ML032680796

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Enclosure 6, WCAP-13705, Revision 5, Westinghouse Setpoint Methodology for Protection Systems, Diablo Canyon Units 1 & 2, 24-Month Fuel Cycle Evaluation, (Nonproprietary)
ML032680796
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 02/28/2003
From: Tuley C
Westinghouse
To:
Office of Nuclear Reactor Regulation
References
DCL 03-111 WCAP-13705, Rev 5
Download: ML032680796 (85)


Text

I Enclosure 6 PG&E Letter DCL 03-111 WCAP-13705, Revision 5, "Westinghouse Setpoint Methodology for Protection Systems, Diablo Canyon Units I & 2, 24-Month Fuel Cycle Evaluation," (Nonproprietary).

Westinghouse Non-Proprietary Class 3 WCAP-13705 February 2003 Revision 5 Westinghouse Setpoint Methodology for Protection Systems Diablo Canyon Units 1 & 2 24 Month Fuel Cycle Evaluation J

WESTINGHOUSE NON-PROPRIETARY CLASS 3 WCAP-13705 Revision 5 Westinghouse Setpoint Methodology for Protection Systems Diablo Canyon Units 1 & 2 24 Month Fuel Cycle Evaluation C. R Tulley February 2003 Westinghouse Electric Company LLC P.O. Box 355 Pittsburgh, PA 15230-0355 0 2003 Westinghouse Electric Company LLC All Rights Reserved 6116NP.doc-031203

iii FOREWORD The Westinghouse Protection System Setpoint Study provides a basis for the Reactor Protection System, and Engineered Safety Features Actuation System values contained in the Technical Specifications. This report contains the results associated with implementation of the Technical Specifications as well as recormmended Trip Setpoints.

The following changes have been made to this document revision:

Pages 2 Updated Reference 4 Pages 3-1 & 3 Updated Reference 6 Page 3 Replaced Reference 6 with Reference 7 Page 3 Added Reference 7 Tables 3-11, 3-18, 3-25, and 2.2-1 (pgs. A-3, A-12)

February 2003 61 16NP.doc-03 1403 Revision 5

V ACKNOWLEDGMENTS The author of this report wishes to acknowledge D. K. Ohkawa, G H. Heberle, and R. M. Jakub for their cooperation and technical assistance throughout the Diablo Canyon Units I and 2 24-Month Fuel Cycle Evaluation Program.

February 2003 61 16NP.doc-03 1403 Revision 5

vii TABLE OF CONTENTS FOREWORD ......................

ACKNOWLEDGMENTS .v LIST OF TABLES .ix I . INTRODUCTION ............................ 1-1

1.1 REFERENCES

/STANDARDS ........................... 1-1 2 COMBINATION OF UNCERTAINTY COMPONENTS . ...........................................................

2-1 2.1 METHODOLOGY ................................................... 2-1 2.2 SENSOR ALLOWANCES ................................................... 2-22 2.3 RACK ALLOWANCES ................................................... 2-4 2.4 PROCESS ALLOWANCES ................................................... 2-5 2.5 MEASURINGAND TEST EQUIPMLENTACCURACY ............................................... 2-5

2.6 REFERENCES

/STANDARDS .................................................... 2-5 3 PROTECTION SYSTEM SETPOINT METHODOLOGY . ...................................3-1 3.1 MARGIN CALCULATION ........................................................... 3-1 3.2 DEFINITIONS FOR PROTECTION SYSTEM SETPOINT TOLERANCES ............... 3-1

3.3 REFERENCES

/STANDARDS ........................................................... 3-8 4 APPLICATION OF THE SETPOINT METHODOLOGY . ..........................................................

4-1 4.1 UNCERTAINTY CALCULATION BASIC ASSUMPTIONS/PREMISES .................... 4-1 4.2 SENSOR/TRANSMITTER PROCEDURAL EVALUATION ........................................ 4-2 4.3 PROCESS RACK OPERABILrrY DETERMINATION PROGRAM AND CRITERIA ................................................ 4-4 4.4 APPLICATION TO THE PLANT TECHNICAL SPECIFICATIONS ............................ 4-4

4.5 REFERENCES

/STANDARDS .................... 4-4 APPENDIX A SAMPLE DIABLO CANYON UNITS I AND 2 SETPOINT TECHNICAL SPECIFICATIONS ...................... A-I February 2003 61 16NP.doc-03 1403 Revision 5

ix LIST OF TABLES Table 3-1 Power Range, Neutron Flux - High and Low Setpoints** . ..............................................

3-9 Table 3-2 Power Range, Neutron Flux - High Positive Rate and High Negative Rate" .... 3-10 Table 3-3 Intermediate Range, Neutron Flux** ..................................................... 3-11 Table 3-4 Source Range, Neutron Flux**.................................................... 3-12 Table 3-5 Negative Steamline Pressure Rate - High ..................................................... 3-13 Table 3-6 Overtemperatitre AT.......................................................................................................3-14 Table 3-7 Overpower AT................................................................................................................3-16 Table 3-8 Pressurizer Pressure - Low And High Reactor Trip . ...................................

3-18 Table 3-9 Pressurizer Water Level - High ...................................................... 3-19 Table 3-10 Loss of Flow..................................................... 3-20 Table 3-11 Steam Generator Narrow Range Water Level - Low-Low . ..............................3-21 Table 3-12 Reactor Coolant Pump Undervoltage** BASLER BEI-27 Relay . 3-23 Table 3-13 Reactor Coolant Pump Underfrequency** BASLER BE1-81 O/U Relay ................... 3-24 Table 3-14 Containment Pressure - High, High-High ........................................... 3-25 Table 3-15 Pressurizer Pressure - Low, Safety Injection ......................................... 3-26 Table 3-16 Steam Line Pressure - Low Rosemount 1154 Transmitter..........................................3-27 Table 3-17 Steam Line Pressure - Low Barton 763 Trinsmitter . ..................................

3-28 Table 3-18 Steam Generator Narrow Range Water Level - High-High . .............................

3-29 Table 3-19 RCS Loop AT Equivalent to Power .................................................. 3-31 Table 3-20 Seismic Trip** Kinemetrics Electromagnetic Seismic Triggers Model TS-33A ........... 3-33 Table 3-21 4.16 KV Bus Undervoltage* Westinghouse Relays/Nominal Setpoint 85 Volts ............ 3-34 Table 3-22 4.16 KV Bus Undervoltage* Westinghouse Relays/Nominal Setpoint 107.8 Volts......... 3-35 Table 3-23 4.16 KV Bus Undervoltage* General Electric Relays/Nominal Setpoint 82.45 Volts ...3-36 Table 3-24 4.16 KV Bus Undervoltage* General Electric Relays/Nominal Setpoint 76.5 Volts ..... 3-37 Table 3-25 Reactor Protection System/Engineered Safety Features Actuation System Channel Error Allowances ............................. 3-39 Table 3-26 Overtemperature AT Calculations ............................. 3-41 Table 3-27 Overpower AT Calculations ............................. 3-43 Table 3-28 AP Measurements Expressed in Flow Units ............................. 344 Table 4.2-1 Sensor/Transmitter As-Found Criteria ............................. 4-3 February 2003 6116NP.doc-031403 Revision 5

1-1 1 INTRODUCTION In Generic Letter 91 04,klt the NRC has noted that uncertainty calculations should be performed in a manner which results in values at a high probability and a high confidence level. The implication of this is that a more statistically rigorous calculation is required. In addition, Generic Letter 9l-l1823 clarifies the NRC's definition of operability. In particular, Generic Letter 91-04 provides guidance on the use of statistically derived drift values based on plant specific operational data. In response to these documents and because of the use of uncertainty values derived from actual plant data, Westinghouse has modified the basic uncertainty algorithm. To address the requirements for a definitive basis for drift, explicit calculations were made to determine appropriate values for the transmitters/sensors.

The basic Westinghouse approach to an uncertainty calculation is to achieve an understanding of the plant instrumentation calibration and operability verification processes. The uncertainty algorithm resulting from this understanding can be ftnction specific, i.e., is very likely different for two functions if their calibration or operability determination processes are different. Effort is expended in determination of what parameters are dependent statistically or functionally. Those parameters that are determined to be independent are treated accordingly. This allows the use of a Square-Root-Sum-Of-The-Squares (SRSS) summation of the various components. A direct benefit of the use of this technique is increased margin in the total allowance. For those parameters determined to be dependent, appropriate (conservative) summation techniques are utilized. An explanation of the overall approach is provided in Section 2.

Section 3 provides a description, or definition, of each of the various components, to allow a clear understanding of the methodology. Also provided is a detailed example of each setpoint margin calculation demonstrating the methodology and noting how each parameter value is utilized. In all cases, margin exists between the summation and the total allowance.

Section 4 provides a description of the methodology utilized in the determination of the Diablo Canyon Units 1 and 2 Technical Specifications and an explanation of the relationship between a trip setpoint and an operability verification. An Appendix is provided noting a recommended set of Technical Specifications using the plant specific data and the revised Westinghouse approach that reflects the plant specific operability verification process.

