ML022910379

Request for Technical Specification Change Concerning Change of Trip Level Settings, Calibration Frequencies, and Editorial Changes, Revision 1

ML022910379
Person / Time
Site:	Pilgrim
Issue date:	10/10/2002
From:	Bellamy R Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
2.02.084
Download: ML022910379 (94)

Text

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' 'EnteWg Entergy Nuclear Operations, Inc.

Pilgnm Nuclear Power Station 600 Rocky Hill Road Plymouth, MA 02360 Mike Bellamy Site Vice President October 10 , 2002 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555

SUBJECT:

Entergy Nuclear Operations, Inc.

Pilgrim Nuclear Power Station Docket No. 50-293 License No. DPR-35 Request for Technical Specification Change Concerning Change of Trip Level Settings, Calibration Frequencies, and Editorial Changes, Revision 1

REFERENCE:

Entergy Letter No. 2.01.086, Request for Technical Specification Change Concerning Change of Trip Level Settings, Calibration Frequencies, and Editorial Changes, dated December 12, 2001.

LETTER NUMBER: 2.02.084

Dear Sir or Madam:

By the above reference, Pilgrim Nuclear Power Station (Pilgrim) requested NRC review and approval of changes to Pilgrim's Technical Specification Tables 3.2.A, 3.2.B, 4.2.A, and 4.2.B in accordance with 10 CFR 50.90. Subsequent discussions with the NRC staff have identified changes needed in the submittal to support the NRC's review. This letter provides the information discussed with the NRC Staff and replaces the original submittal.

If you have any questions or require additional information, please contact Mr. Bryan Ford, Licensing Manager, at (508) 830-8403.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on the o1th day of October ,2002.

Sincerely, Robert M. Bellamy Attachment 1: Narrative on Proposed Changes and "No Significant Hazards Consideration" (9 - pages)

Attachment 2: Marked-up Technical Specification Pages (9 - pages)

Attachment 3: Calculation Methodology Information (4 - pages)

Attachment 4: Portions of Two of the Associated Calculations (36 - pages and 26 - pages)

Attachment 5: Summary of Regulatory Commitments (1 - page) 202084

Entergy Nuclear Operations, Inc. Letter Number: 2.02.084 Pilgrim Nuclear Power Station Page 2 cc: Mr. Travis Tate, Project Manager Mr. Robert Hallisey Project Directorate 1-3 Radiation Control Program Office of Nuclear Reactor Regulation Commonwealth of Massachusetts Mail Stop: 0-8B-1 Exec Offices of Health & Human Services U. S. Nuclear Regulatory Commission 174 Portland Street 1 White Flint North Boston, MA 02114 11555 Rockville Pike Rockville, MD 20555-0001 U.S. Nuclear Regulatory Commission Mr. Steve McGrail, Director Region I Mass. Emergency Management Agency 475 Allendale Road 400 Worcester Road King of Prussia, PA 19406 P.O. Box 1496 Framingham, MA 01701-0313 Senior Resident Inspector Pilgrim Nuclear Power Station 202084

ATTACHMENT 1 NARRATIVE ON PROPOSED CHANGES AND "NO SIGNIFICANT HAZARDS CONSIDERATION" 202084

ATTACHMENT 1 Description of Proposed Changes

1) Pilgrim Nuclear Power Station (Pilgrim) proposes the following changes to Technical Specification Table 3.2.A, "InstrumentationThat Initiates PrimaryContainment Isolation" (page 3/4.2-7).

a) The current trip level setting for the "Main Steam Line Tunnel Exhaust Duct High Temperature" is < 1700 F. Pilgrim proposes to change the trip level setting to

< 1750 F.

b) The trip level setting of the "Turbine Basement Exhaust Duct High Temperature" is currently < 150 F. Pilgrim proposes to change the trip level setting to

< 1550 F.

c) The name of the instrument "ReactorCleanup System High Flow"is changed to "ReactorWater Cleanup System (RWCU) High Flow."

d) The trip level setting of the "Reactor Water Cleanup System High Temperature" is currently < 150' F. Pilgrim proposes to change the trip level setting to

< 1480 F. The number of required channels is corrected to identify the sensors and their locations consistent with plant design and to show that there is one required channel in each of the two trip systems for each location. The sensors and their locations are as follows:

"RWCU Back Wash Receiver Tank Room High Temperature" "RWCU Heat Exchanger and Pump Rooms High Temperature" "RWCU Line in RHR Valve Room "A" High Temperature" "RWCU Line Near East CRD Modules High Temperature" e) The column identifying the number of available channels is removed from the table.

2) Pilgrim proposes the following changes to Technical Specification Table 3.2.B, "InstrumentationThat Initiates or Controls the Core and Containment Cooling Systems" (pages 3/4.2-12, 3/4.2-16, and 3/4.2-17).

a) Not used.

b) Not used.

c) The trip level settings of the "RCIC Turbine Compartment Wall" is currently

< 1700 F. Pilgrim proposes to change the trip level setting to1< 1680 F.

d) The "Torus Cavity Exhaust Duct" is renamed "RCIC Exhaust Duct Torus Cavity."

The trip level setting of the "RCIC Exhaust Duct Torus Cavity" is currently

< 1500 F. Pilgrim proposes to change the trip level setting to <1480 F.

e) The trip level setting of the "RCIC Valve Station Area Wall" is currently < 2000 F.

Pilgrim proposes to change the trip level setting to 51980 F.

Page 1 of 9

f) The "RCIC" Steam Line Lo-Press" is renamed "RCIC Steam Line Low Pressure".

The current trip level setting for the "RCIC Steam Line Low Pressure" trip level setting is 100 > P > 50 psig. The new trip level setting is proposed to be 77 > P > 63 psig.

g) The current trip level setting of the "HPCI Turbine Steam Line High Flow" is

< 300% of rated flow. Pilgrim proposes to change the trip level setting to

• 296% of rated flow.

h) The "HPCI Turbine Compartment Exhaust Ducts" is renamed "HPCI Turbine Compartment Exhaust Duct." The trip level settings of the "HPCI Turbine Compartment Exhaust Duct" is currently < 1700 F. Pilgrim proposes to change the trip level setting to < 1680 F.

i) The "Torus Cavity Exhaust Duct" for HPCI is renamed "HPCI Exhaust Duct Torus Cavity." The current trip level setting for the "HPCI Exhaust Duct Torus Cavity" high temperature is 1900 F - 2000 F. Pilgrim proposes to change the trip level setting of this trip function to < 1980 F.

j) The current trip level setting for the "HPCI/RHR Valve Station Area Exhaust Duct" high temperature is currently < 1701 F. Pilgrim proposes to change the trip level settings of these trip functions to < 1680 F.

k) Table 3.2.B footnote 6 (page 3/4.2-17) is added regarding the trip level setting for the RCIC steam line low-pressure trip function. The footnote clarifies that the pressure indicated for the trip level setting, 70 +/- 7 psig, does not include the static head pressure which is 17.5 psi.

1) Pilgrim proposes to move the note numbers on page 3/4.2-16 to the "Remarks" column to correct the numbers' misplacement.

3) Pilgrim proposes the following change to Technical Specification Table 4.2.A, "Minimum Test and CalibrationFrequencyfor PCIS"(page 3/4.2-31 and 3/4.2-41).

a) The current calibration frequency of the "Main Steam High Temp" is "Once/3 months". Pilgrim proposes to change the calibration frequency to "Once/24 months".

b) The "Reactor Water Cleanup High Flow" on Table 4.2.A is renamed "Reactor Water Cleanup System (RWCU) High Flow ". The "Reactor Water Cleanup High Temp" on Table 4.2.A is changed to the following to reflect the change made to Table 3.2.A (see 1d):

"RWCU Back Wash Receiver Tank Room High Temperature" "RWCU Heat Exchanger and Pump Rooms High Temperature" "RWCU Line in RHR Valve Room "A" High Temperature" "RWCU Line Near East CRD Modules High Temperature" The current calibration frequency for the "Reactor Water Cleanup High Temperature" is "Once/3 months." Pilgrim proposes to change the calibration frequency to "Once/24 months".

c) Reference to Figure 4.1.1 in Note 1 on "Notes for Tables 4.2.A through 4.2.G (page 3/4.2-41)" is changed to reference the correct figure (Figure 4.2.1).

Page 2 of 9

4) Pilgrim proposes the following changes to Technical Specifications Table 4.2.B, "Minimum Test and Calibration Frequency for CSCS" (pages 3/4.-32 and 3/4.2-33).

a) Not used.

b) The current calibration frequency of the "Steam Line High Temp. (HPCI &

RCIC)" is "Once/3 months". Pilgrim proposes to change the calibration frequency to "Once/24 months".

c) The current calibration frequency of the "Safeguards Area High Temperature" is "Once/3 months". Pilgrim proposes to change the calibration frequency to "Once/24 months".

d) The current calibration frequency for the "RCIC Steam Line Low Pressure" is "Once/3 months". Pilgrim Station proposes to change the calibration frequencies for these instrument channels to "Once/12 months".

5) Following approval of the proposed Technical Specification changes Pilgrim will make the following changes to Technical Specifications Bases in accordance with Technical Specification 5.6.6 (Technical Specifications Bases Control Program).

a) Pilgrim proposes the following changes to Technical Specification Bases 3.2 "Protective Instrumentation" (page B3/4.2-2):

The current setting of 1700 F for the main steam line tunnel detector is low enough to detect leaks on the order of 5 - 10 gpm. Pilgrim proposes to change the trip value to 1750 F for the "main steam line tunnel detector," which is low enough to detect leaks of > 20 gpm.

b) Pilgrim proposes the following changes to Technical Specification Bases 3.2 "Protective Instrumentation" (page B3/4.2-3).

i) The current setting of _ 300% of design flow for HPCI high flow and 2000 F or 1700 F, depending on sensor location, for HPCI high temperature require revision. Pilgrim proposes to change the HPCI high flow trip value to < 296% and HPCI high temperature sensors to

< 1980 F or < 1680 F, depending on sensor location.

ii) The current setting for RCIC area high temperature is 2000 F, 1700 F, or 1500 F, depending on sensor location. Pilgrim proposes to change the RCIC high temperature sensor trip setting to < 1980 F, < 1680 F, or

< 1480 F, depending on sensor location.

iii) The current Bases description of the RWCU system temperature and high flow instrumentation is changed by substituting the phrase"... is arranged with one instrument in each trip system for each area" for the current "... are arranged similar as that for the HPCI."

The revision of the submittal adds additional information that was identified as needed during discussions with the NRC staff and removes the changes previously requested as items 2.a, 2.b, and 4.a.

Page 3 of 9

Reason for Proposed Change Pilgrim station proposes setpoint changes to incorporate the results of setpoint calculations and decreased calibration frequencies associated with existing instruments, without adversely affecting instrument reliability. The changes also enhance the usability of the Technical Specifications by providing a clearer description of the "RWCU High Temperature" trip configuration. Changing the names of certain trips gives clearer definition of the system and is editorial. Moving the note numbers is editorial and is done for consistency. Correcting the mis-referenced figure is administrative.

These changes will have the affect of improving the usability of the Technical Specifications, decreasing plant staff burden, and reduces radiological dose.

Safety Evaluation The functions affected by the proposed changes provide isolation signals to isolate non-limiting leaks from piping outside of containment. These instruments do not have a design basis safety function. Other functions provide the required isolation during design basis accidents.

To support the requested Technical Specification changes Pilgrim analyzed the associated setpoint and calibration frequency changes using the following methodology:

1. Proposed instrument setpoint changes (changes la, 1b, Ild, 2c, 2d, 2e, 2f, 2g, 2h, 2i, 2j) were determined following the guidance of Regulatory Guide 1.105, Revision 2. This is a more recent and rigorous methodology than the original license and design bases for these instruments. As a result, the setpoints for the associated instruments are more conservative than the original setpoints. The trip level settings were determined while analyzing the instruments in accordance with procedures that are subject to a quality assurance program that complies with 10 CFR 50 Appendix B and were found to be acceptable for the reasons described below. The analyses supporting the setpoint changes are based on a 95% probability limit that the trips would occur before the design basis analytical limit is exceeded. Each instrument has a documented "analytical limit" and an "allowable limit." The setpoint calculations fully document the basis for changes to limits, trip level settings, and calibration frequencies.

2. Proposed instrument calibration frequencies (changes 3a, 3b, 4b, 4c, and 4d) were determined following the guidance of Generic Letter 91-04.

3. The new calculated instrument setpoints were evaluated against the original associated analysis assumptions. The original associated analysis assumptions correspond to the nominal setpoints originally identified in the Technical Specifications for these instruments. When possible, the original associated analysis assumptions are maintained and the proposed instrumentation setpoints support these analysis assumptions (changes 1d, 2c, 2d, 2e, 2f, 2g, 2h, 2i, 2j).

4. Applying the more rigorous setpoint methodology to the original analysis assumptions resulted in inadequate margins to support plant operational needs (e.g., potential for spurious actuations). The associated analysis was revised to provide necessary margin (changes la and lb). The values chosen for the new analysis assumptions were chosen to be high enough to support plant operational needs while being low enough to limit the potential impact of the associated leaks.

Page 4 of 9

Additional information concerning the calculation methodology and selected portions of two of the calculations can be found in Attachments 3 and 4.

The following provides a discussion of the specific changes requested.

The trip level setting for the "Main Steam Line Tunnel Exhaust Duct High Temperature" (la) is currently *1700 F. It is proposed that the trip level setting be increased to

• 1750 F to support an analytical limit of 1780 F. The existing Technical Specification limit of *1700 F was based on detection and isolation of a 10 gpm leak from the main steam lines inside the main steam tunnel while meeting 10 CFR 20 dose limits. The purpose of this isolation is to limit the release of radiation during a non-limiting leak from the main steam lines, while other systems and functions are designed to address a limiting main steam line break. This isolation is designed to limit dose effects of the analyzed leak to within 10 CFR 20 dose limits and ensure that for leaks smaller than the analyzed leak, it is not credible that dose limits are challenged prior to manually isolating the leak. The new trip setting allows detection and isolation of a main steam line leak of 20 gpm with an associated new analytical limit of 1780 F. Calculations show that 20 gpm of system leakage would be detected and isolated in a timely manner (approximately 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />). The 20 gpm would need to go undetected for > 1000 days before 10 CFR 20 radiological limits could be exceeded. Such a leak going undetected for such a period is highly unlikely and thus the new setting does not result in consequences that exceed 10 CFR 20 dose limits. There is no impact on environmental qualification of electrical equipment from the potential increase in main steam tunnel temperatures. The new setting ensures adequate margin exists between the trip level setting and the new design basis analytical limit to account for all instrument and process inaccuracies and is high enough to avoid spurious isolation signals. Leaks < 20 gpm from adjacent feedwater and RWCU piping inside the main steam tunnel will still be detected by this instrumentation and result in increased area temperature indication in the control room. If the temperature increase persists, actions to identify and isolate these leaks can still be performed as described in the current licensing basis.

The trip level setting for the "Turbine Basement Exhaust Duct High Temperature" (1b) is currently < 1500 F. It is proposed that the trip level setting be increased to < 1550 F to support an analytical limit of 1580 F. The existing Technical Specification limit of < 1500 F was based on detection and isolation of a 150 gpm leak from the main steam lines in the turbine basement while meeting 10 CFR 20 dose limits. The purpose of this isolation is to limit the release of radiation during a non-limiting leak from the main steam lines, while other systems and functions are designed to address a limiting main steam line break. This isolation is designed to limit dose effects of the analyzed leak to within 10 CFR 20 dose limits and ensure that for leaks smaller than the analyzed leak, it is not credible that dose limits are challenged prior to manually isolating the leak. The new trip setting allows detection and isolation of a main steam line leak of 225 gpm with an associated new analytical limit of 1580 F. Calculations show that the system leakage would still be detected and isolated in a timely manner (approximately 1.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />). The 225 gpm leak would need to continue undetected for > 7 days before 10 CFR 20 radiological limits could be exceeded. Such a leak going undetected for such a period is unlikely and thus the new setting does not result in consequences that exceed 10 CFR 20 dose limits. There is no impact on environmental qualification of electrical equipment from the potential increase in main steam tunnel temperatures. The new setting ensures adequate margin exists between the trip level setting and the new design basis analytical limit to account for all instrument and process inaccuracies and is high enough to avoid spurious isolation signals. Leaks from other piping in the turbine basement will still be detected by this instrumentation. If the temperature increase persists, actions to identify and isolate these leaks can still be performed as described in the current licensing basis. Renaming the "Reactor Cleanup System High Flow" to "Reactor Water Cleanup System (RWCU) High Flow" (1 c, 3b),

removing the column identifying the number of available instruments channels (le), and relocating footnote numbers to the "Remarks" column (21) are administrative changes that do not change any technical requirements and do not impact safety.

Page 5 of 9

The trip level setting of the "Reactor Water Cleanup System High Temperature" (1d) is currently

< 1500 F. It is proposed that the trip level setting be decreased to *1480 F to support an analytical limit of 1500 F for all four sensor locations. High temperature in the vicinity of the reactor water cleanup (RWCU) equipment and piping could indicate a break in a RWCU line.

When high temperature occurs near the RWCU equipment, the RWCU system is isolated. This new trip level setting ensures that the analytical limit of 1500 F will not be exceeded and timely detection and isolation of the RWCU system occurs in the event of a RWCU line break. The new trip level setting of <1 480 F is sufficiently above normal operational upper limits to avoid spurious isolation, yet low enough to provide timely detection of a line break.

The RWCU system high temperature instruments are delineated by instrument location to ensure the appropriate requirements are implemented. The minimum number of instrument channels required to be operable for each location is changed to one in each of 2 trip systems (1d). High temperature in the vicinity of the RWCU system is sensed by four sets of two bimetallic temperature switches. A set of two temperature switches is installed in each of the four areas to be monitored. Each of the switches in an area is capable of initiating isolation of its associated valve(s). This change is consistent with plant design as described in the UFSAR and the presentation of this function in NUREG-1433, "Standard Technical Specifications, BWR 3/4."

