ML100850398

Markup of Proposed Technical Requirements Manual & Technical Specifications Bases Pages

ML100850398
Person / Time
Site:	Limerick
Issue date:	03/25/2010
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
Shared Package
ML100850379	List: ML100850391 ML100850392 ML100850395 ML100850398 ML100850399 ML100850401 ML100850403 ML100850406 ML100850410 ML100850411 RIS 2002-03, Attachment 4: NRC Regulatory Issue Summary 2002-03 Cross-Reference RS-10-002, Request for License Amendment Re Measurement Uncertainty Recapture Power Uprate
References
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Text

ATTACHMENT 3 Markup of Proposed Technical Requirements Manual and Technical Specifications Bases Pages Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 (For Information Only)

REVISED TECHNICAL REQUIREMENTS MANUAL PAGES TRM - 3/4 3-97 (Units 1 and 2)

REVISED TECHNICAL SPECIFICATIONS BASES PAGES B 2-7 (Units 1 and 2)

B 2-7a (Units 1 and 2)

B 3/4 1-4 (Units 1 and 2)

B 3/4 3-1a (Units 1 and 2)

B 3/4 3-1d (Units 1 and 2)

B 3/4 3-1e (Units 1 and 2)

B 3/4 3-3a (Units 1 and 2)

INSTRUMENTATION FEEDWATER FLOW INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.7.10 The Leading Edge Flow Meter instrumentation system shall be OPERABLE:

APPLICABILITY: OPERATIONAL CONDITION 1, with THERMAL POWER > 3458 MWt.

ACTION:

With the Leading Edge Flow Meter system inoperable, restore the required instrumentation to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Otherwise, reduce power to < 3458 MWt within the next two hours.

SURVEILLANCE REQUIREMENTS 4.3.7.10.1 The Leading Edge Flowmeter instrumentation system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per shift.

LIMERICK - UNIT 1 TRM - 3/4 3-97 Revision xx Date

INSTRUMENTATION FEEDWATER FLOW INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.7.10 The Leading Edge Flow Meter instrumentation system shall be OPERABLE:

APPLICABILITY: OPERATIONAL CONDITION 1, with THERMAL POWER > 3458 MWt.

ACTION:

With the Leading Edge Flow Meter system inoperable, restore the required instrumentation to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Otherwise, reduce power to < 3458 MWt within the next two hours.

SURVEILLANCE REQUIREMENTS 4.3.7.10.1 The Leading Edge Flowmeter Instrumentation system shall be demonstrated OPERABLE by performance of a CHANNEL CHECK at least once per shift.

LIMERICK - UNIT 2 TRM - 3/4 3-97 Revision xx Date

LIMITING SAFETY SYSTEM SETTINGS BASES REACTOR PROTECTION SYSTEM INSTRUMENTATION SETPOINTS (Continued)

Average Power Range Monitor (Continued)

Because the flux distribution associated with uniform rod withdrawals does not involve high local peaks and because several rods must be moved to change power by a significant amount, the rate of power rise is very slow. Generally the heat flux is in near equilibrium with the fission rate. In an assumed uniform rod withdrawal approach to the trip level, the rate of power rise is not more than 5% of RATED THERMAL POWER per minute and the APRM system would be more than adequate to assure shutdown before the power could exceed the Safety Limit.

The 15% Neutron Flux - Upscale (Setdown) trip remains active until the mode switch is placed in the Run position.

The APRM trip system is calibrated using heat balance data taken during steady state conditions. Fission chambers provide the basic input to the system and therefore the monitors respond directly and quickly to changes due to transient operation for the case of the Neutron Flux - Upscale setpoint; i.e.,

for a power increase, the THERMAL POWER of the fuel will be less than that indicated by the neutron flux due to the time constants of the heat transfer associated with the fuel. For the Simulated Thermal Power - Upscale setpoint, a time constant of 6 +/- 0.6 seconds is introduced into the flow-biased APRM in order to simulate the fuel thermal transient characteristics. A more conservative maximum value is used for the flow-biased setpoint as shown in Table 2.2.1-1.

A reduced Trip Setpoint and Allowable Value is provided for the Simulated Thermal Power - Upscale Function, applicable when the plant is operating in Single Loop Operation (SLO) per LCO 3.4.1.1. In SLO, the drive flow values (W) used in the Trip Setpoint and Allowable Value equations is reduced by 7.6%. The 7.6% value is established to conservatively bound the inaccuracy created in the core flow/drive flow correlation due to back flow in the jet pumps associated with the inactive recirculation loop. The Trip Setpoint and Allowable Value thus maintain thermal margins essentially unchanged from those for two-loop operation.

The Trip Setpoint and Allowable Value equations for single loop operation are only valid for flows down to W = 7.6%. The Trip Setpoint and Allowable Value do not go below 62.8% and 63.3% RATED THERMAL POWER, respectively. This is acceptable because back flow in the inactive recirculation loop is only an issue with drive flows of approximately 40% or greater (Reference 1).

61.5% and 62.0%

The APRM setpoints were selected to provide adequate margin for the Safety Limits and yet allow operating margin that reduces the possibility of unneces-sary shutdown.

The APRM channels also include an Oscillation Power Range Monitor (OPRM) Upscale Function. The OPRM Upscale Function provides compliance with GDC 10 and GDC 12, thereby providing protection from exceeding the fuel MCPR Safety Limit due to anticipated thermal-hydraulic power oscillations. 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.