1.1 REFERENCES

/STANDARDS

1. Generic Letter 91-04, 1991, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24 Month Fuel Cycle."
2. Generic Letter 91-18, 1991, "Information to Licensees Regarding Two NRC Inspection Manual Sections on Resolution of Degraded and Nonconforming Conditions and on Operability."

Introduction February 2003 61 16NP.doc-03 1403 Revision 5

2-1 2 COMBINATION OF UNCERTAINTY COMPONENTS 2.1 METHODOLOGY The methodology used to combine the uncertainty components for a channel is an appropriate combination of those groups which are statistically and functionally independent Those uncertainties which are not independent are conservatively treated by arithmetic summation and then systematically combined with the independent terms.

The basic methodology used is the SRSS technique which has been utilized in other Westinghouse reports. This technique, or others of a similar nature, has been used in WCAP-l O3951'1 and WCAP-8567m 1 . WCAP-8567 is approved by the NRC noting acceptability of statistical techniques for the application requested. Also, various ANSI, American Nuclear Society, and Instrument Society of America standards approve the use of probabilistic and statistical techniques in determining safety-related setpointst 3 41. The basic methodology used in this report is essentially the same as that noted in an ISA paper presented in 1992151.

The relationship between the uncertainty components and the calculated uncertainty fora channel is given in Eq. 2.1, CSA= {(PMA)+ (PE"A )+ (SMTE + SD)2 + (SMTE + SCA)2 + (SPE9 +

(STE) 2 + (SRA) 2 + (RMTE + RD) 2 + (RMTE + RCA)2 + (RvTE +

RCSA)2 + (RTE)2}) 2 + EA + BLAS (Eq. 2.1) where:

CSA = Channel Statistical Allowance PMA = Process Measurement Accuracy PEA = Primary Element Accuracy SMTE = Sensor Measuring & Test Equipment Accuracy SD = Sensor Drift SCA = Sensor Calibration Accuracy SPE = Sensor Pressure Effects STE = Sensor Temperature Effects SRA = Sensor Reference Accuracy RMTE = Rack Measuring & Test Equipment Accuracy RD = Rack Drift RCA = Rack Calibration Accuracy RCSA = Rack Comparator Setting Accuracy RTE = Rack Temperature Effects EA = Environmental Allowance BIAS = One directional, known magnitude This equation was originally designed to address analog process racks with bistables. Digital process racks generally operate in a different manner by simulating a bistable. The protection function setpoint is a value held in memory. The digital process racks compare the flnctions value with the value stored in Combination of Uncertainty Components February 2003 61 16NP.doc-03 1403 Revision 5

2-2 memory. A trip is initiated when the function input corresponds to or exceeds the value in memory. Thus, with the absence of a physical bistable, the RCSA term can be eliminated. Equation 2.1 represents a slight variation from the equations noted in Reference 5. In particular, it has been determined that the calibration accuracies (SCA and RCA) can be treated as random terms rather than biases. This determination for SCA is based on evaluations which showed that the sensor As Left data can be generally characterized as having a near zero mean and a small standard deviation. Although the Eagle 21 rack As Left data was not evaluated. it is considered to be a random term based on the self-checking feature of the Eagle 21 System.

As can be seen in Equation 2.1, drift and calibration accuracy allowances are treated as dependent parameters with the measuring and test equipment uncertainties. The environmental allowance is not necessarily considered dependent with all other parameters, but as an additional degree of conservatism is added to the statistical sum. Bias terms are one directional with a known magnitude and are added to the statistical sum. The calibration terms are treated in the same radical based on the Generic Letter 9104061 requirement for general trending. Pacific Gas & Electric (PG&E) has indicated that trending will be performed to support the requirements of Generic Letter 91-04. This results in a net reduction of the CSA magnitude over that which would be determined if trending was not performed.

It should be noted here that uncertainties for several Reactor Protection System channels were not recalculated by Westinghouse as part of the 24-month fuel cycle evaluation. These channels are the Power Range Neutron Flux High and Low Setpoints, the Power Range Neutron Flux High Positive and High Negative Rates, the Intermediate Range Neutron Flux, and the Source Range Neutron Flux. The CSA equation used for combining the uncertainty components for these channels is the same one used in Revision 2 of WCAP-1 1082, "Westinghouse Setpoint Methodology for Protection Systems, Diablo Canyon Units I and 2, Eagle 21 Version." supporting the current Diablo Canyon Technical Specifications setpoints for those channels. That CSA equation assumed that calibration accuracy and drift are dependent terms, and results in a more conservative CSA than would be obtained if these channels were reevaluated with Equation 2.1. Although these channels were not part of the 24-month fuel cycle evaluation, they have been included in this WCAP for completeness. The uncertainties associated with the Intermediate Range Neutron Flux and the Source Range Neutron Flux channels have been updated by PG&E.

The results in this document are based on the premise that the instrument surveillance program at Diablo Canyon Units I and 2 consists of a combination of quarterly rack tests and sensor/relay calibrations performed each refueling outage. Digital Rack Drift is based on system design. Process Measurement Accuracy P) terms are considered to be conservative values. The cable insulation resistance degradation terms, the reference leg heatup uncertainty for steam generator level, and the transmitter Environmental Allowance terms for transmitters not supplied through Westinghouse were developed by PG&E.

2.2 SENSOR ALLOWANCES Six parameters are considered to be sensor allowances: SCA, SRA, SMTE, SD, STE, and SPE (see Table 3-25). Ofthese parameters, three are considered to be independent (SRA, STE and SPE), and three are considered dependent with at least one other term (SCA, SMTE and SD). SRA is the manufacturer's reference accuracy that is achievable by the device. This term is introduced to address repeatability and Combination of Uncertainty Components February 2003 6116NP.doc.031403 Revision 5

-I------------ ------- ---- -. 1-- I- -,-- - -- - , -

-11 ----.- - -

2-3 hysteresis concerns when only performing a single pass calibration, i.e., one up and one down[5. STE and SPE are considered to be independent due to the manner in which the instrumentation is checked; i.e., the instrumentation is calibrated and drift determined under conditions in which pressure and temperature are assumed constant. An example of this would be as follows. Assume a sensor is placed in some position in the containment during a refueling outage. After placement, an instrument technician calibrates the sensor. This calibration is performed at ambient pressure and temperature conditions. At some later plant shutdown, an instrument technician checks the sensor's performance using the same technique as for the initial calibration and from the two sets of readings a drift value can be determined. The ambient temperature and pressure conditions should be essentially the same as those for the initial calibration.

Therefore, these conditions have no significant impact on the drift determination and are independent of the drift allowance. The discussion about calibration at plant shutdown is for illustrative purposes only and shutdown is not a necessary condition for the data to be valid. Any variations in the data due to changes in calibration temperature will be inherent in the drift result.

SCA, SMTE and SD are considered to be dependent for the same reason that STE and SPE are considered independent; i.e., due to the manner in which the instrumentation is checked. When calibrating a sensor, the sensor output is checked to determine if it is accurately representing the input. The sensor response, measured by applying known inputs and recording the sensor output, involves the calibrated accuracy of both the sensor and the Measuring & Test Equipment (M&TE). The plant specific drift equals the difference between the "as-found" and the previous "as-left" data and therefore involves the actual sensor drift and calibration M&TE. The "as-found" calibration data indicates whether the sensor input/output relationship was within reasonable allowances over the interval since the last calibration. The combination of "as-left" calibration data and plant specific sensor drift indicate whether it is reasonable to expect the sensor to continue to perform this function for future cycles.

Statistically based drift values were determined for all sensors except where there was insufficient data due to recent sensor replacement. In these cases, a thirty (30) month drift value was determined through engineering judgment which considered manufacturer specifications, drift exhibited by devices of the same manufacturer in similar applications, and Westinghouse experience. Drift for the following devices was not statistically based all Pressurizer Pressure transmitters, Containment Pressure transmitters, RCP Undervoltage relays and Steam Pressure Rosemount transmitters.

The calibration accuracy and 30 month drift values were combined with the Measuring & Test Equipment accuracy term to form the dependent relationships. A hypothetical example of the impact of this treatment for a level transmitter is (sensor parameters only):

SCA - _

SRA =

SMTE =

SPE STE T

SD Combination of Uncertainty Components February 2003 61 I6NP.doc-03 1403 Revision 5

2-4 excerpting the sensor portion of Equation 2.1 results in:

4(SMTE + SCA)2 + (SMTE + SD9 +(SPEt + (SE)2 + (SRA)}'2

-or-

] [ =2.0 %

Assuming no dependencies for any of the parameters results in the following:

((SCA) 2 + (SMTE+ + (SD+ + (STE)2 + (SRA)2})1 (Eq. 2.2)

-or-

[  : ]+- = 1.5%

Thus it can be seen that the approach represented by Equation 2.1, which accounts for dependent parameters, results in a more conservative summation of the allowances.