The trip level setting for the "RCIC Turbine Compartment Wall" (2c) is currently < 1700 F. The proposed trip level setting is < 1680 F to support an analytical limit of 1700 F. The trip level setting for the "RCIC Exhaust Duct Torus Cavity" (2d) is currently < 1500 F. The proposed trip level setting is < 1480 F to support an analytical limit of 1500 F. The trip level setting for the "RCIC Valve Station Area Wall" (2e) is currently < 2000 F. The proposed trip level setting is

< 1980 F to support an analytical limit of 2000 F. The new trip level settings for the "RCIC Turbine Compartment Wall" (2c), "RCIC Exhaust Duct Torus Cavity" (2d), and "RCIC Valve Station Area Wall" (2e) are lower. The analytical limits for these setpoints are based on detecting RCIC steam line leaks of approximately 10 gpm and initiating isolation of the RCIC steam line. Calculations conclude that satisfactory margin exists between the trip level settings and the design basis analytical limit to account for all instrument and process inaccuracies. The probability of an inadvertent actuation caused by the decrease in operating margin was evaluated and found to be acceptable; the proposed changes do not increase the probability of an inadvertent actuation based on normal historical operating conditions. The new trip level settings are sufficiently below those for the HPCI system so that preferential isolation of the RCIC steam line occurs in the event of a small line break, and permits the HPCI system to remain operable.

Changing the RCIC "Torus Cavity Exhaust Duct" to "RCIC Exhaust Duct Torus Cavity" (2d) clarifies the instruments' location. This is an administrative change and has no impact on safety. The trip level setting for the "RCIC Steam Line Low Pressure" (2f), is currently 100 > P > 50 psig. The proposed trip level setting is 77 > P > 63 psig. The analytical limits (100 > P > 50 psig) for the "RCIC Steam Line Low Pressure" (2f) were selected to ensure the RCIC steam line is isolated at a value that ensures steam and radioactive gases will not escape from the RCIC turbine shaft seals into the reactor building after steam pressure has decreased to such a low value that the turbine can not be operated. The proposed trip level setting of 77 > P > 63 psig, by taking into account total instrument loop uncertainty, ensures steam line isolation occurs before the analytical limit is exceeded.

The "HPCI Turbine Steam Line High Flow" (2g) trip level setting is currently

• 300% of rated flow. The proposed trip level setting for the "HPCI Turbine Steam Line High Flow" instruments of < 296% is more conservative than the current setting because it isolates HPCI at a slightly lower flow, thereby increasing the margin between the trip level setting and the analytical limit of Page 6 of 9

300%. The new trip level setting is closer to the normal operating band but it has been determined that adequate operating margin exists. This change does not adversely impact HPCI performance.

The trip level setting for the "HPCI Turbine Compartment Exhaust Duct" (2h) is currently <

1700 F. The proposed trip level setting is < 1680 F to support an analytical limit of 1700 F. The trip level setting for the "HPCI Exhaust Duct Torus Cavity" (2i) is currently 1900 F - 2000 F. The proposed setting is < 1980 F to support an analytical limit of 2000 F with the removal of the bottom of the band for the isolation. The lower end of the current band is to preserve system availability by establishing a setting high enough to preclude spurious isolations. However, this lower setting point is not assumed in the accident analysis and therefore, is removed from the Technical Specifications.

The trip level setting for the "HPCI/RHR Valve Station Area Exhaust Duct" (2j) is currently

< 1700 F. The proposed trip level setting is 5 1680 F to support an analytical limit of 1700 F.

The new trip level settings for the "HPCI Turbine Compartment Exhaust Duct" (2h), "HPCI Exhaust Duct Torus Cavity" (2i), and "HPCI/RHR Valve Station Area Exhaust Duct" (2j) are lower. The analytical limits for these setpoints are based on detecting HPCI steam line leaks of approximately 10 gpm and initiating isolation of the HPCI steam line. Decreasing the trip level settings will slightly improve the ability of the instrumentation to detect and isolate steam leaks.

Calculations conclude that satisfactory margin exists between the trip level settings and the design basis analytical limit to account for all instrument and process inaccuracies. The probability of an inadvertent actuation caused by the decrease in operating margin was evaluated and found to be acceptable; thus the proposed changes do not increase the probability of an inadvertent actuation based on normal historical operating conditions.

Renaming the "HPCI Turbine Compartment Exhaust Ducts" to "HPCI Turbine Exhaust Duct" (2h) is editorial and does not impact safety.

Renaming the "Torus Cavity Exhaust Duct" to "HPCI Exhaust Duct Cavity"(2i), clarifies the instrument's location. This is an administrative change and has no impact on safety.

The addition of Note 6 (2k) provides information concerning the presence of 17.5 psi static head due to the difference in elevation between the location of the sensing lines attached to the RCIC steam line and the location of the pressure sensing instrument. The note is intended to clarify that the trip level setting is based on the pressure in the steam line (process pressure) rather than instrument sensed pressure. Adding Note 6 is an administrative change and has no impact on safety.

Calibration frequencies are decreased for the "Main Steam High Temp" (3a), and the renamed "Reactor Water Cleanup High Temp" (3b) systems, the "Steamline High Temp (HPCI & RCIC)"

(4b), the "Safeguards Area High Temperature" (4c), and the "RCIC Steam Line Low Pressure" (4d). The effect on total instrument loop uncertainty due to decreasing the calibration frequencies were included in the calculations that established the new Technical Specification trip settings in accordance with methodologies endorsed by R.G. 1.105. The calculations conclude that sufficient margin exists between the trip level settings and the design basis analytical limit to account for all instrument and process inaccuracies, including decreased calibration frequencies. Therefore, the decreased calibration frequencies will have no effect on the ability of the affected instrumentation to perform their safety functions. Note 1 of "Notes for Tables 4.2.A through 4.2.G" is changed to reference Figure 4.2-1 instead of the currently referenced Figure 4.1.1 (3c). This change corrects an oversight that occurred when the reformatting of Technical Specifications granted by Revision 177 renamed the Figure as Figure 4.2-1, but Note 1 was not changed. The content of Figure 4.2-1 is identical to the previous Figure 4.1.1; therefore, this is an administrative change.

Page 7 of 9

Environmental Consideration The proposed amendment changes instrument surveillance intervals and trip level settings.

The proposed change is consistent with accepted engineering practice and methodologies.

The proposed change does not impact plant configuration or design. Each proposed change is to be used within the restricted area as defined in 10 CFR Part 20. Pilgrim has determined the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and there is no significant increase in individual or cumulative occupational radiation exposure resulting from the implementation of this proposed change. Pilgrim has performed a no significant hazards consideration analysis (see below) and found the proposed amendment involves no significant hazards. Accordingly, Pilgrim concludes the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR Part 51.22(c)(9). Therefore, pursuant to 10 CFR Part 51.22(b),

Pilgrim concludes no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

No Significant Hazards Considerations 10 CFR 50.91 requires that at the time a licensee requests an amendment, it must provide to the Commission its analysis using the standards in 10 CFR 50.92, to determine no significant hazards considerations. In accordance with 10 CFR 50.91, Pilgrim has performed an analysis for the proposed changes to Technical Specification Tables 3.2.A and 3.2.B and 4.2.A and 4.2.B. Operation of Pilgrim in accordance with the proposed amendment:

"* Will not involve a significant increase in the probability or consequences of an accident previously evaluated.

The methodology used to determine the proposed trip level settings and surveillance intervals ensure adequate performance of the affected instrumentation. In addition, the affected instruments are not initiators of any accident previously evaluated. Therefore, the proposed trip level settings and surveillance intervals will not involve a significant increase in the probability of an accident previously evaluated.

The proposed changes to trip level settings and surveillance intervals were established using methodologies subject to a 10 CFR Appendix B Quality Assurance program and ensure existing radiological limits are met. Therefore, the proposed trip level settings and surveillance intervals will not involve a significant increase in the consequences of an accident previously evaluated.

Other changes are editorial or administrative in nature and can not significantly increase the probability or consequences of an accident previously evaluated.

"* Will not create the possibility of a new or different kind of accident from any accident previously evaluated.

No new or different types of accidents or malfunctions than those previously analyzed in Pilgrim's UFSAR are introduced by this proposed change because there are no new failure modes introduced. Therefore, the proposed changes will not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 8 of 9

Will not involve a significant reduction in the margin of safety.

The proposed changes to trip level settings and surveillance intervals were established using approved methodologies subject to a 10 CFR, Appendix B, Quality Assurance program and existing radiological limits are met. These changes do not impact Pilgrim's configuration or operation.

Editorial and administrative type changes do not impact the operation or configuration of Pilgrim. For the above reasons the proposed change does not result in a significant reduction in the margin of safety.

Schedule of Change This change will be implemented within 90 days following Pilgrim's receipt of NRC approval.

Page 9 of 9

ATTACHMENT 2 MARKED UP TECHNICAL SPECIFICATION PAGES

PNPS TABLE 3.2.A TNSTRI4ENTATION THAT INITIATES PRIMARY CONTAINMENT ISOLATION Operable Instrument AI) Aýtion_(2*

Instrument Trip Level Setting Reactor Low Water Level >11.6" indicated level (3) A and D Reactor High Pressure D

<76 psig A o ° Reactor Low-Low Water Level at or above - 46.4 in.

indicated level (4)

B, Z -- 2 Reactor High.Water Level <55.4" Indicated level (5) 2(7) High Drywell Pressure A

<2.22 psig 2 . Low Pressure Main Steam Line >_10 paig (R) 2(6) High Flow Main Steam Line <136% of rated steam flow B

2) Main Steam Line Tunniel _<o F

• B SExhauist Duct High Temperature 2 Ttrbine Basement Exhaust _* r /,-

-Duct Ifigh Temperature I Reacgg enup System GQ7wcL)C)

High Flow <300% of rated 2 4*flow C c ..

C C JJ4 F

I 45/0 F

• flevN-aeo.4 - -l4*-l/ 3/4. 2-7 Amendment No. 34r-421-R6T-]47;-l50;-SI-15vl4T-162,~ ~-

C-L)I-jAVA) AHRV ',b2")iqVI Z 1 7v-(4PI/tp t//iZJ ei-/

LJ 2,,Q* ,) ) VAI-'_ V*o-oq"/"tH rMP*&F ...

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PNPS MTnsRIrnENTA'rION. THA lTTTA'PgS OR CONTROLS Trug CORE AND) CONTAINMMET COOLTUC0 SYSTEMS 1i -11f (IIti ii~iof Operabl e flnstrtlment 63it"pAeŽjl Per -rrI iyfe 1 1171p -tnctionj Trip Level Settin~g Remarks 2 Coindensate Storage Tank

>18" above tank zero *Providles, interlock to IIPCI PtIMP Low Level. suicti on valves..-

Slippression Chamber <1'11" below tortis zero 111gh Level I RCIC Ttirbine Steam Line

<300% of rated highZ rlow 2 RGTC Turb ine Compartment (2)

(2) 2 o' *s AlT (2)'

ý5:)>p>a ig I

IWCGI TuirbIne ~teatm Line lMigl Flow IIPCT Tiir1vIn crnrrnni-i-rrinnt

-a~kV0 ExhatistDi

- ~~2 "FL -e c rt--Gvty-BE-aoit 1OZf0I) P

• 2 CA ulHlPCI/RIIR Valve Station Area Exhaust Duct L V18 I&

Ameunudiiem- t in. I')-1411 3 /4. 2-1 6

NOTES FOR TABLE 3`6 2.B

1. *nenever any *CSCS subsystem i required by Section 3.5 to be operable, there shall be two (Note 5) operable trip systems. if the first column cannot be met for one of the trip systems, th.at system shall be repaired or the reactor shall be placed in the Cold Shutdow-r Condition vithin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after this trio system is made or foujnd to be ifoper-ie

2. Close isolation valves in RCIC S'IbsYste Close isolation valves in H2CI subsystem.

1. Instrument set point corresponds to 79.96 inches above top of active fuel.

5. RCIC has only one tri? system for these sensors.

6. D0 -5 10 - /tA)C2 f ,q oF

~ 5~ ?SL

/

PNPS TABLE 4.2.A l1TNTfIIff1 TEST Ati)h GALTIIRATION FRIEQUJENCY FOR rPUS Totrjien:Chajnnel (51 Instroment Fuinctional Tent Calthrnt-lon Ere -Lengy InstrumentClei I) React~or 111gh Pressure (1 2) fnve/3 montli Nn fReActor Low-Laty Water Level. Once/3 months (7) (7) once/day

31) Reacftor f11gb Ilater Level, Onca/3 months (7) (7) Non On'ce Is) fa in Si(.Pai Hi1gh Temp. _jVSMq (1) Once4!s months Nn

ý) Hain Steam Hi1gh Flow \.(tp'i0CjtjOnce/3 months (7) 6)

(7) ~Once/day flai Steam Low Pre9ssure Once/3 monnt~hs(7 (7) Once/day I) Hfluact~or water Cl ennuit liigli Flow (1) Onne/ 3 montlis Oc/

11) Rit~J U~e m44~-eP() Once/emnntis 2~(None I)Ham Steami Line Isolation \lvs.

Once/Operating Cycle lakIn SI:eamn U11ne'hrahi Vvs.

Re~act~or llantr Sample V',s.

2) MIIR - Isolation Vv. Control Once/Operati-0g Cycl e Shutitdown Cool ing Vvs.

1105(1 Spray Dischanrge t~o Radi~aste R)Ieactonr tVater Cl eantip Tsola 1:1on Oncte/Opernting Cycle I,) Drywall Isolation Vva.

Once/Operating Cycle

'I,fP Wi thdrat-al Al~i~nsliharerht Control 'Jvs.

Rmimp Drainm Valvesj

') SVIandby GaS Treatment System Once/operating Cycle lefmct.or hultd~ding Tsola ntlf t&)"RIWCU lBack Wash Receiver Tank ROOM High Tempermaturn 1 h~evj~rj177~~. 9)"RWCU I-leal Exchianger and'Pimp Roomns Hiugh Temperature" 99-10--1l-.-llh.

Am'mnuhmmem(: /)"nWCU Lino Ini RI-R Valve ROOM "A" Hiugh Temnperature" 3/to.2-31 "h/FWCULi-ne Near East CR0 Modules H-1igh Temperature"

PNPS TABLE 4.2.B MINIMU TEST AND CALIBRATION F jREQUENY FOR CSCS MINIMUM TEST AND CALIBRATION F Instrument Check Tnstrument Channel Instr ument Functional Test Ca libration Frequency Once/day (1) (7) (7)

1) Reactor Water Level Once/day (1) (7) (7)

2) Drywell Pressure Once/day (1) (7) (7)

3) Reactor Pressure Once/Operating Cycle None NA

4) Auto Sequencing Timers

5) ADS - LPCI or CS Pump Disch. Once/3 months None (1)

Pressure Interlock

6) Start-up Transf. (4160V) Once/Operating Cycle None Monthly

a. Loss of Voltage Relays Once/Operating Cycle None

b. Degraded Voltage Relays Monthly NA Once/day Once/Operating Cycle

7) Trip System Bus Power Monitors Once/3 months Once/day (1)

8) Recirculation System d/p Once/l8 months Once/day NA

9) Core Spray Sparger d/p (1) Once/3 months ,> None

10) Steam Line High Flow (IIPCI & RCIC)

(1) None

11) Steam Line High Temp. (IIPCI & RCIC)

(1) None

12) Safeguards Area High Temp.

3/4.2-32 Amendment No. 42;-61;-99;-148;1-51

PNPS TABLE 4.2.11 (rant:)

HMTIiMrnn TEST AND CALI11RA'TT0HFREQUJENCY FOR GSCS Tn~st-ritient Firnationnl Teat CallbratI on Frequency Instruiment Check

13) ~~ani St Line Low Presstire Onrelq ionths Nonte

14) IIPC'I imetion Tank Levels Once/3 months None I ') ""Eiir9PicY 41160V Blisas AMi & A6 L~os... of Vol tagoe Relays Monthly Once/Operating Cycle Nonte I eni umvt tini

. 112-i- 61 9 -1 9 -5 3 //1 .2-33

NOTES FOR TABLES 4.2.A THROUGH 4.2.G

1. Initially once per month until exposure hours M as defined on Figur 4.1.1) is 2.0 x 105; thereafter, according to Figure with an interval not less than one month nor more than three months. 421

2. Functional tests, calibrations and instrument checks are not required when these instruments are not required to be operable or are tripped. Functional tests shall be performed before each startup with a required frequency not to exceed once per week. Calibrations of IRMs and SRMs shall be performed during each startup or during controlled shutdowns with a required frequency not to exceed once per week. Instrument checks shall be performed at least once per day during those periods when the instruments are required to be operable.

3. This instrumentation is excepted from the functional test definition. The functional test will consist of injecting a simulated electrical signal intb the measurement channel.

4. Simulated automatic actuation shall be performed once each operating cycle.

Where possible, all logic system functional tests will be performed using the test jacks.

5. Reactor low water level and high drywell pressure are not included on Table 4.2.A since they are tested on Tables 4.1.1 and 4.1.2.

6. The logic system functional tests shall include a calibration of time delay relays and timers necessary for proper functioning of the trip systems.

7. Calibration of analog trip units will be performed concurrent with functional testing. The functional test will consist of injecting a simulated electrical signal into the measurement channel. Calibration of associated analog transmitters will be performed each refueling outage.

Amendment No. 427-997-110-147;-154 3/4.2-41

BA.SES:

3.2 R.OTECTTv7E INS7iM{CNTATION (Cont)

UD to the com6lete circumferential break of a 28-inch rec;rnulation line and With the trip setting given above, CSCS initiation and primary system isolation are initiated in time to meet the above criteria.

