with the RHR heat exchanger cross-tie). LPCI position lights are also provided in the Control Room to indicate to the operator that the throttling RHR flow control valves are in the proper alignment for LPCI operation. One white light will correspond to the valve position at the minimum LPCI flow rate, and the second white light will correspond to the valve position at the maximum allowable flow precluding RHR pump runout. An annunciator alarm is provided in the control room that will alarm when the valve position has moved outside of its allowable range of travel.

New hand switches and indicating lights are being provided in the Control Room for manually controlling the transfer of power to the MOV from the Normal to Alternate source or vice versa. The indicating lights indicate if power is available on the Normal and Alternate sources. All components in the control circuit shall be classified as Active Safety-Related components. c, Section 5.0 OPERATING WITH RHR HEAT EXCHANGER CROSS-TIE/Surveillance Testing and Inservice Inspection, pages 11-12 Periodic surveillance testing will also include performance verification of the RHR heat exchanger cross-tie, aPd RHR flow control and RHR heat exchanger HPSW outlet valves in accordance with the MOV program and flow loop instrumentation calibration. A functional test of the normally closed RHR cross-tie MOVs, and RHR flow control,valves and RHR heat exchanger HPSW outlet valves will be performed by stroking the valves during the test. Periodic verification of the manual transfer capability of the power supply for these valves from the normal to alternate source will be conducted in accordance with the proposed surveillance requirements. c, Section 6.2, SINGLE FAILURE ANALYSIS Without a Failure of iOne Erenrgency Ad Electrical Power* Source_

g.

MCC Compartment with Transfer Switch fails at Normal power selected With the transfer switch failed in the normal power position, the MOVs for the associated motor-operated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves are still available to satisfy the containment cooling analysis requirements; therefore, there is no impact to the system.

h.

MCC Compartment with Transfer Switch failure resulting in a loss of normal source and inability to transfer

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 8 With no power available to the MCC Compartment with Transfer Switch, the MOVs for the associated RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves will fail in the normal position. The other complete RHR division is available with its two HPSW pumps providing flow through its two RHR heat exchangers, thus satisfying the containment cooling analysis requirements.

MCC Compartment with Transfer Switch fails at Alternate power selected With the transfer switch failed in the Alternate power position, the associated motor-operated RHR cross-tie, RHR flow control, and RHR heat exchanger HPSW outlet valves are still available to satisfy the containment cooling analysis requirements; therefore, there is no impact to the system.

2.4 Risk Assessment of Changes to RHR Heat Exchanger Cross-Tie Modification The original assessment of the evaluation of the change in risk associated with the EPU was submitted as Attachment 12 to Reference 1. On the basis of this assessment, EGC concluded in PUSAR Section 2.13, Risk Evaluation (Attachment 4 and 6 of Reference

1) that it had adequately modeled or addressed the potential impacts associated with implementation of the EPU and that the associated risks are acceptable and do not create the "special circumstances" described in Appendix D of SRP Chapter 19. An additional evaluation has now been performed that reconfirms that the impacts on plant risk of the EPU are still acceptable with the changes to the RHR Modification that allow the Control Room operator to transfer power for the RHR cross-tie, RHR flow control and RHR heat exchanger HPSW outlet MOVs from a safety-related normal to a safety-related alternate 4kV bus, within the same electrical division, backed by separate Emergency Diesel Generators.

The evaluation, which did not take credit for the benefit of having back-up power supplies for these valves, included a bounding sensitivity case to determine the potential risk impact of changes to operator actions requiring the use of these valves that are necessitated by the RHR Modification. It concluded that there would be negligible potential increases to Core Damage Frequency (CDF) and Large Early Release Frequency (LERF). External events and low power shutdown risk were also assessed to be negligibly impacted. Therefore, the implementation of the proposed additional hardware changes would have no impact on the conclusions regarding overall plant risk in the EPU LAR.

2.5 Description of Changes to Inhibit HPCI /RCIC Pump Inadvertent Pump Suction Swap Although the pre-EPU Appendix R scenarios assumed transfer of the suction of the HPCI and RCIC pumps from the CST to the suppression pool on low level, the post-EPU Appendix R scenarios rely on the greater decay heat removal capability of the cooler

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 9 CST and RWST source over the duration of the event. Enclosure 9e to Attachment 9 of the EPU LAR describes modifications that support CAP credit elimination by ensuring that the CST is the only suction source for the HPCI and RCIC systems during certain transients including Appendix R events. As stated in Enclosure 9e, the post-EPU configuration is evaluated as part of the normal implementation process to identify any potential circuits or equipment that are required for safe shutdown that could be affected by a design basis fire. This evaluation identified the need to manually inhibit Unit 2 RCIC, and Unit 3 HPCI and RCIC pump automatic suction swap from the CST to the suppression pool, as applicable, for a fire in certain fire areas. This will be accomplished by installing key-lock switches in the Control Room that will allow the operator to manually inhibit spurious suction swap that might occur as a result of fire damage.

Annunciator windows will be provided in the Control Room to alert the operators when any of the key-lock switches are switched to an off-normal condition. This modification will be developed through the EGC Configuration Change Process. These changes involve new operator actions that are discussed in Section 3.0 below and Attachment 4 to this supplement.

3.0 HUMAN PERFORMANCE REVIEWS This section addresses the human factors reviews related to the changes described in this supplement that are incorporated into the revision to PUSAR Section 2.11, Human Performance, which is included as Attachment 4 to this supplement. It provides updates to RAI's received in Reference 4 and responded to in Reference 5 that reflect the changes to the RHR Modification and key-lock switch for inhibiting HPCI and RCIC pump automatic suction swapover.

3.1 Revision to PUSAR Section 2.11, Human Performance During the course of the detailed design process for implementation of the EPU, EGC has identified the need to make the following additional design changes in support of EPU and CAP credit elimination:

New MCC compartments with remote manual transfer switches and associated control switches in the Control Room will be installed that will allow the operator to transfer power from a safety-related normal source to an alternate safety related source for the motor-operated RHR heat exchanger cross-tie, RHR flow control and RHR heat exchanger HPSW outlet valves.