References 2, 3 and 4 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: the period based detection algorithm, the amplitude based algorithm, and the growth rate algorithm. All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the period based detection algorithm. The remaining algorithms provide defense in depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specification purposes is based only on the period based detection algorithm.

LIMERICK - UNIT 1 B 2-7 Amendment No. 66, 141, 177

LIMITING SAFETY SYSTEM SETTINGS BASES REACTOR PROTECTION SYSTEM INSTRUMENTATION SETPOINTS (Continued)

Average Power Range Monitor (Continued)

Because the flux distribution associated with uniform rod withdrawals does not involve high local peaks and because several rods must be moved to change power by a significant amount, the rate of power rise is very slow. Generally the heat flux is in near equilibrium with the fission rate. In an assumed uniform rod withdrawal approach to the trip level, the rate of power rise is not more than 5% of RATED THERMAL POWER per minute and the APRM system would be more than adequate to assure shutdown before the power could exceed the Safety Limit.

The 15% Neutron Flux - Upscale (Setdown) trip remains active until the mode switch is placed in the Run position.

The APRM trip system is calibrated using heat balance data taken during steady state conditions. Fission chambers provide the basic input to the system and therefore the monitors respond directly and quickly to changes due to transient operation for the case of the Neutron Flux - Upscale setpoint; i.e.,

for a power increase, the THERMAL POWER of the fuel will be less than that indicated by the neutron flux due to the time constants of the heat transfer associated with the fuel. For the Simulated Thermal Power - Upscale setpoint, a time constant of 6 +/- 0.6 seconds is introduced into the flow-biased APRM in order to simulate the fuel thermal transient characteristics. A more conservative maximum value is used for the flow-biased setpoint as shown in Table 2.2.1-1.

A reduced Trip Setpoint and Allowable Value is provided for the Simulated Thermal Power - Upscale Function, applicable when the plant is operating in Single Loop Operation (SLO) per LCO 3.4.1.1. In SLO, the drive flow values (W) used in the Trip Setpoint and Allowable Value equations is reduced by 7.6%. The 7.6% value is established to conservatively bound the inaccuracy created in the core flow/drive flow correlation due to back flow in the jet pumps associated with the inactive recirculation loop. The Trip Setpoint and Allowable Value thus maintain thermal margins essentially unchanged from those for two-loop operation. The Trip Setpoint and Allowable Value equations for single loop operation are only valid for flows down to W = 7.6%. The Trip Setpoint and Allowable Value do not go below 62.8% and 63.3% RATED THERMAL POWER, respectively. This is acceptable because back flow in the inactive recirculation loop is only an issue with drive flows of approximately 40% or greater (Reference 1).

61.5% and 62.0%

The APRM setpoints were selected to provide adequate margin for the Safety Limits and yet allow operating margin that reduces the possibility of unneces-sary shutdown.

The APRM channels also include an Oscillation Power Range Monitor (OPRM)

Upscale Function. The OPRM Upscale Function provides compliance with GDC 10 and GDC 12, thereby providing protection from exceeding the fuel MCPR Safety Limit due to anticipated thermal-hydraulic power oscillations. 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.

References 2, 3 and 4 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: the period based detection algorithm, the amplitude based algorithm, and the growth rate algorithm.

All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the period based detection algorithm. The remaining algorithms provide defense in depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specification purposes is based only on the period based detection algorithm.

LIMERICK - UNIT 2 B 2-7 Amendment 48, 109, 139

LIMITING SAFETY SYSTEM SETTINGS BASES REACTOR PROTECTION SYSTEM INSTRUMENTATION SETPOINTS (Continued)

Average Power Range Monitor (Continued) 29.5%

The OPRM Upscale trip output shall be automatically enabled (not bypassed) when APRM Simulated Thermal Power is 30% and recirculation drive flow is < 60%

as indicated by APRM measured recirculation drive flow. (NOTE: 60% recirculation drive flow is the recirculation drive flow that corresponds to 60% of rated core flow. Refer to TS Bases 3/4.3.1 for further discussion concerning the recirculation drive flow/core flow relationship.) This is the operating region where actual thermal-hydraulic instability and related neutron flux oscillations may occur. See Reference 5 for additional discussion of OPRM Upscale trip enable region limits. These setpoints, which are sometimes referred to as the auto-bypass setpoints, establish the boundaries of the OPRM Upscale trip enabled region. The APRM Simulated Thermal Power auto-enable setpoint has 1% deadband while the drive flow setpoint has a 2% deadband. The deadband for these setpoints is established so that it increases the enabled region.

An OPRM Upscale trip is issued from an APRM channel when the period based detection algorithm in that channel detects oscillatory changes in the neutron flux, indicated by the combined signals of the LPRM detectors in a cell, with period confirmations and relative cell amplitude exceeding specified setpoints.

One or more cells in a channel exceeding the trip conditions will result in a channel trip. An OPRM Upscale trip is also issued from the channel if either the growth rate or amplitude based algorithms detect oscillatory changes in the neutron flux for one or more cells in that channel. 29.5%

There are four sets of OPRM related setpoints or adjustment parameters:

a) OPRM trip auto-enable setpoints for APRM Simulated Thermal Power (30%) and recirculation drive flow (60%); b) period based detection algorithm (PBDA) confirmation count and amplitude setpoints; c) period based detection algorithm tuning parameters; and d) growth rate algorithm (GRA) and amplitude based algorithm (ABA) setpoints.