The high drywell p'essure instrumentation is a diverse signal to the water level instrumentation and in addition to initiating CSCS, it causes isolation of Group 2 isolation valves. For the breaks discussed above, this instrumentation will initiate CSCS operation at about the same time as the low low water level instrumentation; thus the results given above are applicable here also. The low low water level instrumentation initiates protection for the full spectra_- of loss-of-coolant accidents and causes isolation of Group 1 isolation valves.

Venturis are provided in the man steam lines as a means of measuring steam flow and also limiting the loss of mass inventorY from the vessel during a steam line break accident. The primary function of the instrumentation detect a break in the main steam line. is to For the worst case accident, main steam line break outside the drywell, steam flow trip setting in conjunction With the flow Ilimiters and main steemtiine steam line valve closure, limits inlconcunsuion inventory loss such that fuel is not uncovered, the mass fuel temperatures remain approximately 100l'F and release of radioactivity to the environs is well below !0CFý!00 guidelines. `_O /I "L ov Temperature monitoring instrumeration is provide in t e main steam line tUnn and the turbine baseme~ to deect leaks n these dere areas. Trips are provided on this instrumenta!on and when exceeded, cause closure valves. of isolation The setting of.F for the maindteam line tunnel detector is low enough to detect leaks on the order of ý1 gPm; thus, it covering the entire snectr m of breaks. For large breaks, theis high capable of steam flow Coverin en intue tat ion sta fo instrumentation is a backup to the temperature instrumentation.

Pressure instrumentation is provided to close the main steam isolation valves in the RUN mode before the reactor pressure drops below function is primarily intended to prevent 785 psig. This excessive vessel depressuirzation in the event of a malfunction of the nuclear system pressure regulator. This function also provides automatic protection of the low-pressure core-ther-mal power safety limit (25% of rated core thermal power for reactor pressure <

psig). In the Refuel or Startup Mode, the inventory 785 loss associated with such a malfunction would be limited by closure of the Main Steam Isolation Valves due to either high or low reactor water level; no fuel would be uncovered.

This function is not required to satisfy any safety design bases.

32L.-

3.

BASES:

3.2 PROTECTIVE INSTRUMENTATIOQN (Cont)

The lPi high flow and temperature instrumentaticn provided to detect a break in the HPCI steam piping. Tripping of this -nstrmentazion results in actuation of E2CI isolation valves. Tripping logic for the high flow is a 1 out of 2 logic, and all sensors are required to be operable.

Temperature is monitored at three (3) locations with four (4) temperature sensors at each location. Two (2) sensors at each location are powered by "A" direct current control bus and two (2) by "B5 direct current controi bus.

Each pair of sensors, e.g., "A" or "B", at each location are physically separated and the tripping of either "A" or "B" bus sensor will actuate jjCi isolation valves.

The trip settings of< .  % of desifgn flow for hien flow and or depending on sensor location, for high tEm=erature are such that core u,-covery is prevented and fission product release iswithin limits.

Thea.CIC high flow and temperature instrumentation thWaflgeda that for the HFCi. The trip setting of--5 300% for high flow an_4F, F ss-a F( dependingaon sensor iocaaEoD, Zor temp~erature are Oased on the

_ s*ame Recriteria c-hc Wate as __ the *HPCI. y ,,g-. _

-: heReato WaerCleanup System sig flow and temperature ins trumentation~

Tpdh he trip settrings are such that core arncoerym- i: ,atcar eis prevented and fission product release is within limits.

'* *" *'* \' __re

,-'ui_

ONr Te *instr-umelitat-on

' ait~

t--- resner vesh n~ a e oSCS whichc initiates C C action c i nis s arrang-jed a ran e in n a duae uu

- sYstem. As for other vital instrumentation arra-nged in this fashion, the S - )P Specification presees the effectiveness of the system even durir.g periods Wr-en maintenance or testing is being performed. An exception to this is when

!ogicfunctional testing is being performed.

The control rod block functions are provided to prevent excessive control rod withdrawal . The trio loic for this function is 1 out of n: e.g., any trip on one of= six P*'s, two D.'s, eight IUK'-s, or four SR.'s will result in a rod block.

The minimum instrument channel requirements assure sufficient instrumentation to assure' the single failure criteria is met. The minimum instrument channel requirements for the BM may be reduced by one for not longer than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without significantly increasing the risk of an inadvertent control rod withdrawal..

Reactor power may be varied by moving control rods or by varying the recirculation flow rate. The APRM system provides a control rod block to prevent rod withdrawal beyond a given poin thereby possibly avoidi a P Scram.-The rod block se-point is autamazically reduced with recirculation flow to form the upper boundary of the*FNFS pcwa:/flcw mam. The flow biased A-2FR. rod block is not necessary to prohi.bit fuel damage and is not included in tne analysis of anticioated transienas.

Amend.men No /

ATTACHMENT 3 CALCULATION METHODOLOGY INFORMATION

ATTACHMENT 3 A. Application of the Guidance of Generic Letter 91-04 Generic Letter 91-04 provided a methodology for determining and evaluating instrument surveillance intervals. As discussed in the Generic Letter a proposed surveillance interval was acceptable if it met certain requirements.

A setpoint calculation using the same methodology that was used for the proposed changes was submitted to the NRC by letter, dated June 7, 1993. The submittal was made to facilitate NRC review and approval of a 24-month fuel cycle for Pilgrim in accordance with Generic Letter 91-04. The NRC found Pilgrim's method and results acceptable in the NRC's safety evaluation report granting License Amendment 151, dated April 6, 1994, (TAC Nos. M83787, M87191, and M88390). In addition, as requested by the NRC staff, selected portions on two of the calculations associated with this change are included in Attachment 4.

The following is a discussion of the application of the requirements of Generic Letter 91-04 for the proposed calibration frequencies.

1. Confirm that instrument drift as determined by as-found and as-left calibration data from surveillance and maintenance records has not, except on rare occasions, exceeded acceptable limits for a calibration interval.

Discussion As-found and as-left data for the instruments being evaluated were obtained and the instrument drift for the proposed duration confirmed that the drift supported the requested interval.

As-found and as-left calibration data was collected from calibration records and statistically analyzed to determine drift. Pilgrim looked at the proposed calibration intervals plus a 25% margin (e.g.15 months for yearly calibration intervals and 30 months for 2 year calibration intervals). Pilgrim then evaluated the intervals associated with the device for which no adjustments were required during the entire interval, i.e., the device had not drifted for the entire interval and required no action on the part of the technician.

From the raw data, the shift between calibrations and the interval between calibrations was determined. Mean, standard deviation, and outliers were determined for each set of data. Then, based on the sample size, the appropriate multiplier was determined and utilized to convert the standard deviation value corresponding to 95% probability at a 95% confidence level.

Statistical analysis was performed on the data to determine if the data set is normal or bounded by the normal curve. WAPD-TM-1 292 (DOE Research and Development Report) "Statistics for Nuclear Engineers and Scientist, Part 1:

Basic Statistical Inference" was used to obtain the multiplier to obtain a 95%

probability at a 95% confidence level.

2. Confirm that the values of drift for each instrument type (make, model, and range) and application have been determined with a high probability and a high degree of confidence. Provide a summary of the methodology and assumptions used to determine the rate of instrument drift with time based upon historical plant calibration data.

Page 1 of 4

Discussion The as-found and as-left data were analyzed to ensure that the drift values corresponded to a 95% probability at a 95% confidence level. A detailed discussion of the methodology used is supplied in a Pilgrim letter to the NRC dated June 7,1993. In addition, as requested by the NRC staff, selected portions on two of the calculations associated with this change are included in Attachment 4.

3. Confirm that the magnitude of instrument drift has been determined with a high probability and a high degree of confidence for a bounding calibration interval of 30 months for each instrument type (make, model number, and range) and application that performs a safety function. Provide a list of the channels by TS section that identifies these instrument applications.

Discussion Attachment 1 in the Description of Proposed Changes section provides a list of the instrument applications affected.

The calculations used existing analytical limits as bounding values for the setpoint analyses. As-found/as-left historical instrument calibration data were statistically analyzed to calculate 95/95% probability and confidence level values.

These values were then used in the setpoint calculations. The value determined in this process was considered to include the effects of measurement and test equipment (M&TE), reference or basic component accuracy and other parameters as well as component drift. The rack and sensor setting tolerances were retained. This approach is consistent with the proposed Instrument Society of America (ISA) Recommended Practice (ISA-$67.04-1982, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants",

including consideration of the 6 items in Section 4.2.1 of the Standard).

The 95% probability at a 95% confidence level values were statistically analyzed to determine if the data sets were normal or bounded by a normal curve.

All uncertainties identified in the calculations were individually evaluated to determine whether they were random or biased. In the context of instrument uncertainty, it is accepted within the industry that random uncertainties are those uncertainties that a manufacturer specifies as having a + or - magnitude.

Random uncertainties were combined using the root sum of the squares (RSS) technique. Biases were expressed with either a + or a - sign and were added together separately according to sign. Individual component error terms which contained both a bias and a random value were split up so that the random part was combined with other component error terms, and the biases were added to other component bias terms of the same sign. Both random and bias terms were added together to determine Total Loop Uncertainty (TLU). A random or bias term can also be further classified as being dependent or independent. Two error terms are classified as dependent if they possess a significant correlation, for whatever cause, known or unknown. Instrument proximity or physical connections alone do not cause dependency because the sign of the error term is determined solely by that instrument's measured response to the stimulus (temperature, pressure, etc.). Dependent errors were summed algebraically to form independent errors.

Page 2 of 4

The interval used for the calculations was the proposed calibration interval plus 25% (i.e., 15 months or 30 months).

4. Confirm that a comparison of the projected instrument drift errors has been made with the values of drift used in the setpoint analysis. If this results in revised setpoints to accommodate larger drift errors, provide proposed TS changes to update trip setpoints. If the drift errors result in a revised safety analysis to support existing setpoints, provide a summary of the updated analysis conclusions to confirm that safety limits and safety analysis assumptions are not exceeded.

Discussion A comparison of projected drift errors was made with the drift values used in the setpoint analysis. The calculations determined setpoints with sufficient margin to ensure at least a 95% probability of achieving the design basis setpoint analytical limit. The cases where the safety analysis assumptions needed to be revised are discussed in Attachment 1 in the Safety Evaluation section.

5. Confirm that the projected instrument errors caused by drift are acceptable for control of plant parameters to effect a safe shutdown with the associated instrumentation.

Discussion Instrument errors caused by drift were evaluated as part of the process and found to be acceptable as part of the calculation process.

6. Confirm that all conditions and assumptions of the setpoint and safety analyses have been checked and are appropriately reflected in the acceptance criteria of plant surveillance procedures for channel checks, channel functional tests, and channel calibrations.

Discussion The assumptions of the calculations were validated as required by the applicable setpoint calculation procedures.

7. Provide a summary description of the program for monitoring and assessing the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.

Discussion Pilgrim commits to a program that consists of monitoring, feedback, and assessment to verify instrument performance, including drift, is consistent with the parameters specified in the calculations for those instruments whose surveillance interval is being increased. Data collected from surveillance procedures will be evaluated to confirm the validity of assumptions supporting the setpoint calculations and the calculations' conclusions. The proposed (revised) setpoints will be evaluated during the first calibration interval(s) to ensure the new setpoints have no adverse impact on plant operations. The extended surveillance intervals will be monitored for three calibration interval(s) to ensure the assumptions in the calculations continue to be valid. If surveillance test results indicate that instrument performance does not meet surveillance Page 3 of 4

procedure requirements, corrective actions will be taken in accordance with existing station prbcedures. Changes made as a result of the corrective action will be reflected in the setpoint calculations. Subsequent monitoring will rely on existing plant procedures and controls to ensure continued safe operation of Pilgrim.

B. Calculation Methodology The methodologies used are in accordance with Regulatory Guide 1.105, Revision 2, ISA-S67.04-1982, and Generic Letter 91-04. A sample setpoint calculation using the same methodology that was used for the proposed changes was submitted to the NRC by letter dated June 7, 1993. The submittal was made to facilitate NRC approval of a 24-month fuel cycle for Pilgrim in accordance with Generic Letter 91-04. The NRC found Pilgrim's method and results acceptable in the NRC's safety evaluation report granting License Amendment 151, dated April 6, 1994, (TAC Nos. M83787, M87191, and M88390). In addition, as requested by the NRC staff, selected portions on two of the calculations associated with this change are included in Attachment 4.

In the calculations, as-found and as-left calibration data was collected from calibration records and statistically analyzed to determine drift. From the raw data, the shift between calibrations and the interval between calibrations was determined. Mean, standard deviation, and outliers were determined for each set of data. Then, based on the sample size, the appropriate multiplier was determined and utilized to convert the standard deviation value corresponding to 95% probability at a 95% confidence level.

Statistical analysis was performed on the data to determine if the data set is normal or bounded by the normal curve. WAPD-TM-1292 (DOE Research and Development Report) "Statistics for Nuclear Engineers and Scientist, Part 1: Basic Statistical Inference" was used to obtain the multiplier to obtain a 95/95 confidence level.

All calculations were prepared using this same methodology.

Page 4 of 4

ATTACHMENT 4 PORTIONS OF TWO OF THE ASSOCIATED CALCULATIONS

Pilgrim Calculation No. 1-NI-115 Pages 2 thru 21 and 24 thru 38

CALCULATION SHEET Rev 0 Date 11/21/95 4 Boston Edison Sheet 2 of 4-L FORM 4. CALCULATION SHEET CALCULATION NUMBER I-NI- 115 CALCULATION WORK OR REMARKS:

Statement of Problem This calculation will provide the uncertainity analysis for the development of the RWCU system space high temperature group 6 isolation setpoint based on a twenty-four month calibration frequency. It will determine a plant setpoint and allowable value which will ensure at least 95%

probability of achieving the isolation on or before reaching the setpoint analytical limit.

Parameters determined by this calculation are:

"* Trip Setpoint

"* Technical Specification Allowable Value

"* Setpoint Analytical Limit

"* Field Reset Value

"* Calibration No Adjust Limits

"* Instrument Surveillance Interval

"* Measurement and Test Equipment Equipment Accuracy Method of Solution This calculation is performed based on the methodology described in BECO NEDWI No. 394 and uses ABB Impell Project Instruction No. 25-226-PI-001 for the analysis of the as-found as-left instrument calibration data. The calculation is in accordance with the U.S. NRC Regulatory Guide No. 1.105, Rev. 2 and Instrument Society of America Standard ISA-S67.04-1 982.

Input Data and Assumptions The RWCU system space high area temperature instruments consists of four sets of two bimetallic temperature switches. Each set is a one out of two trip system capable of initiating isolation. The temperature switch sets are located in the following areas:

CALCULATION SHEET Rev 0 Date 11/21/95 Boston Edison Sheet 3 of l..

FORM 4. CALCULATION SHEET CALCULATION NUMBER, I -N1- 115

"* HV duct from the Backwash Receiver Tank Room

"* HV duct from the RWCU Heat Exchanger Room

"* RHR Piping Room

"* HV duct from the RHR "A"Valve Room Input data and references are listed on Form 1 of this calculation. Any assumptions are identified under the notes section.

Summary of Results and Recommendations This calculation determined a new instrument setpoint, technical specification allowable value and setpoint calibration frequency. These values were determined based on industry and plant specific calibration data and NEDWI No. 394 methodology. The new setpoint is more conservative than the present. The new values determined by this calculation require a plant design change for implementation at PNPS.

Note, the new setpoint allowable value and calibration frequency require a Technical Specification change.

The results of this calculation are listed below:

Trip Setpoint: 138 deg F Technical Specification Allowable Value: _148 deg F Setpoint Analytical Limit: *<150 deg F Setpoint Reset Value: 133 deg F (Typically)

No Adjust Limits: +/- 3 deg F Surveillance Interval: Once per 24 months plus 25%

M&TE Accuracy: +/- 5 deg F

CALCULATION SHEET Rev __ Date AJL /*L- 4 Boston Edison Sheet -S,.of 47-FORM 4. CALCULATION SHEET CALCULATION NUMBER T - RI -11'5 CALCULATION WORK OR REMARKS:

R:wCU c6STEY- E)PAOC_ TEMP. ITSDLATION 1~-s 17-91 L4

.,, . I owe4

- t I Dws. M ?A-7~

Dw. tN 9---

I0% K oxe-wc~'

CALCULATION SHEET Rev 0 Date 11/17/95 Boston Edison Sheet 4 of 17 FORM 4. CALCULATION SHEET CALCULATION NUMBER I-NI-115 CALCULATION WORK OR REMARKS:

Notes:

1. The RWCU system space high temperature switches are part of the Primary Containment and Reactor Vessel Isolation Control System (PCIS). The objective of the PCIS is to provide timely protection against the onset and consequences of accidents (leaks and breaks) involving the gross release of radioactive materials from the fuel and nuclear system process barrier by initiating automatic isolation of appropriate lines which penetrate the primary containment whenever monitored variables exceed preselected operational limits (FSAR Section 7.3.1). This protects the fuel by limiting losses of reactor coolant and stopping the release of radioactive materials. See FSAR Section 7.3.3 for the PCIS Safety Design Bases.

The safety function of the RWCU system space high temperature instrumentation is to detect high temperature in the vicinity of the RWCU system equipment in excess of its preselected setpoint.

High temperature could indicate a leak or a break in a RWCU system pipe line. -The high temperature isolation setting is selected far enough above anticipated normal RWCU system operational levels to avoid spurious isolations, but low enough to provide timely detection of a RWCU line break (FSAR section 7.3.4.7).

