ML14251A080

NRR E-mail Capture - Follow Up Question for Columbia, Regarding Implementation of TSTF-493, Option a

ML14251A080
Person / Time
Site:	Columbia
Issue date:	09/05/2014
From:	Linda Williams Energy Northwest
To:	Andrea George Division of Operating Reactor Licensing
References
MF2863
Download: ML14251A080 (26)

Text

1 NRR-PMDAPEm Resource From:

Williams, Lisa L. [llwilliams@energy-northwest.com]

Sent:

Friday, September 05, 2014 1:23 PM To:

Lyon, Fred; George, Andrea

Subject:

RE: Follow up question for Columbia, regarding implementation of TSTF-493, Option A (TAC No. MF2863)

Attachments:

Go2-14-103 RAI excerpt.pdf; Go2-14-128.pdf; GO2-14-076 excerpt.pdf; Figure.pdf Fred, Annie, The teleconference greatly assisted in helping us understand why the NRC is requesting information on the setpoint methodology even though the TSTF-493 submittal is not requesting any changes to values or other information in the Technical Specifications. We understand that the model LAR contained an Attachment 3 for Summary Calculations for the Revised Setpoints. We have reviewed the requested information and believe that this information has previously been submitted as described in blue below.

From: Lyon, Fred [1]

Sent: Wednesday, July 30, 2014 3:37 AM To: Williams, Lisa L.

Cc: George, Andrea

Subject:

FYI: Follow up question for Columbia, regarding implementation of TSTF-493, Option A (TAC No. MF2863)

Based on our phoncon yesterday, this is the information that EICB requires to continue our safety evaluation of the LAR (MF2863).

NRC staff expects to see at least the following ingredients in the licensees setpoint methodology. Please refer to the attached slide for the setpoint terminology.

1. Licensees methodology for consistently establishing adequate margins (Total Loop Uncertainty Allowance) between the limiting and/or nominal trip setpoints and the plant analytical limits. These margins should be reflective of NRC staff guidance (e.g., use of accurate estimates of statistical (95/95) and bias terms for channel performance errors, use of appropriate channel performance modeling assumptions that reflect actual plant engineering and maintenance practices, controlled data, etc.)

A sample methodology for establishing the total loop uncertainty allowance between the analytical limit and the limiting trip setpoint was provided for the proposed Function 7.b instruments in Technical Specification (TS)

Table 3.3.1.1-1 in letter GO2-14-076 dated May 8, 2014, as response to NRC request #2. This function is composed of a transmitter and a trip unit. The device uncertainty for each was computed as documented on page 9 for the transmitter and page 10 for the trip unit (also referred to as a level switch). The total loop uncertainty was the sum of these as documented on page 11. Additionally, the calibration and drift component of the total loop uncertainty was documented on page 9 for the transmitter, page 10 for the trip unit, and page 11 for the total loop. As shown on page 13, the total loop uncertainty is applied to the analytical limit (in the case of the Function 7.b there is no analytical limit, so the uncertainty is applied to the process limit) to determine the limiting trip setpoint. (Energy Northwest calculations use the term maximum setting for limiting trip setpoint.) As shown on page 13, the calibration and drift component represents the difference between the maximum setting and the allowable value. The individual terms that comprise the total uncertainty were provided in Tables 2.1 and 2.2. These terms were further clarified in letter GO2-14-128 dated August 27, 2014, in response to NRC requests #1 and #2. As stated in Attachment 5 to letter GO2-14-103 dated June 19, 2014, this basic methodology exemplifies the methodology used for all the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2.

2

2. Licensees methodology for establishing conservatively small, but practically-applied acceptance tolerance bands for as-found channel performance deviation, and as-left post-calibration setting tolerances that can be used to assure a tight control on allowed setpoint deviations, while permitting a knowledgeable assessment of channel operability.