Control switches will be installed on the ASD panels for the 'B' motor-operated RHR cross-tie valves with each having a transfer/isolation switch in an emergency bus room panel to isolate the ASD panel control circuits from potentially fire damaged portions of the circuits that are routed to the Control Room.

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 10

Transfer/isolation switches will be installed on the ASD panels to isolate the control circuits for the 2B and 3D MCC Compartments remote (i.e., Control Room) transfer switches and align these MCCs to their normal power supplies during Appendix R events where evacuation of the Control Room is required.

" Key-lock control switches will be installed to allow the operators to manually inhibit Unit 2 RCIC, and Unit 3 HPCI and RCIC pump automatic suction swap from the condensate storage tank to the suppression pool, as applicable, for a fire in certain fire areas. (see Enclosure 9e to Attachment 9 of Reference 1 for detailed discussion of the modification to raise the swapover setpoint in support of EPU and CAP credit elimination).

The revision to PUSAR Section 2.11 in Attachment 4 to this supplement also includes the following other changes:

In Section 2.11.2.2, the time by which an operator must initiate Alternate Shutdown Cooling (ASDC) for Appendix R Method "A" with a Stuck Open Relief Valve (SORV) is changed to the current pre-EPU time of 180 minutes. It was determined that no change to the current operator response time is required to support the EPU Appendix R analysis. Prior to ASDC initiation, RCIC is utilized for Reactor Pressure Vessel (RPV) makeup. Therefore, the time limit of 180 minutes for ASDC initiation for RPV makeup is unchanged for EPU.

Section 2.11.1.4 is revised to add the statement that the Safety Parameter Display System (SPDS) indications will be changed to reflect the fact that the percentage of Standby Liquid Control (SLC) tank volume required to achieve Hot Shutdown Boron Weight (HSBW) will change due to the increase in Boron-10 enrichment.

Section 2.11.1.1 contains minor updates to the modifications associated with procedure changes.

The regulatory acceptance criteria for the human factors reviews are based on GDC-19, 10 CFR 50.120, 10 CFR 55, and the guidance in Generic Letter 82-33. The human factors reviews of the changes to operator actions, human-system interfaces, procedures and training resulting from the EPU LAR including the changes described in this supplement have no adverse affect on the existing programs, procedures, training, and other plant design features related to operator performance during normal and accident conditions.

3.2 Update to Health Physics and Human Performance (AHPB) Branch RAI's In Reference 5, EGC provided responses to RAI's on the PBAPS EPU LAR received from the NRC in Reference 4. EGC's responses to three of the AHPB RAI's stated that additional information would be provided in a supplement to the EPU LAR. This information is provided herein as follows:

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 11 AHPB RAI-1 This RAI asked EGC if there were any new operator actions as a result of the proposed EPU other than those identified in PUSAR Section 2.11.1.2. EGC's response referred to PUSAR Section 2.11.1 for a general description of new operator actions and to Enclosures 9c and 9d (HPSW Cross-Tie Modification) for details of those operator actions specific to the RHR and HPSW systems. It also stated that a supplement would identify any additional operator actions. Those additional operator actions including those related to the modifications described above consist of the following:

" Operating procedures will be required to manually control the transfer of power from the Normal to Alternate source or vice versa for each of the four new MCC Compartments per unit associated with powering the motor-operated RHR flow control valves, RHR heat exchanger cross-tie valves, and the RHR heat exchanger HPSW outlet valves.

Operating procedures will be revised to direct the operators to perform new actions to operate key-lock switches in the CR to inhibit Unit 2 RCIC, and Unit 3 HPCI and RCIC pump automatic suction swap, as applicable, for a fire in certain fire areas.

" New operator actions are required for Safe Shutdown Method "D" to address use of new transfer/isolation switches installed on the ASD panels to isolate the control circuits for the 2B and 3D MCC Compartments remote (i.e., Control Room) transfer switches and align these MCCs to their normal power supplies for a fire in the Control Room.

New operator actions are required for Safe Shutdown Method "D" to address use of new control switches on the ASD panels for the "B" motor-operated RHR heat exchanger cross-tie valves, and their associated transfer/isolation switches in emergency bus room panels, to isolate the ASD panel control circuits from control circuits in the Control Room for a fire in the Control Room.

New operator actions are required for Safe Shutdown Method "D" to direct the operators to ensure the new RHR flow control valves (MO-2-10-2677B & MO-3 3677D) are fully open by manually opening these valves at their respective MCC Compartment breaker by manipulating the motor contactor and then opening the breakers to preclude spurious mispositioning for a fire in the Control Room.

The above additional operator actions are incorporated into the revision of PUSAR Sections 2.11.1.2 and 2.11.1.3 provided in Attachment 4 to this supplement.

AHPB RAI-2 The RAI requested EGC to delineate which of the changes in PUSAR Section 2.11.1.2 are related to emergency or abnormal operating procedures. EGC's response in Reference 5 referred to PUSAR 2.11.1.1 for the identification of changes to EOP's and AOP's as a result of EPU. The response provided a table indicating which of the changes to operator actions identified in PUSAR Sections 2.11.1.2 and 2.11.1.3, are

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 12 related to EOP's or AOP's. The response also indicated that a future supplement would be provided which would include additional operator actions that are related to EOP's and AOP's. The attached Table 1-1 provides this information as an update to the table provided in the response to this RAI. It includes the additional operator actions resulting from the modifications discussed above.

AHPB RAI-3 The RAI asked EGC if there are any operator actions as a result of EPU that will have additional or reduced response time other than those identified in PUSAR Section 2.11.1.2. EGC's response in Reference 5 referred to PUSAR Section 2.11.1.2 for a description of all operator actions involving additional or reduced response times. It also stated that a supplement to the EPU LAR would describe changes to the RHR Heat Exchanger Modification and provide any resulting changes to operator response times. It has been confirmed that neither the changes to the RHR Modification described in this supplement nor the new key-lock control switch to prevent automatic swapover of the RCIC and HPCI pump suctions will change the operator response times previously identified in the EPU LAR submittal (Reference 1). In the case of the new operator actions directly related to these changes and described in the update of the response to AHPB RAI-1 above, no time challenges were identified that would prevent completion of these actions in the required time. This information is incorporated into the attached revision of PUSAR Sections 2.11.1.2 and 2.11.1.3.