2. The Circuit Leakage Allowance is applicable to low energy analog signals only. The RWCU system space high temperature switches are mechanical on/off 120 vac devices. The performance of 120 vac on/off signals are not affected by circuit leakage. Therefore, this error is not applicable.

3. Process Measurement Accuracy for a temperature switch is typically the response time of the sensor. The actual sensor temperature always lags a change in the process temperature which translates to an error in the process setpoint if time is essential in the operation of the switch.

Because dynamic effects such as time response are addressed in the plant accident analysis the error associated with sensor response time will not be included in the setpoint calculation.

Also, it is assumed the temperature switches are located at the highest temperature of the room.

Therefore, there will not be an error due to sensor location.

CALCULATION SHEET Rev 0 Date 11/17/95 Boston Edison Sheet 5 of .47 FORM 4. CALCULATION SHEET CALCULATION NUMBER I-Nl-115

4. The sensor drift was statistically analyzed for a three month interval in attachment no. 2 in accordance with ABB Impell Project Instruction 25-226-PI-001. The analysis used empirical data from 5/18/93 through 5/21/95 obtained from the PNPS as-found as-left instrument calibration records. Reference PNPS Procedure 8.M.2-1.2.2. The drift value determined is .62 +/- 6.27. Also, industry data for the EGS Patel temperature switch was statistically analyzed in attachment no. 3 for a 30 month interval. The drift value determined is 2.22 +/- 7.05. The value obtained from the statistical analysis has a probability and confidence of 95/95%.

The Pilgrim specific drift data for a 3 month interval when compared to industry drift data for a 30 month interval is not significantly different. It is therefore concluded the drift of these switches are not a function of time. Based on this data the calibration interval for these switches is to be extended to 24 months. This calculation will assume drift of TS 1291-14CD,E,F,G,H,J&K for a 24 month calibration frequency is the value determined from the industry data above.

The as-found as-left calibration data used to determine the drift also includes the error associated with sensor accuracy and measurement and test equipment (M&TE) accuracy. Therefore, the value for the sensor normal accuracy and calibration accuracy is considered to be included in the drift error and will be identified as N/A in this calculation. It is assumed that the accuracy of the M&TE used for calibration is less than or equal to the accuracy of the instrument being calibrated.

Reference PNPS Procedure 1.3.36.

5. The Environmental Allowance includes errors due to temperature, radiation, humidity, pressure, and seismic effects. This error is identified in Patel Report PEI-TR-831200-1 in section X-2.3.2.1.

The accuracy of the switches tested remained within the +/- 6 deg F acceptance criteria throughout the entire test program without any adjustments. The environmental conditions for TS-1 291-14C, TS-1291-14D, TS-1291-14E, TS-1291-14F, TS-1291-14G, TS-1291-14H, TS-1291-14J and TS 1291-14K applications are identified in Boston Edison Co. Environmental Qualification Evaluation Sheets. The conditions of the Patel test program envelope both the normal and accident environment at PNPS. Therefore, the Environmental Allowance of TS-1291-14C, TS-1291-14D, TS-1291-14E, TS-1291-14F, TS-1291-14G, TS-1291-14H, TS-1291-14J and TS-1291-14K is considered to include all the above effects. --

CALCULATION SHEET Rev 0 Date 11/17/95 4 Boston Edison Sheet (o of -47 FORM 4. CALCULATION SHEET CALCULATION NUMBER I-Nl-115

6. From the as-found as-left calibration data (reference PNPS Procedure 8.M.2-1.2.2) the reset differential for the EGS Patel temperature switch, model no. 01-170020-090 is typically less than 5 deg F. Therefore the reset value is typically greater than 133 deg F.

CALCULATION SHEET V Boston Edison REV 0 DATE_11/21/95 SHEET "1 OF-"/

Calculation Number__l-N1-1__15 Instrument NumberTS-1291-14C thru k FORM 1 INSTRUMENT DATA Page 1of 9 TITLE DESCRIPTION/VALUE I REFERENCE REMARKS TS-1291-14C,D,E,F,G,HJ & K DWG. M 247 INSTRUMENT NUMBER Reactor Water Cleanup FSAR Section 7.3.4.7 SERVICE DESCRIPTION System Space High Temperature Isolation Q PNPS Q-List QUALITY CATEGORY Page 3-45-9 YES EQ Master List ENVIRONMENTAL EQ Area 1.11 C, 1.11, 1.9A, System 45 QUALIFICATION & 1.9 GENERAL See Note 1 FSAR Section 7.3.3 and INFORMATION SAFETY FUNCTION 7.3.4.7 (IFAPPLICABLE)

TECHNICAL <150 deg F Technical Specification SPECIFICATION Table 3.2.A (IF APPLICABLE)

EGS Patel Equipment Qualification MANUFACTURER Data Files TS-1291-14C,D SE,F,G,H,J & K 01-170020-090 Equipment Qualification MODEL NUMBER Data Files TS-1291-14C,D

,E,F,GH,J &,K

CALCULATION SHEET V Boston Edison REV. 0 DATE__ 1/21/95 SHEET 8 OF 4-7 Calculation Numberl-N1-115 Instrument NumberTS-1291-14C thru k FORM I INSTRUMENT DATA Page 2 of 9 TITLE DESCRIPTION/VALUE J REFERENCE 3 REMARKS

<150 deg F S&SA Memo 95-47 ANALYTICAL LIMIT (AL)

• 148 deg F Sheet 3, Form 3 this calc ALLOWABLE VALUE (AV)

SETPOINT TRIP 138 deg F Sheet 3, Form 3 this calc RESET 133 deg F Sheet 4, Form 3 this calc. Switch has a fixed reset 105 deg F Specification E536 NORMAL OPERATION UPPER LIMIT (NUL)

INSTRUMENT N/A N/A Not a decreasing setpoint SETPOINT DATA NORMAL OPERATION LOWER LIMIT (NLL)

N/A The switch is calibrated at PROCESS CALIBRATED the setpoint only RANGE 33 deg F Sheet 4, Form 3 this calc.

OPERATING MARGIN (OM)*

• NOTE: ADEQUATE OPERATING MARGIN IS REQUIRED BETWEEN THE SETPOINT AND THE NORMAL OPERATION UPPER OR LOWER LIMIT, AS APPLICABLE, TO AVOID INADVERTENT TRIPS DUE TO PROCESS NOISE, TRANSIENTS AND MEASUREMENT UNCERTAINTIES.

CALCULATION SHEET 4 Boston Edison REV 0 DATE_1 1/21/95 SHEET 9 OF 4-7 Calculation Number__l-N1-115 Instrument NumberTS-1291-14C thru k FORM 1 INSTRUMENT DATA Page 3 of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS

-100 deg F to 600 deg F Patel/EGS Product Data Sheet (Attachment 1)

ADJUSTABLE RANGE Ambient Air FSAR Section 7.3.4.7 INPUT SIGNAL FROM N/A N/A The switch Is calibrated at INPUT SIGNAL the setpolnt only CALIBRATED RANGE Group 6 Isolation FSAR Table-5.2-4 INSTRUMENT OUTPUT SIGNAL TO SETPOINT DATA (CONT)

N/A N/A The switch is calibrated at OUTPUT SIGNAL the setpolnt only CALIBRATED RANGE Once per 24 months plus This Calculation See Note 4 SETPOINT 25%

CALIBRATION FREQUENCY I - I- -1

CALCULATION SHEET 0 Boston Edison REV 0 DATE_11/21/95 SHEET 10 OF 4" Calculation Number__lI-NI - _115 Instrument NumberTS-1291-14C thru k FORM 1 INSTRUMENT DATA Page 4of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS I Patel Report See Note 5 TEMPERATURE PEI-TR-831200-1 EFFECT (Te) (EQDF ReF 340)

Patel Report See Note 5 ENVIRONMENT RADIATION EFFECT PEI-TR-831200-1 ALLOWANCE (EA) (Re) (EQDF REF 340)

FORM 3 STEP 1 Patel Report See Note 5 STEAM/CHEMICAL PEI-TR-831200-1 SPRAY EFFECT (S/Ce) (EQDF REF 340)

PRESSURIZATION Patel Report See Note 5 (EXTERNAL) EFFECT PEI-TR-831200-1 (Pe) (EQDF REF 340)

Patel Report See Note 5 SEISMIC PEI-TR-831200-1 EFFECT (Se) (EQDF REF 340)

N/A N/A See Note 2 CABLE LEAKAGE (CI)

CIRCUIT LEAKAGE N/A N/A See Note 2 ALLOWANCE (LA) TERMINAL BLOCK FORM 3 STEP 2 LEAKAGE (TI)

PENETRATION N/A N/A See Note 2 LEAKAGE (PI)

CALCULATION SHEET

- Boston Edison REV 0 DATE_11/21/95 SHEET I I OF -'7 Calculation Number__l-NI -_115 Instrument NumberTS-1291-14C thru k FORM 1 INSTRUMENT DATA Page 5 of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS N/A N/A See Note 2 SPLICE LEAKAGE (SI)

CIRCUIT LEAKAGE ALLOWANCE (LA)

(CONTINUED) N/A N/A See Note 2 SEALING DEVICE LEAKAGE (DI)

N/A N/A See Note 3 PROCESS PROCESS MEASUREMENT ALLOWANCE (PA) ACCURACY (Pma)

FORM 3 STEP 3 N/A N/A No Primary Element PRIMARY ELEMENT ACCURACY (Pea)

N/A N/A See Note 4 SENSOR CALIBRATION CALIBRATION ACCURACY (Sca)

ALLOWANCE (CA) N/A N/A No Rack Equipment FORM 3 STEP 4 RACK EQUIPMENT CALIBRATION ACCURACY (Rca)

CALCULATION SHEET SBoston Edison REV_0 DATE_11/21/95 SHEET ?-" OF 4.7 Calculation Number__l-N1-115 Instrument NumberTS-1291-14C thru k FORM 1 INSTRUMENT DATA Page 6 of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS N/A N/A No rack equipment RACK EQUIPMENT ACCURACY (Rea)

N/A N/A No rack equipment RACK TEMPERATURE EFFECTS (Rte)

RACK EQUIPMENT ALLOWANCE (RA) N/A N/A No rack equipment FORM 3 STEP 5 RACK POWER SUPPLY EFFECTS (Rps)

N/A N/A No rack equipment RACK EQUIPMENT MISCELLANEOUS EFFECTS (Rme)

CALCULATION SHEET V Boston Edison REV.0_ DATE_11/21/95 SHEET 15 OF +-7 Calculation Number__I-N1-115 Instrument NumberTS-1291-14C thru k FORM I INSTRUMENT DATA Page 7 of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS N/A N/A See Note 4 SENSOR BASIC ACCURACY (Sa)'

N/A N/A Temperature elements are SENSOR STATIC not pressure sensitive PRESSURE SPAN SHIFT (Ssps)

N/A N/A Temperature elements are SENSOR STATIC not pressure sensitive SENSOR PRESSURE ZERO SHIFT ALLOWANCE (SA) (Sspz)

FORM 3 STEP 6 N/A N/A . Not applicable to SENSOR temperature sensors TEMPERATURE EFFECTS (Ste)

N/A N/A Mechanical temperature SENSOR POWER sensors do not use power SUPPLY EFFECTS (Spse) supplies for operation N/A N/A SENSOR MISCELLANEOUS EFFECTS (Sme)__

CALCULATION SHEET SBoston Edison REV_0 DATE_11/21/95 SHEET 1--OF ___

Calculation Number__I-N1-115_ Instrument NumberTS-1291-14C thru k FORM 1 INSTRUMENT DATA Page 8 of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS

+ 2.22 +/- 7.05 deg F See Note 4 and Attachment 2 and 3 SENSOR DRIFT (Sd)

DRIFT ALLOWANCE (DA) N/A N/A No rack equipment FORM 3 STEP 7 RACK EQUIPMENT DRIFT (Red)

+/-3 deg F PNPS Procedure 8.M.2-1 .2.2 This application is to use the SENSOR TOLERANCE same no adjust limits as utilized by the HPCI, RCIC &

(St) Main Steam line leak detection setpoints TOLERANCE *6- -t ALLOWANCE (TA) N/A N/A No rack equipment FORM 3 STEP 8 RACK EQUIPMENT TOLERANCE (Ret)

CALCULATION SHEET SfBoston Edison REV 0.- DATE 1I/I7/95.1 7 SHEET 15 OF L4-7 Calculation Number_l -NI- 115_ Instrument Number TS-1291-14C, 14D, 14E, 14F, 14G, 14H, 14J &14K FORM 2A CALCULATION INPUT SHEET (INCREASING SETPOINT)

PARAMETER DESCRIPTION ABBREVIATION/VALUE I COMMENTS A4NALT I IY...AL LINlI I L OCX.)' memo 70-4/

ENVIRONMENTAL TEMPERATURE EFFECT Te See note 5 ALLOWANCE W._) RADIATION EFFECT Re } See note 5 STEAM/CHEM SPRAY S/Ce. + See note 5 EFFECT PRESSURIZATION (EXT.) Pe See note 5 EFFECT SEISMIC EFFECT Se See note 5 T CIRCUIT LEAKAGE CABLE LEAKAGE CI = N/A See note 2 ALLOWANCE M TERMINAL BLOCK LEAKAGE TI = N/A See note 2 T PENETRATION LEAKAGE PI = N/A See note 2 A SPUCE LEAKAGE SI = N/A See note 2 L SEALING DEVICE LEAKAGE DI = N/A See note 2 L PROCESS ALLOWANCE (PA) PROCESS MEASUREMENT Pma = N/A See note 3 C ACCURACY C PRIMARY ELEMENT Pea = N/A P ACCURACY U CAUBRATION ALLOWANCE SENSOR CALIBRATION ACCURACY Sca = N/A See note 4 N (CAJ RACK EQUIPMENT Rca = N/A C CALIBRATION ACCURACY E

R RACK EQUIPMENT RACK EQUIPMENT ACCURACY Rea = N/A T ALLOWANCE (RAt RACK TEMPERATURE EFFECT Rte = N/A A RACK POWER SUPPLY EFFECT Rps = N/A I RACK EQUIPMENT Rme = N/A N MISCELLANEOUS EFFECT T

Y SENSOR BASIC ACCURACY Sa = +/-5 deg F See note 4 SENSOR STATIC PRESSURE SPAN SHIFT Ssps = N/A SENSOR STATIC PRESSURE ZERO SHIFT Sspz = N/A SENSOR SENSOR TEMPERATURE EFFECTS Ste = N/A ALLOWANCE ISA) SENSOR POWER SUPPLY EFFECTS Spse = N/A SENSOR MISCELLANEOUS Sme = N/A ALLOWABLE EFFECTS VALUE - 4 AV%* < 148degF DRIFT ALLOWANCE (DA) SENSOR DRIFT Sd= + 2.22 +/- 7.05 deg F See note 4 RACK EQUIPMENT DRIFT Red = N/A TOLERANCE ALLOWANCE IA) SENSOR TOLERANCE St = +/-3 deg F RACK EQUIPMENT TOLERANCE Ret = N/A "L--TRIPSErPOINT RESET VALUE Ti~ I TSp**

RV OM

= 138 deg F

= 133 deg F

= 33 deg F See note 6 OPERATING MARGIN NORMAL OPERATION UPPER LIMIT NUL = 105degF NORMAL OPERATING BAND NORMAL OPERATION tOWFR LIMIT- 4- NLL = N/A LOWER LIMIT

• NOTE: VALUES ARE IDENTIFIED FOR MAGNITUDE ONLY AND ARE COMBINED IN ACCORDANCE WITH THE EQUATIONS ON FORM 3 "SONOTE: CALCULATED VALUES FROM FORM 3

CALCULATION SHEET j Boston Edison REV 0 DATE -11/17/95 SHEEr 16 OF'-

FORM 3. CALCULATION SHEET SHEET NO. 1 of 4 Calculation Number I -N1-1 15 Instrument Number__TS-1291-14C, 14D, 14E, 14F, 14G, 14H, 14J & 14K

1. ENVIRONMENTAL ALLOWANCE (EA)

EAi= \,/Te)2 + (Re) 2 + (S/Ce)2 + (Pe) 2 + (Se)2 EA= \/Te)2 + (Re) 2 .+ (S/Ce) 2 + (Pe) 2 + (Se) 2 = +/-6degF

2. CIRCUIT LEAKAGE ALLOWANCE (LA)

LA=CI + TI + P1 + SI + DI LA = N/A + N/A + N/A + N/A + N/A = N/A

3. PROCESS ALLOWANCE (PA)

PA = (PmO) 2 + (Pea)2 PA= (N/A) 2 + (N/A) 2 N/A

4. CALIBRATION ALLOWANCE (CA)

CA= (Sca)2 + (Rca) 2 CA= (N/A) 2 + (N/A) 2

=N/A

5. RACK EQUIPMENT ALLOWANCE (RA)

RA= (Rea)2 + (Rte) 2 + (Rps) 2 + (Rme)2 RA= 2 + (N/A) 2 +

(N/A) (N/A) 2 + (N/A) 2 =N/A

CALCULATION SHEET SBoston Edison REV 0 DATE -11/17/95 SHEET 17 OF 4-7 FORM 3. CALCULATION SHEET SHEET NO. 2 of 4 Calculation Number I -N1-1 15 Instrument Number_TS-1291-14C, 14D, 14E, 14F, 14G, 14H, 14J & 14K

6. SENSOR ALLOWANCE (SA)

SA \ (Sa) 2 + (Ssps + Sspz) 2 + (Ste)2 + (Spse)2 + (Sme)2 SA= \ ( N/A )2 + (N/A+N/A) 2 + (N/A) 2 + (N/A) 2 + (N/A) 2 SA = N/A