A sample methodology for establishing the as-found tolerance (AFT) and as-left tolerance (ALT) bands around the nominal trip setpoint was provided for the proposed Function 7.b instruments in TS Table 3.3.1.1-1 on page 12 of letter GO2-14-076 dated May 8, 2014. The individual terms used to calculate the AFT and ALT were provided in Tables 2.1 and 2.2. An input to the calculation of the AFT was further clarified in letter GO2-14-128 dated August 27, 2014, in response to NRC request #1. As stated in Attachment 5 to letter GO2-14-103 dated June 19, 2014, this basic methodology exemplifies the methodology used for all the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2. As stated in GO2-14-128, the correction to the drift assumption for the AFT is applicable for all the TSTF-493 footnoted functions.

3. It would help the staff to see how these margins and tolerances relate to the Allowable Value published in the plant Technical Specifications. This could be in the form of a Figure that shows the relationship among all the values presented, perhaps with a few examples of the attached slide with the values filled in.

A graphical representation was provided for the proposed Function 7.b instruments in Technical Specification (TS) Table 3.3.1.1-1 in letter GO2-14-076 dated May 8, 2014, on page 13. Additionally, a Figure is provided as requested. This Figure uses the term Maximum (or Minimum) Setting in lieu of Limiting Trip Setpoint. The ALT is also referred to as ST (Setting Tolerance).

Please let me know if you have any additional questions. Thanks, Fred

Hearing Identifier:

NRR_PMDA Email Number:

1548 Mail Envelope Properties (1A9664F6E486074BA0CCA69CF22E5900B50A55)

Subject:

RE: Follow up question for Columbia, regarding implementation of TSTF-493, Option A (TAC No. MF2863)

Sent Date:

9/5/2014 1:22:44 PM Received Date:

9/5/2014 1:28:37 PM From:

Williams, Lisa L.

Created By:

llwilliams@energy-northwest.com Recipients:

"Lyon, Fred" <Fred.Lyon@nrc.gov>

Tracking Status: None "George, Andrea" <Andrea.George@nrc.gov>

Tracking Status: None Post Office:

SERVER153.domain1.energy-northwest.com Files Size Date & Time MESSAGE 5317 9/5/2014 1:28:37 PM Go2-14-103 RAI excerpt.pdf 2088114 Go2-14-128.pdf 1502535 GO2-14-076 excerpt.pdf 924275 Figure.pdf 24235 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509.377.8555 l F. 509.377.4150 aljavorik@energy-northwest.com GO2-14-103 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION

Reference:

1. Letter, GO2-13-138, dated October 2, 2013, A. L. Javorik (Energy Northwest) to NRC, License Amendment Request for Adoption of TSTF-493, Revision 4, Option A

2. Letter, dated April 30, 2014, C. F. Lyon (NRC) to ME Reddemann (Energy Northwest), Columbia Generating Station - Request for Additional Information related to License Amendment Request to Adopt TSTF-493, Revision 4, Option A (TAC No. MF2863)

Dear Sir or Madam:

By Reference 1, Energy Northwest requested approval of a license amendment request to revise the Technical Specifications (TS) by adding requirements to assess channel performance during testing that verifies instrument channel setting values established by the plant-specific setpoint methodologies. Attachment 1 to this letter documents a proposed change to the instrument Functions to be annotated with the TSTF-493 Surveillance Notes. The proposed change will remove the Surveillance Notes from TS Table 3.3.5.1-1 Functions 1.c, 1.d, 2.c, and 2.d and add the Surveillance Notes to TS Table 3.3.6.2-1 Function 1. Revised pages of the TS and TS Bases markups are provided in Attachments 2 and 3, respectively. Revised pages of TS (clean pages) are provided in Attachment 4.

Via Reference 2, the Nuclear Regulatory Commission (NRC) requested additional information. Attachment 5 provides the response to the requested information.

This letter and its enclosures contain no regulatory commitments. If there are any questions or if additional information is needed, please contact Ms. L. L. Williams, Licensing Supervisor, at 509-377-8148.

June 19, 2014

PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 1 of 3 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-493, Revision 4, Option A NRC Request:

1.

Please provide the Nominal Trip Setpoint and Limiting Trip Setpoint (LTSP) for the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2.