4.0 OSCILLATION POWER RANGE MONITOR (OPRM) TS CHANGE 4.1 Proposed Changes to RPS Instrumentation Technical Specification 3.3.1.1 The EPU LAR (Reference 1) proposed two changes to Technical Specification 3.3.1.1 related to the OPRM that would revise the power level by which the OPRM Upscale function is required to be OPERABLE from 25% Rated Thermal Power (RTP) to 21.2%

RTP. EGC now requests that the power level for this requirement be established at 23%

RTP rather than 21.2% RTP. This change will align the operability requirement of the OPRM Upscale function with the requirement for calibration of Average Power Range Monitors (APRM) per SR 3.3.1.1.2. Specifically:

Table 3.3.1.1-1, Function 2.f, OPRM Upscale - This table item established the applicable power level at which the OPRM Upscale function is required to be OPERABLE. For EPU, it is now proposed that the stated value be changed from

_>25% to _>23% RTP.

REQUIRED ACTION J.1 -As directed by the requirements of Table 3.3.1.1-1, Function 2.f, Technical Specification Condition D invokes Required Action D.1 for the OPRM Upscale function. Should operability of the function not be restored in accordance with Required Action I, Required Action J would then require the operator to reduce power to a level at which the OPRM Upscale function is not

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 13 applicable. This power level is established by the applicability requirement for Item 2.f of TS Table 3.3.1.1-1. For EPU, it is now proposed this be changed from <25%

RTP to <23% RTP.

SR 3.3.1.1.2 requires calibration of the APRM simulated thermal power (STP) output to Core Thermal Power (CTP) calculated using the plant heat balance. The APRM STP output signal is used to enable OPRM protection at the OPRM trip auto-enable setpoint.

Alignment of these requirements will ensure that the APRM STP signal is valid over the entire power range between the OPRM Upscale function operability threshold and the OPRM trip auto-enable setpoint. The SR 3.3.1.1.19 requirement establishing the OPRM trip auto-enable setpoint, currently proposed in Attachment 2 to Reference 1 at a power level of 26.2% RTP, is not affected by this request.

4.2 Technical Evaluation for Proposed Changes to TS 3.3.1.1

Background

The proposed changes to Technical Specification 3.3.1.1 in the EPU LAR (Reference 1) included two items related to the operable threshold of the OPRM Upscale function.

EGC requests that the EPU amendment approval include a revised value for the OPRM Upscale function operability threshold change in two places in the Technical Specifications. This change is based on the implementation of a plant-specific analysis rather than the generic evaluation criteria used to establish the value in Reference 1.

This proposed change will also maintain consistency between the power levels at which the OPRM Upscale function operability is required, the power levels at which the APRM gain calibration surveillance (SR 3.3.1.1.2) is performed, and the power levels at which the fuel thermal margin monitoring is initiated (SR 3.2.1.1, SR 3.2.2.1, and SR 3.2.3.1).

In the current PBAPS TS, the required power level for operability of the OPRM Upscale function is consistent with the power level at which the APRM gain calibration is performed (see TS SR 3.3.1.1.2.) This is also the power level at which fuel thermal margin monitoring is initiated (see TS Surveillance Requirements 3.2.1.1, 3.2.2.1, and 3.2.3.1). The EPU LAR (Reference 1) proposed the APRM gain calibration surveillance be performed at the power level consistent with the proposed fuel thermal margin monitoring threshold change. That threshold is established as described in Section 2.8.2.1.2 of Attachments 4 and 6 of the EPU LAR. For PBAPS, it is established at >23%

RTP.

The value for establishing OPRM Upscale function operability was being revised in Reference 1 to a value that would provide margin to the proposed OPRM trip auto-enable setpoint of 26.2% RTP. The magnitude of this margin, proposed in Reference 1 as 5%, was intended to provide protection for an event that may occur below the auto-enable setpoint and result in power increasing above that setpoint without operator intervention. The margin to the OPRM Upscale function operability threshold in Reference 1 was determined to be consistent with generic evaluations described in Reference 3. That topical report established nominal thresholds for the operability of the

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 14 OPRM Upscale function and the trip auto-enable setpoint but it also states that the value for a plant can be established based on plant-specific analysis and setpoint considerations.

In support of this change, EGC has performed a plant-specific evaluation as described below.

Justification Currently, the OPRM trip enabled region boundary is automatically enabled when RTP is

>29.5% which is 4.5% above the 25% RTP OPRM Upscale operable threshold for the system. During the evaluation of the power uprate documented in the Power Uprate Safety Analysis Report (Attachments 4 and 6 of Reference 1), the generic evaluation criteria found in Reference 3 had been used. That approach resulted in the 5%

difference between these parameters proposed in the EPU LAR. In order to demonstrate the acceptability of reducing the current 4.5% margin between the OPRM trip-enabled region boundary and the Upscale function operable threshold to the revised margin of 3.2%, EGC performed a plant-specific evaluation to identify the expected impact of credible transients that could occur at low power and result in uncontrolled power increases without operator action. Based on a plant-specific review of transients, it was concluded that the loss of feedwater heating transient (LFWH) is the only significant event that could potentially raise the reactor power into the region of anticipated oscillations without operator action.

An analysis was then undertaken to determine the power level increase that would be expected due to such an event. Considering normal feedwater temperatures and operation at power levels up to 23% RTP, it was determined that a LFWH event could result in a feedwater temperature reduction of up to 43°F. This lower feedwater temperature could result in a power increase in the core with a magnitude of about 1.5%

power. Even this resulting increase (to 24.5% RTP) remains below the point at which the OPRM trip is required to be enabled (26.2% RTP). Thus, the resulting power transient would not be into a region where significant power oscillations would be expected before the automatic trip functions of the OPRM were enabled.