29.5%

The first set, the OPRM auto-enable region setpoints, are treated as nominal setpoints with no additional margins added as discussed in Reference 5.

The settings, 30% APRM Simulated Thermal Power and 60% recirculation drive flow, are defined (limit values) in a note to Table 2.2.1-1. The second set, the OPRM PBDA trip setpoints, are established in accordance with methodologies defined in Reference 4, and are documented in the COLR. There are no allowable values for these setpoints. The third set, the OPRM PBDA tuning parameters, are established or adjusted in accordance with and controlled by station procedures.

The fourth set, the GRA and ABA setpoints, in accordance with References 2 and 3, are established as nominal values only, and controlled by station procedures.

3. Reactor Vessel Steam Dome Pressure-High High pressure in the nuclear system could cause a rupture to the nuclear system process barrier resulting in the release of fission products. A pressure increase while operating will also tend to increase the power of the reactor by compressing voids thus adding reactivity. The trip will quickly reduce the neutron flux, counteracting the pressure increase. The trip setting is slightly higher than the operating pressure to permit normal operation without spurious trips. The setting provides for a wide margin to the maximum allowable design pressure and takes into account the location of the pressure measurement compared to the highest pressure that occurs in the system during a transient. This trip setpoint is effective at low power/flow conditions when the turbine stop valve and control fast closure trips are bypassed. For a turbine trip or load rejection under these conditions, the transient analysis indicated an adequate margin to the thermal hydraulic limit.

LIMERICK - UNIT 1 B 2-7a Amendment No. 66, 141, 177

LIMITING SAFETY SYSTEM SETTINGS BASES REACTOR PROTECTION SYSTEM INSTRUMENTATION SETPOINTS (Continued)

Average Power Range Monitor (Continued) 29.5%

The OPRM Upscale trip output shall be automatically enabled (not bypassed) when APRM Simulated Thermal Power is 30% and recirculation drive flow is < 60%

as indicated by APRM measured recirculation drive flow. (NOTE: 60%

recirculation drive flow is the recirculation drive flow that corresponds to 60%

of rated core flow. Refer to TS Bases 3/4.3.1 for further discussion concerning the recirculation drive flow/core flow relationship.) This is the operating region where actual thermal-hydraulic instability and related neutron flux oscillations may occur. See Reference 5 for additional discussion of OPRM Upscale trip enable region limits. These setpoints, which are sometimes referred to as the auto-bypass setpoints, establish the boundaries of the OPRM Upscale trip enabled region. The APRM Simulated Thermal Power auto-enable setpoint has 1% deadband while the drive flow setpoint has a 2% deadband. The deadband for these setpoints is established so that it increases the enabled region.

An OPRM Upscale trip is issued from an APRM channel when the period based detection algorithm in that channel detects oscillatory changes in the neutron flux, indicated by the combined signals of the LPRM detectors in a cell, with period confirmations and relative cell amplitude exceeding specified setpoints.

One or more cells in a channel exceeding the trip conditions will result in a channel trip. An OPRM Upscale trip is also issued from the channel if either the growth rate or amplitude based algorithms detect oscillatory changes in the neutron flux for one or more cells in that channel. 29.5%

There are four sets of OPRM related setpoints or adjustment parameters:

a) OPRM trip auto-enable setpoints for APRM Simulated Thermal Power (30%) and recirculation drive flow (60%); b) period based detection algorithm (PBDA) confirmation count and amplitude setpoints; c) period based detection algorithm tuning parameters; and d) growth rate algorithm (GRA) and amplitude based algorithm (ABA) setpoints.

29.5%

The first set, the OPRM auto-enable region setpoints, are treated as nominal setpoints with no additional margins added as discussed in Reference 5.

The settings, 30% APRM Simulated Thermal Power and 60% recirculation drive flow, are defined (limit values) in a note to Table 2.2.1-1. The second set, the OPRM PBDA trip setpoints, are established in accordance with methodologies defined in Reference 4, and are documented in the COLR. There are no allowable values for these setpoints. The third set, the OPRM PBDA tuning parameters, are established or adjusted in accordance with and controlled by station procedures.

The fourth set, the GRA and ABA setpoints, in accordance with References 2 and 3, are established as nominal values only, and controlled by station procedures.

3. Reactor Vessel Steam Dome Pressure-High High pressure in the nuclear system could cause a rupture to the nuclear system process barrier resulting in the release of fission products. A pressure increase while operating will also tend to increase the power of the reactor by compressing voids thus adding reactivity. The trip will quickly reduce the neutron flux, counteracting the pressure increase. The trip setting is slightly higher than the operating pressure to permit normal operation without spurious trips. The setting provides for a wide margin to the maximum allowable design pressure and takes into account the location of the pressure measurement compared to the highest pressure that occurs in the system during a transient. This trip setpoint is effective at low power/flow conditions when the turbine stop valve and control fast closure trips are bypassed. For a turbine trip or load rejection under these conditions, the transient analysis indicated an adequate margin to the thermal hydraulic limit.

LIMERICK - UNIT 2 B 2-7a Amendment 48, 109, 139.