23 RACK ALLOWANCES Five parameters. as noted by Table 3-25., are considered to be rack allowances: RCA, RMTE, RCSA.

RIE, and RD. Three of these parameters (RCA, RMTE, and RD) are considered to be dependent for much the same reason outlined for sensors in Section 2.2. As noted in Section 2. 1, the rack comparator setting accuracy (RCSA) may be eliminated for digital channels. When calibrating or determining drift in the racks for a specific channel, the processes are performed at essentially constant temperature; i.e.,

ambient temperature (which is reasonably controlled). Because of this, the RTE parameter is considered

'to be independent of any factors for calibration or drift. However, the same cannot be said for the other rack parameters. As noted in Section 2.2. when calibrating or determining drift for a channel, the same end result is desired; that is, the point at which the bistable changes state. Based on this logic, these factors have been conservatively summed to form several independent groupings (see Equation 2.1). The impact of this approach (formation of independent groups based on dependent components) is significant.

For the hypothetical example of an analog channel, using the same approach outlined in Equations 2.1 and 2.2 results in the following:

RCA -

RMTE =

RCSA L RTE -

RD excerpting the rack portion of Equation 2.1 results in:

{(RMTE + RCA)2 + (RMTE + RCSA)2 +(RMTE + RD)'+ (RTE) 2 }" 2

-or-

[ - "'a~c= I.5 %

Combination of Uncertainty Components February 2003 61 16NP.doc-03 1403 Revision S

2-5 Assuming no dependencies for any of the parameters yields the following less conservative results:

{(RCA)2 + (RMTE)2 + (RCSA)2 + (RD)2 + (RTE)2 } 1:2 (Eq. 2.3)

-or-r JIt_ 1.3 %

Thus, the use of Equation 2.1 is conservative for rack effects and for sensor effects. Therefore, accounting for dependencies in the treatment of these allowances provides a conservative result. Similar results, with different magnitudes, would be arrived at using digital process rack uncertainties.

2.4 PROCESS ALLOWANCES Finally, the PMA and PEA parameters are considered to be independent of both sensor and rack parameters. PMAprovides allowances for the non-instrument related effects; e.g., neutron flux, calorimetric power uncertainty assurmptions, fluid density changes, and temperature stratification assumptions. PMA may consist of more than one independent uncertainty allowance. PEA accounts for uncertainties due to metering devices, such as elbows, venturis, and orifice plates. Thus, these parameters have been factored into Equation 2.1 as independent quantities. It should be noted that treatment as an independent parameter does not preclude determination that a PMA or PEA term should be treated as a bias. If that is determined to be appropriate, Equation 2.1 would be modified such that the affected term would be treated by arithmetic summation as deemed necessary.

2.5 MEASURING AND TEST EQUIPMENT ACCURACY Based on information from PG&E, it was concluded that the test equipment used for calibration of the transmitters does not meet ISA S51.1 -1979") with regards to allowed exclusion from the calculation. This implies that test equipment without an accuracy of 10 % or less of the calibration accuracy is required to be included in the uncertainty calculations of Equations 2.1 and 3.1. Information from PG&E indicated that the Rack Measuring and Test Equipment (Eagle 21 only) does meet the ISA standard, and therefore the RMTE terms are taken to be zero. The Sensor Measuring & Test Equipment (SMTE) accuracies used in this study represent the maximum allowed inaccuracy of the test equipment.

2.6 REFERENCES

/STANDARDS I. Crigsby, J. M., Spier, E. M., Tuley, C. R., "Statistical Evaluation of LOCA Heat Source Uncertainty," WCAP-10395 (Proprietary), WCAP- 10396 (Non-Proprietary), November 1983.

2. Chelemer, H., Boman, L. H., and Sharp, D. R., "Improved Thermal Design Procedure,"

WCAP-8567 (Proprietary), WCAP-8568 (Non-Proprietary), July, 1975.

3. ANSIANS Standard 58.4-1979, "Criteria for Technical Specifications for Nuclear Power Stations."
4. ANSI/ISA-67.04.01-2000, "Setpoints for Nuclear Safety-Related Instrumentation."

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2-6

5. Tuley, C. R., Williams, T. P., "The Significance of Verifying the SAMA PMC 20.1-1973 Defined Reference Accuracy for the Westinghouse Setpoint Methodology," Instrumentation, Controls and Automation in the Power Industry, Vol. 35, Proceedings of the Thirty-Fifth Power Instrumentation Symposium (2d Annual ISA/EPRI Joint Controls and Automation Conference),

Kansas City, Mo., June, 1992, p. 497.

6. Generic Letter 91-04, 1991, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24 Month Fuel Cycle."
7. Westinghouse Letter to PG&3E, PGE-96-569, J. Hoebel to S. D. Katndar, 6/14/96.
8. Instrument Society of America Standard S51.1-1979 (Reaffirmed 1993), "Process Instrumentation Terminology."

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3-i 3 PROTECTION SYSTEM SETPOINT METHODOLOGY 3.1 MARGIN CALCULATION As noted in Section 2.0, Westinghouse utilizes the square root of the sum of the squares for summation of the various components of the channel uncertainty. This approach is valid where no dependency is present Arithmetic summation is a conservative treatment when a dependency between two or more parameters exists. The equation used to determine the margin, and thus the acceptability of the parameter values used, is:

Margin = TA - ((PMA) 2 + (PEA)2 + (SMTE + SCA)2 + (SMTE + SD)2 +

(SPE) 2 + (STE) 2 + (SRA)2 + (RMTE + RCA)2 + (RMTE +

RCSA) 2 + (RMTE + RD) 2 + (RTE)2 } "2 - EA - BIAS (Eq. 3.1) where:

TA = Total Allowance, which is defined as (Safety Analysis Limit - Nominal Trip Setpoint) and all other parameter-s are as defined for Equation 2.1.

This equation is appropriate when trending of transmitter calibration and drift is taking place. Using Equation 2.1, Equation 3.1 may be simplified to:

Margin =TA- CSA (Eq. 3.2)

For those channels which were not evaluated for the 24-month fuel cycle program, Equation 3.2 may still be used for determining margin. The value for CSA to be used in Equation 3.2 would be based on the CSA equation which was used for that particular channel.

Determination of margin and Total Allowance is appropriate only for those channels which have an explicit Safety Analysis Limit (or other licensing basis limit).

Tables 3-1 through 3-24 provide individual component uncertainties and CSA calculations for the protection functions noted in Tables 2.2-1 and 3.34 of the Diablo Canyon Units I and 2 Technical Specifications. Table 3-25 provides a summary of the Reactor Protection System/Engineered Safety Features Actuation System Channel Uncertainty Allowances for Diablo Canyon Units I and 2 and includes Safety Analysis and Technical Specification values, Total Allowance and Margin. The values in these tables are reported to two decimal places using the conventional technique of rounding down numbers less than 5 and rounding up numbers greater than or equal to 5. Parameters reported in the tables as "N/A", "0", or "-" are not applicable or have no value for that channel.

3.2 DEFINITIONS FOR PROTECTION SYSTEM SETPOINT TOLERANCES To insure a clear understanding of the channel uncertainty values used in this report, the following definitions are provided. For terms which are not defined in this section, refer to ANSI/ISA-67.04.01 -20001'1.

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3-2

  • Analog-to-Digital (AID)

An electronic circuit module used to convert a continuously variable analog signal to a discrete digital signal via a prescriptive algorithm.

  • Allowable Value A bistable trip setpoint (analog function) or CPIJ trip output (digital function) in plant Technical Specifications, which allows for deviation, e.g., Rack Drift plus Rack Measuring & Test Equipment Accuracy, from the Nominal Trip Setpoint. A trip setpoint found non-conservative with respect to the Allowable Value requires some action for restoration by plant operating personnel.
  • As Found The condition in which a transmitter, process rack module or process instrument loop is found after a period of operation. For example, after a period of operation, a transmitter was found to deviate from the ideal condition by -0.5 % span. This would be the 'as found" condition.
  • As Left The condition in which a transmitter, process rack module or process instrument loop is left after calibration or bistable trip setpoint verification. This condition is typically better than the calibration accuracy for that piece of equipment. For example, the permitted calibration accuracy for a transmitter is +0.5 % of span, while the worst measured deviation from the ideal condition after calibration is +0.1 % span. In this instance, if the calibration was stopped at this point (i.e., no additional efforts were made to decrease the deviation) the "as left" error would be

+0.1 % span.

  • Channel The sensing and process equipment, i.e., transmitter to bistable (analog function) or transmitter to CPU trip output (digital finction), for one input to the voting logic of a protection function.

Westinghouse designs protection functions with voting logic made up of multiple channels, e.g., 2/3 Steam Generator Level - Low-Low channels per one steam generator must have their bistables in the tripped condition for a Reactor Trip to be initiated.

  • Channel Statistical Allowance (CSA)

The combination of the various channel uncertainties via SRSS and arithmetic summation, as appropriate. It includes both instrument (sensor and process rack) uncertainties and non-instrument related effects (Process Measurement Accuracy). This parameter is compared with the Total Allowance for determination of instrument channel margin.

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3-3

  • Environmental Allowance (EA)

The change in a process signal (transmitter or process rack output) due to adverse environmental conditions from a limiting accident condition. Typically this value is determined from a conservative set of enveloping conditions and may represent the following:

a) temperature effects on a transmitter, b) radiation effects on a transmitter, c) seismic effects on a transmitter, d) temperature effects on a level transmitter reference leg, e) temperature effects on signal cable insulation, and f) seismic effects on process racks.

