GO2-14-076, Supplemental Information Regarding License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level - High.

Supplemental Information Regarding License Amendment Request for Changing Technical Specification Table 3.3.1.1-1 Function 7, Scram Discharge Volume Water Level - High.

ML14141A538
Person / Time
Site:	Columbia
Issue date:	05/08/2014
From:	Javorik A Energy Northwest
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GO2-14-076, TAC MF3673
Download: ML14141A538 (16)

Text

~N ~ Alex L Javorik A ~ ~ ~ CA0bib Genertin Smtio 4 P.O. m M68. PEN4 NRd. WA 93Q-OQ W 50.377A8M51 F. 509.377.4150 atlao*O w=~wwwtreco, May 8,2014 10 CFR 50.90 G02-14-076 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20565-0001 SuectC LUA GENEASIS STrA1ION DOCKET NO. 504W SUPPLEMUMWAL *F"..W.Tl RIGAINWOG LUN AMENDENT REWUEST FOR CNAN1 N1IMCNNICAL OC AIrON TABLE 3.31.11-I O , SCRA DISIHARE VOLUME WATER LEVEL - HIGH"

References:

1) Letle, G02-14-043, 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"

2) Letter dated Apuil 28, 2014, CF Lyon (NRC) to ME Reddemann (Energy Northwest), "Supplemental Information Needed for Acceptance of Requested Licensing Action Re: 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 requested approval of a license amendment request to revise the Columbia Generating Station Technical Specification (TS) Table 3.3.1.1 -1, Function 7 "Scram Discharge Volume Water Level-High" to support planned instrumentation upgrades.

Via Reference 2, the Nuclear Regulatory Commission (NRC) indicated that additional information was needed to complete the acceptance review of the proposed TS changes. Enclosure I provides the requested infornurtion.

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

A c-)

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 33.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Page 2 of 2 1declare under penalty of perjury that the foregoing is true and correct. Executed on the date of this letter.

Respectfully, Vice President, Engineering

Enclosure:

As stated cc: NRC RIV Regional Administrator NRC NRR Project Manager NRC Senior Resident Inspoctor/988C M Jones - BPA/1 399 (email)

JO Luce - ESFEC RR Cowley - WDOH (email)

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page I of 14 RESPONSE TO SUPPLEMENTAL INFORMATION NEEDED

1. By letter dated March 24, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14098A400), Energy Northwest submitted a license amendment request (LAR) for Columbia Generating Station (CGS). The proposed amendment request would revise the specified function description and surveillance requirements (SRs) in Technical Specification (TS) Table 3.3.1.1-1, "Reactor Protection System [RPSJ Instrumentation," Function 7, "Scram Discharge Volume [SDVI Water Level- High." The LAR supports planned upgrades to level sensing equipment different and diverse from the level sensing equipment currently used for TS Table 3.3.1.1-1, Function 7a. However, the LAR does not provide enough information regarding the proposed Instrument for TS Table 3.3.1.1-1, Function 7b, for the NRC staff to be able to evaluate the proposed TS change.

Please provide the following information:

a. Manufacturer and model of the level transmitter to be used for TS Table 3.3.1.1-1, Functions 7.a and 7.b. For Function 7.b, please provide a sketch of the typical instrument channel showing the "before change" and "after change" configurations.

b. Identify the power sources for the level sensing equipment for TS Table 3.3.1.1-1, Functions 7.a and 7.b.

c. Please clarify whether the instrumentation for TS Table 3.3.1.1-1, Function 7.a includes a trip unit.

E MM NorthwastggM The Scram Discharge Volume (SDV) consists of large diameter piping from the solenoid scram pilot valve headers to the two interconnected Scram Discharge Instrument Volume (SDIV) tanks A and B. Each SDIV tank has 4 instrument loops on each tank for sensing level in the SDIV and providing a trip signal for Reactor Protection System (RPS) Scram actuation. The instrument loops (transmitter/trip units) comprise the input to the four RPS trip channels (Al, A2, 81 &82) of the reactor protection trip system, Each RPS channel has two SDV instrument loops (one mounted on each SDIV tank);

one from Function 7.a (an existing transmitter/indicating trip unit) and one from Function 7.b (new transmitter/non-indicating trip unit) that provide redundant and diverse trip signals to the RPS trip channel,

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 2 of 14 The change in title of the Function 7.a to transmitter/level indicating switch is administrative only. The instrument loop remains a transmitter/trip unit design. The proposed term, Transmitter/level indicating switch more accurately describes the instrumentation and was made to align to the terminology used in the plant's FSAR, the component equipment plant nomenclature (LIS), and to highlight the indicating capability of Function 7.a from the non-indicating capability of Function 7.b. Similarly, the Function 7.b title was chosen to be Transmitter/level switch (LS) which has a transmitter and a non indicating trip unit comprising the instrument loop.