Bounding sensitivity cases were also evaluated considering higher initial feedwater temperatures and greater decreases in feedwater temperatures. These bounding cases are not representative of expected typical startup conditions, but the results of these cases provide additional confidence in the conclusion of the acceptability of this change.

The use of higher initial feedwater temperatures and larger assumed (although not considered credible) feedwater temperature reductions results in larger core inlet subcooling and a larger positive reactivity insertion. Even with feedwater at its maximum temperature and a temperature drop of 580F due to the loss of heating, the resulting power excursion is still less than 3.2%.

In summary, based on the results of a plant-specific evaluation, an OPRM Upscale function operable threshold value of >23% RTP provides adequate margin and assures

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 15 that no credible event could result in an uncontrolled power excursion into a region where significant power oscillations could occur.

5.0 MISCELLANEOUS CHANGES AND CORRECTIONS TO THE EPU LAR Additional corrections and clarifications that are unrelated to the changes to the RHR Modification or the proposed TS changes discussed above were also identified following submittal of the EPU LAR (Reference 1) and Supplement 1 to the EPU LAR (Reference

2) and are being provided here to prevent unnecessary RAI's. A description of the correction or clarification and a conclusion of the impact of each are provided in this section. Where text in paragraphs is affected, additions are indicated with bolded characters and deletions are indicated with 6trkethrough markers. EGC performed a review that concluded these changes do not affect the analyses performed, the conclusions reached, or the justification utilized for the proposed EPU.

The corrections to the PBAPS EPU LAR Attachments 4 and 6, Power Uprate Safety Analysis Report (PUSAR), consist of the following:

5.1 Deletion of PUSAR Table 2.5-7, EPU TBCCW Impact PUSAR Section 2.5.3.3 evaluates the Turbine Building Closed Loop Cooling Water (TBCCW) System. The Technical Evaluation and Conclusion sections provide information to support the conclusion that the proposed EPU is acceptable with respect to the TBCCW system. This text does not rely on information that had been provided in Table 2.5-7. This correction deletes PUSAR Table 2.5-7 on page vii and 2-234.

5.2 Correction of PUSAR Reference 103 for NUREG-0713 Section 3 of the PUSAR contains the References utilized in the document. Reference 103 cites NUREG-0713, "Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities - 2006." The technical evaluation performed to support PUSAR Section 2.10.1.2 used the data from NUREG-0713 - 2008. The correction changes the reference title to reflect the report volume used in the analysis as noted below.

103.

NUREG-0713, Volume 30, "Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities 2008,"published January 2010.,

5.3 Correction of Numerical Value in PUSAR Section 2.10.1.2 PBAPS Section 2.10.1.2 evaluates the Occupational and Onsite Radiation Exposures.

In the third paragraph on Page 2-511, the text incorrectly states the average dose per exposed worker at PBAPS is 0.024% of the limit allowed by 10 CFR 20.1201. The text correctly cites the average dose value of 0.12 Rem from NUREG-0713, "Occupational Radiation Exposure at Commercial Nuclear Power Reactors and other Facilities 2008."

PBAPS EPU LAR SUPPLEMENT NO. 5 ATTACHMENT 1 Evaluation of Proposed Changes PAGE 16 Since the annual limit is 5.0 Rem, the 0.12 Rem value is 2.4% of the annual limit. The correction replaces 0.024% with 2.4% as noted in the revised text below.

"Annual cumulative occupational radiation exposure may increase by as much as 20%

due to EPU compared to OLTP conditions. Individual worker exposure will continue to be maintained within acceptable limits by the ALARA program, which controls access to radiation areas. The radiation exposure in all affected plant areas is not expected to increase greater than the proposed 20% EPU compared to OLTP conditions with the exception of areas that contain N-16 containing components as noted above. The post-EPU increase in the radiation exposure in various areas housing the steam components remains within the currently established dose zone limits as described above. Therefore, no additional measures are required to maintain the plant exposure ALARA. The post-EPU plant operation and maintenance activities will be controlled by the existing radiation protection and ALARA procedures. For example, for the year 2008, the average dose per exposed worker at PBAPS (Total Combined Units) was 0.12 Rem, which is 2.4%0:24W% of the limit allowed by 10 CFR 20.1201. Annual cumulative occupational radiation exposure may increase by approximately 14% due to EPU, which is well within the historical variation in station annual cumulative exposure. Additionally, improvements in performance with respect to occupational doses, as documented in NUREG-0713 (Reference 103), exceed by an order of magnitude anticipated EPU effects."

6.0 REFERENCES

1. Exelon Generation to U.S. Nuclear Regulatory Commission dated September 28, 2012; License Amendment Request - Extended Power Uprate (ML122860201).

2. Exelon Generation to U.S. Nuclear Regulatory Commission dated February 15, 2013; Supplemental Information and Corrections Supporting License Amendment Request -

Extended Power Uprate-Supplement No. 1 (ML13051A032).

3. GEH Licensing Topical Report "Nuclear Measurement Analysis and Control Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function,"

NEDC-32410P-A Supplement 1, dated November 1997.

4. U.S. Nuclear Regulatory Commission to Exelon Generation dated April 26, 2013; Peach Bottom Atomic Power Station - Units 2 and 3 - Request for Additional Information for Extended Power Uprate (TAC Nos. ME9631 and ME9632).

5. Exelon Generation to U.S. Nuclear Regulatory Commission dated May 24, 2013; Supplement 3 Response to Request for Additional Information - Extended Power Uprate.

PBAPS EPU LAR SUPPLEMENT NO.5 TABLE 1-1 Evaluation of Proposed Changes PAGE 17 TABLE 1-1 NEW OR CHANGED OPERATOR ACTIONS THAT IMPACT EMERGENCY OR ABNORMAL PROCEDURES (New or changed operator actions not included in the Reference 5 EGC response to AHPB RAI-2 are shaded)

OPERATOR ACTION PROCEDURE TYPE IMPACTED PUSAR Section 2.11.1.2.1 ACTIONS

1.

A new operator action will be created to place the RHR EOP heat exchanger cross-tie valve in service if required to mitigate a rise in suppression pool temperature during an accident or event.