Also, please provide a description of the methodology for calculating the LTSPs, As-Left Tolerance, and As-Found Tolerance based on the analytical limits, where applicable.

Energy Northwest Response:

NTSP and LTSP for Functions that Will Include TSTF-493, Revision 4, Surveillance Notes 1 and 2.

The nominal trip setpoint (NTSP) and LTSP for the instrument Functions that will include the TSTF-493, Revision 4, Surveillance Notes are provided in Table 1 on the following pages. The calculations of the AFT and ALT values are still in progress.

Energy Northwest applies the AFT and ALT around the NTSP. In some cases, the values for the AFT and ALT require changes to the NTSP. For these cases, revisions to the NTSP are still in progress and will be processed using Energy Northwests setpoint change process. These cases are marked by TBD in the NTSP column.

Description of Methodology for Calculating the LTSPs, As-Left Tolerance, and As-Found Tolerance Based on the Analytical Limits Energy Northwest provided supplemental information regarding application of TSTF-493 Option A Surveillance notes to TS Table 3.3.1.1-1, Function 7, Scram Discharge Volume Water Level - High, in letter GO2-14-076, from A. L. Javorik (Energy Northwest) to the Nuclear Regulatory Commission (NRC), dated May 8, 2014. Pages 7 through 13 of the enclosure to that letter provided a description of the methodology used to determine the AFT, ALT, and LTSP for a proposed change to the instrumentation that fulfils Function 7.b in Table 3.3.1.1-1. The basic methodology described in that enclosure exemplifies the methodology used for calculating the AFTs, ALTs, and LTSPs for all the functions that will include TSTF-493, Revision 4, Surveillance Notes 1 and 2. Note that Energy Northwest utilizes the term maximum setting or minimum setting, as appropriate, synonymously with LTSP.

PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 2 of 3 Table 1 TS or Table Fun.

Type Description Units TS Allowable Value Instruments LTSP NTSP 3.3.1.1-1 1.a RPS Intermediate Range Monitor Neutron Flux -

High divisions LE 122 IRM-EMSQ-601A-H 121.2 120 3.3.1.1-1 3

RPS Reactor Vessel Steam Dome Pressure - High psig LE 1079 MS-PS-23A-D 1063.1 TBD 3.3.1.1-1 4

RPS Reactor Vessel Water Level - Low, Level 3 inches GE 9.5 MS-LIS-24A-D 10.4 13.2 3.3.1.1-1 6

RPS Primary Containment Pressure - High psig LE 1.88 RPS-PS-2A,C,D 1.72 TBD RPS-PS-2B 1.79 TBD 3.3.1.1-1 7.a RPS Scram Discharge Volume Water Level - High n/a LE 529' 9" CRD-LIS-601A-D 529' 7.68" 529' 7"

3.3.1.1-1 9

RPS Turbine Governor Valve Fast Closure, Trip Oil Pressure - Low psig GE 1000 RPS-PS-5A-D 1171 1252 3.3.4.1.2 b

EOC-RPT Turbine Governor Valve Fast Closure, Trip Oil Pressure - Low psig GE 1000 RPS-PS-5A-D 1171 1252 3.3.5.1-1 1.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE

-142.3 MS-LIS-37A,C

-139.2

-127.7 3.3.5.1-1 1.b ECCS Drywell Pressure - High psig LE 1.88 MS-PS-48A,C 1.75 1.65 3.3.5.1-1 2.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE

-142.3 MS-LIS-37B,D

-139.2

-127.7 3.3.5.1-1 2.b ECCS Drywell Pressure - High psig LE 1.88 MS-PS-48B 1.72 1.65 MS-PS-48D 1.75 1.65 3.3.5.1-1 3.a ECCS Reactor Vessel Water Level - Low Low, Level 2

inches GE

-58 MS-LIS-31A-D

-55.1

-49.5 3.3.5.1-1 3.b ECCS Drywell Pressure - High psig LE 1.88 MS-PS-47A-D 1.72 1.65 3.3.5.1-1 3.c ECCS Reactor Vessel Water Level - High, Level 8 inches LE 56 MS-LIS-100A,B 55.1 54.3 3.3.5.1-1 3.f ECCS HPCS System Flow Rate - Low (Minimum Flow) gpm GE 1200 HPCS-FIS-6 1223 1277 gpm LE 1512 1493 1362 3.3.5.1-1 4.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE

-142.3 MS-LIS-37A,C

-139.2

-127.7 3.3.5.1-1 4.c ECCS Reactor Vessel Water Level - Low, Level 3 (Permissive) inches GE 9.5 MS-LIS-38A 10.4 13.2 3.3.5.1-1 4.f ECCS Accumulator Backup Compressed Gas System Pressure - Low psig GE 151.4 CIA-PS-21A 154 160 CIA-PS-22A 154 156 CIA-PS-39A 154 160

PROPOSED REVISION TO LICENSE AMENDMENT REQUEST TO ADOPT TSTF-493, REVISION 4, OPTION A, AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION Page 3 of 3 TS or Table Fun.

Type Description Units TS Allowable Value Instruments LTSP NTSP 3.3.5.1-1 5.a ECCS Reactor Vessel Water Level - Low Low Low, Level 1 inches GE

-142.3 MS-LIS-37B,D

-139.2

-127.7 3.3.5.1-1 5.c ECCS Reactor Vessel Water Level - Low, Level 3 (Permissive) inches GE 9.5 MS-LIS-38B 10.4 13.2 3.3.5.1-1 5.e ECCS Accumulator Backup Compressed Gas System Pressure - Low psig GE 151.4 CIA-PS-21B 154 160 CIA-PS-22B 154 156 CIA-PS-39B 154 160 3.3.5.2-1 1

RCIC Reactor Vessel Water Level - Low Low, Level 2

inches GE

-58 MS-LIS-37A-D

-55.1

-49.5 3.3.5.2-1 2

RCIC Reactor Vessel Water Level - High, Level 8 inches LE 56 MS-LIS-24B,D 55.1 54.3 3.3.6.2-1 1

SCII Reactor Vessel Water Level - Low Low, Level 2

inches GE

-58 MS-LS-300A-D

-52.5

-50 ECCS = emergency core cooling system LE = less than or equal to EOC-RPT = end of cycle recirculation pump trip GE = greater than or equal to RCIC = reactor core isolation and cooling TBD = to be determined RPS = reactor protection system SCII = secondary containment isolation instrumentation

Alex L. Javorik Columbia Generating Station P.O. Box 968, PE04 Richland, WA 99352-0968 Ph. 509.377.8555 l F. 509.377.2354 aljavorik@energy-northwest.com

















10 CFR 50.90 GO2-14-128 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001

Subject:

COLUMBIA GENERATING STATION, DOCKET NO. 50-397 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH

References:

1)

Letter, GO2-14-043, dated March 24, 2014, AL Javorik (Energy Northwest) to NRC, License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level - High" (ADAMS Accession No. ML14098A400)

2)

Letter, GO2-14-076, dated May 8, 2014, AL Javorik (Energy Northwest) to NRC, Supplemental Information Regarding License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level-High (ADAMS Accession No. ML14141A538)

3)

Letter dated July 31, 2014, CF Lyon (NRC) to ME Reddemann (Energy Northwest), Request for Additional Information Related to License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level High (TAC No. MF3673)

Dear Sir or Madam:

By Reference 1, Energy Northwest submitted a License Amendment Request (LAR) to change Technical Specification (TS) Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level - High. By Reference 2, Energy Northwest provided supplemental information to support its initial LAR at the request of the NRC. By Reference 3, the Nuclear Regulatory Commission (NRC) requested additional information related to the Energy Northwest submittal. Transmitted herewith in Attachment 1 is the Energy Northwest response to the request for additional information.