Technical Specification Table 3.3.1.1-1 Function 7.a design and logic configuration are unchanged. The level transmitters (CRD-LT-12A, B, C, D) are now supplied by Ametek Gulton-Statham. The Ametek model number Is PD-3218. This instrument loop includes existing Rosenxxt model 510 level indicating switches (indicating trip units) (CRD-LIS-601A, B, C, D) and remains unchanged. The Ametek transmitters have sensors which employ strain gauge technology for sensing a pressure differential which Is converted to a level signal. The strain gage sensor converts a mechanical force (pressure) to an electrical signal. A Wheatstone resistance bridge circuit is molecularly deposited on a metal bending beam using a technique similar to the process used to manufacture high density integrated circuit chips. The sensing mechanism is Isolated from the process fluid by an isolation diaphragm and silicone fill fluid.

The Technical Specification Table 3.3.1.1-1 Function 7.b sensing and trip signal design and logic configuration has changed, however the interface with RPS trip logic remains unchanged. The existing Fuction 7.b instruments are Magnetrol level switches (CRD-LS-13A, B, C, D) with associated relays that are the interface with the RPS Technical Specification Scram Function. After this change the functions that are now performed by the level float switches will be performed by new level transmitters and level switches (non-indicating trip units) (CRD-LT-13A, B, C, D and CRD-LS-613A, B, C, 0).

This change replaces the instrumentation for the existing Magnetrol level switches with Rosemount 3152N Level Transmitters and the Ametek ET-1200 series non indicating trip units. The Rosemount 3150N Series pressure transmitters are electro-mechanical devices that convert a process pressure to an electrical output signal proportional to the pressure within a predetermined range of pressure values. The design uses an oil-filled cavity with a capacitance plate as the pressure-sensing element. Differential pressure changes result in a corresponding differential capacitance change In the sensing element (sensor). This signal Is then decoded, amplified, and linearized by an analog circuit, converting the pressure change into a proportional 4-2OmA electrical current

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECWICATION TABLE 3.&1.11-11 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 3 of 14 output signal. The sensing mechanism is isolated from the process fluid by an isolation diaphragm and silicone fill fluid.

Figure 1 provides a sketch depicting a typical channel of the existing and new design for Function 7.b. There is no change to the RPS logic. Additionally, Figure 1 provides the typical channel for Function 7.a showing that channel logic remained the same.

RPCH. A EXlSTIN NEW DESIGN I

~Ž

~ 1%

Figure I - Typical SDV Water Level - High Insbrument Channel (Before &After)

SUPPLEMENTAL INFORMATION REGARDING UCENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 4 of 14 A detailed explanation showing the existing and new components along with the power suppies for all SDV Function 7.b components is provided in Table 1. For completeness, Table I shows the component manufacturer/model and power supplies for the unchanged Function 7.a design. Table I also provides the Function and the SDIV Tank A or Tank B that the instrument measures.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Encosure Page 5 of 14 Table I - of SDV WaWs Level -

TS 3.3.1.1 RPS Trip manubactmw Function New Deviues Lcog SDIV Tank mom~

chm"n CRD-LS-1 3A (ftltsw#;) Magwtrl I hit.urr"Aw CRD-LT-1 3A I CRD4.S413A I3152ND2S2/

CRD-LS-138 Magneol (momteWOW CRD-LT-138 /

CRD-LS-13C (Poom -w mageww CRD-.T-130 I

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 6 of 14

2. The LAR proposed adoption of Technical Specification Task Force (TSTF) traveler TSTF-493 (Revision 4), Option A Surveillance Notes, for Function 7.b. The LAR described the licensee's intent to replace the existing level float switches with electronic analog transmitters and trip units for Function 7,b. Installation of the proposed equipment for Function 7.b would require modifications to accommodate new level sensing instrument and trip unit. These changes could affect the TS Allowable Value (AV) and SRs for Function 7.b. Section 3.2 of the LAR stated that the setpoint calculations did not result in any changes to the TS AV for this function.