2.

A new operator action will be created to start a second EOP HPSW Pump and establish a flow path through the second RHR Heat Exchanger when the RHR heat exchanger cross-tie is placed in service, and place the HPSW cross-tie in service, if required.

3.

Operators will control the depressurization of the units AOP to minimize the impact of a rise in suppression pool temperature associated with the interruption of containment cooling (SPC or sprays) that occurs upon receipt of a LOCA signal.

PUSAR Section 2.11.1.2.2 ACTIONS

4.

Operating procedures will require the operators to refill AOP the CST from the RWST during Method 'A", 'B' and 'D' shutdowns to provide inventory for the HPCI or RCIC system and maintain the suction of the HPCI and RCIC pumps on the CST rather than the suppression pool, and ensure NPSH margin without the need for CAP credit.

5.

Operating procedures will be revised to direct the AOP (Planned) operators to perform new actions to operate key-lock switches in the CR to inhibit Unit 2 RCIC, and Unit 3

PBAPS EPU LAR SUPPLEMENT NO.5 Evaluation of Proposed Changes TABLE 1-1 PAGE 18 OPERATOR ACTION PROCEDURE TYPE IMPACTED HPCI and RCIC pump automatic suction swap, as applicable, for a fire in certain fire areas.

6.

The time is reduced in which an operator is required to AOP secure, from the CR, a HPCI pump that has spuriously started from 10 to 7.5 minutes during a Method "A" shutdown without a SORV.

7.

The time by which an operator must initiate ASDC AOP during a Method "A" shutdown with a SORV is unchanged from the current Method "A" requirement of 180 minutes.

8.

The time for an operator to initiate ASDC during EOP Method "C" shutdowns is increased from 30 minutes to 14 hours1.62037e-4 days 0.00389 hours 2.314815e-5 weeks 5.327e-6 months , while the time for initiation of RPV depressurization from the Control Room is decreased from 27.5 minutes to 26.5 minutes for case C1 and 15 to 14.7 minutes for case C2.

9.

The time for an operator to initiate ASDC during AOP Method "D" shutdowns, without a SORV, is increased from 300 minutes to 364 minutes, while the time for initiation of RPV depressurization from the ASD panel is decreased from 5 to 3.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months .

10.

The time for an operator to initiate SPC from the AOP Control Room during Method "D" shutdowns with a SORV is decreased from 4 to 2.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months , while without a SORV, the time for initiation of SPC is decreased from 180 minutes to 150 minutes.

11.

The time for an operator to initiate ASDC during AOP Method "D" shutdowns, with a SORV, is increased from 240 to 270 minutes.

12.

New operator actions are required for Method "D" to AOP address use of new transfer/isolation switches installed on the ASD panels to isolate the control circuits for the 2B and 3D MCC Compartments remote (Control Room) transfer switches and align these MCCs to their normal power supplies for a fire in the Control Room.

PBAPS EPU LAR SUPPLEMENT NO.5 Evaluation of Proposed Changes TABLE 1-1 PAGE 19 OPERATOR ACTION PROCEDURE TYPE IMPACTED

13.

New operator actions are required for Method "D" to AOP address use of new control switches on the ASD Panels for the 'B' Loop RHR heat exchanger cross-tie MOV's, and their associated transfer/isolation switches in emergency bus room panels, to isolate the ASD panel control circuits from control circuits in the Control Room for a fire in the Control Room.

14.

New operator actions are required for Method "D" to AOP direct the operators to ensure the new RHR flow control valves (MO-2-10-2677B & MO-3-10-3677D) are fully open by manually opening these valves at their respective MCC Compartment breaker by manipulating the motor contactor and then opening the breakers to preclude spurious mispositioning for a fire in the Control Room.

PUSAR Section 2.11.1.3 ACTIONS

15.

Balance flow through the RHR heat exchangers when EOP operating with the RHR heat exchanger cross-tie open.

16.

Manually control the transfer of power for the HPSW AOP cross-tie MOV from the Normal to Alternate source or vice versa.

17.

Manually control the transfer of power from the Normal AOP to Alternate source or vice versa for each of the four new MCC Compartments per unit associated with powering the motor-operated RHR flow control valves, RHR heat exchanger cross-tie valves, and the RHR heat exchanger HPSW outlet valves.

Enclosure la to Attachment 1 Peach Bottom Atomic Power Station Units 2 and 3 Supplement No. 5 to Extended Power Uprate License Amendment Request NRC Docket Nos. 50-277 and 50-278 Figure 9c-1, RESIDUAL HEAT REMOVAL SYSTEM CURRENT CONFIGURATION WITH RHR MODIFICATION CHANGES - FOR INFORMATION ONLY Figure 9c-2 RHR AND HPSW MODIFICATIONS SINGLE LINE ELECTRICAL DIAGRAM - FOR INFORMATION ONLY

Residual Heat Removal (RHR) Heat c to Attachment 9 Exchanger Cross-Tie Modification FIGURE 9c-1 RESIDUAL HEAT REMOVAL SYSTEM CURRENT CONFIGURATION WITH RHR MODIFICATION CHANGES FOR INFORMATION ONLY NOT A CONTROLLED DRAWING

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Residual Heat Removal (RHR) Heat Exchanger Cross-Tie Modification c to Attachment 9 FIGURE 9c-2 RHR AND HPSW MODIFICATIONS SINGLE LINE ELECTRICAL DIAGRAM FOR INFORMATION ONLY NOT A CONTROLLED DRAWING BLACK lines show plant configuration prior to the EPU modification.

RED lines show the addition of the HPSW Cross-Tie transfer switch modification for EPU.

GREEN lines show the addition of the RHR Heat Exchanger Cross-Tie transfer switch modification for EPU.