REACTIVITY CONTROL SYSTEMS BASES 3/4.1.5 STANDBY LIQUID CONTROL SYSTEM The standby liquid control system provides a backup capability for bringing the reactor from full power to a cold, Xenon-free shutdown, assuming that the withdrawn control rods remain fixed in the rated power pattern. To meet this objective it is necessary to inject a quantity of boron which produces a concen-tration of 660 ppm in the reactor core and other piping systems connected to the reactor vessel. To allow for potential leakage and improper mixing, this concentration is increased by 25%. The required concentration is achieved by having available a minimum quantity of 3,160 gallons of sodium pentaborate solution containng a minimum of 3,754 lbs of sodium pentaborate having the requisite Boron-10 atom % enrichment of 29% as determined from Reference 5.

This quantity of solution is a net amount which is above the pump suction shutoff level setpoint thus allowing for the portion which cannot be injected.

The above quantities calculated at 29% Boron-10 enrichment have been demonstrated by analysis to provide a Boron-10 weight equivalent of 185 lbs in the sodium pentaborate solution. Maintaining this Boron-10 weight in the net tank contents ensures a sufficient quantity of boron to bring the reactor to a cold, Xenon-free shutdown.

The pumping rate of 41.2 gpm provides a negative reactivity insertion rate over the permissible solution volume range, which adequately compensates for the positive reactivity effects due to elimination of steam voids, increased water density from hot to cold, reduced doppler effect in uranium, reduced neutron leakage from boiling to cold, decreased control rod worth as the moderator cools, and xenon decay. The temperature requirement ensures that the sodium pentaborate always remains in solution.

With redundant pumps and explosive injection valves and with a highly reliable control rod scram system, operation of the reactor is permitted to continue for short periods of time with the system inoperable or for longer periods of time with one of the redundant components inoperable.

The SLCS system consists of three separate and independent pumps and explosive valves. Two of the separate and independent pumps and explosive valves are required to meet the minimum requirements of this technical specification and, where applicable, satisfy the single failure criterion.

Bases Insert 1 The SLCS must have an equivalent control capacity of 86 gpm of 13%

weight sodium pentaborate in order to satisfy 10 CFR 50.62 (Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants). As part of the ARTS/MELLL program the ATWS analysis was updated to reflect the new rod line. As a result of this it was determined that the Boron 10 enrichment was required to be increased to 29% to prevent exceeding a suppression pool temperature of 190oF. This equivalency requirement is fulfilled by having a system which satisfies the equation given in 4.1.5.b.2.

The upper limit concentration of 13.8% has been established as a reasonable limit to prevent precipitation of sodium pentaborate in the event of a loss of tank heating, which allow the solution to cool.

LIMERICK - UNIT 1 B 3/4 1-4 Amendment No. 22, 66, 185

REACTIVITY CONTROL SYSTEMS BASES 3/4.1.5 STANDBY LIQUID CONTROL SYSTEM The standby liquid control system provides a backup capability for bringing the reactor from full power to a cold, Xenon-free shutdown, assuming that the withdrawn control rods remain fixed in the rated power pattern. To meet this objective it is necessary to inject a quantity of boron which produces a concen-tration of 660 ppm in the reactor core and other piping systems connected to the reactor vessel. To allow for potential leakage and improper mixing, this con-centration is increased by 25%. The required concentration is achieved by having available a minimum quantity of 3,160 gallons of sodium pentaborate solution containng a minimum of 3,754 lbs of sodium pentaborate having the requisite Boron-10 atom % enrichment of 29% as determined from Reference 5.

This quantity of solution is a net amount which is above the pump suction shutoff level setpoint thus allowing for the portion which cannot be injected.

The above quantities calculated at 29% Boron-10 enrichment have been demonstrated by analysis to provide a Boron-10 weight equivalent of 185 lbs in the sodium pentaborate solution. Maintaining this Boron-10 weight in the net tank contents ensures a sufficient quantity of boron to bring the reactor to a cold, Xenon-free shutdown.

The pumping rate of 41.2 gpm provides a negative reactivity insertion rate over the permissible solution volume range, which adequately compensates for the positive reactivity effects due to elimination of steam voids, increased water density from hot to cold, reduced doppler effect in uranium, reduced neutron leakage from boiling to cold, decreased control rod worth as the moderator cools, and xenon decay. The temperature requirement ensures that the sodium pentaborate always remains in solution.

With redundant pumps and explosive injection valves and with a highly reliable control rod scram system, operation of the reactor is permitted to continue for short periods of time with the system inoperable or for longer periods of time with one of the redundant components inoperable.

The SLCS system consists of three separate and independent pumps and explosive valves. Two of the separate and independent pumps and explosive valves are required to meet the minimum requirements of this technical specification and, where applicable, satisfy the single failure criterion. Bases insert 1 The SLCS must have an equivalent control capacity of 86 gpm of 13% weight sodium pentaborate in order to satisfy 10 CFR 50.62 (Requirements for reduction of risk from anticipated transients without scram (ATWS) events for light-water-cooled nuclear power plants). As part of the ARTS/MELLL program the ATWS analysis was updated to reflect the new rod line. As a result of this it was determined that the Boron 10 enrichment was required to be increased to 29% to prevent exceeding a suppression pool temperature of 190°F. This equivalency requirement is fulfilled by having a system which satisfies the equation given in 4.1.5.b.2.

The upper limit concentration of 13.8% has been established as a reasonable limit to prevent precipitation of sodium pentaborate in the event of a loss of tank heating, which allow the solution to cool.

LIMERICK - UNIT 2 B 3/4 1-4 Amendment No. 48, 146

3/4.3 INSTRUMENTATION BASES 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION (continued)

Action b, so the voter Function 2.e must be declared inoperable if any of its functionality is inoperable. The voter Function 2.e does not need to be declared inoperable due to any failure affecting only the APRM Interface hardware portion of the Two-Out-Of-Four Logic Module.