Implementation of TSTF-493, Note I requires the licensee to calculate appropriate magnitudes for ALT and AFT. Please provide information necessary to confirm that the AV remains the same, and provide a description of the menthodolo used to calculate the As-Left Tolerance (ALT), and As-Found Tolerance (AFT). Also, please provide a summary setpoint calculation for Function 7.b, and supporting design input data, consistent with Regulatory Guide 1.105, Revision 3, "Setpoints for Safety-Related Instrumentation," December 1999 (ADAMS Accession No. ML993560062),

and Regulatory Issue Summary (RIS) 2006-17, *NRC Staff Position on the Requirements of 10 CFR 50.36, Technical Specifications,' Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels,"

dated August 24,2006 (ADAMS Accession No. ML051810077).

[ntw=['L7 1 The SDV receives the water displaced by the motion of the Control Rod Drive (CRD) pistons during a reactor scram. Should this volume fill to a point where there Is insufficient volume to accept the displaced water, control rod Insertion would be hindered. The header piping is sized to receive and contain all the water discharged by the drives during a full scram independent of the instrument volume. Therefore, a reactor scram is initiated when the remaining free volume is still sufficient to accommodate the water from a full core scram. However, even though the two types of Scram Discharge Volume Water Level - High Function am an input to the RPS logic, no credit is taken for a scram initiated from these Functions for any of the design basis accidents or transients analyzed in the Final Safety Analysis Report (FSAR). However, they are retained to ensure that the RPS remains OPERABLE. The Allowable Value, measured as a level In the scram discharge Instrument volume is chosen low enough to ensure that there is sufficient volume with margin in the SDV to accommodate the water from a full scram.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 7 of 14 Since the design of the scram discharge volume does not credit any of the scram discharge instrument volume to perform the scram discharge safety function, an allowable value within the instrument volume would assure ample margin for the safety function. Thus, the Instrumentation of the SDIV is such that the upper allowable value for the function must be capable of accurately measuring a level in the instrument volume. A limiting design constraint for the existing Technical Specification Allowable Value is to not allow the accumulation of water In the instrument volume higher than a level that can be accurately measured. Although the calculated allowable value Is higher than the existing TS allowable value, the instrumentation would not be able to accurately measure this higher value when water level rose above the Instrument's diaphragm.

Thus, this change maintains the existing TS allowable value limit of 529'-9" in the instrument volume.

Setpoint calculations for the new Function 7.b instruments were performed In accordance with Columbia's setpoint procedure. The basic methodology is summarized as follows:

" Define the loop to be analyzed

" Determine analytical limit for the instrument loop in question

" Determine normal and accident environmental conditions and associated effects on the accuracy of each instrument in the loop

" Determine normal drift effects for each instrument in the loop

" Combine the effect terms and determine the setting range

" Determine as-found and as-left tolerances

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 8 of 14 The following provides the appropriate magnitude for the As Left Tolerance and the As Found Tolerance. The calculation provides that a calculated allowable value higher than the current TS limit could be justified. However, due to center line of the transmitter's sensing diaphragm elevation, an allowable value above the accurate measurement range of the Instrument is inappropriate. Energy Northwest has elected to maintain the more conservative existing TS allowable value. This assures additional margin for the discharge scram volume RPS scram function. A brief summary of uncertainty, calibration, drift and other factors associated with the derivation of calculated allowable value, as found tolerance and the as left tolerance is provided below. A number of normal factors which did not affect the instrument loop uncertainty and device calibration and drift were considered but not listed Inthis summary. These include humidity (HE),

insulation resistance (IR), pressure (PE), seismic (SE), static pressure (SP) and combined accident (CAE) effects.

The summary of the calculation Is provided in the following pages. Function 7.b Transmitters for the SDIV Tank B are more constraining due to the tank's height and its corresponding calibration span. This was chosen as the summary of the typical set point calculation requested.

Supporting design input data is provided in Tables 2.1 and 2.2 for level transmitters and trip units, respectively. Finally, a graphical summary of the calculation is presented In Figure 2 below.

Table 2.1 - Instrument Uncertaintes and Calibraton and Drift Design Inputs for CRD-LT-13C & D Desin hW ~ DOW74fn Bmwi TS Calibration Frequency 18 Months Table 3.3.1.1-1 Function 7.b. The calibration period Is 18 months.