ATTACHMENT 2 Peach Bottom Atomic Power Station Units 2 and 3 Supplement No. 5 to Extended Power Uprate License Amendment Request NRC Docket Nos. 50-277 and 50-278 Replacement Markups of Technical Specification Pages for Units 2 and 3 (Proposed revisions to the TS changes proposed in Attachment 2 of the EPU LAR dated September 28, 2012 are shaded) 3.3-3 3.3-7 3.6-28 3.6-30 3.7-2

RPS Instrumentation 3.3.1.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

As required by H.1 Initiate action to Immediately Required Action D.1 fully insert all and referenced in insertable control Table 3.3.1.1-1.

rods in core cells containing one or more fuel assemblies.

I.

As required by 1.1 Initiate alternate 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Required Action D.1 method to detect and and referenced in suppress thermal Table 3.3.1.1-1.

hydraulic instability oscillations.

AND 1.2

NOTE--------

LCO 3.0.4 is not applicable.

Restore required 120 days channels to OPERABLE.

J.

Required Action and J.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to 425% RTP.

Time of Condition I not met.

PBAPS UNIT 2 3.3-3 Amendment No.

251

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page I of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

1. Wide Range Neutron Monitors

a.

Period-Short 2

3 3

G SR SR SR SR SR H

SR SR SR SR SR G

SR SR 3.3.1.1.1 3.3.1.1.5 3.3.1.1.12 3.3.1.1.17 3.3.1.1.18 3.3.1.1.1 3.3.1.1.6 3.3.1.1.12 3.3.1.1.17 3.3.1.1.18 3.3.1.1.5 3.3.1.1.17 13 seconds 13 seconds NA NA

b.

Inop 2

3 3

5 (a)

SR 3.3.1.1.6 SR 3.3.1.1.17

2. Average Power Range Monitors

a.

Neutron Flux-High (Setdown)

b.

Simulated Thermal Power-High

c.

Neutron Flux-High

d.

Inop

e.

2-Out-Of-4 Voter

f.

OPRM Upscale 2

1,2 1,2 3(c) 3 (c) 3(5) 3(c)

G SR SR SR SR F

SR SR SR SR SR F

SR SR SR SR SR G

SR G

SR SR SR SR SR SR SR SR SR 3.3.1.1.1 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.1 3.3.1.1.2 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.1 3.3.1.1.2 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.11 3.3.1.1.1 3.3.1.1.11 3.3.1.1.17 3.3.1.1.18 3.3.1.1.1 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.19

!5 15.0% RTP

_< O.

W

+ 6-&.% RTP(b) and* 118.0%

RTP 5 119.7% RTP NA NA (d)

R3(c)

RTP II (continued) ith any control rod withdrawn from a core cell containing one or more fuel assemblies.

(b) 9.6& (W - AW) + 63.*F% RTP when reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."

S(c)

Each APRM channe 4provides inputs to both trip systems.

(d)

See COLR for OPRM period based detection algorithm (PBDA) setpoint limits.

lInser B,

/*BAPS UNIT 2 3.3-7 Amendment No.

273

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control can be aligned to the correct position.

Program.

SR 3.6.2.3.2 Verify each required RHR pump develops a In accordance flow rate >

gpm through the with the associated at exchanger while operating Inservice in the su ression pool cooling mode.

Testing Program 8, 6-00 1_

PBAPS UNIT 2 3.6-28 Amendment No.

278

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control can be aligned to the correct position.

Program.

SR 3.6.2.4.2 Verify each suppression pool spray nozzle In accordance is unobstructed.

with the Surveillance Frequency Control Program.

PBAPS UNIT 2 3.6-30 Amendment No.

278

HPSW System 3.7.1 ACTIONS (continued)

CONDITION TREQUIRED ACTION j COMPLETION TIME E E.

Required Action and associated Completion Time of Condition G not met.

E R-74.

Be AND Be 1KA1fl in MODE 3.

in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each HPSW manual and power operated In accordance valve in the flow path, that is not locked, with the sealed, or otherwise secured in position, Surveillance is in the correct position or can be Frequency aligned to the correct position.

Control Program.

PBAPS UNIT 2 3.7-2 Amendment No.

278

RPS Instrumentation 3.3.1.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

As required by H.1 Initiate action to Immediately Required Action D.1 fully insert all and referenced in insertable control Table 3.3.1.1-1.

rods in core cells containing one or more fuel assemblies.

I.

As required by I.1 Initiate alternate 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Required Action D.1 method to detect and and referenced in suppress thermal Table 3.3.1.1-1.

hydraulic instability oscillations.

AND 1.2

NOTE-------

LCO 3.0.4 is not applicable.

Restore required 120 days channels to OPERABLE.

J.

Required Action and J.1 Reduce THERMAL POWER 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion to <

Time of Condition I not met.

PBAPS UNIT 3 3.3-3 Amendment No.

254

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 1 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

1. Wide Range Neutron Monitors

a.

Period-Short 5(a) 3 G

SR SR SR SR SR H

SR SR SR SR SR G

SR SR 3.3.1.1.1 3.3.1.1.5 3.3.1.1.12 3.3.1.1.17 3.3.1.1.18 3.3.1.1.1 3.3.1.1.6 3.3.1.1.12 3.3.1.1.17 3.3.1.1.18 3.3.1.1.5 3.3.1.1.17 13 seconds 13 seconds NA NA

b.

Inop 5(a)

SR 3.3.1.1.6 SR 3.3.1.1.17

2.

Average Power Range Monitors

a.

Neutron Flux-High (Setdown)

b.

Simulated Thermal Power-High

c.

Neutron Flux-High 3 (c) 3 (c)

G SR SR SR SR F

SR SR I

3 (c)

SR SR SR SR SR SR SR SR SR SR SR SR SR 3.3.1.1.1 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.1 3.3.1.1.2 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.1 3.3.1.1.2 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.11 3.3.1.1.1 3.3.1.1.11 3.3.1.1.17 3.3.1.1.18 3.3.1.1.1 3.3.1.1.8 3.3.1.1.11 3.3.1.1.12 3.3.1.1.19 s 15.0% RTP

< O-0.6 W

+ 6*--% RTP(b) and +

118.0%

RTPP s 119.7% RTP NA NA (d) d.

e.

Inop 2-Out-Of-4 Voter 1,2 1,2 3 (c) 2 G

G J

3(c)

RTP

f.