7. DRIFT ALLOWANCE (DA)

DA= (Sd)2 + (Red)2 DA=2.22 \/ (7.05)2 +(N/A) 2

+2.22 V

=

deg F7.05

8. TOLERANCE ALLOWANCE (TA)

TA (St)2 + (Ret) 2 TA (3) 2 +(-N/A) 2

= _3deg F

9. TOTAL LOOP UNCERTAINTY ALLOWANCE (TLU)

TLU = LA +/-\/(EA)2 + (PA) 2 + (CA) 2 + (RA) 2 + (SA) 2 + (DA) 2 + (TA)2 TLU= N/A _ \/ý(6)2+ (N/A/A )2+ (7.05)2+(3)2 +2.22 TLU = 2.22 +/- 9.73 deg F

CALCULATION SHEET 4&Boston Edison REV 0 DATE -11/17/95 SHEET 18 OFjj FORM 3. CALCULATION SHEET SHEET NO. 3 of 4 Calculation Number I -N1-1 15 Instrument Number._TS-1291-14C, 14D, 14E, 14F, 14G, 14H, 14J & 14K

10. TRIP SETPOINT (TSp) IN PROCESS UNITS 1 A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IFDECREASING SETPOINT)

TSp = AL - TLU TSp = 150 - 11.95 = 138.05, say 138 deg F 1OB. FOR DECREASING SETPOINT - FROM 2B: (ENTER N/A IFINCREASING SETPOINT)

TSp = AL + TLU TSp = N/A + N/A = N/A

11. ALLOWABLE VALUE (AV) 11 A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IF DECREASING SETPOINT)

AV = TSp + VDA2 + TA2 AV= 138 + V (7.05)2 + (3)2 + 2.22 AV = 147.88, say 148 deg F 11 B. FOR DECREASING SETPOINT - FORM 2B: (ENTER N/A IFINCREASING SETPOINT)

AV= TSp - \/DA2+TA2 AV= N/A - (N/A) 2 + (N/A) 2 AV = N/A

CALCULATION SHEET j Boston Edison REV 0 DATE 11/17/95 SHEET7 OF 47 FORM 3. CALCULATION SHEET SHEET NO. 4 of 4 Calculation Number I -NI-1 15 Instrument Number__TS-1291-14C, 14D, 14E, 14F, 14G, 14H, 14J & 14K

12. OPERATING MARGIN (OM) 12A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IF DECREASING SETPOINT)

OM = TSp - NUL OM=138- 105= 33degF 12B. FOR DECREASING SETPOINT - FORM 2B: (ENTER N/A IF INCREASING SETPOINT)

OM = NLL - TSp OM = N/A - N/A = N/A

13. RESET VALUE (RV) 13A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IF DECREASING SETPOINT)

RV > NUL RV = 133 deg F See note 6 NUL= 105 deg F 13B. FOR DECREASING SETPOINT - FORM 2B: (ENTER N/A IF INCREASING SETPOINT)

RV < NLL RV =N/A NLL= N/A 14.TRIP SETPOINT (TSp) IN PROCESS UNITS TSs = TSp MODIFIED BY THE FACTORS ACCOUNTING FOR CONVERSION FROM PROCESS UNIT TO SIGNAL UNITS (VOLTS, AMPS, COUNTS, etc.).

TSs = N/A

CALCULATION SHEET Rev 0 Date 11/21/95 4 Boston Edison Sheet 20 of .47 FORM 4. CALCULATION SHEET CALCULATION NUMBER I -N1-115 CALCULATION WORK OR REMARKS:

References:

1. Drawings:

"* M-247, Rev. E36 - P&ID; RWCU System

"* M-312, Rev. E6 - HV&AC; Reactor Bldg. Aux. Bay

"* M-313, Rev. E5 - HV&AC; Reactor Bldg. Plan El. 51

"* M-319, Rev. E4 - HV&AC; Reactor Bldg. Aux. Bay

"* M1 N39-13, Rev. E17 - Elementary Diagram; Primary Containment Isolation System

2. Pilgrim Unit I Specification E-536, Rev. 4; Environmental Parameters for use in the Environmental Qualification of Electrical Equipment (Per 10CFR50.49)

3. PNPS EQ List, Rev. E43

4. PNPS Q-List, Rev. E63

5. PNPS - FSAR, Rev. 16

6. PNPS Technical Specification, Rev. 184

7. Boston Edison Co. Equipment Qualification Data Files; TS-1291-14C, TS-1291-14D, TS-1291 14E, TS-1291-14F, TS-1291-14G, TS-1291-14H, TS-1291-14J &TS-1291-14K; Rev. E2

8. PNPS Procedure No.1.3.36, Rev. 13; Measurement and Test Equipment

9. PNPS Procedure No. 8.M.2-1.2.2, Rev. 22; RWCU Area High Temperature Sensors

10. Office Memorandum No. S&SA 95-47, Dated 9/7/95; HPCI, RCIC and RWCU Steam Leak Detection Setpoint Information

CALCULATION SHEET Rev 0 Date 11/21/95 4 Boston Edison Sheet 2-1 of +-t7 FORM 4. CALCULATION SHEET CALCULATION NUMBER I -N1-115

11. Patel Engineers Technical Report No. PEI-TR-831200-1, Rev. a; Final Report on the Qualification of a Patel Engineers Modified Fenwal Temperature Switch Manufactured by Fenwal Inc. (EQDF Ref. # 340)

12. Patel / EGS Temperature Switch Product Data Sheet,Rev. 11/89 (Attachment 1)

13. ABB Impell Project Instruction No. 25-226-PI-001, Rev. E2; Data Collection and Analysis

14. NEDWI 394, Rev. 3; Methodology for Calculation of Instrument Setpoints

15. U.S. NRC Regulatory Guide 1.105, Rev. 2; Instrument Setpoints for Safety Related Systems

16. Instrument Society of America Standard ISA-67.04-1982; Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants

ATTACHMENT 2 6V 2 TS1291-14C,D,E,FG,H,J,K DRIFT DATA oA 4 DATA CAL. DATA RAW DATA SUM. 1ST OUT. SUM. 2ND OUT. SUM DATE STATUS "1. "D" INT REMARKS 1.. "D"

. ..I. "D"

.. ..I. .D" 5/18/93 AS FOUND 149.2 TS1291-14C ....

AS LEFT 1461 7/16/93 AS FOUND 149.2 59 3.10 3.10 3.10 AS LEFT 146.9 10/19/93 AS FOUND 145 95 -1.90 -1.90 -1.90 AS LEFT 143.3 1/19/94 AS FOUND 143.3 92 0.00 0.00 0.00 AS LEFT 141.7 4/28/94 AS FOUND 142.1 99 0.40 0.40 0 40 AS LEFT 141.2 7/28/94 AS FOUND 141.7 91 0.50 0.50 0.50 AS LEFT 141.7 11/14/94 AS FOUND 142.2 109 0.50 0.50 0.50 AS LEFT 140.3 2/15/95 AS FOUND 142.1 93 1.80 1.80 1.80 AS LEFT 142.3 5/21/95 AS FOUND 145.2 95 2.90 2.90 2.90 AS LEFT 140.6 5/18193 AS FOUND 148.3 TS1291-14D AS LEFT 146.5 7/16/93 AS FOUND 152.6 59 6.10 6.10 6.10 AS LEFT 144.3 10/19/93 AS FOUND 141.8 95 -2.50 -2.50 -2.50 AS LEFT 140.9 1/19/94 AS FOUND 146.1 92 5.20 5.20 520 AS LEFT 144.1 4/28/94 AS FOUND 1426 99 -1.50 -1.50 -1.50 AS LEFT 140.1 7/28/94 AS FOUND 145 8 91 5.70 5.70 5.70i AS LEFT 140.7 11/14/94 AS FOUND 145.3 109 4.60 4.60 4.60 AS LEFT 145.4 2/15/95 AS FOUND 145 93 -0.40 -0.40 -040 AS LEFT 142.9 5/21/95 AS FOUND 143.9 95 1.00 1.00 1.00 AS LEFT 143.5 5/18/93 AS FOUND 139.3 TS1291-14E

_AS LEFT 144.9 1_1_1 Page 1

ATTACHMENT 2 S2.5 oF LFl TS1291-14C,D,E,F,G,H,J,K DRIFT DATA CALC. NO. I-NI-115 R,.0 7/16/93 AS FOUND 149.3 59 4.40 4.40 4 40 AS LEFT 144.3 10/19/93 AS FOUND 140.9 95 -3 40 -3.40 -3.40 AS LEFT 144.2 1/19/94 AS FOUND 145 92 0.80 0.80 0.80 AS LEFT 142.4 4/28/94 AS FOUND 139.1 99 -3.30 -3.30 -3.30 AS LEFT 142.6 7/28/94 AS FOUND 141.7 91 -0.90 -0.90 -0.90 AS LEFT 142.4 11/14/94 AS FOUND 142.8 109 0.40 0.40 0.40 AS LEFT 143.4 2/15/95 AS FOUND 143.9 93 0.50 0.50 0.50 AS LEFT 140.9 5/21/95 AS FOUND 144.9 95 4.00 4.00 4.00 AS LEFT 145.1 5/18/93 AS FOUND 146.1 TS1291-14F AS LEFT 146.4 7/16/93 AS FOUND 147.5 59 1.10 1.10 1.10 AS LEFT 143.5 10/19/93 AS FOUND 138.1 95 -5.40 -5.40 -5.40 AS LEFT 142.5 1/19/94 AS FOUND 142.9 92 0.40 0.40 0.40 AS LEFT 143.8 4/28/94 AS FOUND 140.9 99 -2.90 -2.90 -2.90 AS LEFT 144.8 7/28/94 AS FOUND 146.2 91 1.40 1.40 1.40 AS LEFT 142.4 11/14/94 AS FOUND 145.7 109 3.30 3.30 3.30 AS LEFT 146.7 2/15/95 AS FOUND 145.8 93 -0.90 -0.90 -0.90 AS LEFT 141.6i 5/21/95 AS FOUND 143.7 95 2.10 2.10 2.10 AS LEFT 145.7 5/18/93 AS FOUND 148 8 TS1291-14G AS LEFT 144.6 7/16/93 AS FOUND 146.8 59 2.20 2.20 2.20 AS LEFT 143.8 10/19/93 AS FOUND 147.4 95 3.60 3.60 3.60 AS LEFT 146.6 1/19/94 AS FOUND 147.7 92 1.10 1.10 1.10 Page 2

ATTACHMENT 2 5kZ~6F 4-I.7 TS1291-14C,D,E,F,G,H,J,K DRIFT DATA CALC. NO. I-Nl-115 P.o AS LEFT 141.5 4/28/94 AS FOUND 141.2 99 -0.30 -0.30 -0.30 AS LEFT 142.5 7/28/94 AS FOUND 145.4 91 2.90 2.90 2.90 AS LEFT 142.1 11/14194 AS FOUND 145.1 109 3.00 3.00 3.00 AS LEFT 145.9 2/15/95 AS FOUND 145 93 -0.90 -0.90 -0.90 AS LEFT 141.8 5/21/95 AS FOUND 144.7 95 2.90 2.90 2.90 AS LEFT 145.3 5/18/93 AS FOUND 153.5 TS1291-14H AS LEFT 143.1 7/16/93 AS FOUND 144.9 59 1.80 1.80 1.80 AS LEFT 143.1 10119/93 AS FOUND 142.5 95 -0.60 -0.60 -0 60 AS LEFT 143.2 1/19/94 AS FOUND 142.9 92 -0.30 -0.30 -0.30 AS LEFT 145.3 4/28194 AS FOUND 145.8 99 0.50 0.50 050 AS LEFT 140.5 7/28/94 AS FOUND 142.4 91 1.90 1.90 1.90 AS LEFT 145.4 11/14/94 AS FOUND 143.2 109 -2.20 -2.20 -2.20 AS LEFT 142.3 2/15/95 AS FOUND 143.2 93 0.90 0.90 0.90 AS LEFT 145.5 5/21/95 AS FOUND 1456 95 0.10 0.10 0.10 AS LEFT 143.2 5/18/93 AS FOUND 145.1 TS1291-14J AS LEFT 147 7/16/93 AS FOUND 148.2 59 1.20 1.20 1.20 AS LEFT 144.7 10/19/93 AS FOUND 147.5 95 2.80 2.80 2.80 AS LEFT 142.3 1/19/94 AS FOUND 149.8 92 7.50 7.50 7.50 AS LEFT 142.8 4/28/94 AS FOUND 141.3 99 -1.50 -1.50 -1.50 AS LEFT 144.7 7/28/94 AS FOUND 143.6 91 -1.10 -1.10 -1.10

_AS LEFT 141.4 Page 3

ATTACHMENT 2 .6h a ) ý /-

TS1291-14C,D,E,F,G,HJ,K DRIFT DATA CALC. NO. I-Nl-115 R.o 11/14/94 AS FOUND 143.8 109 2.40 2.40 2.40 AS LEFT 145.3 2/15/95 AS FOUND 145.1 93 -0.20 -0.20 -0 20 AS LEFT 142 5/21/95 AS FOUND 143.1 95 1.10 1.10 1.10 AS LEFT 144.5 5/18/93 AS FOUND 144 TS1291-14K AS LEFT 146.5 7/16/93 AS FOUND 144.3 59 -2.20 -2.20 -2.20 AS LEFT 144 10/19/93 AS FOUND 137.9 95 -6.10 -6.10 -6.10 AS LEFT 145.1 1/19/94 AS FOUND 143.4 92 -1.70 -1.70 -1.70 AS LEFT 144.2 4/28194 AS FOUND 144.3 99 0.10 0.10 0.10 AS LEFT 141.5 7128/94 AS FOUND 142.6 91 1.10 1.10 1.10 AS LEFT 143.4 11/14/94 AS FOUND 143 109 -0.40 -040 -0.40 AS LEFT 143.4 2/15/95 AS FOUND 138.5 93 -4.90 -4.90 -4.90 AS LEFT 142.7 5121/95 AS FOUND 140.6 95 -2.10 -2.10 -2.10 AS LEFT 146.6 AVERAGE 0.62 0 62 0.62 STANDARD DEVIATION 2.69 2.69 2.69 COUNT 64 64 64

% OF ORIGINAL DATA POINTS 100% 100%

95%/95% TOL. INT.DEG F _ _ 6.27 6.27 Page 4

ATTACHMENT 3 PATEL/EGS TEMP. SWITCH DRIFT DATA khz-CALC. NO. I-Ni-1.15 Rev. 0 DATA CAL. DATA RAW DATA SUM. 1ST OUT. SUM. 2ND OUT. SUM.

DATE STATUS "Il., "D-0 INT SERIAL NUMBER 1 1...D ... I..0 D.1.. I _....D" 8113/86 AS FOUND AS LEFT 189.5 3/9189 AS FOUND 194 939 1733 4.50 4.50 4.50 AS LEFT 8/13/86 AS FOUND AS LEFT 190 3/9189 AS FOUND 197.2 939 1731 7.20 7.20 7.20 AS LEFT 8113/86 AS FOUND AS LEFT 188.5 3/9/89 AS FOUND 207 .939 1752 18.50 _OUTLIER OUTLIER AS LEFT 8/13/86 AS FOUND AS LEFT 189.5 3/9/89 AS FOUND 190 939 1783 0.50 0.50 0.50 AS LEFT 8/13/86 AS FOUND AS LEFT 189.5 3/9/89 AS FOUND 187 939 1755 -2.50 -2.50 -2.50 AS LEFT 8/13/86 AS FOUND AS LEFT 189 3/9/89 AS FOUND 189.9 939 1712 0.90 0.90 0 90 AS LEFT 8/13/86 AS FOUND AS LEFT 189 3/9/89 AS FOUND 187 939 1718 -2.00 -2.00 -2.00 AS LEFT 8/13/86 AS FOUND AS LEFT 189 3/9/89 AS FOUND 190 939 1760 1.00 1.00 1.00 AS LEFT 8/13/86 AS FOUND AS LEFT 190 3/9/89 AS FOUND 190.5 939 1711 0.50 0.50 0.50 AS LEFT 8/13/86 AS FOUND AS LEFT 191 Page 1

ATTACHMENT 3 LbO' PATELJEGS TEMP. SWITCH DRIFT DATA CALC. NO. I-Ni-115, Rev. 0 319189 AS FOUND 190.9 939 1708 -0.10 -0.10 -0.10 AS LEFT 8113/86 AS FOUND AS LEFT 189.2 3/9189 AS FOUND 191.9 939 1769 2.70 2.70 2.70 AS LEFT 1 8/13/86 AS FOUND L AS LEFT 190.5 3/9/89 AS FOUND 193.3 939 1706 2.80 2.80 2.80 AS LEFT 8/13/86 AS FOUND AS LEFT 191 319/89 AS FOUND 192.1 939 1743 1.10 1.10 1.10 AS LEFT _

8/13/86 AS FOUND AS LEFT 189.6 3/9/89 AS FOUND 192.5 939 1728 2.90 2.90 ..... 2.90 AS LEFT 8/13/86 AS FOUND AS LEFT 189.8 3/9/89 AS FOUND 194 939 1726 4.20 4.20 4.20 AS LEFT 8/13/86 AS FOUND AS LEFT 189.8 3/9/89 AS FOUND 191 939 1749 1.20 1.20 1.20 AS LEFT 8/13/86 AS FOUND AS LEFT 190.2 3/9/89 AS FOUND 190.5 939 1737 0.30 0.30 0.30 AS LEFT 8/14/86 AS FOUND _

AS LEFT 189 3/9/89 AS FOUND 191 938 1704 2.00 2.00 2.00 AS LEFT 8/14/86 AS FOUND AS LEFT 191.6 3/9/89 AS FOUND 194.9 938 1723 3.30 3.30 3.30 AS LEFT 8/14/86 AS FOUND AS LEFT 190 3/9/89 AS FOUND 192.6 1 938 1719 2.60 2.60 1 2.60 Page 2

ATTACHMENT 3 6,113 C CA:L11 PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-Ni-115. Rev. 0 AS LEFT 8/14186 AS FOUND AS LEFT 190 3/9/89 AS FOUND 194 938 1758 4.00 4.00 4.00 AS LEFT 8/14/86 AS FOUND AS LEFT 191.8 3/9/89 AS FOUND 198.2 938 1714 6 40 6.40 6.40 AS LEFT 8/14/86 AS FOUND AS LEFT 189.4 3/9/89 AS FOUND 189.9 938 1735 0.50 0.50 0.50 AS LEFT 8/14/86 AS FOUND AS LEFT 189.2 3/9/89 AS FOUND 194 938 1740 4.80 4.80 4.80 AS LEFT 8/14/86 AS FOUND AS LEFT 190.1 3/9/89 AS FOUND 199.7 1 938 1710 9 60 9.60 9.60 AS LEFT 8/14/86 AS FOUND '

AS LEFT 190 3/9/89 AS FOUND 199.8 938 1764 9.80 9.80 9.80 AS LEFT 8/14/86 AS FOUND AS LEFT 188.3 3/9/89 AS FOUND 188 938 1753 -0.30 -0.30 -0.30 AS LEFT ....