Calculation Calibration 24 months A more conservative value is 24 months.

Frequency Calibration Frequency + 25% 30 Months 24 months plus a 25% margin of 6 months = 30 months.

C =Corecton0.839 Correction for end device when set point is approached from a cin0". s C =0...

-59 The maxnmum seismic loadin for the device installation Seismic RRS (s) () 5g location isaWRRgMs 5.0 G.

2.4 VDC The power supply to thi device Isassumed to be within t10%

Power Supply Stability (V) .of the nominal 24 VDC supply.

Under normal conditions the water level Inthe SDO will be Instrument's nominal reading 0.0 below the lower sensng diaphragm of the transmitter. Output

... __._will

. ........ .. ... ... be at rinimum .

Period of operation during and 0.0 The Instrumet will perform No safety funcxo operation after LOCA (Scram) prior to being exposed to the LOCA environment.

RA = Reference Accuracy , 0.2% of CS Vendor Oata Sheet- Accuracy of Calibrated Span (CS)

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 9 of 14 Assumes Pressure input a+/- 0.125 In wg, Span 66 inches, and MT&E a Maintenance and tog 0.26% of CS MT & E accuracy of 0.25 or less than device under test per equipment uncertainty calibration standards.

The input device has a minor graduation of 0.2 lrmg. The SA=Seltting Aomua 0.15% of CS reading accuracy Is %of the minor graduation. 0.2 + 2+ 66.0 x 100% a 0.15% of CS.

2 2 CAL a Calibration Effect 0.30% of CS Plant Selxont Methodology SWtUndr EES-4, jM&TE +SA,11' DR = Dri 0.48 ofs C The nauiactures statement of drift e t per 30 monts is

. ... .. 0.48OfCS 00.1% URL + 0.1% span).

The manufacturers statement of power supply efet for this PSE a Power Supply Eflect 0.012% Of CS device Is *0.008% of span per vot. The pow supply stability Ps assumed to be t 10% of the nominal 24 VDC loop supply

_ _ _ _ voliane.

Sonivty to specific gravity (SG) is a function of process PPE = Primary 0.58% of CS temperatur. The meidmw ASG that will occur from the Element Effect calbration temperature of 70"F to fmaim envroniental

... . . . ...... . . ........ . .... .. . tem ,perture of 104F is 0.58% Of CS.

The manufactur's statement of radiation affect Is *0.25% of URL during and after nWal exposure to a TID of I Mrad at a RE = Radiation Effect 0.10% of CS dose rate of 0.1 Mrads/hr. Assuming the effct Is linearly proportional to TID, the radiaton effect in radiation dose zone

_ 6228. TI" of SAES Rds.,Is OAO % of CS.

The Temperature Effect of the system is determined by adding together the contributions from the tranwsitter and the remote diaphragm seal. The manufacturer's statement of teemperature effect for the transmitter Is *(0.15% URL + 0.6% span) per TE Temperature Effect 6.96% Of CS tOO"F and temperature effect for the remote seal with DC704 silicone oil Is *(3.0 inwg/100Ffit 5 ft of caply + 1.5 inwg/100"F each additional 5 ft). CapIllary length is 40ft Maximum tenperature shift from calibration temperature Is

............. 34T . The total Temperature Effect Is 8.96% of CS.

Level Transmitter Uncertainty and Diift [refer to Table 2.1 abovel UO.R = C X [RA + CAL2 + pSE2 + SE? + DR2 + RE2 + T2]112 = 5.90% of CS UM.8 = CAE+DR+HE+IR+PE+PPE+SP = 0.56% of CS UD = UDR+ UD. 8 The device unctalt for the anmitter Is o 6.48% of CS CDD = CAL + DR The device Calibration and Drift components for the tnsmiter Is CD m 0.78% of CS

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 10 of 14 Level Switch (nonmdrlcatina Trip Unit) Uncertainty and Drift rrefer to Table 2.2 below]

UD'R = C x RA 2 + CAL2 + PSE2 +SE21 = 0.42% of CS UDA. = CAE+DR+HE+IR+PE+PPE+RE+SP+TE = 1.0% of CS Uo = UD.R+UD.B The device uncertainty for the trip unit Is Uo 1A2% of CS CDD = CAL + DR The device Calibration and Drift cmponents for the trip unit Is COD 1.33%

of CS Table 2.2 - Instrument Uncertainties and Callbration and Drift Design Inputs for CRD4413C & D TS Calibration Frequency 18 Months Table 3.3.1.1-1 Function 7.b. The calibration period is 18 Calculation Calibration 24 month A more conservative value Is 24 months.