OPRM Upscale I

SR SR SR SR SR I--

(continued)

(a)

Wd* any control rod withdrawn from a core cell containing one or more fuel assemblies.

(b) 0.66 (W - AW) + 6-37% RTP wnen reset for single loop operation per LCO 3.4.1, "Recirculation Loops Operating."

61 5

(c)

Each APRM channel tovides inputs to both trip systems.

(d)

See COLR for OPRM period based detection algorithm (PBDA) setpoint limits.

lnser BjNI PBAPS UNIT 3 3.3-7 Amendment No.

277

RHR Suppression Pool Cooling 3.6.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.3.1 Verify each RHR suppression pool cooling In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control can be aligned to the correct position.

Program.

SR 3.6.2.3.2 Verify each required RHR pump develops a In accordance flow rate > 10,-0@ gpm through the with the associated at exchanger while operating Inservice in the s pression pool cooling mode.

Testing Program 8.600_

//

PBAPS UNIT 3 3.6-28 Amendment No.

281

RHR Suppression Pool Spray 3.6.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.2.4.1 Verify each RHR suppression pool spray In accordance subsystem manual, power operated, and with the automatic valve in the flow path that is Surveillance not locked, sealed, or otherwise secured Frequency in position is in the correct position or Control can be aligned to the correct position.

Program.

SR 3.6.2.4.2 Verify each suppression pool spray nozzle In accordance is unobstructed.

with the Surveillance Frequency Control Program.

I PBAPS UNIT 3 3.6-30 Amendment No.

281

HPSW System 3.7.1 ACTIONS (continued)

CONDITION

=

REQUIRED ACTION COMPLETION TIME

ý E.ýa-/

Required Action and associated Completion Time of Condition &

not met.

4Be in MODE 3.

ANDM D-4 Be in MODE 4.

'ýý ýE2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours i

I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each HPSW manual and power operated In accordance valve in the flow path, that is not locked, with the sealed, or otherwise secured in position, Surveillance is in the correct position or can be Frequency aligned to the correct position.

Control Program.

L (A

PBAPS UNIT 3 3.7-2 Amendment No.

281

ATTACHMENT 3 Peach Bottom Atomic Power Station Units 2 and 3 Supplement No. 4 to Extended Power Uprate License Amendment Request NRC Docket Nos. 50-277 and 50-278 Replacement Markups of Technical Specification Bases Pages for Units 2 and 3 (Proposed revisions to the TS Bases changes proposed in Attachment 3 of the EPU LAR dated September 28, 2012 are shaded)

B 3.3-12a B3.6-59 B3.6-63 B3.7-5

RPS Instrumentation B 3.3.1.1 BASES APPLICABLE 2.f. Oscillation Power Range Monitor (OPRM)

Upscale SAFETY ANALYSES,

LCO, and The OPRM Upscale Function provides compliance with 10 CFR APPLICABILITY 50, Appendix A, General Design Criteria (GDC) 10 and 12, (continued) thereby providing protection from exceeding the fuel MCPR safety limit (SL) due to anticipated thermal-hydraulic power oscillations.

References 14, 15 and 16 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: the period based detection algorithm (PBDA),

the amplitude based algorithm (ABA),

and the growth rate algorithm (GRA).

All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the PBDA.

The remaining algorithms provide defense in depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specifications purposes is based only on the PBDA.

The OPRM Upscale Function receives input signals from the local power range monitors (LPRMs) within the reactor core, which are combined into "cells" for evaluation by the OPRM algorithms. Each channel is capable of detecting thermal-hydraulic instabilities, by detecting the related neutron flux oscillations, and issuing a trip signal before the MCPR SL is exceeded. Three of the four channels are required to be OPERABLE.

The OPRM Upscale trip is automatically enabled (bypass removed) when THERMAL POWER is

! 29.-6% RTP, as indicated by the APRM Simulated Thermal Power, a d reactor core flow is

< 60% of rated flow, as indicated APRM measured recirculation drive flow. This is t e operating region where actual thermal-hydraulic instabili and related neutron flux oscillations may occur (Reference 8). These setpoints, which are sometimes referred to as the " uto-bypass" setpoints, establish the boundaries of the OP M Upscale trip enabled region.

r A l 26.2u The OPRM Upsca Function required to be OP E when the plant is at 2ý% RTP.

The M-% RTP level *s selecte provide margin in the unlikely event that a react power increase transient occurring while the plant is operating below 29-._% RTP causes a power increase to or beyond the 29.--%

APRM Simulated Thermal Power OPRM Upscale trip auto-enable setpoint without operator action. This OPERABILITY requirement assures that the OPRM Upscale trip auto-enable function will be OPERABLE when required.

(continued)

PBAPS UNIT 2 B 3.3-12a Revision No.

50

RHR Suppression Pool Cooling B 3.6.2.3 BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3.6.2.3.1 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.

This is acceptable since the RHR suppression pool cooling mode is manually initiated.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

I SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate

> 41-9-*AA gpm while operating in the suppression pool cooling de with flow through the associated heat exchanger ensures 896j-that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance required by ASME Code (Ref.

3).

This test confirms one point on the pump design curve, and the results are indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend r C

.623 performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this SR is in accordance with the Inservice Testing Program.

REFERENCES

1.

UFSAR, Section 14.6.3.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

3.

ASME Code for Operation and Maintenance of Nuclear Power PI ants.

PBAPS UNIT 2 B 3.6-59 Revision No.

86

RHR Suppression Pool Spray B 3.6.2.4 BASES (continued)

SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.

This is acceptable since the RHR suppression pool cooling mode is manually initiated.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

SR 3.6.2.4.2 This Surveillance is performed to verify that the spray nozzles are not obstructed and that flow will be provided when required.

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

REFERENCES

1.

UFSAR, Sections 5.2 and 14.6.3.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 2 B 3.6-63 Revision No.

86

HPSW System B 3.7.1 BASES (continued)

E.1 and l

2 ACTIONS (continued)

D.1 and D,2 M

D If the HPSW subsystems cannot be restored to OPERABL status within the associated Completion Time of Condition -G the unit must be placed in a MODE in which the LCO does not apply.