Three of the four APRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal. To provide adequate coverage of the entire core, consistent with the design bases for the APRM Functions 2.a, 2.b, and 2.c, at least 20 LPRM inputs, with at least three LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRM channel. In addition, no more than 9 LPRMs may be bypassed between APRM calibrations (weekly gain adjustments). For the OPRM Upscale Function 2.f, LPRMs are assigned to cells of 3 or 4 detectors. A minimum of 23 cells (Reference 9), each with a minimum of 2 OPERABLE LPRMs, must be OPERABLE for each APRM channel for the OPRM Upscale Function 2.f to be OPERABLE in that channel. LPRM gain settings are determined from the local flux profiles measured by the TIP system. This establishes the relative local flux profile for appropriate representative input to the APRM System. The 2000 EFPH frequency is based on operating experience with LPRM sensitivity changes.

References 4, 5 and 6 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: the period based detection algorithm, the amplitude based algorithm, and the growth rate algorithm. All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the period based detection algorithm. The remaining algorithms provide defense in depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specification purposes is based only on the period based detection algorithm.

An OPRM Upscale trip is issued from an APRM channel when the period based detection algorithm in that channel detects oscillatory changes in the neutron flux, indicated by the combined signals of the LPRM detectors in any cell, with period confirmations and relative cell amplitude exceeding specified setpoints. One or more cells in a channel exceeding the trip conditions will result in a channel trip. An OPRM Upscale trip is also issued from the channel if either the growth rate or amplitude based algorithms detect growing oscillatory changes in the neutron flux for one or more cells in that channel. 29.5%

The OPRM Upscale Function is required to be OPERABLE when the plant is at 25% RATED THERMAL POWER. The 25% RATED THERMAL POWER level is selected to provide margin in the unlikely event that a reactor power increase transient occurring while the plant is operating below 30% RATED THERMAL POWER causes a power increase to or beyond the 30% RATED THERMAL POWER OPRM Upscale trip auto-enable point without operator action. This OPERABILITY requirement assures that the OPRM Upscale trip automatic-enable function will be OPERABLE when required.

Actions a, b and c define the Action(s) required when RPS channels are discovered to be inoperable. For those Actions, separate entry condition is allowed for each inoperable RPS channel. Separate entry means that the allowable time clock(s) for Actions a, b or c start upon discovery of inoperability for that specific channel. Restoration of an inoperable RPS channel satisfies only the action statements for that particular channel. Action statement(s) for remaining inoperable channel(s) must be met according to their original entry time.

Because of the diversity of sensors available to provide trip signals and the redundancy of the RPS design, an allowable out of service time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been shown to be acceptable (NEDC-30851P-A and NEDC-32410P-A) to permit restoration of any inoperable channel to OPERABLE status. However, this out of service time is only acceptable provided that the associated Functions (identified as a Functional Unit in Table 3.3.1-1) inoperable channel is in one trip system and the Function still maintains RPS trip capability.

LIMERICK - UNIT 1 B 3/4 3-1a Amendment No. 53,89,132,141,177, 195

3/4.3 INSTRUMENTATION BASES 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION (continued)

Action b, so the voter Function 2.e must be declared inoperable if any of its functionality is inoperable. The voter Function 2.e does not need to be declared inoperable due to any failure affecting only the APRM Interface hardware portion of the Two-Out-Of-Four Logic Module.

Three of the four APRM channels and all four of the voter channels are required to be OPERABLE to ensure that no single failure will preclude a scram on a valid signal. To provide adequate coverage of the entire core, consistent with the design bases for the APRM Functions 2.a, 2.b, and 2.c, at least 20 LPRM inputs, with at least three LPRM inputs from each of the four axial levels at which the LPRMs are located, must be operable for each APRM channel. In addition, no more than 9 LPRMs may be bypassed between APRM calibrations (weekly gain adjustments). For the OPRM Upscale Function 2.f, LPRMs are assigned to cells of 3 or 4 detectors. A minimum of 23 cells (Reference 9), each with a minimum of 2 OPERABLE LPRMs, must be OPERABLE for each APRM channel for the OPRM Upscale Function 2.f to be OPERABLE in that channel. LPRM gain settings are determined from the local flux profiles measured by the TIP system. This establishes the relative local flux profile for appropriate representative input to the APRM System. The 2000 EFPH frequency is based on operating experience with LPRM sensitivity changes.

References 4, 5 and 6 describe three algorithms for detecting thermal-hydraulic instability related neutron flux oscillations: the period based detection algorithm, the amplitude based algorithm, and the growth rate algorithm. All three are implemented in the OPRM Upscale Function, but the safety analysis takes credit only for the period based detection algorithm. The remaining algorithms provide defense in depth and additional protection against unanticipated oscillations. OPRM Upscale Function OPERABILITY for Technical Specification purposes is based only on the period based detection algorithm.