Frequency Calibration Period 3C Months 24 months plus a 25% margin of 6 months a 30 months.

Frequency + 25%

C = Correction 0.839 C for and de s W point i approached from a whe

_singse side. C s0.83 when applicable Seismic RRS (s) (g) 0.6 The maxmum seismic loading for the device installation location

_is approxhwlmt0.6G.

The voltage supplied to the level switch devce must be within Power Supply Stability (V) 4.8 20% of the nominal 24 VOC supply. The actual power supply Is wihn 10%of the nominal voltage. This device Is assumed to be within 010% of the nominal 24 VOC supply.

Instrument's nominal Under normal conditions the water level in the SDIV will be below 0.0 the lower sensing diaphragm of the transmitter. Output will be at reading minimum.

Period of operation during The insrument Is located In the control room and will perform it 0.0 safety hon n operation (Scram) prior to being exposed to the and after LOCA LOCA environment.

RA =Reference Accuracy 0.1% of CS Vendor Data Sheet. Accuracy of Calibrated

• a* u The deaeresistance network used for the calibration of Othi device Is assumed to be accurate to within 0.1% of reading. The M&TE x Maintenance and M&TE specified for this calibration Is a Fluke model 45 digital Test Equipment 0.33% of CS multimeter with an accuracy of a 0.25% CS. Reference Uncertainty standards used for the calibration of the M&TE am required to have accuracy uncertainties 0.25 or less than the equipment being tested.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 11 of 14 D n bpW -ecrpto SA = So" Accuracy 0.0% of CS The decade resistor network is a digital device. There is no

____________ nceraijnty associated with the setting of thi device.

CAL = Calibration Effect 0,33% of CS Plant Setpolnt Methodology Standards EES-4, (M&TE2+SA1112 Per EES., Inthe absence of a mnarufacturoes expression of drift, DR=rt1.0% Of CS or a calculated expression of drit as derved from actual performance histories, the default value of 1.0% of CS bias should be used.

PSE = Power Supply The manufactunes slatment of powr supply eect for this 0.36%Of CS device Is*.0.15% of specified power variation.

Effect

.. = 0. This device isnot connected or exposed to a process. Any PPE = ProcessolPdmary EWment elaffcts ae included in the uncertainty Element Effect _e nt of the associated difrnta pressure tranitr.

RE = Radiation Effect 0.0% of CS The opormt is wihn th control room and radiation effect Is noeg10ble.

The performce spec*ict*ons for Ofti device ae for operation TE = Temperature Effect 0.0% Of CS under amtbent Wteerature conditions that envelope those at the

,__ installation location. ThTemperature Effct is zero.

Total Loco Uncertainty The above uncertainties for the transmitter and the trip units are combined UT = ULT+U75 UTR = [z UD.R,Rn 2)1/2 = 5.91 % of CS UM = I Uo,B.n = 1.56 %of CS UT =UTR+Urs 7.47% of CS UT = 4.9302 Inches Total Loop Uncertainty Is UT a 4.9302 inches Total Calibration and Drift The above Calibration and Drift components for the transmitter and the trip units are combined CD = [1 CALOR,n, 2 +WRDRon 2 ]12+ FDRO.e.. =1.66 % of CS = 1.0956 Inches Total Loop Calibration and Drift Component CD a 1.0956 inches.

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 12 of 14 As-Found Tolerance (AFT9) and AsLeft Tolerance (ALT)

For those instruments subject to the requirements of TSTF-493, Setting Tolerance has two parts. As-Found Tolerance (AFT) and As-Left Tolerance (ALT).

AFT is defined as the bounds, within which the setpolnt is expected to be found at the end of surveillance, and ALT Is defined as the bounds within which the setpoint must be adjusted at the end of surveillance.

The following calculations are for instrument loop CRD-LT-13C and CRD-LS-613C, but the results also apply to CRD-LT-1 3D and CPD-LS-613D.