August 27, 2014

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH Page 1 of 5 Response to Request for Additional Information EICB-RAI-1:

The calibration frequency in the TSs for CGS is defined as 18 months. In the supplemental letter dated May 8, 2014, Tables 2.1 and 2.2 show that a more conservative value of 24 months was selected for the instrument uncertainties and calibration calculation. Please explain why a frequency of 24 months was selected, since this is not the surveillance frequency defined in the TS, and the licensee has not submitted a license amendment request to modify the surveillance frequency. Also, please explain what calibration frequency was used to estimate instrument drift.

Energy Northwest Response:

The calibration frequency for scram discharge instrumentation is 18 months. The drift published by Rosemount for its 3152ND2 transmitter is +/- (0.1 % Upper Range Limit +

0.1% of Span) per 30 months. For determination of total loop uncertainty, taking the full value of the vendor published drift was considered conservative. However, taking the full value of drift becomes non-conservative for calculation of the as found calibration tolerance. Therefore, CGS is recalculating the as found tolerance using the drift associated with 18 months.

In addition, a review of all calculations associated with the TSTF-493 functions indicates that the drift period considered in these calculations matches the Technical Specification (TS) calibration frequency with the exception of three functions where the drift period was 22.5 months (18 months plus 25% extension per TS Surveillance Requirement (SR) 3.0.2). CGS is recalculating the as found calibration tolerances for these three functions using the drift associated with their associated TS calibration periods.

On October 2, 2013, Energy Northwest submitted a license amendment request to adopt TSTF-493, Revision 4, Option A (Reference 1.1). In a letter dated April 30, 2014, the NRC requested Energy Northwest provide additional information related to this submittal (Reference 1.2). Specifically, the NRC requested a description of the methodology for calculating the limiting trip setpoints (LTSPs), As-Left Tolerance (ALT),

and As-Found Tolerance (AFT) based on the analytical limits, where applicable. On June 19, 2014, Energy Northwest responded to this request (Reference 1.3). The response referenced the description of the methodology that was provided previous in letter GO2-14-076 (Reference 1.4). Specifically, Energy Northwest stated that pages 7 through 13 of the enclosure to that letter provided a description of the methodology used to determine the AFT, ALT, and LTSP for a proposed change to the instrumentation that fulfils Function 7.b in Table 3.3.1.1-1. The basic methodology described in that enclosure exemplifies the methodology used for calculating the AFTs, ALTs, and LTSPs for all the functions that will include TSTF-493, Revision 4,

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH Page 2 of 5 Surveillance Notes 1 and 2. As such, the response provided above to this latest RAI applies to the Reference 1.1 and 1.3 submittals as well.

References:

1.1 Letter, GO2-13-138, dated October 2, 2013, AL Javorik (Energy Northwest) to NRC, License Amendment Request for Adoption ofTSTF-493, Revision 4, Option A

1.2 Letter, dated April 30, 2014, CF Lyon (NRC) to ME Reddemann (Energy Northwest), Columbia Generating Station - Request for Additional Information related to License Amendment Request to Adopt TSTF-493, Revision 4, Option A (TAC No. MF2863) 1.3 Letter, GO2-14-103, dated June 19, 2014, AL Javorik (Energy Northwest) to NRC, Proposed Revision to License Amendment Request for Adoption ofTSTF-493, Revision 4, Option A and Response to Request for Additional Information 1.4 Letter, GO2-14-076, dated May 8, 2014, AL Javorik (Energy Northwest) to NRC, Supplemental Information Regarding License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level-High EICB-RAI-2:

Tables 2.1 and 2.2 of the supplemental information provided instrument uncertainties and drift design inputs in terms of accuracy of calibrated span. Please provide the vendor-published values representing the appropriate accuracies associated with the minimum calibrated span, the maximum calibrated span, and the licensees proposed calibrated span.

Energy Northwest Response:

Tables 2.1 and 2.2 below provide the requested information for CRD-LT-13C & D and CRD-LS-613C & D, respectively. Note that uncertainty and drift inputs which are independent of the design of the replacement instruments are not included in the tables.

For each design input, the table shows the vendor published data, calculations at minimum, maximum and proposed spans. Where appropriate, assumptions are listed as part of the table data. The values (in terms of percentage of calibrated span) which were provided in Reference 2.1 are indicated by boxed text.