An OPRM Upscale trip is issued from an APRM channel when the period based detection algorithm in that channel detects oscillatory changes in the neutron flux, indicated by the combined signals of the LPRM detectors in any cell, with period confirmations and relative cell amplitude exceeding specified setpoints. One or more cells in a channel exceeding the trip conditions will result in a channel trip. An OPRM Upscale trip is also issued from the channel if either the growth rate or amplitude based algorithms detect growing oscillatory changes in the neutron flux for one or more cells in that channel. 29.5%

The OPRM Upscale Function is required to be OPERABLE when the plant is at 25% RATED THERMAL POWER. The 25% RATED THERMAL POWER level is selected to provide margin in the unlikely event that a reactor power increase transient occurring while the plant is operating below 30% RATED THERMAL POWER causes a power increase to or beyond the 30% RATED THERMAL POWER OPRM Upscale trip auto-enable point without operator action. This OPERABILITY requirement assures that the OPRM Upscale trip automatic-enable function will be OPERABLE when required.

Actions a, b and c define the Action(s) required when RPS channels are discovered to be inoperable. For those Actions, separate entry condition is allowed for each inoperable RPS channel. Separate entry means that the allowable time clock(s) for Actions a, b or c start upon discovery of inoperability for that specific channel. Restoration of an inoperable RPS channel satisfies only the action statements for that particular channel. Action statement(s) for remaining inoperable channel(s) must be met according to their original entry time.

Because of the diversity of sensors available to provide trip signals and the redundancy of the RPS design, an allowable out of service time of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has been shown to be acceptable (NEDC-30851P-A and NEDC-32410P-A) to permit restoration of any inoperable channel to OPERABLE status. However, this out of service time is only acceptable provided that the associated Function's (identified as a "Functional Unit" in Table 3.3.1-1) inoperable channel is in one trip system and the Function still maintains RPS trip capability.

LIMERICK - UNIT 2 B 3/4 3-1a Amendment No. 17,52,93,109,139, 156

3/4.3 INSTRUMENTATION BASES 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION (continued) limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment. The evaluation of the use of alternate methods concluded, based on engineering judgment, that the likelihood of an instability event that could not be adequately handled by the alternate methods during the 120-day period was negligibly small. Plant startup may continue while operating within the allowed completion time of Action 10a. The primary purpose of this is to allow an orderly completion, without undue impact on plant operation, of design and verification activities in the event of a required design change to the OPRM Upscale function. This exception is not intended as an alternative to restoring inoperable equipment to OPERABLE status in a timely manner.

Action 10a is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status. Correction of routine equipment failure or inoperability is expected to be accomplished within the completion times allowed for LCO 3.3.1 Action a or Action b, as applicable.

Action 10b applies when routine equipment OPERABILITY cannot be restored within the allowed completion times of LCO 3.3.1 Actions a or b, or if a common mode OPRM deficiency cannot be corrected and OPERABILITY of the OPRM Upscale Function restored within the 120-day allowed completion time of Action 10a.

29.5%

The OPRM Upscale trip output shall be automatically enabled (not-bypassed) when APRM Simulated Thermal Power is 30% and recirculation drive flow is < 60%

as indicated by APRM measured recirculation drive flow. NOTE: 60% recirculation drive flow is the recirculation drive flow that corresponds to 60% of rated core flow. This is the operating region where actual thermal-hydraulic instability and related neutron flux oscillations may occur. As noted in Table 4.3.1.1-1, Note c, CHANNEL CALIBRATION for the OPRM Upscale trip Function 2.f includes confirming that the auto-enable (not-bypassed) setpoints are correct. Other surveillances ensure that the APRM Simulated Thermal Power properly correlates with THERMAL POWER (Table 4.3.1.1-1, Note d) and that recirculation drive flow properly correlates with core flow (Table 4.3.1.1-1, Note g).

29.5%

If any OPRM Upscale trip auto-enable setpoint is exceeded and the OPRM Upscale trip is not enabled, i.e., the OPRM Upscale trip is bypassed when APRM Simulated Thermal Power is 30% and recirculation drive flow is < 60%, then the affected channel is considered inoperable for the OPRM Upscale Function.

Alternatively, the OPRM Upscale trip auto-enable setpoint(s) may be adjusted to place the channel in the enabled condition (not-bypassed). If the OPRM Upscale trip is placed in the enabled condition, the surveillance requirement is met and the channel is considered OPERABLE.

As noted in Table 4.3.1.1-1, Note g, CHANNEL CALIBRATION for the APRM Simulated Thermal Power - Upscale Function 2.b and the OPRM Upscale Function 2.f, includes the recirculation drive flow input function. The APRM Simulated Thermal Power - Upscale Function and the OPRM Upscale Function both require a valid drive flow signal. The APRM Simulated Thermal Power - Upscale Function uses drive flow to vary the trip setpoint. The OPRM Upscale Function uses drive flow to automatically enable or bypass the OPRM Upscale trip output to RPS. A CHANNEL CALIBRATION of the APRM recirculation drive flow input function requires both calibrating the drive flow transmitters and establishing a valid drive flow /

core flow relationship. The drive flow / core flow relationship is established once per refuel cycle, while operating within 10% of rated core flow and within LIMERICK - UNIT 1 B 3/4 3-1d Amendment No. 177

3/4.3 INSTRUMENTATION BASES 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION (continued) suppress trip capability is formally in place. The 120-day period during which use of alternate methods is allowed is intended to be an outside limit to allow for the case where design changes or extensive analysis might be required to understand or correct some unanticipated characteristic of the instability detection algorithms or equipment. The evaluation of the use of alternate methods concluded, based on engineering judgment, that the likelihood of an instability event that could not be adequately handled by the alternate methods during the 120-day period was negligibly small. Plant startup may continue while operating within the allowed completion time of Action 10a. The primary purpose of this is to allow an orderly completion, without undue impact on plant operation, of design and verification activities in the event of a required design change to the OPRM Upscale function. This exception is not intended as an alternative to restoring inoperable equipment to OPERABLE status in a timely manner.