8/14/86 AS FOUND AS LEFT 191 3/9/89 AS FOUND 192.2 938 1722 1.20 1.20 1.20 AS LEFT 8/14/86 AS FOUND AS LEFT 190.6 3/9/89 AS FOUND 189.5 938 1738 -1.10 -1.10 -1.10 AS LEFT 8114/86 AS FOUND AS LEFT 190.2 3/9/89 AS FOUND 195 938 1739 4.80 4.80 4.80 ASLEFT I I I II _III Page 3

ATTACHMENT 3 'k OF wi~-

PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-N1-115, Rev. 0 8/14/86 AS FOUND AS LEFT 189.9 3/9/89 AS FOUND 191.9 938 1757 2.00 2.00 2.00 AS LEFT 8114186 AS FOUND AS LEFT 189.3 3/9/89 AS FOUND 188.5 938 1716 -0.80 -0.80 -0.80 AS LEFT 8/14/86 AS FOUND AS LEFT 189 3/9/89 AS FOUND 192.5 938 1759 3.50 3.50 3.50 AS LEFT 8/14/86 AS FOUND AS LEFT 190.5 3/9/89 AS FOUND 196 938 1763 5.50 5.50 5.50 AS LEFT 8/14/86 AS FOUND AS LEFT 190.9 3/9/89 AS FOUND 191.1 938 1727 0.20 0.20 0.20 AS LEFT 8/14/86 AS FOUND AS LEFT 188.3 3/9/89 AS FOUND 192.5 938 1767 4.20 4.20 4.20 AS LEFT 8/14/86 AS FOUND AS LEFT 188 3/9/89 AS FOUND 192.5 938 1746 4.50 4.50 4.50 AS LEFT 8/14/86 AS FOUND AS LEFT 189.1 3/9/89 AS FOUND 193 938 1734 3 90 3.90 3.90 AS LEFT 8/14/86 AS FOUND AS LEFT 189.5 3/9/89 AS FOUND 189.6 938 1736 0.10 0.10 0.10 AS LEFT 8/14/86 AS FOUND AS LEFT 189 3/9/89 AS FOUND 191.5 938 1777 2.50 2.50 2.50 AS LEFT I_1_1 8/14/86 AS FOUND_

i Page 4

ATTACHMENT 3 6k3cL 6F1 PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-NI-115, Rev. 0 AS LEFT

_ 190 3/9/89 AS FOUND 189.3 938 1707 -0.70 -0.70 -0.70 AS LEFT 8/14/86 AS FOUND AS LEFT 190.5 3/9/89 AS FOUND 187.9 938 1744 -2.60 -2.60 -2.60 AS LEFT 8/14/86 AS FOUND AS LEFT 189.3 3/9/89 AS FOUND 190.1 938 1697 0.80 0.80 0.80 AS LEFT 8114/86 AS FOUND AS LEFT 189.7 3/9/89 AS FOUND 188.9 938 1725 -0.80 -0.80 -0.80 AS LEFT 8/14/86 AS FOUND AS LEFT 189.5 3/9/89 AS FOUND 182.9 938 1703 -6.60 -6.60 -6.60 AS LEFT 8/14/86 AS FOUND AS LEFT 189.1 3/9/89 AS FOUND 191.4 938 1771 2.30 2.30 2.30 AS LEFT 8/14/86 AS FOUND AS LEFT 188.1 3/9/89 AS FOUND 186.5 938 1768 -1.60 -1.60 -1.60 AS LEFT 8/14/86 AS FOUND AS LEFT 191 "

3/9189 AS FOUND 195 938 1778 4.00 ........ 4.00 4.00 AS LEFT 8/18/86 AS FOUND AS LEFT 189.6 3/9/89 AS FOUND 195.9 934 1779 6.30 6.30 6.30 AS LEFT 8/18/86 AS FOUND AS LEFT 189.8 3/9/89 AS FOUND 190.6 934 1761 0.80 0.80 0.80 AS LEFT 8/18/86 AS FOUND L AS LEFT 189.3 Page 5

ATTACHMENT 3 6 32> 0F PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-NI-115. Rev. 0 319/89 AS FOUND 188.3 934 1705 -1.00 -1.00 -1.00 AS LEFT 8/18/86 AS FOUND AS LEFT 190 319189 AS FOUND 190 934 1721 0.00 0.00 0.00 AS LEFT 8/18/86 AS FOUND AS LEFT 190 3/9/89 AS FOUND 190 934 1732 0.00 0.00 0.00 AS LEFT 8/18/86 AS FOUND AS LEFT 188.8 ....

3/9/89 AS FOUND 195.9 934 1774 7.10 7.10 7.10 AS LEFT 8/18/86 AS FOUND AS LEFT 190 3/9/89 AS FOUND 194.2 934 1730 4.20 4.20 4.20 AS LEFT 8/18/86 AS FOUND AS LEFT 191f.5 3/9/89 AS FOUND 194.5 934 1773 3.00 3 00 3.00 AS LEFT _

8/18/86 AS FOUND AS LEFT 191 3/9/89 AS FOUND 195.1 934 1700 4.10 4.10 4.10 AS LEFT 8/18/86 AS FOUND AS LEFT 189 3/9/89 AS FOUND 192.3 9344 1766 3.30 3.30 " 3.30 AS LEFT 8/18/86 AS FOUND AS LEFT 188 3/9/89 AS FOUND 193 934 1724 5.00 5.00 5.00 AS LEFT 8/18/86 AS FOUND AS LEFT 188.4 3/9/89 AS FOUND 193.2 934 1782 4.80 4.80 4.80 AS LEFT ....

8/18/86 AS FOUND AS LEFT 190.9 3/9/89 AS FOUND 197.4 934 1770 6.50 6.50 6.50 Page 6

ATTACHMENT 3 ~~k 3dlk4.

PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-N1-115, Rev. 0 AS LEFT 8118/86 AS FOUND AS LEFT 188.6 3/9/89 AS FOUND 195 934 1780 6.40 6.40 6.40 AS LEFT 8/18/86 AS FOUND AS LEFT 189.8 3/9/89 AS FOUND 191 934 1696 1.20 1.20 1.20 AS LEFT 8/18/86 AS FOUND AS LEFT 190.9 ___

3/9/89 AS FOUND 195 934 1729 4.10 4.10 4.10 AS LEFT 12/17/86 AS FOUND AS LE FT 190 3 .90 3/3/89 AS FOUND 193.9 807 1789 3.90 3.90 3.90

_AS LEFT 12/17/86 AS FOUND AS LEFT 192 3/3/89 AS FOUND 188.8 807 1834 -3.20 -3.20 -3.20 AS LEFT 12/17/86 AS FOUND AS LEFT 191 1.5 3/3/89 AS FOUND 192.5 807 1825 1.50 1.50 1.50 AS LEFT 12/17/86 AS FOUND AS LEFT 188 3/3/89 AS FOUND 187.1 807 1843 -0.90 -0.90 -0.90 AS LEFT 12/17/86 AS FOUND AS LEFT 192 313/89 AS FOUND 1904 807 1899 -1.60 -1.60 -1.60 AS LEFT 12/17/86 AS FOUND I A S LE FT 193 -1.20 3/3/89 AS FOUND 191.8 807 1713 -1.20 -1.20 -1.20 AS LEFT 12/17/86 AS FOUND A S LE FT 193 0. 0 0 .40 3/3/89 AS FOUND 193.4 1 8071 1841 0.40 0.40 0.40 AS LEFT I ___i Page 7

ATTACHMENT 3 PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-N1-115, Rev. 0 12/17/86 AS FOUND AS LEFT 189 3/3/89 AS FOUND 190.2 807 1829 1.20 1.20 1.20 AS LEFT 12/17/86 AS FOUND AS LEFT 193 3/3/89 AS FOUND 191.3 807 1833 -1.70 -1.70 -1.70 AS LEFT 12/17/86 AS FOUND AS LEFT 191 3/3/89 AS FOUND 192.5 807 1842 1.50 1.50 1.50 AS LEFT I 12/17/86 AS FOUND AS LEFT 190 3/3/89 AS FOUND 198.5 807 1835 8.50 8.50 8.50 AS LEFT 12117/86 AS FOUND AS LEFT 191 3/3189 AS FOUND 191 807 1827 0 00 0.00 0.00 AS LEFT _

12/17/86 AS FOUND AS LEFT 190 3/3/89 AS FOUND 188 807 1826 -2.00 -2.00 -2.00 AS LEFT 12/17/86 AS FOUND AS LEFT 188 3/3/89 AS FOUND 199.6 807 1822 11.60 11.60 11.60 AS LEFT 12/17/86 AS FOUND AS LEFT 188 3/3/89 AS FOUND 196 807 1933 8.00 8.00 8.00 AS LEFT 12/17/86 AS FOUND AS LEFT 190.2 3/3/89 AS FOUND 191.6 807 1874 1.40 1.40 1.40 AS LEFT 12/17/86 AS FOUND AS LEFT 192 3/3/89 AS FOUND 194 807 1875 2.00 2.00 2.00 AS LEFT 12/17/86 AS FOUND Page 8

ATTACHMENT 3 5 '34,64-7 PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-NI-115, Rev. 0 AS LEFT 190 3/3/89 AS FOUND 190.9 807 1838 0.90 0.90 0.90 AS LEFT 12/17/86 AS FOUND AS LEFT 190.8 3/3/89 AS FOUND 192 807 1925 1.20 1.20 1.20 AS LEFT 12/17/86 AS FOUND AS LEFT 192, 3/3/89 AS FOUND 190 807 1839 -2.00 -2.00 -2.00 AS LEFT 12/17/86 AS FOUND AS LEFT 190.5 3/3/89 AS FOUND 191.2 807 1830 0.70 0.70 0.70 AS LEFT 12/17/86 AS FOUND AS LEFT 189 3/3/89 AS FOUND 190.9 807 1836 1.90 1.90 1.90 AS LEFT 12/17/86 AS FOUND AS LEFT 1885 3/3/89 AS FOUND 211 807 1919 22.50 OUTLIER OUTLIER AS LEFT 12/17/86 AS FOUND AS LEFT 189.5!

3/3/89 AS FOUND 189.8 807 1930 0.30 0.30 0.301 AS LEFT 12/17/86 AS FOUND AS LEFT 190 3/3/89 AS FOUND 191.4 807 1916 1.40 1.40 1.40 AS LEFT 12/17/86 AS FOUND AS LEFT 189.8 3/3/89 AS FOUND 192.3 807 1790 2.50 2.50 2.50 AS LEFT 12/17/86 AS FOUND AS LEFT 188.1 313/89 AS FOUND 189.1 807 1846 1.00 1.00 1.00 AS LEFT 12/17/86 AS FOUND AS LEFT 190 1 1 Page 9

ATTACHMENT 3 th 37 '.V+

PATEL/EGS TEMP. SWITCH DRIFT DATA CALC. NO. I-NI-115. Rev. 0 3/3/89 AS FOUND 191.4 807 1854 1.40 _, 1.40 1.40 AS LEFT 12/17/86 AS FOUND AS LEFT 190.8 3/3/89 AS FOUND 199 807 1880 8.20 8.20 8.20 AS LEFT 12/17/86 AS FOUND AS LEFT 1868 3/3/89 AS FOUND 189.6 807 1754 2.80 2.80 2.80 AS LEFT 12/17/86 AS FOUND AS LEFT 189.2 3/3/89 AS FOUND 191.6 807 1844 2.40 2.40 2.40 AS LEFT 12/17/86 AS FOUND AS LEFT 187.8 3/3/89 AS FOUND 194.6 807 1795 6.80 6.80 6.80 AS LEFT 12/17/86 AS FOUND AS LEFT 192.8 3/3/89 AS FOUND 191.6 807 1845 -1.20 -1.20 -1.20 AS LEFT 12/17/86 AS FOUND AS LEFT 189 3/3/89 AS FOUND 193 807 1882 4.00 4.00 4.00 AS LEFT 12/17/86 AS FOUND AS LEFT 191 3/3/89 AS FOUND 194.1 807 1741 3.10 3.10 3.10 AS LEFT 12/17/86 AS FOUND AS LEFT 186 3/3/89 AS FOUND ...

193.1 807 1698 7.10 .... 7.10 7.10 AS LEFT 12/17/86 AS FOUND AS LEFT 188.1 3/3/89 AS FOUND 190 807 1896 1.90 1.90 1 90 AS LEFT 12/17/86 AS FOUND

_ AS LEFT 186.2 3/3/89 AS FOUND 190.5 807 1848 4.30 4.30 4.30 i

Page 10

ATTACHMENT 3 PATEUEGS TEMP. SWITCH DRIFT DATA CALC. NO. I-NI-115, Rev. 0

_AS LEFT 12/17/86 AS FOUND AS LEFT 191 3/3/89 AS FOUND 188 807 1891 -3.00 -3.00 -3.00 AS LEFT _

AVERAGE 2.57 2.22 2.22 STANDARD DEVIATION 4.04 3.17 3.17 COUNT 103 101 101

% OF ORIGINAL DATA POINTS 98.1% 98.1%

1_95%/95% TOL. INT.DEG F _ _ 7.06 7.061 Page 11

Pilgrim Calculation No. 1-NI-195 Pages 3 thru 26 and 31 and 32

CALCULATION SHEET Rev 1 Date *,.!97 4D Boston Edison SheetS of 24 FORM 4. CALCULATION SHEET CALCULATION NUMBER I-N1 -195 CALCULATION WORK OR REMARKS:

Statement of Problem This calculation will provide the uncertainty analysis for the development of the RCIC steam line low pressure isolation setpoint. It will determine a plant setpoint and allowable value which will ensure initiation on or before reaching the design basis analytical limits. Other parameters determined by this calculation are:

• Instrument Surveillance Interval

• Measurement and Test Equipment Accuracy

• Calibration No Adjust Limits

• Field Reset Value Method of solution This calculation is performed based on the methodology described in Beco NEDWI No. 394 and uses ABB Impell Project Instructions No. 25-226-PI-001 for analysis of the as-found and as-left instrument calibration data. The calculation has been prepared in accordance with the U.S.

Nuclear Regulatory Commission Regulatory Guide No. 1.105, Rev. 2 and Instrument Society of America Standard ISA-$67.04-1982.

Input Data and Assumptions In accordance with PNPS FSAR Sections 7.3.4.7 and 7.3.4.8 the RCIC turbine steam line low pressure switches are utilized to isolate the RCIC turbine steam line so that steam and radioactive gases will not escape from the RCIC turbine shaft seals into the Reactor building after steam pressure has decreased to such a low value that the turbine cannot be operated. This trip is not considered a PCIS function. The mission time of these switches is based upon an accident which RCIC is required to function.

CALCULATION SHEET Rev 1 Date __ _

4 Boston Edison Sheet of 34-FORM 4. CALCULATION SHEET CALCULATION NUMBER I-N1 -195 Summary of Results and Recommendations This calculation determined a new setpoint and Technical Specification allowable value. These values were determined based on plant specific calibration data and NEDWI No. 394 methodology.

The sensed instrument setpoint includes margin to account for an instrument line static head of 17.5 psig. The sensed instrument setpoint is equal to the process setpoint plus the instrument line static head.

The results of the calculation are listed below (see note 8):

Trip Setpoint:

70 psig (process pressure) 87.5 psig (instrument sensed pressure)

Technical Specification Allowable Value:

70 +/- 7 psig (process pressure) 87.5 +/- 7 psig (instrument sensed pressure)

Setpoint Analytical limit:

>50 psig, but < 100 psig (process pressure)

>67.5 psig, but < 117.5 psig (instrument sensed pressure)

Setpoint Reset Value:

<79 psig (process pressure)

_<96.5 psig (instrument sensed pressure)

No Adjust Limits: +/-5 psig Surveillance Interval: Once per 24 months M&TE Accuracy: +/- 1% of full scale

CALCULATION SHEET Rev I Date ,/z.)97 1 Boston Edison Sheet .5 of 3_*

FORM 4. CALCULATION SHEET CALCULATION NUMBER I-N1 -195 This calculation is based on the accuracy specifications of the Static-O-Ring pressure switch model number 6TA-B3-U8-ClA-JJTTNQ and PNPS specific drift data for the Static -O-Ring pressure switch model number 6TA-B3-NX-ClA-JJTTX6 and 6TA-B3-NX-CIA-JJTTX12. These switches are similar in design. The performance data used in the calculation is considered representative of these model numbers.

Pressure switch PS1360-9B is a Static-O-Ring model no. 6TA-B3-NX-ClA-JJTTX12 and PS1360 9A, C and D are Barksdale model no. P1H-M85SSV. Replacement of switches PS1360-9A, C and D with Static-O-Ring model no. 6TA-B3-U8-ClA-JJTTNQ or 6TA-B3-NX-ClA-JJTTX12 is required for this calculation to be in effect. The Barksdale switches are being replaced because their setpoint cannot be adjusted to the new value determined by this calculation.