References:

2.1 Letter, GO2-14-076, dated May 8, 2014, AL Javorik (Energy Northwest) to NRC, Supplemental Information Regarding License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level-High

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH Page 3 of 5 Table 2.1 - Instrument Uncertainties and Calibration and Drift Design Inputs for CRD-LT-13C & D (Instrument Range 0-25 to 0-250 H2O)

Design Input Vendor Published Value Minimum Span (25)

Maximum Span (250)

CGS Proposed Span (66)

RA =

Reference Accuracy

+/- 0.2% of CS

+/- 0.2% of CS

= +/- 0.05

+/- 0.2% of CS

= +/- 0.5

+/- 0.2% of CS

= +/- 0.132 DR = Drift

+/- (0.1% URL +

0.1% span) per 30 monthsa

+/- (0.1% x 250 + 0.1% x 25)

= +/- 0.275

= +/- 0.275÷ 25 x100

= +/- 1.1% CS

+/- (0.1% x 250 + 0.1% x 250)

= +/- 0.5

= +/- 0.5÷ 250 x100

= +/- 0.2% CS

+/- (0.1% x 250 + 0.1% x 66)

= +/- 0.316

= +/- 0.316 ÷ 66 x 100

= +/- 0.48% of CS Drift for 18 months (Vendor Published Value above for 30 months) x 18 ÷30

+/- 0.275 x 18 ÷30

= +/- 0.165

= +/- 0.165÷ 25 x100

= +/- 0.66% CS

+/- 0.5 x 18 ÷30 =

= +/- 0.3

= +/- 0.3÷ 250 x100

= +/- 0.12% CS

+/- 0.316 x 18 ÷30

= +/- 0.1896

= +/- 0.1896÷ 66 x 100

= +/- 0.28% CS PSE = Power Supply Effect

+/- 0.005% of span per volt

+/-.005% of span x 2.4b

= +/- 0.012% of CS

= +/- 0.012% x 25

= +/- 0.003

+/- 0.012% of CS

= +/- 0.012% x 250

= +/- 0.03

+/- 0.012% of CS

= +/- 0.012% x 66

+/- 0.0792 RE

Radiation Effect

+/-0.25% of URL during and after initial exposure to a TID of 1 Mrad at a dose rate of 0.1 Mrads/hr.

+/- 0.25% of URL x 0.84.c

= 0.25% x 250 x 0.84

= 0.525

= +/- 0.525 ÷ 25 x 100

= +/- 2.1 % CS

+/- 0.25% of URL x 0.84

= +/- 0.25% x 250 x 0.84

= +/- 0.525

= +/- 0.525 ÷ 250 x 100

= +/- 0.21 % CS

+/- 0.25% of URL x 0.84

= 0.25% x 250 x 0.84

= +/- 0.525

= +/- 0.525 ÷ 66 x 100

= +/- 0.80 % CS a Upper Range Limit = 250 b The power supply stability is assumed to be +/- 10% of the nominal 24 VDC loop supply voltage.

c TID in zone 522B is of 8.4E5 Rads. Assuming the effect is linearly proportional to TID, it will be.25 % of URL x 8.4E5/1E6

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH Page 4 of 5 Table 2.1 - Instrument Uncertainties and Calibration and Drift Design Inputs for CRD-LT-13C & D (continued) d Maximum temperature shift from calibration temperature is 34°F e Specification for transmitter and the remote seal can be linearly interpolated down to 50°F f Capillary length is 40ft.

g Reference 2.1 previously reported 6.96% of CS the change to 4.8% of CS is due to updated vendor specifications on the Remote Diaphragm Seal Design Input Vendor Published Value Minimum Span (25)

Maximum Span (250)

CGS Proposed Span (66)

TE =

Temperature Effect Transmitter:

+/-(0.15% URL +

0.6% span) per 100°F temperature shiftd

= +/- (0.15% URL + 0.6% span)

÷ 2e

= +/- (0.15% x 250 + 0.6% x25)