  • Margin The calculated difference between the Total Allowance and the Channel Statistical Allowance.
  • Nominal Trip Setpoint (NTS)

A bistable trip setpoint (analog function) or CPU trip output (digital function) in plant Technical Specifications or plant administrative procedures. This value is the nominal value to which the bistable is set, as accurately as reasonably achievable (analog function) or the defined input value for the CPU trip output setpoint (digital function).

  • Normalization The process of establishing a relationship, or link, between a process parameter and an instrument channel. This is in contrast with a calibration process. A calibration process is performed with independent known values, i.e., a bistable is calibrated to change state when a specific voltage is reached. This voltage corresponds to a process parameter magnitude with the relationship established through the scaling process. A normalization process typically involves an indirect measurement, e.g., determination of Steam Flow via the Ap drop across a flow restrictor. The flow coefficient is not known for the restrictor, effectively an orifice, therefore a mass balance between Feedwater Flow and Steam Flow must be made. With the Feedwater Flow known through measurement via the venturi, the Steam Flow is normalized.
  • Primary Element Accuracy (PEA)

Uncertainty due to the use of a metering device, e.g., venturi, orifice, or elbow. Typically, this is a calculated or measured accuracy for the device.

  • Process Loop (Instrument Process Loop)

The process equipment for a single channel of a protection function.

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3-4

  • Process Measurement Accuracy (PMA)

Allowance for non-instrument related effects which have a direct bearing on the accuracy of an instrument channel's reading, e.g., temperature stratification in a large diameter pipe, fluid density in a pipe or vessel.

  • Process Racks The analog or digital modules downstrearn of the transmitter or sensing device, which condition a signal and act upon it prior to input to a voting logic system. For Westinghouse process systems, this includes all the equipment contained in the process equipment cabinets, e.g., conversion resistor, transmitter power supply, R/E, lead/lag, rate, lag functions, function generator, summnator, control/protection isolator, and bistable for analog functions; conversion resistor, transmitter power supply, signal conditioning-AID converter and CPU for digital functions. The go/no go signal generated by the bistable is the output of the last module in the analog process rack instrument loop and is the input to the voting logic. For a digital system, the CPU trip output signal is the input to the voting logic.
  • R/E Resistance (R) to voltage (E) conversion module. The R1D output (change in resistance as a function of temperature) is converted to a process loop working parameter (voltage) by this analog module. Westinghouse Eagle-21 Process Instrumentation System utilizes R/E converters for treatment of RTD output signals.
  • Rack Calibration Accuracy (RCA)

The reference (calibration) accuracy, or accuracy rating as defined by ISA Standard S51. 1-1979('1, for a process loop string. Inherent in this definition is the verification of the following under a reference set of conditions; 1) confornity1 21 , 2) hysteresisl31 and 3) repeatability'4 1 . The Westinghouse definition of a process loop includes all modules in a specific channel. Also it is assumed that the individual modules are calibrated to a particular tolerance and that the process loop as a string is verified to be calibrated to a specific tolerance. The tolerance for the string is typically less than the arithmetic sum or SRSS ofthe individual module tolerances. This forces calibration of the process loop without a systematic bias in the individual module calibrations, i.e., as left values for individual modules must be compensating in sign and magnitude.

For a Westinghouse supplied digital channel, RCA represents calibration of the signal conditioning -AID converter providing input to the CPU. Typically there is only one module present in the digital process loop, thus compensation between multiple modules for errors is not possible. However, for protection functions with multiple inputs, compensation between multiple modules for errors is possible. Each signal conditioning - A/D converter module is calibrated to within an accuracy of [ ]"' for functions with process rack inputs of 4 - 20 mA or 10 - 50 nA, or[ ]*ac for RTD inputs.

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3-5

  • Rack Comparator Setting Accuracy (RCSA)

The reference (calibration) accuracy. or accuracy rating as defined by ISA Standard S51. 1-19791 '1 ,

of the instrument loop comparator (bistable). Inherent in this definition is the verification of repeatabilityl4l under a reference set of conditions.For a single input bistable (fixed setpoint) the typical calibration tolerance is ( ]". This assumes that comparator nonlinearities are compensated by the setpoint For a dual input bistable (floating setpoint) the typical calibration tolerance is [ ] s. This allows for nonlinearities between the two inputs. In many plants calibration of the bistable is included as an integral part of the rack calibration, ie., string calibration. Westinghouse supplied digital channels do not have an electronic comparator, therefore no uncertainty is included for this term for these channels.

  • Rack Drift (RD)

The change in input-output relationship over a period of time at reference conditions. Typical values assumed for this parameter are dd.0 % span for analog channels and [ ]4*.C for digital channels. An example of RD is: for an "as found' value of -0.5 % span and an "as left" value of +0.1 % span, the magnitude of the drift would be {((-.5) - (+0.1) = -0.6 % span) in the negative direction.

  • Rack Measuring & Test Equipment Accuracy (RMTE)

The accuracy of the test equipment (typically a transmitter simulator, voltage or current power supply, and DVM) used to calibrate a process loop in the racks. When the magnitude of RMTE meets the requirements of by ISA Standard S51.1-197915) it is considered an integral part of RCA.

Magnitudes in excess of the 10:1 limit are explicitly included in Westinghouse calculations.

  • Rack Temperature Effects (RTE)

Change in input-output relationship for the process rack module string due to a change in the ambient environmental conditions (temperature, humidity, voltage and frequency) from the reference calibration conditions. It has been determined that temperature is the most significant, with the other parameters being second order effects. For Westinghouse supplied process instrumentation, a value of [ I"" is used for analog channel temperature effects and

[ j]""is used for digital channels. It is assumed that calibration is performed at a nominal ambient temperature of +70 OF.

  • Safety Analysis Limit (SAL)

The parameter value assumed in a transient analysis or other plant operating limit at which a reactor trip or actuation fimction is initiated.

  • Sensor Calibration Accuracy (SCA)

The calibration accuracy for a Sensor or transmitter as defined by the Diablo Canyon Units 1 and 2 calibration procedures. For transmitters, this accuracy is typically +/-0.5 % span as defined by Protection System Setpoint Methodology February 2003 6116NP.doc031403 Revision 5

3-6 PG&E Procedures. Utilizing Westinghouse recommendations for RTD cross-calibration, this accuracy is typically ( ]f for the Hot and Cold Leg RTDs.

  • Sensor Drift (SD)

The change in input-output relationship over a period of time at reference calibration conditions.

An example of SD is: for an "as found"' value of +0.5 % span and an "as left" value of +0.1 %

span, the magnitude of the drift would be ((+0.5) - (+0.1) = +0.4 % span} in the positive direction. For this evaluation, a maximum surveillance interval of 30 months was assumed when projecting drift allowance.

  • Sensor Measuring & Test Equipment Accuracy (SMTE)

The accuracy of the test equipment (typically a high accuracy local readout gauge and DVM) used to calibrate a sensor or transmitter in the field or in a calibration laboratory. When the magnitude of SMTE meets the requirements of by ISA Standard S51.1-1979I51 it is considered an integral part of SCA. Magnitudes in excess of the 10:1 limit are explicitly included in Westinghouse calculations.

  • Sensor Pressure Effects (SPE)

The change in input-output relationship due to a change in the static head pressure from the calibration conditions or the accuracy to which a correction factor is introduced for the difference between calibration and operating conditions for a Ap transmitter.

  • Sensor Temperature Effects (STE)

The change in input-output relationship due to a change in the ambient environmental conditions (temperature, humidity, voltage and frequency) from the reference calibration conditions. It has been determined that temperature is the most significant, with the other parameters being second order effects. It is assumed that calibration is performed at a nominal ambient temperature of

+70 OF.

  • Sensor Reference Accuracy The reference accuracy that is achievable by the device as specified in the manufacturers specification sheets. Reference (calibration) accuracy or accuracy rating for a sensor or transmitter as defined by ISA Standard S51.1-1979"']. Inherent in this definition is the verification of the following under a reference set of conditions; 1) conformity[21, 2) hysteresis131 and 3) repeatability 41 . This term is introduced into the uncertainty calculation to address repeatability concerns when only performing a single pass calibration (i.e., one up and one down),

or repeatability and hysteresis when performing a single pass calibration in only one direction.

Protection System Setpoint Methodology February 2003 61 16NP.doc.03 1403 Revision 5

3-7 Span The region for which a device is calibrated and verified to be operable, e.g., for a Pressurizer Pressure transmitter with a calibrated range of 1250 - 2500 psig would yield a span of 1250 psig.

For Pressurizer Pressure, considerable suppression of the zero and turndown of the operating range is exhibited.

  • SRSS Square root of the sum of the squares, i.e.,

E= J(a)2 + (b)2 + (c) 2 as approved for use in setpoint calculations by ANSIIISA-67.04.01 -2 0 0 0rn.