Given Data:

EPN CRD-LT-13C CRD-LS-613C k 0.839* 0.8390 CALI = CAL" 0.30 0.33 RA+ = RA 0.20 0.1 0.48 0.0 oRft DRW9 DR'e 0.0 1.00

• Note: k=1 for a normal distribution and 0.839 for a single sided distribution Calculated Values:

As Found Toleances (AFT) are calculated as follows:

AFT* = k x [(ZCAL) 2 + (RA+)2 + (WRR)2j 1' 2 + Z1RM = 1.71% of CS = 1.13 inches AFT = k x [(ECAL-) + (ZRA-) + (EDRRf) 2I" 2 + ED% = 1.71% of CS = 1.13 inches 6

As Left Tolerances (ALT) are calculatld as follows:

ALT k X [('CAL') 2 +(jRA÷j),2] 0.59% of CS = 0.39 inches ALT = k x [(ECAL) 2 + (ZRA)j" 2 = 0.59% of CS = 0.39 inches

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7,

"'SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 13 of 14

• Sý1F, Aov sac, 7

?p~ ~cs tu 49332

- "*,  ;, ,Cý,-5ý:f C3 2E. 7~

- 52$1~ TS Aleb ai As- Fzn To 4 no A. C? Ak;'

AS4A To*'arcw-As.Fo~td To4,a'~ce~

~

C2Q7

~w Aliowab~ VaIie V"

52~ 6 376O'~ ~w F~ocrn .n~n Figure 2 - Setpotnt T"bis for CRD-L$413C, D Scram Setpoint

• NOTE: The Instnnnt accuracy isspecfed from centoeno of the diaphragm of the reference leg to centerline of te upper sensingdIaphragm. This ithe100%rangeoftheinstrument. Anyfuthwrinom bveecnte eoftheuppers ng diaphragm affects the accuracy of the measured value. Once the upper sensing diaphragm m fully submeewed no ft increase in We.e will result in a detected levelwchange. Therefore, the upper allowable value ie limied by desig to the center*ine of the upper enaong diaphrgm. The upper sensing d r celi neelevalion for thme transmitters s 529'-0r. Therefore, an Upper Allowable Value of S29'-9 wil be used; ti sInagreement with the Tech. Spec.

- NOTE: With the upper alowale vou of 529'-W' percT Specs, the maimum setting is 829'.7.9" (529S- - 1.09W).

A NOTE: The combined As Found Tol*er*ns AFT+ and AFT- valuee for WInsru t CRO.LT-130CRDOLS-813C and CRD- LT-13D/CRO-L.S6130 we 0.06 mA (1.13 inches H20). The combined As Left Tolerances ALT+ and ALT. values for Instruments CRD, LT-13C/CRD-LS413C and CR0-LT-130/CRD-LS-"130 are 00.048 mA (0.39 Inches 1120). Magin: Nominal scram setpoint assumed to be 52W-6.

TkSwi alu... AFT+ Norn na ....... to TS TS Alowable Value A Vs 529'-r 529'-7.13" 1.87"

SUPPLEMENTAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGING TECHNICAL SPECIFICATION TABLE 3.3.1.1-1 FUNCTION 7, "SCRAM DISCHARGE VOLUME WATER LEVEL - HIGH" Enclosure Page 14 of 14

3. The licensee proposed to add SRs for TS Table 3.3.1.1-1, Function 7.a. Please explain the rationale for the selection of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> as the required periodicity for performance of the channel check function.

The 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Frequency was chosen as it corresponds to the frequency used for other reactor protection functions and Is consistent with the Standard Technical Specifications and Bases documents. (NUREG-1434) The Frequency Is based upon operating experience that demonstrates channel failure is rare.

4. The LAR stated the proposed level Instrument for TS Table 3.3.1.1-1, Function 7.b would consist of level transmitter and trip unit. Please explain Ifthe proposed instrument for TS Table 3.3.1.1-1, Function 7.b would support performance of the channel check and whether it would require periodic trip unit calibration.

The new trip unit for function 7.b does not include a level indication that would support a channel check surveillance. The existing design with float switches for the Function 7.b instruments does not provide the ability to perform a channel check. Because two channels per instrument volume are available from the Function 7.a instrumentation, sufficient indication is available to the operator to verify that the scram discharge volume capacity remained within the ability to support the RPS scram function.

The TS Table 3.3.1.1-1 Function 7.b transmitter and trip unit does require periodic channel functional testing (92 days) and channel calibration testing (18 months) per the existing surveillance requirements of SR 3.3.1.1.8 and SR 3.3.1.1.10 respectively.