Action 10a is not intended and was not evaluated as a routine alternative to returning failed or inoperable equipment to OPERABLE status. Correction of routine equipment failure or inoperability is expected to be accomplished within the completion times allowed for LCO 3.3.1 Action a or Action b, as applicable.

Action 10b applies when routine equipment OPERABILITY cannot be restored within the allowed completion times of LCO 3.3.1 Actions a or b, or if a common mode OPRM deficiency cannot be corrected and OPERABILITY of the OPRM Upscale Function 29.5%

restored within the 120-day allowed completion time of Action 10a.

The OPRM Upscale trip output shall be automatically enabled (not-bypassed) when APRM Simulated Thermal Power is 30% and recirculation drive flow is < 60%

as indicated by APRM measured recirculation drive flow. NOTE: 60% recirculation drive flow is the recirculation drive flow that corresponds to 60% of rated core flow. This is the operating region where actual thermal-hydraulic instability and related neutron flux oscillations may occur. As noted in Table 4.3.1.1-1, Note c, CHANNEL CALIBRATION for the OPRM Upscale trip Function 2.f includes confirming that the auto-enable (not-bypassed) setpoints are correct. Other surveillances ensure that the APRM Simulated Thermal Power properly correlates with THERMAL POWER (Table 4.3.1.1-1, Note d) and that recirculation drive flow properly correlates with core flow (Table 4.3.1.1-1, Note g).

29.5%

If any OPRM Upscale trip auto-enable setpoint is exceeded and the OPRM Upscale trip is not enabled, i.e., the OPRM Upscale trip is bypassed when APRM Simulated Thermal Power is 30% and recirculation drive flow is < 60%, then the affected channel is considered inoperable for the OPRM Upscale Function.

Alternatively, the OPRM Upscale trip auto-enable setpoint(s) may be adjusted to place the channel in the enabled condition (not-bypassed). If the OPRM Upscale trip is placed in the enabled condition, the surveillance requirement is met and the channel is considered OPERABLE.

As noted in Table 4.3.1.1-1, Note g, CHANNEL CALIBRATION for the APRM Simulated Thermal Power - Upscale Function 2.b and the OPRM Upscale Function 2.f, includes the recirculation drive flow input function. The APRM Simulated Thermal Power - Upscale Function and the OPRM Upscale Function both require a valid drive flow signal. The APRM Simulated Thermal Power - Upscale Function uses drive flow to vary the trip setpoint. The OPRM Upscale Function uses drive flow to automatically enable or bypass the OPRM Upscale trip output to RPS. A CHANNEL CALIBRATION of the APRM recirculation drive flow input function requires both calibrating the drive flow transmitters and establishing a valid drive flow /

LIMERICK - UNIT 2 B 3/4 3-1d Amendment No. 139

3/4.3 INSTRUMENTATION BASES 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION (continued) 10% of RATED THERMAL POWER. Plant operational experience has shown that this flow correlation methodology is consistent with the guidance and intent in Reference 8. Changes throughout the cycle in the drive flow / core flow relationship due to the changing thermal hydraulic operating conditions of the core are accounted for in the margins included in the bases or analyses used to establish the setpoints for the APRM Simulated Thermal Power - Upscale Function and the OPRM Upscale Function.

Bases insert 2 As noted in Table 3.3.1-2, Note *, the redundant outputs from the 2-Out-Of-4 Voter channel are considered part of the same channel, but the OPRM and APRM outputs are considered to be separate channels, so N = 8 to determine the interval between tests for application of Specification 4.3.1.3 (REACTOR PROTECTION SYSTEM RESPONSE TIME). The note further requires that testing of OPRM and APRM outputs shall be alternated.

Each test of an OPRM or APRM output tests each of the redundant outputs from the 2-Out-Of-4 Voter channel for that function, and each of the corresponding relays in the RPS. Consequently, each of the RPS relays is tested every fourth cycle. This testing frequency is twice the frequency justified by References 2 and 3.

Automatic reactor trip upon receipt of a high-high radiation signal from the Main Steam Line Radiation Monitoring System was removed as the result of an analysis performed by General Electric in NEDO-31400A. The NRC approved the results of this analysis as documented in the SER (letter to George J. Beck, BWR Owners Group from A.C. Thadani, NRC, dated May 15, 1991).

The measurement of response time at the frequencies specified in the Surveillance Frequency Control Program provides assurance that the protective functions associated with each channel are completed within the time limit assumed in the safety analyses. No credit was taken for those channels with response times indicated as not applicable except for the APRM Simulated Thermal Power - Upscale and Neutron Flux - Upscale trip functions and the OPRM Upscale trip function (Table 3.3.1-2, Items 2.b, 2.c, and 2.f). Response time may be demonstrated by any series of sequential, overlapping or total channel test measurement, provided such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either (1) inplace, onsite or offsite test measurements, or (2) utilizing replacement sensors with certified response times.

Response time testing for the sensors as noted in Table 3.3.1-2 is not required based on the analysis in NEDO-32291-A. Response time testing for the remaining channel components is required as noted. For the digital electronic portions of the APRM functions, performance characteristics that determine response time are checked by a combination of automatic self-test, calibration activities, and response time tests of the 2-Out-Of-4 Voter (Table 3.3.1-2, Item 2.e).