  • Total Allowance (TA)

The absolute value ofthe calculated difference between the Safety Analysis Limit and the Nominal Trip Setpoint I(SAL - NTS)I in % instrument span. Two examples of the calculation of TA are:

- NIS Power Range Neutron Flux - High SAL 118 % RTP NTS - 109 % RTP TA 9 % RTP If the instrument span = 120 % RTP, then TA= (9 % RTP)(100 % span)/(120 % RTP) = 7.5 % span

- Pressurizer Pressure - Low Trip SAL 1845 psig NTS - 1950 psig TA I- 105 psil = 105 psi If the instrument span = 1250 psi, then TA = (105 psi)(100 % span)/(1250 psi) = 8.4 % span Protection System Setpoint Methodology February 2003 611 6NP.doc.03 1403 Revision 5

3-8

3.3 REFERENCES

/STANDARDS

1. Instrument Society of America Standard S51.1-1979 (Reaffirmed 1993), "Process Instrumentation Terminology," p 6.
2. Ibid, p 8.
3. ibid, p20.
4. Ibid, p 27.
5. Ibid, p 32.
6. ANSIIISA-67.04.01-2000, "Setpoints for Nuclear Safety-Related Instrumentation," p 15, 2000.
7. ibid, p 21.

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-9 Table 3-1 Power Range, Neutron Flux - High and Low Setpoints**

Parameter Allowance*

Process Measurement Accuracy

[_ +aXcc Primary Element Accuracy Sensor Calibration Sensor Pressure Effects Sensor Temperature Effects Sensor Drift Environmental Allowance Rack Calibration Rack Measuring & Test Equipment Accuracy Comparator One input Rack Temperature Effects Rack Drift In percent span (120 % Rated Thermal Power)

Be Not processed by Eagle-21 racks.

Channel Statistical Allowance =

((PMA) 2 + (PEA) 2 + (SCA + SD)2 + (SPE) 2 + (STY) 2 +

_ -1 _+a,e (RCA + RMTE + RCSA + RD)'+ (RTE)}1 2 + EA+ BIAS Protection System Setpoint Methodology February 2003 6116NP.doc-031403 Revision 5

3-10 Table 3-2 Power Range, Neutron Flux - High Positivc Rate and High Negative Rate**

Parameter Allowance*

Process Measurement Accuracy K

+a.c I

Primary Element Accuracy Sensor Calibration

]4te I

Sensor PressureEffects Sensor Temperature Effects

[

Sensor Drift Ii Environmental Allowance Rack Calibration Rack Measuring & Test Equipment Accuracy Comparator One input Rack Temperature Effects Rack Drift In percent span (I20 ff %atedThermal Power)

    • Not processed by Eagle-21 racks.

Channel Statistical Allowance =

{(PMA) 2 + (PEA) 2 + (SCA + SD)2 + (SPE)2 + (STEf +

(RCA + RMTE + RCSA+ RD)2 + (RTE) 2 }I2 + EA + BIAS

[  : a Protection System Setpoint Methodology February 2003 6116NP.doc-03 1403 Revision 5

3-11 Table 3-3 Intermediate Range, Neutron Flux" Parameter Allowance*

Process Measurement Accuracy Primaty Element Accuracy Sensor Calibration I ]+Ile Sensor Pressure Effects Sensor Temperature Effects Sensor Drift Environmental Allowance Rack Calibration Rack Measuring & Test Equipment Accuracy Comparator One input Rack Temperature Effects Rack Drift 4V,.

  • In percent span (conservatively assumcd to be 120 % Ratcd Thermal Power)
  • Not processed by Eaglc-21 racks.

Channel Statistical Allowance =

{(PMA) 2 + (PEA) 2 + (SCA + SD)2 + (SPE) 2 + (STE)2 +

[ (RCA + RMTE + RCSA + RD)- + (RTE9)}' + EA + BIAS

]

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-12 Table 34 Source Range, Neutron Flux**

Parameter Allowance*

Process Measurement Accuracy F

Primary Element Accuracy Sensor Calibration I 1 Sensor Pressure Effects Sensor Temperature Effects

]Ic I

Sensor Drift Environmental Allowance Rack Calibration Rack Measuring & Test Equipment Accuracy Comparator One input Rack Temperature Effects Rack Drift 3x lO4 cps

  • In %span (I xlO6 cps)

A Not processed by Eagle-21 racks.

Channel Statistical Allowance =

{(PMA)2 + (PEA)2 + (SCA + SD)2 + (SPE) + (STE)2 +

(RCA + RMTE + RCSA + RD)' + (RTE 2 }'In+ EA + BIAS

[ 1.a,c Protection System Setpoint Methodology February 2003 611 6NP.doc-03 1403 Revision 5

3-13 Table 3-5 Negative Steamline Pressure Rate - High Parameter Allowance*

Process Measurement Accuracy Primary Element Accuracy Sensor Calibration

[

Sensor Pressure Effects Sensor Temperature Effects 4

I+ac

[

Sensor Drift I

Environmental Allowance Rack Calibration Rack Measuring & Test Equipment Rack Temperature Effects Rack Drift 1n%span(1200psi)

Channel Statistical Allowance =

{(pMA) 2 + (PEA)2 + (SCA + SMTE) 2 + (SMTE + SD)2 + (SPE)2 + (STE) 2 +

(RCA + RMTE) 2 + (RMTE + RD)2 (RTE)2 }112 + EA+ BIAS F

+a,c Protection System Setpoint Methodology February 2003 61 16NP.doc03 1403 Revision S

3-14 Table 3-6 Overtemperature AT Parameter Allowance*

Process Measurement Accuracy

+a,c P+s I

I raLC I I beete Primary Element Accuracy Sensor Calibration Accuracy

]+&C

],,C Sensor Reference Accuracy jtzlc C ..

Sensor Measuring & Test Equipment Accuracy 11c I IJ4 Sensor Pressure Effects Sensor Temperature Effects I

Sensor Drift Environmental Allowance Rack Calibration Accuracy I

[1 <14*

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-15 Table 3-6 (continued)

Overtemperature AT K

Parameter Allowance*

Rack Measuring & Test Equipment Accuracy 4a.2c

[ I3hsc 1 jIaxc Rack Temperature Effect I

I ^c I

Rack Drift I ]1C I

I I-

  • I perCnt AT span (AT -96.6 °F - Unit 1 (this is bounding for thc Unit I uprated value of 98.6 TF); 97.5 IF - Unit 2)

NH= #of hot leg RTDs - 2 Nc = # of cold leg RTDs - I Channel Statistical Allowance =

{(PMA)2 + (PEA) +

[{(SMTEAT +SDAT) 2 +(SMTE&T +SCAAT) 2 +

NH 2

(SMTEAT +SDAT) +(SMTENI. +SCAr)2 }'t] 2

+

Nc 2

[fRMTEAr +RDgr) +(RTEAT) 2 +(RMTEAT +RCAsr)2 +

(RMTEAT + RDAT )2 + (RTEAT) 2 + (RMTEA&T + RCA&T )2 l +

NC (SMTEp + SDpf + (SRAP)2 + (SPE ) 2 + (STE )2 + (SMTEp + SCAp) 2 +

2 2 (RMTEp + RDp) + (RTEp) + (RMTEp + RCAp) 2(RMTEA, + RDMt 2 + 2(RTEh, 1)2 + 2(RMTEm + RCAM9I i!2 + EA + BIAS 1U-4 Protection System Setpoint Methodology February 2003 6116NP.doc.031403 Revision 5

3-16 Table 3-7 Overpower AT' Parameter Allowance*

Process Measurement Accuracy I-- - +ac I

I I +9.c I

I 1-1-&C I-Mc I

Primary Element Accuracy Sensor Calibration Accuracy

[

Sensor Reference Accuracy I ]ta Sensor Measuring & Test Equipment Accuracy I

Sensor Pressure Effects Sensor Temperature Effects Sensor Drift I Ic Environmental Allowance AT - Cable IR Effects (+1 OF)

Tavg - Cable IR Effects (+8 IF)

Rack Calibfation Accuracy I: I].k Rack Measuring & Test Equipment Accuracy I

I+*IC Protection System Setpoint Methodology February 2003 61 16NP.doc03 1403 Revision 5

. - -..- 1-1-1-1--l-I - . -I,,- --- .- I- --- - -.-I - - I..- - -- --- - ------- - - - - - --- -- -- -

3-17 Table 3-7 (continued)

Overpower AT' Parameter Allowance*

Rack Temperature Effect Rack Drift nhpecent AT span (AT - 96.6 ° - Unit I (this is bounding for dhe Unit I uprated value oF 98.6 eF); 97.5 TF - Unit 2)

N3 =# of hot leg RIDs = 2 N(= # of cold leg RIDS = I Channel Statistical Allowance

((pMA) 2 + (pEA) 2 +

2

[{(SMTEAT +SDa&.) +(SMTEAT +SCAAT) 2 +

NH 2 2 2 (SMTEA.T +SSDM ) +(SMTEAT +SCAAT) )'}] +

NC 2 2

[{(RMTEM. + RDAr) + (RTEAT) + (RMTEAT + RCAAT) 2 +

NH 2

(RMTEAT + RDAT)2 + (RTE AT) 2 + (RMTEAT + RCAAT) }2 ] 2 }" +

NC EA + BIAS Protection System Setpoint Methodology February 2003 6116NP.doc03 1403 Revision S

3-18 Table 3-8 Pressurizer Pressure - Low And High Rcactor Trip Parameter Aflowane*

+a.c Process Measurement Accuracy Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Rack Calibration Acclracy Rack Measuring & Test Eqmipment Accuracy Rack Temperature Effect Rack Drift

  • In percent span (1250 psi)

Channel Statistical Allowance =

{(PMA)2+ (PEA) 2 + (SMTE + SD)2 + (SRA)2 + (SPE) 2 + (STE) 2 +

(SMTE + SCA)2 + (RMTE + RD) 2 + (RTE) + (RMTE + RCA) 2})" + EA + BLAS

]+ac

[

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-19 Table 3-9 Pressurizer Water Level - High Parameter Allowance*

Process Measurement Accuracy aU,c 1"-

I -#c I 4 I

Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Eflects Sensor Temperature Effects Sensor Drift/Process Effects (30 months)**

Environmental Allowance Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift

  • Tn percent span (100 %j
    • A drift allowance of *+5.0% has been calculated based on the Pressurizer Level as-found and as-left data. Since Rosemount transmitter drift is typically in the range of +0.6 % to *+12%, it is the joint P(;&E and Westinghouse engineering judgment that the *5 % drift is caused by installationlconriguration effects associated with the DP level measurement system, as well as the transmitter. As long as the as-found and as-left data reflects both the process effects and transmitter drift, the 5 %

process.transmitter drift allowance may be used to verify continued performance consistent with historical data.