CALCULATION SHEET Rev 1 Date ./2./97 1D Boston Edison Sheet _ of 3" FORM 4. CALCULATION SHEET CALCULATION NUMBER I-Nl-195 I

Calculation Work Or Remarks:

Notes:

1. RCIC turbine steam line low pressure is used to automatically close the two isolation valves in the RCIC turbine steam line, so that steam and radioactive gases will not escape from the RCIC turbine shaft seals into the reactor building after steam pressure has decreased to such a low value that the turbine cannot be operated. See FSAR Section 7.3.4.7.9. In accordance with FSAR Table 4.7-1 the RCIC Turbine Steam Inlet pressure range is 150 to 1,120 psia. Therefore, to ensure that RCIC is available for the above pressure range the Turbine should not be trip off or re started greater than 135 psig. The isolation setpoint and reset are chosen at a pressure below that at which the RCIC turbine can operate effectively. This isolation is expected to be operational anytime RCIC is operated including after an accident.

2. The calculation is based on the Static-O-Ring switch model numbers 6TA-B3-U8-ClA-JJTTNQ and 6TA-B3-NX-C1A-JJTTX12. The switches are similar in design and the accuracy data used in this calculation is considered representative of these switches. See SOR Forms # 216 and 651.

Presently, switches PS1360-9A,C and D are Barksdale model no. P1H-M85SSV and switch PS1360-9B is a Static-O-Ring model no. 6TA-B3-NX-ClA-JJTTX12. A design change is to be performed which will replace the Barksdale switches with static-o-ring model no. 6TA-B3-U8-ClA JJTTNQ. Therefore, the results of this calculation are not in effect until the design change has been completed.

3. The Static-O-Ring pressure switch will not experience a pressure effect due to a pipe break outside containment. The maximum ambient pressure due to a steam line break is 15.22 psia.

Reference Pilgrim Unit 1 Specification E-536, Figure C.4.1-7 for the pressure profile. This transient will not cause the pressure switch to experience an error because the switch housing is sealed and the sensing element is referenced to the pressure inside the switch housing.

Reference Attachment 1. See note 4 for internal housing pressure changes due to ambient temperature variations.

CALCULATION SHEET Rev I Date !1L-9&7 S BOStOn Edison Sheet oof FORM 4. CALCULATION SHEET CALCULATION NUMBER I-Nl-195

1. The

4. The temperature effect of the Static-O-Ring pressure switch is identified in Attachment influence.

switch setpoint changes as a result of a sealed housing effect and natural temperature 6TA-B3-U8 This relationship is applicable to the Static-O-Ring pressure switch model numbers a temperature CIA-JJJTTNQ and 6TA-B3-NX-C1A-JJTTX12. The change in setpoint due to F to the peak accident temperature of 242 increase from a normal operating temperature of 60 deg.

is:

deg. F (reference FSAR Table 10.9-1 and Specification E-536, Fig.C.4.1-7)

Change in Setpoint = (.04psi/deg F - .0003 x SP psi/deg F)A deg F F= 2.5 psig

(.04psig/deg. F)(242-60)deg. F - (.0003/deg. F)(87.5)psig(242-60)deg.

sooner on a Because the change in setpoint is positive, the error will make the switch trip Limit when decreasing signal and therefore will be subtracted from the upper Analytical determining the setpoint.

testing. The

5. The radiation effect or error is defined as the change in setpoint due to radiation in attachment 2. Six switches radiation effect of the Static-O-Ring pressure switch is determined were tested. Though the models 6TA-B3-U8-CIA-JJTTNQ and 6TA-B3-NX-CIA-JJTTX12 of these switches were not included in the switches tested, the test results are representative setpoint in models and can be used in this analysis. The greatest change (error) for a decreasing other errors in these tests is 2.8% of span. Assuming this error is random and independent of the radiation effect of the this analysis, a value of (+1- .028

• 88 psig = +1-2.5 psig) is to be used for the Static-O-Ring switch.

testing. The

6. The seismic effect or error is defined as the change in setpoint due to seismic

2. Six switches seismic effect of the static-o-ring pressure switch is determined from attachment switches were tested. Though the model 6TA-B3-U8-C1A-JJTTNQ and 6TA-B3-U8-CIA-JJTTX12 and can be used in were not included in the test, the results are representative of these models of span.

this analysis. The greatest change for a decreasing setpoint in these tests is 4%

of (+/- .04

• 88 Assuming the error is random and independent of the errors in this analysis, a value psig = +1-3.5 psig) is to be used for the seismic effect. --

CALCULATION SHEET Rev I Date ?JZgf/l , Boston Edison Sheet _R_ of 34d FORM 4. CALCULATION SHEET CALCULATION NUMBER I-NI-195

7. The circuit leakage allowance is applicable to low energy analog signals only. The RCIC low pressure switches are mechanical on/off switches. Therefore, this error is not applicable.

8. The RCIC steam line low pressure switches connect to the process at approximately 44'- 6" elevation in the drywell. Reference drawings M1 001 sh 55 and 56 and MIOOBC21-3. the pressure switches are located in the reactor building and are shown on drawings M15 and M1 P355-5. The instrument line drywell penetrations are shown on drawings M1002 sh. 68 and 69. These drawings delineate the instrument line routing and are used to determine equipment elevations in the below static head calculation.

The instrument lines are maintained filled with condensate which creates a static head that is sensed by PS1360-9A ,B ,C & D. Due to dimensional differences, these four installations have different instrument line static heads. This analysis will use the installation which has the greatest head to determine uSensed Instrument Setpoint". The sensed instrument setpoint is equal to the process setpoint plus instrument line greatest static head.

The instrument line head is a function of reactor pressure, and drywell and reactor building temperature. The operating conditions which causes the greatest static head will be assumed.

The conditions are reactor pressure equal to 50 psig, drywell ambient temperature equal to 120 deg. F and reactor bldg. ambient temperature equal to 60 deg. F (reference Pilgrim Unit 1 Specification E-536, Figure C.4.1-18 and FSAR Table 10.9-1).

Instrument Line Greatest Static Head Static Head = [Process Conn. El. -D.W. Pent. El] Density Inside Drywell

= [45.25'-17.19'] x (61.73 lbs./ cu. ft.) / 144 sq. in. / sq. ft.

=12.03 psig

CALCULATION SHEET Rev 1 Date 7 , Boston Edison Sheet 9R of "154 FORM 4. CALCULATION SHEET CALCULATION NUMBER l-NI-195-Static Head Static Head = [D.W. Pent. El. -Instrument El. ] Density Outside Drywell

=117.19' - 4.583'] x (62.38 lbs./ cu. ft.)/144 sq. in./ sq. ft.

= 5.46 psig Total Static Head = 17.5 psig The effects on the instrument setpoint of this static head being less than maximum will introduce a nonconservative error between the setpoint and the upper analytical limit. The instrument line installation and operating condition (LOCA) which provides the least static head is calculated below. This value is to be used when determining the instrument line static head error. See Form 3, sheet 3, item 1 Ob.

The operating condition is reactor pressure equal to 50 psig, drywell ambient temperature equal to 330 deg.F and reactor bldg. ambient temperature equal to 112 deg. F (reference Pilgrim Unit I Specification E-536, Figure C.4.1-18 and Table 7.0-1).

Instrument Line Least Static Head Static Head = [ Process Conn. El. - Drywell Pent. El. ] Density Inside Drywell

[44.3'- 17.11' ][.14306 Ibs./cu. ft. ] /144 sq. in. 1sq. ft.

= .03 psig (Flashing)

Static Head [ Drywell Pent. El. - Inst. El. ] Density Outside Drywell

= [17.11' - 6.58' ][ 61.84 lbs./ cu. ft. ]/144 sq. in. 1sq. ft.

= 4.52 psig Total Static Head = 4.55psig

CALCULATION SHEET Rev 1 Date -- 7 S- Boston Edison Sheet 1. of A24 FORM 4. CALCULATION SHEET CALCULATION NUMBER I-Nl-195 Instrument Line Static Head Error Error = Maximum Static Head - Minimum Static Head

= 17.5 psig - 4.55psig

= 13 psig This error will make the switch trip sooner on a decreasing signal and therefore will be subtracted from the upper Analytical Limit when determining the setpoint.

9. The sensor drift was statistically analyzed in Attachment no. 3 in accordance with ABB Impell Project Instruction 25-226-PI-001. The analysis used empirical data from 6/20/88 through 6/27/96 obtained from the PNPS as-found as-left instrument calibration records (reference PNPS Procedure 8.M.2- 2.6.4). The calibration frequency of the switches for the above data is once per 3 months. The drift interval for the above analysis is 30 months. This interval is determined by combining consecutive surveillance's that do not require interim calibration. The value obtained from the statistical analysis has a probability and confidence of 95/95 %.

The sensor drift determined is considered to include the effects of measurement and test equipment (M&TE) and sensor basic accuracy. Therefore, values will not be entered in this calculation for SCA (calibration accuracy) or SA (sensor accuracy). It is assumed the accuracy of the M&TE used for calibration is less than or equal to the instrument being calibrated (reference PNPS Procedure 1.3.36).

10. The errors identified in this calculation are to be used to determine the setpoint and allowable value. See Form 3, sheets 2 and 3. Because of the instrument line static head, the process setpoint and allowable value are different than the "sensed" instrument setpoint and notify watch engineer value. The relationship between these values are:

Instrument Setpoint = Process Setpoint + Maximum Instrument Line Static Head Notify Watch Engineer Value = Allowable Value + Maximum Instrument Line Static Head

CALCULATION SHEET Rev I Date 4 Boston Edison Sheet I*I of.__

FORM 4. CALCULATION SHEET CALCULATION NUMBER I-N 1-195 The process setpoint and allowable value are:

Process Setpoint = 70 psig Allowable Value = 70 +/- 7 psig The instrument setpoint and notify watch engineer value are:

Instrument Setpoint = 87.5 Notify Watch Engineer Value = 87.5 +/- 7 psig

CALCULATION SHEET V Boston Edison REV 1 DATE 7//I. SHEET 1Z OF 3.__

Calculation Number I-N1-195 Instrument NumberPS1360-9A,B,C&D_

FORM I INSTRUMENT DATA Page 1of 9 TITLE DESCRIPTION/VALUE I REFERENCE REMARKS PS1360-9A, B, C & D Dwg. M245" INSTRUMENT NUMBER RCIC Turb. Steam Line Low FSAR Section 7.3.4.8 SERVICE DESCRIPTION Press. Isolation Q PNPS Q-Ust QUALITY CATEGORY Yes, EQ Area 1.7 Environmental ENVIRONMENTAL Qualification Master List QUALIFICATION GENERAL See Note I FSAR Section 7.3.4.7.9 INFORMATION SAFETY FUNCTION (IF APPLICABLE)

TECHNICAL 100 psig >p > 50 pslg Technical Specification SPECIFICATION Table 3.2.B (IF APPLICABLE)

Static-O-Ring Data sheet See Note 2 MANUFACTURER M221ADS7 6TA-B3-NX-C1A-JJTTX12 & Data sheet See Note 2 MODEL NUMBER 6TA-B3-U8-C1A-JJTTNQ M221ADS7

__________________________ I ________________________________ I _________________________________________ ___________________________________ L

CALCULATION SHEET S Boston Edison REV 1 DATE ,/*Z /7 SHEET 1' OF 3' Calculation Number IN1 -1 95 Instrument Number PS1360-9A,B,C&D_

FORM I INSTRUMENT DATA Page 2 of 9 TITLE I DESCRIPTION/VALUE I REFERENCE REMARKS

> 50 pslg, <100 pslg FSAR Table 7.3-2 See Notel ANALYTICAL LIMIT S&SA Memo 95-10 (AL) 70 +/- 7 psig Form 3, Sheet 3 this calc. See Note 10 ALLOWABLE VALUE (process pressure)

(AV)

SETPOINT TRIP 70 psig ( process press.) Form 3, Sh. 3 this calc. See Note 10 RESET < 79 psig (process press.) Form 3, Sh.4 this calc.

N/A Decreasing selpolnt NORMAL OPERATION UPPER LIMIT (NUL)

INSTRUMENT 940 pslg PNPS Procedure 2.1.1 SETPOINT DATA NORMAL OPERATION LOWER LIMIT_(NLL)

Adjustable, 12 TO 100 pslg SOR Inc. Form 216 PROCESS CALIBRATED and 651 RANGE 870 psig Form 3 Sheet 4, OPERATING MARGIN this calc.

(OM)*

• NOTE: ADEQUATE OPERATING MARGIN IS REQUIRED BETWEEN THE SETPOINT AND THE NORMAL OPERATION UPPER OR LOWER LIMIT, AS APPLICABLE, TO AVOID INADVERTENT TRIPS DUE TO PROCESS NOISE, TRANSIENTS AND MEASUREMENT UNCERTAINTIES.

CALCULATION SHEET V Boston Edison SHEET 14- OF 3+

REV 1 DATE / h7 -

Calculation Number I-N1-195 Instrument NumberPS1360-9A,B,C&D_

FORM 1 INSTRUMENT DATA Page 3 of 9 DESCRIPTION/VALUE REFERENCE REMARKS TITLE 12 TO 100 pslg SOR Inc. Form 216 and 651 ADJUSTABLE RANGE RCIC Steamllne Dwg. M245 INPUT SIGNAL FROM N/A Instrument Is a pressure INPUT SIGNAL switch CALIBRATED RANGE RCIC automatic DWG. M1GI2-12 INSTRUMENT OUTPUT SIGNAL TO isolation SETPOINT DATA (CONT)

N/A Instrument is a pressure OUTPUT SIGNAL switch CALIBRATED RANGE Once per 3 months PNPS Tech. Spec. This calculation Is performed plus 25% Table 4.2.b and based on a 24 month SETPOINT CALIBRATION Section 1.0, u calibration frequency. The Tech. Spec. isto be revised.

FREQUENCY

CALCULATION SHEET

Boston Edison REV 1 DATE ZiaIg 7 SHEET_'15"OF -9+

Calculation Number I-NI-195. Instrument NumberPS1360-9A,B,C&D_

FORM 1 INSTRUMENT DATA Page 4 of 9 TITLE DESCRIPTION/VALUE [ REFERENCE REMARKS

-2.5 pslg Attachment I See Note 4 TEMPERATURE EFFECT (Te)

+/- 2.5 psig Attachment 2 See Note 5 ENVIRONMENT RADIATION EFFECT ALLOWANCE (EA) (Re)

FORM 3 STEP 1 N/A Equipment Is STEAM/CHEMICAL environmentally sealed and SPRAY EFFECT (S/Ce) located In secondary cont.

PRESSURIZATION N/A Attachment I See Note 3 (EXTERNAL) EFFECT (Pe)

+/- 3.5 psig Attachment 2 See Note 6 SEISMIC EFFECT (Se)

N/A See Note 7 CABLE LEAKAGE (CI)

CIRCUIT LEAKAGE N/A See Note 7 ALLOWANCE (LA) TERMINAL BLOCK FORM 3 STEP 2 LEAKAGE (TI)

PENETRATION N/A See Note 7 LEAKAGE (PI)

CALCULATION SHEET 0 Boston Edison SHEET 'ý6 OF-3" REV 1 DATE h7 Instrument NumberPS1360-9A,B,C&D_

Calculation Number I-N1-195 Page 5 of 9 FORM 1 INSTRUMENT DATA TITLE I DESCRIPTION/VALUE REFERENCE REMARKS TITLE N/A See Note 7 SPLICE LEAKAGE (SI)

CIRCUIT LEAKAGE ALLOWANCE (LA) See Note 7 N/A (CONTINUED)

SEALING DEVICE LEAKAGE (DI)

See Note 8

- 13 pslg Dwgs. M1001, Sh 55 & 56; M1002, Sh 68 & 69; PROCESS M1 OOBC21-3; M1 P355-5; PROCESS MEASUREMENT M15 and ASME.Stm Table ALLOWANCE (PA) ACCURACY (Pma) No primary element. Switch N/A FORM 3 STEP 3 ' directly sensors process.

PRIMARY ELEMENT ACCURACY (Pea)

See Note 9 N/A SENSOR CALIBRATION CALIBRATION ACCURACY (Sca)

ALLOWANCE No rack equipment N/A (CA)

FORM 3 STEP 4 RACK EQUIPMENT CALIBRATION ACCURACY (Rca)

CALCULATION SHEET

ý Boston Edison SHEET/'7 OF 3+

REV 1 DATE , zs- u 7 Calculation Number l-N1-195 Instrument NumberPS1360-9A,B,C&D_

FORM I INSTRUMENT DATA Page 6 of 9 DESCRIPTION/VALUE REFERENCE REMARKS TITLE N/A No rack equipment RACK EQUIPMENT ACCURACY (Rea)

N/A No rack equipment RACK TEMPERATURE EFFECTS (Rte)

RACK EQUIPMENT N/A No rack equipment ALLOWANCE (RA)

FORM 3 STEP 5 RACK POWER SUPPLY EFFECTS (Rps)

N/A No rack equipment RACK EQUIPMENT MISCELLANEOUS EFFECTS (Rme)

CALCULATION SHEET i Boston Edison REV-i1 DATE...-..IL7 SHEET I_ OF VLý Calculation Number I-N1 -195 Instrument Number_PS1360-9A,B,C&D_

FORM 1 INSTRUMENT DATA Page 7 of 9 TITLE ' DESCRIPTION/VALUE REFERENCE REMARKS N/A See Note 9 SENSOR BASIC ACCURACY (Sa)

N/A Sensor Is not a differential SENSOR STATIC pressure switch PRESSURE SPAN SHIFT (Ssps)

N/A Sensor Is not a differential SENSOR STATIC pressure switch SENSOR PRESSURE ZERO SHIFT ALLOWANCE (SA) (Sspz)

FORM 3 STEP 6 N/A Sensor Temperature effect SENSOR Included In Temperature TEMPERATURE Effect, Te EFFECTS (Ste)

N/A SENSOR POWER SUPPLY EFFECTS (Spse)

N/A SENSOR MISCELLANEOUS EFFECTS (Sme)

CALCULATION SHEET

, Boston Edison 2T7 SHEET )9 OFj3L+.