To achieve this status, the unit must be placed in at least MODE 3 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SURVEILLANCE REQUIREMENTS SR 3.7.1.1 Verifying the correct alignment for each manual and power operated valve in each HPSW subsystem flow path provides assurance that the proper flow paths will exist for HPSW operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position, and yet considered in the correct position, provided it can be realigned to its accident position.

This is acceptable because the HPSW System is a manually initiated system.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

A Bss F

The Surveillance Frequency is controlled under the

ýýýS urveillance Frequency Control Program.

REFERENCES

1.

UFSAR, Section 10.7.

2.

UFSAR, Chapter 14.

NEDC-33566P, "Safety Analysis Report for Exelon Peach Bottom Atomic Power Station, Units 2 and 3, Constant Pressure Power Uprate," Revision 0.

3.

4.

K 11 n r

1) 1) 1 0 1) n

ý- n -

r) -

ý -

C' -

C-ý A -

I -

4 r-11 I'll- 'j

.,-V-c'eden 60EtOM e & 6, n19 di

+/-tltl.

UFSAR, Section 14.6.3.

I

5.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 2 B 3.7-5 Revision No.

86

RPS Instrumentation B 3.3.1.1 BASES APPLICABLE SAFETY ANALYSES,

LCO, and APPLICABILITY (continued) 2.f. Oscillation Power Range Monitor (OPRM)

Upscale The OPRM Upscale Function provides compliance with 10 CFR 50, Appendix A, General Design Criteria (GDC) 10 and 12, thereby providing protection from exceeding the fuel MCPR safety limit (SL) due to anticipated thermal-hydraulic power oscillations.

References 14, 15 and 16 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: the period based detection algorithm (PBDA),

the amplitude based algorithm (ABA),

and the growth rate algorithm (GRA).

All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the PBDA. The remaining algorithms provide defense in depth and additional protection against unanticipated oscillations.

OPRM Upscale Function OPERABILITY for Technical Specifications purposes is based only on the PBDA.

The OPRM Upscale Function receives input signals from the local power range monitors (LPRMs) within the reactor core, which are combined into "cells" for evaluation by the OPRM algorithms.

Each channel is capable of detecting thermal-hydraulic instabilities, by detecting the related neutron flux oscillations, and issuing a trip signal before the MCPR SL is exceeded. Three of the four channels are required to be OPERABLE.

The OPRM Upscale trip removed) when THERMAL is automatica POWER is

Ž 29-9 lly enabled (bypass

.- % RTP, as indicated by the APRM Simulated Thermal Power, ad reactor core flow is

< 60% of rated flow, as indicated Ly APRM measured recirculation drive flow. This is the operating region where actual thermal-hydraulic instability and related neutron flux oscillations may occur (Reference 18).

These setpoints, which are sometimes ref rred to as the "auto-bypass" setpoints, establish he boundaries of the OPRM Upscale tr d region.

26.2 The OPRM Upscal Function s required to be OPERABLE when plant is at Ž 2-&% RTP.

The 2-%

RTP level is selected to provide margin in the unlikely event that a reactor power increase transient occurring while the plant is operating below 29.-%

RTP causes a power increase to or beyond the

-P---% A*M Simulated Thermal Power OPRM Upscale trip a o-enable setpoint without operator action. This OP17RABIL' TY requirement assures that the OPRM Upscale trip auto-ena le function will be OPERABLE when required.

(r'-nifi

(

n inue the d*

PBAPS UNIT 3 B 3.3-12a Revision No.

51

RHR Suppression Pool Cooling B 3.6.2.3 BASES (continued)

SURVEILLANCE REQUIREMENTS SR 3,6.2.3.1 Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool cooling mode flow path provides assurance that the proper flow path exists for system operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.

This is acceptable since the RHR suppression pool cooling mode is manually initiated.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

SR 3.6.2.3.2 Verifying that each required RHR pump develops a flow rate

Ž gpm while operating in the suppression pool cooling DOD de with flow through the associated heat exchanger ensures L6:

that pump performance has not degraded during the cycle.

Flow is a normal test of centrifugal pump performance required by ASME Code (Ref.

3).

This test confirms one point on the pump design curve, and the results are indicative of overall performance.

Such inservice inspections confirm component OPERABILITY, trend l

r C - B 3.6.2performance, and detect incipient failures by indicating abnormal performance.

The Frequency of this SR is in accordance with the Inservice Testing Program.

REFERENCES

1.

UFSAR, Section 14.6.3.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

3.

ASME Code for Operation and Maintenance of Nuclear Power Plants.

PBAPS UNIT 3 B 3.6-59 Revision No.

87

RHR Suppression Pool Spray B 3.6.2.4 BASES (continued)

SURVEILLANCE SR 3.6.2.4.1 REQUIREMENTS Verifying the correct alignment for manual, power operated, and automatic valves in the RHR suppression pool spray mode flow path provides assurance that the proper flow paths will exist for system operation.

This SR does not apply to valves that are locked, sealed, or otherwise secured in position since these valves were verified to be in the correct position prior to locking, sealing, or securing.

A valve is also allowed to be in the nonaccident position provided it can be aligned to the accident position within the time assumed in the accident analysis.

This is acceptable since the RHR suppression pool cooling mode is manually initiated.

This SR does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

This SR does not apply to valves that cannot be inadvertently misaligned, such as check valves.

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

SR 3.6.2.4.2 This Surveillance is performed to verify that the spray nozzles are not obstructed and that flow will be provided when required.

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

REFEREN ES

1.

UFSAR, Sections 5.2 and 14.6.3.

2.

NEDC-32988-A, Revision 2, Technical Justification to Support Risk-Informed Modification to Selected Required End States for BWR Plants, December 2002.

PBAPS UNIT 3 R 3-6-63 Revision No.

87

HPSW System B 3.7.1 BASES rFTTTT ACTIONS (continued)

If the HPSW subsystems cannot be restored to OPERAB within the associated Completion Time of Condition C, the unit must be placed in a MODE in which the LCO does not apply.