Channel Statistical Allowance

((PMA) 2 + (PEA) 2 + (SMTE + SD)2 + (SRA? + (SPE) 2 + (STE-)2 +

(SMTE + SCA)2 + (RTE) 2 + (RMTE + RD) + (RMTE + RCA) 2 " 2 + EA + BIAS

+Zc

[

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision S

3-20 Table 3-10 Loss of Flow Parameter Allowance*

Process Measurement Accuracy

- +SFac

[

Primary Element Accuracy Sensor Calibration j+a.t Sensor Reference Accuracy 4+Oe Sensor Measuring & Test Equipment Accuracy 11a,c

[

Sensor Pressure Effects rc Sensor Temperature Effects J+LC Sensor Drift Bias Rack Calibration 1j6.c Rack Measuring & Test Equipment Accuracy Rack Temperature Effects Rack Drift

  • In % flow span (120.0 % Thermal Design Flow). Percent A span converted to flow span via Equation 3-28.8, with F.,-, 120.0 % and FN - 90 %

Channel Statistical Allowance

{(PMA) 2 + (PEA) 2 + (SMTE + SD) 2 + (SRA)2 + (SPE) 2-+ (STE)2 +

(SCA)2 + (RTE) 2 +(RMTE + RD) 2 + (RMTE + RCA)2 "2 + EA+ BIAS

[  :]c Protection System Setpoiit Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-21

'ruble 3-11 Steam Generator Narrow Range Water Level - Low-Low (assumed scaling pressure 1010.5 psia)

Parameter Allowance*

Process Measurement Accuracy** _ac

[ 143,C I~~~~~~~~~~

Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Transmitter Elevated Temperature Effects Reference Leg Heatup Cable IR Effects Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drif_

  • In percent span (100 %S)
    • [1 Protection System Setpoint Methodology February 2003 6116NP.doc-031403 Revision 5

3-22 Table 3-11 (continued)

Steam Generator Narrow Range Water Level - Low-Low (assumed scaling pressure - 1010.5 psia)

Channel Statistical Allowance

{(PMA) 2 + (PEA)2 + (SMTE + SD)2 +(SRAY2 + (SPE 2 +

(SThY+SMTE + SCA) 21- t AERD)" + RT+/-+)2 -- tMIEt RCA) 2 ) '+ EA+ HIAS J1-ac

[

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision S

3-23 Table 3-12 Reactor Coolant Pump Undervoltagc**

BASLER BEl-27 Relay Parameter Allowance*

Process Measurement Accuracy Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift

  • In Volts
    • Not processed by Eagle-21 racks.

Channel Statistical Allowance =

{(PMA) 2 + (PEA) 2 + (SMTE + SD)2 + (SRA) 2 + (SPE)2 + (STE) 2 +

(SMTE + SCA)2 + (RMTE + RD) 2 + (RTE9 + (RMTE + RCA) } + EA + BIAS Protection System Setpoint Methodology February 2003 6116NP.doc-031403 Revision 5

3-24

'rable 3-13 Reactor Coolant Pump Underfrequency**

BASLER BEl-81 O/U Relay Parameter Allowance*

Process Measurement Accuracy -_ _ e Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects***

Sensor Drift (30 months)

Environmental Allowance Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift

  • In Hertz
    • Not processed by Eagle-21 racks.
      • Based on cngineeringjudgment not specified byVendor.

Channel Statistical Allowance =

{(PMA)- + (PEA) 2 + (SMTh + SD)2 + (SRA) 2 + (SPE)2 + (STE)2 +

[ 3 (SMTE + SCA) 2 + (RMTE + RD) 2 +(RTE) 2 + (RMTIE + RCA)-) 11-+ EA + BIAS Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-25 Table 3-14 Containment Pressure - High, High-High Parameter Allowance*

Process Measurement Accuracy +c Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift In percent span (60 psi.)

Channel Statistical Allowance =

[ ((PMA) 2 + (PE.A) 2 + (SMTE + SD) 2 + (SRA) 2 + (SPEf + (STE) 2 +

(SMTE + SCA)2 + (RMTE + RD) 2 + (RTE) 2 + (RMTE + RCA)2}1 ' + EA + BIAS j fa.c Protection System Setpoint Methodology February 2003 6116NP.doc.031403 Revision 5

3-26 Table 3-5 Pressurizer Pressure -Low, Safety Injection Parameter Allowance*

Process Measurement Accuracy __+ac Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Transmitter Effects Cable IR Effects Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift In percent span (1250 psi)

Channel Statistical Allowance =

I (PMA) 2 + (PEA)2 + (SMTE + SD9 + (SRA)2 + (SPE32 + (STE)2 +

(SMTE + SCA) 2 + (RMTE + RDl) 2 + (RTE) 2 + (RMTE + RCA)f2 "2 + EA + BIAS

[  : 3]

Protection System Setpoint Methodology February 2003 6116NP.doc6031403 Revision 5

3-27 Table 3-16 Steam LUne Pressure - Low Rosemount 1154 Transmitter Parameter Allowance Process Measurement Accuracy _asc Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Transmitter Effects (RI 154SH9 Temp and Pressure effect)

Cable IR Effects Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift Tag Nos. - P515 (Unit 1), P524 (Unit 1), P545 (Unit 2)

In percent span (1200 psi)

Channel Statistical Allowance =

{(PMA) 2 + (PEA)2 + (SMTE + SD)2 + (SRA) 2 + (SPE) 2 + (STE) 2 +

(SMTE + SCA) 2 + (RMTE + RD)2 + (RTE)2 + (RMTE + RCA) 2 }12 + EA + BIAS

[ j'a]

Protection System Setpoint Methodology February 2003 6116NP.doc.031403 Revision 5

3-28 Table 3-17 Steam Une Prcssure - Low Barton 763 Transmitter Parameter Allowance Process Measurement Accuracy Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Transmitter Elevated Temperature Effects Cable IR Effects Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift _

Tag Nos. - P514, P515 (Unit 2), P516, P524 (Unit 2),

P525, P526, P534, P535., P536, P544, P545 (Unit 1), P546 In percent span (1200 psi)

Channel Statistical Allowance =

{(PMA) 2 + (PEA) 2 + (SMTE + SD)2 + (SRA) 2 + (SPE)2 + (STE)2 +

(SMTE + SCA) 2 + (RMTE + RD) 2 + (RTp)2 (RMT + RCA) 2 ) 2 + A + BAS

[ ' +

]

Protection System Setpoint Methodology February 2003 6116NP.doc-03 1403 Revision 5

I;. 1 3-29 Table 3-18 Steam Generator Narrow Range Water Level - High-High (assumed scaling pressure - 1010.5 psia)

Parameter Allowance*

Process Measurement Accuracy** _ +a,c I +S.c

]+*A II Ic I I Nc I ] s I I+C I

I I

Primary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipmeat Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environmental Allowance Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift lnpercentspan(100%)

    • [ Ac Protection System Setpoint Methodology February 2003 61 16NP.doc.03 1403 Revision 5

3-30 Table 3-18 (continued)

Steam Generator Narrow Range W~ater Level - Hligh-HIlgh (assumed scaling pressure - 1010.5 psLa)

Channel Statistical Allowance =

{(PMA) 2 + (PEA)2 + (SMTE + SD)2 + (SRAf 2 + (SPEf)+ (STE) 2 +

(SMTE + SCA9-+ (RMTE + RD)2 + (RTE) 2 + (RMTE + RCA) 2t +

EA + BIAS J+axv

[

Protection System Setpoint Methodology February 2003 61 16NP.doc03 1403 Revision 5

3-31 Table 3-19 RCS Loop AT Equivalent to Power Parameter Allowance*

Process Measurement Accuracy

] +e I

I

]+N.c

{Iin I

Primary Element Accuracy Sensor Calibration Accuracy I+*C I

Sensor Reference Accuracy

[ ] li.

Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift I ]<0e Environmental Allowance I ]+&C Rack Calibration Accuracy I

Rack Measuring & Test Equipment Accuracy

[

Rack Temperature Effect Rack Drift I L

In percent AT span (AT - 96.6 IF - Unit I (this is bounding for the Unit I uprated value of 98.6 OF); 97.5 °F -Unit 2)

NH -f Nof hot leg RTDs - 2 N - #of coldleg RTDs-1 Protection System Setpoint Methodology -February 2003 61 16NP.doc-03 1403 Revision 5

3-32

'fable 3-19 (continued)

RCS Loop AT Equivalent to Power Channel Statistical Allowance =

{(PMA9 + (PEA)2 +

[{(SMTEsr + SDAT) 2 + (SMTE&T + SCAAT) 2 +

NH 2

(SMTE,,T + SDs1 ) + (SMTEAT + SCAr) 2 ) 1 1] 2 +

NC 2

[f(RMTEAr +RDAsr) +(RTEAT) 2 +(RMTEAT +RCAAT) 2 +

NH 2

(RMTENI. +RDAT) +(RTEATI,) +(RMTEAT +RCANI-)2 )1/2i] 2 1/2 +

NC EA + BIAS I +Oc

[

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision S

3-33 Tablc 3-20 Seismic Tnp**

Kinemetrics Electromagnetic Seismic Triggers Model TS-33A Parameter Allowance*

Process Measurement Accuracy +avc Priinary Element Accuracy Sensor Calibration Accuracy Sensor Reference Accuracy Sensor Measuring & Test Equipment Accuracy Sensor Pressure Effects Sensor Temperature Effects Sensor Drift (30 months)

Environinental Allowance Rack Calibration Accuracy Rack Measuring & Test Equipment Accuracy Rack Temperature Effect Rack Drift

  • In units of acceleration, fraction of the gravitation constant, g. (where g - 32.2 fIsec')
    • Not processed by Eagle-21 racks.

Channel Statistical Allowance =

{(PMA) + (PEA)2 + (SMTE + SD)2 + (SRA)2 + (SpE)2 + (STE)2 +

(SMTE + SCA) 2 + (RMTE + RD)2 + (RTE)2+ (RMT + RCA)y) "2+

EA + BIAS

[_ +a1c Protection System Setpoint Methodology February 2003 6116NP.doc4031403 Revision 5

3-34 Table 3-21 4.16 1KV Bus Undervoltage*

Westinghouse Relays/Nominal Setpoint 85 Volts This CSAis the responsibility of PG&E and will be developed as part of other activities.

Channel Statistical Allowance =

This CSA is the responsibility of PG&1E and will be developed as part of other activities.

  • Not processed by Eagle-2 1racks.

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-35 Table 3-22 4.16 KV Bus Undervoltage*

Westinghouse Relays/Nominal Setpofnt 107.8 Volts This CSA is the responsibility of PG&E and will be developed as part of other activities.

Channel Statistical Allowance =

This CSA is the responsibility of PG&E and will be developed as part of other activities.

  • Not processed by Eagle-21 racks.

Protection System Setpoint Methodology February 2003 6116NP.doc-03 1403 Revision S

3-36 Table 3-23 4.16 KV Bus Undervoltage*

General Electric Relays Nominal Setpolnt 82A5 Volts This CSA is the responsibility of PCG&E and will be developed as part of other activities.

Channel Statistical Allowance =

This CSA is the responsibility of PG&E and will be developed as part of other activities.

  • Not processed by Eagle-21 racks.

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-37 Table 3-24 4.16 KV Bus Undervoltage*

General Electric Relays/Noimnal Setpolnt 76.5 Volts This CSA is the responsibility of PG&E and will be developed as part of other activities.

Channel Statistical Allowance =

This CSA is the responsibility of PG&E and will be developed as part of other activities.

  • Not processed by Eagle-21 racks.

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision S

3-38 This page intentionally left blank Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

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Prvtltion Syrem Settpolnt Mthodoloa'v ftbruary 2003 61 16upim-0,4t.1 Itevision 5

3-41 Table 3-26 Overtemperatre AT Calculations

  • The equation for Overtemperature AT:

AT 4S)<ATo {KI -K 2 (I 1 1S) (T-T')+K 3 (P-PI -f (AW))

(I + 5 S) 0 +-t 2 S)

K, (nominal) = 1.20 Technical Specification value Ki (max) = [

K2 = 0.01821°F K3 = 0.000831/psi Vessel T1, = 608.8 OF*

Vessel Tc = 544.4 OF*

Al gain = 2.38 % RTP//o Al

  • Full power AT calculation:

AT span = [ ]-s4C AT span.pwr = 150 % RTP

  • Process Measurement Accuracy Calculations:

[:  : ]+a,

_ 1c I +a,c Al - Incore/Excore Mismatch

[

] +ac

  • These values are based on Unit I operating conditions prior to power uprating which provides the most conservative result.

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-42 Table 326 (continued)

Overtemperature AT Calculations

  • Pressure Channel Uncertainties

-I +8.C Gain =

+F,c SCA =

SRA =

SMTE =

STE =

SD =

P ac RCA =_

RMTE =

RTE =

RD = _

  • AI Channel Uncertainties

+a,c

+a.c RCA RMTE RTE RD =

  • Total Allowance I +a.c

[

  • These values are based on Unit I operating conditions prior to power uprating which provides the most conservative result.

Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-43 Table 3-27 Overpower AT Calculations

  • The equation for Overpower AT:

AT ((I + 5s) < ATO K4 - K ( )3 S T - K 6 r - T1 - f2 (A1)

(l+'uS) 1~5

+ 1rS)

K4 (nominal) = 1.072 Technical Specification value Kg (max) = ( Alec K5 = 0.0 for decreasing average temperature K5 = 0.0174 for increasing average temperature (sec/0 F)

K6 = 0.00145/"F Vessel To = 608.8 OF*

Vessel Tc = 544.4 'F*

  • Full power AT calculation:

]e AT span = [

AT span pwr = 150 % RTP Process Measurement Accuracy Calculations:

I+S,c

[  :+a~c J +ac

[

  • Total Allowance J+ac

[

  • These values are based on Unit I operating conditions prior to power uprating which provides the most conservative result Protection System Setpoint Methodology f 7 February 2003 61 16NP.doc.03 1403 Revision 5

3-44 Table 3-28 AP Measurements Expressed In Flow Units The AP accuracy expressed as percent of span of the transmitter applies throughout the measured span, i.e., +/-1.5 % of 100 inches AP = 41.5 inches anywhere in the span. Because F2 = f(AP) the same cannot be said for flow accuracies. When it is more convenient to express the accuracy of a transmitter in flow terms, the following method is used:

(FN) = APN where N = Nominal Flow 2 FN 3F = 1AP thus aFN- = APN (Eq. 3-28. 1) 2 FN Error at a point (not in percent) is:

aFN,' aAPN = APN (Eq. 3-28.2)

Fix 2 (F.N.)2 2APN and (F) (Eq. 3-28.3)

APmax (F.)2 where max = maximum flow and the transmitter AP error is:

P,N (100) = percent error in Full Scale AP (%/6 e FS AP) (Eq. 3-28.4)

Tm;:

therefore:

r%cFSAP FN = _APMal 100 J OcFSAP][Fmax 12 (Eq. 3-28.5)

FN 2APmx [ F1 ] 1 (2)(100) JI EN J IFaxI Protection System Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

3-45 Table 3-28 (continued)

AP Measurements Expressed in Flow Units Error in flow units is:

r%cFSAPI 12

[ (2)(100) J FN-8 (Eq. 3-28.6) q Error in percent nominal flow is:

aFN (I0=%c FS AP [~ 2 (Eq. 3-28.7)

FN ~'~2[fFN Error in percent fill span is:

F ((100)

I.Fma Ji O P[F]

_ (100) 2CSAPJ [EFML] (Eq. 3-28.8)

Equation 3-28.8 is used to express errors in percent full span in this document.

Protection System Setpoint Methodology February 2003 61 16NPdoc-03 1403 Revision 5

4-1 4 APPLICATION OF THE SETPOINT METHODOLOGY 4.1 UNCERTAINTY CALCULATION BASIC ASSUMPTIONSIPREMISES The equations noted in Sections 2 and 3 have several basic premises which were determined by a systematic review of the calibration procedures utilized at Diablo Canyon Units I and 2 and statistical evaluations of "as left" and "as found" data for the RPSJESFAS functions noted in Tables 3-6 through 3-24:

1. The instrument technicians optimize, within the calibration tolerance, the Nominal Setpoint's "as left" condition at the start of each process rack's surveillance interval,
2. The instrument technicians optimize, within the calibration tolerance, the sensor/transmitter's "as left" condition at the start of each surveillance interval,
3. The process rack drift is limited by the Eagle 21 self-checking feature,
4. The sensor/transmitter drift is trended over the fuel cycle and evaluated (probability distribution function characteristics and drift magnitude) over multiple fuel cycles,
5. The sensor/transmittet calibration accuracy is evaluated (probability distribution function characteristics and magnitude) over multiple surveillance intervals,
6. The sensor/transmitters are calibrated using a one up and one down pass utilizing multiple calibration points (minimum 5 points, as recommended by ISA5 1.1 [I').