÷ 2

= +/- 0.262

= +/- (0.15% URL + 0.6% span)

÷ 2

= +/- (0.15% x 250 + 0.6% x250)

÷ 2

= +/- 0.937

= +/- (0.15% URL + 0.6% span)

÷ 2

= +/- (0.15% x 250 + 0.6% x66)

÷ 2

= +/- 0.385 Remote seal with DC704 silicone oil: +/-(1.4 in wg for first 5 ft of capillary + 0.7 in wg for each additional 5 ft of capillary) per 100°F temperature shift

= +/- (1.4 in wg for first 5 ft of capillary + 0.7 in wg for each additional 5 ft of capillary)f ÷ 2

= +/- [1.4 + 0.7 x (40-5) ÷ 5] ÷ 2

= +/- 3.15

= +/- 3.15 (It is not span dependent)

= +/- 3.15 (It is not span dependent)

The combined temperature effect is:

= (.262 2+ 3.15 2)1/2

= +/- 3.16

= 3.16 ÷ 25 x 100

= +/- 12.64 % of CS The combined temperature effect is:

= (0.937 2+ 3.15 2)1/2

= +/- 3.29

= 3.29 ÷ 250 x 100

= +/- 1.32 % of CS The combined temperature effect is:

= (0.385 2+ 3.15 2)1/2

= +/- 3.17

= 3.17 ÷ 66 x 100 = +/- 4.80 %

of CSg

RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, SCRAM DISCHARGE VOLUME WATER LEVEL-HIGH Page 5 of 5 Table 2.2 - Instrument Uncertainties and Calibration and Drift Design Inputs for CRD-LS-613C & D (Instrument Range 4-20 mA)

Design Input Vendor Published Value Minimum Span (25)

Maximum Span (250)

CGS Proposed Span (66)

RA =

Reference Accuracy

+/- 0.1% of CS

+/- 0.1% of CS =.025

+/- 0.1% of CS =0.25

+/- 0.1% of CS = +/- 0.066 DR = Drift Noneh 1.0% of CS = 0.25 1.0% of CS = 2.5 1.0%of CS = 0.66 PSE =

Power Supply Effect

+/- 0.15% of specified power variation

= +/- 0.15% x 2.4i

= +/- 0.36% of CS

= 0.36% x 25

= +/- 0.09

+/- 0.36% of CS

= 0.036% x 250

= +/- 0.9

+/- 0.36% of CS

= 0.36% x 66

+/- 0.2376 RE

Radiation Effect None The component is located within the control room and radiation effect is negligible.

0.0% of CS 0.0% of CS 0.0% of CS TE =

Temperature Effect Ambient Temperature Range:

0°F to 140°F Trip Point Stability and Drive:

For 25 °F to 125 °F

+/- 0.01%/°F maximum

+/- 0.004%/°F typicalj 0.0% of CS 0.0% of CS 0.0% of CS h Per Energy Northwests setpoint methodology, in the absence of a manufacturer's expression of drift, or a calculated expression of drift as derived from actual performance histories, the default value of 1.0% of CS bias should be used.

i The power supply stability is assumed to be +/- 10% of the nominal 24 VDC loop supply voltage.

j The component is located within the control room, and is calibrated within the normal temperature range of the control room. The temperature effect is zero.

Number: EES-4 Use Category: INFORMATION Major Rev: 007 Minor Rev: 001 Page: 22 of 91

Title:

Setpoint Methodology

.1, Setpoint Relationship SETPOINT RELATIONSHIP DESIGN/SAFETY LIMIT OR PROCESS LIMIT ANALYTIC LIMIT ALLOWABLE VALUE CAL & DRIFT +

MAXIMUM SETTING AFT +

ALT + or ST +

NOMINAL OR CURRENT SETTING ALT - or ST -

MINIMUM SETTING AFT -

ALLOWABLE VALUE ANALYTICAL LIMIT DESIGN/SAFETY LIMIT OR PROCESS LIMIT END UNCERTAINTIES +

NOMINAL SETTING RANGE CAL & DRIFT -

UNCERTAINTIES -