REV 1 DATE Calculation Number __I-N`1-195 Instrument NumberPS1360-9A,BC&D_

FORM I INSTRUMENT DATA Page 8 of 9 TITLE DESCRIPTION/VALUE REFERENCE REMARKS

+ 4.7 pslg Attachment 3 95/95 drift value based on 30 months. See note 9 SENSOR DRIFT (Sd)

DRIFT ALLOWANCE (DA) N/A No rack equipment FORM 3 STEP 7 RACK EQUIPMENT DRIFT (Red)

+5 psig PNPS Procedure 8.M.2-2.6.4 SENSOR TOLERANCE (St)

TOLERANCE ALLOWANCE (TA) N/A No rack equipment FORM 3 STEP 8 RACK EQUIPMENT TOLERANCE (Ret)

CALCULATION SHEET SBoston Edison REV 1 DATE V9j SHEET ) OF__0__

Calculation Number___ I-N1-195__ Instrument Number_PS1360-9Ao B, C & D__

FORM 2B CALCULATION INPUT SHEET (DECREASING SETPOINT)

DESCRIPTION ABBREVIATIONNALUE

• COMMENTS I'JrUV'I,Ji L %JrC*?AII,,JN r

UPPER LIMIT 4- NUL  : N/A I-NORMAL OPERATING BAND NORMAL OPERATION 4 4- NLL = 940 PSIG LOWER LIMIT OPERATING MARGIN CbM = 870 PSIG RESET VALUE 4- RV - 96.5 PSIG TRIP SETPOINT 4 4 TSp** 70 PSIG SEE NOTE 10 DRIFT ALLOWANCE (DAj SENSOR DRIFT Sd +/- 4.7 PSIG SEE NOTE 9 RACK EQUIPMENT DRIFT Red N/A TOLERANCE ALLOWANCE TAl SENSOR TOLERANCE St +/-5 PSIG RACK EQUIPMENT TOLERANCE Ret N/A ALLOWABLE VALUE AV** 70 +/- 7 PSIG SEE NOTE 10 TEMPERATURE EFFECT Te - 25 PSIG SEE NOTE 4 RADIATION EFFECT Re +/-2.5 PSIG SEE NOTE 5 ENVIRONMENTAL STEAM/CHEM SPRAY S/Ce N/A ALLOWANCE (EA) EFFECT PRESSURIZATION (EXT.) Pe N/A EFFECT T SEISMIC EFFECT Se = +/-3.5 PSIG SEE NOTE 6 0

T CABLE LEAKAGE CI = N/A A TERMINAL BLOCK LEAKAGE TI N/A L CIRCUIT LEAKAGE PENETRATION LEAKAGE PI = N/A ALLOWANCE (LA) SPLICE LEAKAGE SI = N/A L SEALING DEVICE LEAKAGE DI = N/A 0

0 PROCESS MEASUREMENT Pma = -13 PSIG SEE NOTE 8 P PROCESS ACCURACY ALLOWANCE (PA) PRIMARY ELEMENT Pea = N/A U ACCURACY N

C CALIBRATION SENSOR CALIBRATION ACCURACY Sca = N/A E ALLOWANCE (CA) RACK EQUIPMENT Rca = N/A R CALIBRATION ACCURACY T

A RACK EQUIPMENT RACK EQUIPMENT ACCURACY Rea = N/A I ALLOWANCE (RA) RACK TEMPERATURE EFFECT Rte = N/A N RACK POWER SUPPLY EFFECT Rps = N/A T RACK EQUIPMENT Rme = N/A Y MISCELLANEOUS EFFECT SENSOR BASIC ACCURACY Sa N/A SENSOR SENSOR STATIC PRESSURE SPAN SHIFT Ssps N/A ALLOWANCE (SAt SENSOR STATIC PRESSURE ZERO SHIFT Sspz N/A SENSOR TEMPERATURE EFFECTS Ste N/A SENSOR POWER SUPPLY EFFECTS Spse N/A SENSOR MISCELLANEOUS Sine N/A EFFECTS

>5OPSIG, BUT "ANALYTICALLIMIT AL = <- v*PýIr"4

• NOTE: VALUES ARE IDENTIFIED FOR MAGNITUDE ONLY AND ARE COMBINED IN ACCORDANCE WITH THE EQUATIONS ON FORM 3

"**NOTE: CALCULATED VALUE FROM FORM 3

CALCULATION SHEET SBoston Edison REV 1 DATE 2.-0 q9 SHEETrZ OF FORM 3. CALCULATION SHEET SHEET NO. 1 of 4 Calculation Number I-NI-195 Instrument Number PS-1 360-9A, B, C & D

1. ENVIRONMENTAL ALLOWANCE (EA)

EA = \V(e)2 + (Re) 2 + (S/Ce)2 + (Pe) 2 (Se) 2 2 (N/A) 2 + (N/A (3.5)2 -2.5 =-2.5-4.3 EA= (N/A) + (2.5)2 + )2 +

2. CIRCUIT LEAKAGE ALLOWANCE (LA)

LA=CI + TI + PI + SI + DI LA = _N/A_ + -N/A._ + _N/A_ + _N/A_ +_N/AI = _N/A_

3. PROCESS ALLOWANCE (PA)

PA = (Pma)2 + (Pea)2 PA= V (N/A )2 + (N/A) 2 -13 =_-13

4. CALIBRATION ALLOWANCE (CA)

CA= (Sca)2 + (Rca) 2 CA= (N/A )2 + (N/A) 2 =N/A.

5. RACK EQUIPMENT ALLOWANCE (RA)

RA = (Rea) 2 + (Rte) 2 + (Rps) 2 + (Rme)2 RA= (N/A) 2 + (N/A) 2 + (N/A) 2 + (N/A) 2 =NA

CALCULATION SHEET SBoston Edison REV__I DATE XiJ28 1?1 SHEET 22- OF 2'Ed FORM 3. CALCULATION SHEET SHEET NO. 2 of 4 Calculation Number I-NI-195 Instrument Number PS-1360-9A, B, C & D

6. SENSOR ALLOWANCE (SA)

SA= \ (Sa) 2 + (Ssps + Sspz) 2 + (Sie)2 + (Spse)2 + (Sme)2 SA= (N/A) 2 + (N/A +N/A )2 + (N/A) 2 + (N/A) 2 + (N/A) 2 SA = N/A

7. DRIFT ALLOWANCE (DA)

DA = \// (Sd)2 +(Red) 2 DA= \// (4.7) 2 +(N/A) 2

= +4.7

8. TOLERANCE ALLOWANCE (TA)

TA = (St)2 + (Ret) 2 TA= (5) 2 +(N/A ) 2 =_+ 5

9. TOTAL LOOP UNCERTAINTY ALLOWANCE (TLU) 2 2 2 TLU = LA +/-\_/(EA)2 + (PA) 2 + (CA) 2 + (RA) 2 + (SA) + (DA) + (TA)

TLU= N/A +V/(4.3)2+(N/A)2+(N/A)2+(N/A)2+(N/A)2+(4.7)2+(5)2

\ -2.5 -13 TLU= +8.1 - 23.6

CALCULATION SHEET SBoston Edison SHEET Z* OF '3q-FORM 3. CALCULATION SHEET SHEET NO. 3 of 4 Calculation Number I-NI-195 Instrument Number PS-1360-9A, B, C & D

10. TRIP SETPOINT (TSp) IN PROCESS UNITS 10A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IF DECREASING SETPOINT)

TSp = AL - TLU TSp = _N/A_ -._N/A_ = _N/A__

1OB. FOR DECREASING SETPOINT- FROM 2B: (ENTER N/A IF INCREASING SETPOINT)

LOWER AL UPPER AL TSp = AL + TLU Tsp = AL - TLU TSp = _50_ + _8.1 = -58.1 Tsp = -100_ - 23.6- = _76.4_

CHOSE A SETPOINT = 70 PSIG (PROCESS PRESSURE) SEE NOTE 10

11. ALLOWABLE VALUE (AV) 1IA. FOR INCREASING SETPOINT- FORM 2A: (ENTER N/A IF DECREASING SETPOINT) 2 AV TSp + V/DA2 + TA 2

AV = _N/IA +V LN/A_)2 + (_N/A)

AV =_N/A_

11 B. FOR DECREASING SETPOINT - FORM 2B: (ENTER N/A IF INCREASING SETPOINT)

AV = TSp - \/DA 2 + TA2 AV = _70 - V (_4.7_)2 + (_5_)2 AV = 70 +/- 6.9_PSIG;_ SAY 70 +/- 7 PSIG (PROCESS PRESSURE)

CALCULATION SHEET REV 1 DATE E Boston Edison FORM 3. CALCULATION SHEET SHEET NO. 4 of 4 Calculation Number I-NI -195 Instrument Number PS-1360-9A, B, C & D

12. OPERATING MARGIN (OM) 12A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IFDECREASING SETPOINT)

OM = TSp - NUL OMM = _N/A_ - _N/A_ = _N/A_

12B. FOR DECREASING SETPOINT - FORM 2B: (ENTER N/A IF INCREASING SETPOINT)

OM = NLL-TSp OM = _940_ - _70_ = _870 PSIG__ (PROCESS PRESSURE) SEE NOTE 10

13. RESET VALUE (RV) 13A. FOR INCREASING SETPOINT - FORM 2A: (ENTER N/A IF DECREASING SETPOINT)

RV > NUL RV = _N/A._

NUL=-_N/A 13B. FOR DECREASING SEIPOINT - FORM 2B: (ENTER N/A IF INCREASING SETPOINT)

RV < NLL RV -.. < 79 PSIG_ (PROCESS PRESSURE)

NLL = _940 PSIG__ FROM DATA SHEET M221ADS7 RESET DIFFERENTIAL GREATEST VALUE EQUAL TO 9 PSI i.e. RV = SP + RESET DIFF.

14. TRIP SETPOINT (TSp) IN PROCESS UNITS TSs = TSp MODIFIED BY THE FACTORS ACCOUNTING FOR CONVERSION FROM PROCESS UNIT TO SIGNAL UNITS (VOLTS, AMPS, COUNTS, etc.).

TSs = _ N/A . (NOTE: DOCUMENT CONVERSION ON FORM 4)

CALCULATION SHEET Rev I Date 2/2J877 SBoston Edison Sheet, Z5 of .9___

FORM 4. CALCULATION SHEET CALCULATION NUMBER I-NI1-1 95 CALCULATION WORK OR REMARKS:

References

1. Drawings

"* M245, Rev. 25 - P&ID RCIC System

"* M1G2-5, Rev. E9 - Function Control Diagram RCIC System

"* M1G12-12, Rev. E14 - ElementaryDigramnRCIC System

"* M1P355-5, Rev.E3 - Arrangement Drawing Leak Detection Instrument Rack 2257

"* M1001 Sh. 55, Rev. 5 -RCIC System Diff. Press. 1360-1

"* M1001 Sh. 56, Rev. 4 - RCIC System Diff. Press. 13 60-1

"* M1002 Sh. 68, Rev. 7 - RCIC Instrument Piping to DPIS 1360-1

"* M1002 Sh. 69, Rev. 7 - RCIC Instrument Piping to DPIS 1360-1

"* M100BC21-3, Rev. E3 - RCIC Syst. Steam Supply Line to Turbine X-202

"* M15, Rev. E17 - Equipment Location Reactor Building

2. NEDWI 394, Rev. 3; Methodology for Calculation of Instrument Setpoints

3. U.S. NRC Regulatory Guide 1.105, Rev. 2; Instrument Setpoints for Safety Related Systems

4. Instrument Society of America Standard ISA-67.04-1982; Setpoints for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants

5. PNPS - FSAR, Rev. 19

6. PNPS Technical Specification, Rev. 187

7. PNPS Q-List, Rev. E64

8. PNPS Equipment Qualification Master List, Rev. E45

9. PNPS Procedure No. 1.3.36, Rev. 13; Measurement and Test Equipment

CALCULATION SHEET Rev 1 Date ' /Boston Edison Sheet Z6 of L FORM 4. CALCULATION SHEET CALCULATION NUMBER I-NI-195

10. PNPS Procedure No. 2.1.1, Rev. 83; Startup from Shutdown

11. PNPS Procedure No. 8.M.2-2.6.4, Rev. 21; RCIC Steamline Low Pressure

12. ABB Impell Project Instruction No. 25-226-PI-001, Rev. E2; Data Collection and Analysis

13. SOR Inc. Form No. 216 - Rev. 3/90; Pressure Switch by SOR Inc. for Process Applications

14. SOR Inc. Form No. 651 - Rev. 7/93; SOR 1E Qualified Pressure, Vacuum & Temperature Switches for the Nuclear Power Industry

15. Pilgrim Unit 1 Specification E-536, Rev. E5; Environmental Parameters for Use in the Environmental Qualification of Electrical Equipment

16. Data Sheet M221ADS7, Rev. 1

17. Boston Edison Co. Equipment Qualification Data Files; PS1360-9B; Rev. E3

18. SOR Inc. Test Report No. 9058-102, Copyright 1993; Nuclear Qualification Test Report for SOR Pressure, Vacuum, and Temperature Switches (EQDF Ref. 419)

t6t ELý ATTACHMENT 3 PS-1360-98 DRIFT DATA CALC. NO. I-NI-195 1 Re.

DATA CAL.DATA RAW DATA SUM. 1ST OUT. SUM. 2ND OUT. SUM.

DATE STATUS "1.. .D" INT REMARKS "D11 III's "Ds TI "D" D..I" AS FOUND 76 PS1360-gB_

6120188 AS LEFT 76 AS FOUND 76.5 8/13/88 AS LEFT 76.5 AS FOUND 76_

11/13/88 AS LEFT 76 AS FOUND 76.6 2/10/89 AS LEFT 76.6 AS FOUND 73 5114/89 AS LEFT 73 AS FOUND 73 8/14189 AS LEFT 73 AS FOUND 75.4 11/13/891 AS LEFT 75.4 ....

AS FOUND 74 2/15/90 AS LEFT 74 AS FOUND 77 5/16/90 AS LEFT 77 AS FOUND 76_

8/22/90 AS LEFT 76 AS FOUND 77 889 1.00 1.00 1.00 11/26/90 AS LEFT 77 AS FOUND 77 926 0.50 0.50 0.50 2/25/91 AS LEFT 77_

AS FOUND 76.5 955 0.50 0.50 0.50 6/26/91 AS LEFT 76.5 AS FOUND 76 957 -0.60 -0.60 -0.60 9/25/91 AS LEFT 76 1 1 AS FOUND 77 961 4.00 4.00 4.001 12/31/91 AS LEFT 77

_AS FOUND 75.5 964 2.50 2.50 2.50 414/92 AS LEFT 75.5 AS FOUND 74.4 968 -1.00 -1.00 -1.00 7/8/92 AS LEFT 74.4 AS FOUND 73.5 966 -0.50 1 -0.50 -0.50 10/8/92 AS LEFT 73.5 AS FOUND 76 979 -1.00 -1.00 -1.00 1/19/93 AS LEFT 76 i Page 1

ATTACHMENT 3 PS-1360-9B DRIFT DATA CALC. NO. I-Nl-195 Rev, IRev, AS FOUND 75.25 1003 -0.75 -0.75 -0.751 5121193 AS LEFT 75.25 1 1 AS FOUND 76 1018 -1.00 -1.00 -1.00 9/9/93 AS LEFT 76 AS FOUND 75 1015 -2.00 -2.00 -2.00 12/6/93 AS LEFT 75 AS FOUND 74 989 -2.50 -2.50 -2.50 3/11/94 AS LEFT 74 AS FOUND 73.4 999 -2.60 -2.60 -2.60 6/20/94 AS LEFT 73.4 AS FOUND 79 994 2.00 2.00 2.00 1

9/20/94 AS LEFT 79 AS FOUND 75.25 991 -0.25 -0.25 -0.251 75.25 1 1 1 12/21/94 AS LEFT AS FOUND 75 973 0.60 0.60 0.601 318/95 AS LEFT 75 1 AS FOUND 75 995 1.50 1.50 1.50 6/30/95 AS LEFT 75 1 AS FOUND 76.2 974 0.20 0.20 0.20 9/20/95 AS LEFT 76.2 AS FOUND SWITCH REPLACED 10/19/95 AS LEFT 76 AS FOUND 75 12/20/95 AS LEFT 75i AS FOUND 74.5 3/26/96 AS LEFT 74.5 AS FOUND 73.4 6/27/96 AS LEFT 73.4 AVERAGE 0.03 0.03 0.03 STANDARD DEVIATION 1.69 1.69 1.69 COUNT 19 19 19

% OF ORIGINAL DATA POINTS 100.00% 100%

95%/95% TOL INT.DEG F _ 4.66 4.66 I Page 2

ATTACHMENT 5

SUMMARY

OF REGULATORY COMMITMENTS I

Summary of Regulatory Commitments The following table identified those actions committed to by Pilgrim in this document.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory C6mnmitments.

REGULATORY COMMITMENTS DUE DATE

1. Monitor and assess the effects of For three (3) calibration intervals.

decreased calibration surveillance intervals on instrument drift and it's effect on safety.

2. Implement changes to the 90 days following approval of the Technical Specifications within 90 amendment.

days of approval.