LIMERICK - UNIT 1 B 3/4 3-1e Amendment No. 141, 177, 186

3/4.3 INSTRUMENTATION BASES 3/4.3.1 REACTOR PROTECTION SYSTEM INSTRUMENTATION (continued) core flow relationship. The drive flow / core flow relationship is established once per refuel cycle, while operating within 10% of rated core flow and within 10% of RATED THERMAL POWER. Plant operational experience has shown that this flow correlation methodology is consistent with the guidance and intent in Reference 8. Changes throughout the cycle in the drive flow / core flow relationship due to the changing thermal hydraulic operating conditions of the core are accounted for in the margins included in the bases or analyses used to establish the setpoints for the APRM Simulated Thermal Power - Upscale Function and the OPRM Upscale Function.

Bases insert 2 As noted in Table 3.3.1-2, Note *, the redundant outputs from the 2-Out-Of-4 Voter channel are considered part of the same channel, but the OPRM and APRM outputs are considered to be separate channels, so N = 8 to determine the interval between tests for application of Specification 4.3.1.3 (REACTOR PROTECTION SYSTEM RESPONSE TIME). The note further requires that testing of OPRM and APRM outputs shall be alternated.

Each test of an OPRM or APRM output tests each of the redundant outputs from the 2-Out-Of-4 Voter channel for that function, and each of the corresponding relays in the RPS. Consequently, each of the RPS relays is tested every fourth cycle. This testing frequency is twice the frequency justified by References 2 and 3.

Automatic reactor trip upon receipt of a high-high radiation signal from the Main Steam Line Radiation Monitoring System was removed as the result of an analysis performed by General Electric in NEDO-31400A. The NRC approved the results of this analysis as documented in the SER (letter to George J. Beck, BWR Owner's Group from A.C. Thadani, NRC, dated May 15, 1991).

The measurement of response time at the frequencies specified in the Surveillance Frequency Control Program provides assurance that the protective functions associated with each channel are completed within the time limit assumed in the safety analyses. No credit was taken for those channels with response times indicated as not applicable except for the APRM Simulated Thermal Power - Upscale and Neutron Flux - Upscale trip functions and the OPRM Upscale trip function (Table 3.3.1-2, Items 2.b, 2.c, and 2.f). Response time may be demonstrated by any series of sequential, overlapping or total channel test measurement, provided such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either (1) inplace, onsite or offsite test measurements, or (2) utilizing replacement sensors with certified response times. Response time testing for the sensors as noted in Table 3.3.1-2 is not required based on the analysis in NEDO-32291-A.

Response time testing for the remaining channel components is required as noted.

For the digital electronic portions of the APRM functions, performance characteristics that determine response time are checked by a combination of automatic self-test, calibration activities, and response time tests of the 2-Out-Of-4 Voter (Table 3.3.1-2, Item 2.e).

LIMERICK - UNIT 2 B 3/4 3-1e Amendment No. 109, 139, 147

INSTRUMENTATION BASES 3/4.3.4 RECIRCULATION PUMP TRIP ACTUATION INSTRUMENTATION (Continued)

Each EOC-RPT system may be manually bypassed by use of a keyswitch which is administratively controlled. The manual bypasses and the automatic Operating Bypass at less than 30% of RATED THERMAL POWER are annunciated in the control room. 29.5%

The EOC-RPT system response time is the time assumed in the analysis between initiation of valve motion and complete suppression of the electric arc, i.e.,

175 ms. Included in this time are: the response time of the sensor, the time allotted for breaker arc suppression, and the response time of the system logic.

LIMERICK - UNIT 1 B 3/4 3-3a Amendment No. 158

INSTRUMENTATION BASES 3/4.3.4 RECIRCULATION PUMP TRIP ACTUATION INSTRUMENTATION (Continued)

Each EOC-RPT system may be manually bypassed by use of a keyswitch which is administratively controlled. The manual bypasses and the automatic Operating Bypass at less than 30% of RATED THERMAL POWER are annunciated in the control room. 29.5%

The EOC-RPT system response time is the time assumed in the analysis between initiation of valve motion and complete suppression of the electric arc, i.e.,

175 ms. Included in this time are: the response time of the sensor, the time allotted for breaker arc suppression, and the response time of the system logic.

LIMERICK - UNIT 2 B 3/4 3-3a Amendment No. 120

TS Bases Inserts Bases Insert 1 To ensure that SLCS pump discharge pressure does not exceed the SLCS relief valve setpoint during operation following an anticipated transient without scram (ATWS) event, no more than two pumps shall be aligned for automatic operation in OPERATIONAL CONDITIONS 1, 2, and 3. This maintains the equivalent control capacity to satisfy 10 CFR 50.62 (Requirements for reduction of risk from anticipated transients without scram (ATWS). With three pumps aligned for automatic operation, the system is inoperable and ACTION statement (b) applies.

Bases Insert 2 For the Simulated Thermal Power - Upscale Function (Function 2.b), the CHANNEL CALIBRATION surveillance requirement is modified by two Notes. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value. Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition. The second Note requires that the as-left setting for the channel be within the as-left tolerance of the Trip Setpoint. The as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the Trip Setpoint, then the channel shall be declared inoperable. The as-left tolerance for this function is calculated using the square-root-sum-of-squares of the reference accuracy and the measurement and test equipment error (including readability). The as-found tolerance for this function is calculated using the square-root-sum-of-squares of the reference accuracy, instrument drift, and the measurement and test equipment error (including readability).