It should be noted for (I) and (2) that it is not necessary for the instrument technician to recalibrate a device or channel if the "as left" condition is not exactly at the nominal condition but is within the plus or minus "as left" procedural tolerance. As noted above, the uncertainty calculations assume that the "as left" tolerance (conservative and non-conservative direction) is satisfied on a statistical basis, not that the nominal condition is satisfied exactly. Westinghouse evaluated, using actual Diablo Canyon "as left" data, the achieved sensor calibration accuracy (as-left data) for the RPS/ESFAS sensor/transmitters for Diablo Canyon Units I and 2 over multiple calibration cycles and verified them to be consistent with procedural tolerances and the assumptions of the statistical uncertainty combination methodology.

In summary, a sensor/transmitter or a process rack channel is considered to be "calibrated" when the two-sided "as left" calibration procedural tolerance is satisfied. Anr instrument technician may decide to recalibrate if the "as found" condition is near the extremes of the "as lefr" procedural tolerance, but is not required to do so. Recalibration is explicitly required any time the "as found" condition of the device or channel is outside of the "as left" procedural tolerance. A device or channel may not be left outside the "as left" tolerance without declaring the channel "inoperable" and appropriate action taken. Thus an "as left" tolerance may be considered as an outer limit for the purposes of calibration and instrument uncertainty calculations.

As part of this effort, drift data ("as found" - "as left") for the sensor/transmitters was evaluated. Where data was available. multiple surveillance intervals were evaluated to determine the appropriate values for Application of the Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

4-2 drift for a surveillance interval of 30 months. This evaluation determined that the SD parameter values noted in Tables 3-1 through 3-24 were satisfied on a 95 % probability/95 % confidence level basis for a 30 month surveillance interval. Generic Letter 91-0442 requires that drift be monitored or trended on a periodic basis. The equations used in Sections 2 and 3, assume that drift data is evaluated for continuation of the validity of the basic characteristics determined by the Westinghouse evaluation. This assumption has a significant beneficial effect on the basic uncertainty equations utilized, i.e., it results in a reduction in the CSA magnitude.

412 SENSOR/TRANSMITTER PROCEDURAL EVALUATION Generic Letter 91-04, Enclosure 2, requires that the assumptions of the setpoint evaluations be appropriately reflected in plant surveillance procedures and that a program be in place to monitor and assess the effects of increased calibration surveillance intervals on instrument drift and its effect on safety.

The program should ensure that existing procedures provide data for evaluating the effects of increased calibration intervals. The data should confirm that the estimated errors for instrunment drift with increased calibration intervals are within projected limits. This requirement to monitor instrument drift is consistent with the format of the uncertainty equations noted in Sections 2 and 3 of this WCAP, whereby calibration accuracy and drift are treated as two statistically independent parameters. An implication of this format is that equipment performance should be evaluated based, not only on the capability of the equipment to be calibrated, but also on continued equipment performance which is consistent with the drift allowances based on historical performance and incorporated in the uncertainty calculations.

As input to the verification that sensor/transmitter performance is consistent with the assumptions of the setpoint evaluations, an initial surveillance test procedure evaluation criterion is used, based on an "as found" tolerance about the nominal value. A reasonable value for this tolerance is SMTE + SD. SD is the 95/95 drift value identified in the Diablo Canyon statistical setpoint study based on historical performance, and SMTE is the uncertainty for the MTE used to calibrate the sensors as identified in the Diablo Canyon Units I and 2 procedures. Values for the "as found" tolerance evaluation are provided in Table 4.2-1. The tolerance represents the value for the evaluation criterion based on the SMTE program presently used at Diablo Canyon.

These criteria for sensors can be incorporated into plant procedures as the defined "as found" tolerance about the desired calibration value. If the device is found to be outside these criterion, the device characteristics will be evaluated in conjunction with the previous experience for that specific device to determine whether the device performance is within the assumptions of the Diablo Canyon statistical setpoint study. Additional criteria for field performance evaluation are the ability to calibrate the sensor/transmitter within the two-sided "as left" tolerance and the qualitative response characteristics of the device.

The approach described here provides a reasonable set of initial criteria for input to the sensor/transmitter performance evaluation when used in conjunction with the Diablo Canyon drift monitoring and assessment program. The Diablo Canyon drift monitoring and assessment program should confirm that the observed instrument drift with increased calibration intervals is within the projected limits. More elaborate evaluation and more frequent on-line monitoring may be included, as necessary, if the drift appears to be excessive or the device is difficult to calibrate.

Application of the Setpoint Methodology February 2003 6116NP.doc-031403 Revision 5

4-3 Table 4.2-1 Sensor/Transmitter As-Found Criteria Criteria Function (SD + SMTE)

Pressurizer Pressure - Low, Reactor Trip Pressurizer Pressure - Higb Pressurizer Water Level - High Loss ofFlow Steam Generator Water Level - Low-Low Undervoltage - RCP Underftequency - RCP Containment Pressure - High Containment Pressure - High-High Pressurizer Pressure - Low, SI Steamline Pressure - Low (Rosemount)

Steamline Pressure - Low (Barton)

Steam Generator Water Level - High-High Seismic Application of the Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

4-4 4.3 PROCESS RACK OPERABILITY DETERMINATION PROGRAM AND CRITERIA A program has been determined to define operability criteria for the Eagle 21 digital process racks. Since the process racks are self-checking, the critical parameter is the ability of the process racks to be calibrated within the Rack Calibration Accuracy. These values are currently found in the plant calibration procedures as the "as left" calibration accuracy, and are consistent with the Eagle 21 card/channel Analog Input Verification Test Criteria with the following values:

I-~~ ~~~~~~~

a,c EAI ERI-NR (TEMP)

ERI-WR (TEMP)

ERI-WR (Voltage) _

A channel found in excess of the Rack Calibration Accuracy and less than or equal to the Allowable Value, designated as (RD + RMTE), should be considered operable if the "as left" condition can be returned to within the Rack Calibration Accuracy. If the measured setpoint is found in excess of the Allowable Value, the channel bistable/output device must be evaluated for operability. The channel will be considered inoperable if it cannot be returned to within the Rack Calibration Accuracy regardless of the "as found" value. The Allowable Values are defined as:

EAI 0.20 % Span ER1-NR (TEMP) 0.30 % Span ERI-WR (TEMP) 0.20 % Span ERI-WR (Voltage) 0.20 % Span For the Nuclear Instrument channels, PG&E will use the same definition for Allowable Value as is being applied to the other channels in this setpoint study, i.e., the difference between the Allowable Value and the Nominal Trip Setpoint equals Rack Drift plus Rack Measuring & Test Equipment accuracy.

4.4 APPLICATION TO THE PLANT TECHNICAL SPECIFICATIONS Westinghouse recommends revision of Table 2.2-1 "Reactor Trip System Instrumentation Setpoints" and Table 3.3-4, "Engineered Safety Features Actuation System Instrumentation Trip Setpoints" in the Technical Specifications. Appendix A provides the Westinghouse recommendations for revision of these two tables with the recommended Nominal Trip Setpoint and Allowable Value for each RPS/ESFAS protection finction, which was utilized in the Westinghouse uncertainty calculations and determined to be acceptable for use.

4.5 REFERENCES

/STANDARDS I. Instrument Society ofAmerica Standard S51.1-1979 (Reaffirmed 1993), "Process Instrumentation Terminology," p 33.

2. Generic Letter 91-04, 1991, "Changes in Technical Specification Surveillance Intervals to Accommodate a 24 month Fuel Cycle."

Application of the Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

A-1 APPENDIXA SAMPLE DIABLO CANYON UNITS 1 AND 2 SETPOINT TECHNICAL SPECIFICATIONS Application of the Setpoint Methodology February 2003 611 6NP.doc.03 1403 Revision 5

A-2 Table 2.2-1 Reactor Trip System Instrumentation Trip Setpoints Functional Unit Nominal Trip Setpoint Aflowable Vahics

1. Manual Reactor Trip NA NA
2. Power Range. Neutron Flux
a. Low Setpoint < 25 % of RATED THERMAL POWER < 26.2 % ofRATED THERMAL POWER
b. High Setpoint S 109 % ofRATED THERMAL POWER < 110.2 % of RATED THERMAL POWER
3. Power Range, Neutron Flux, < 5 % of RATED THERMAL POWER with a time c 5.6 % of RATED THERMAL POWER with a High Positive Rate constant >.2 seconds time constant;> 2 seconds
4. Power Range, Neutron Flux, S 5 % ofRATED THERMAL POWER with a time
  • 5.6 % of RATED THERMAL POWER with a High Negative Rate constant > 2 seconds time constant 2 2 seconds
5. Intermediate Range, Neutron Flux c 25 % of RATED THERMAL POWER < 30.6 % of RATED THERMAL POWER
6. Source Range, Neutron Flux c lo" counts per second S 1.4 x 105 coumts per second
7. Overtemperature AT See Note l See Note 2
8. Overpower AT See Note 3 See Note 4
9. Pressurizer Pressure - Low '2 1950 psig > 1947.5 psig
10. Pressurizer Pressure - High < 2385 psig <2387.5 psig
11. Pressurizer Water Level - High S 90 % of instrument span c 90.2 % of instrument span
12. Reactor Coolant Flow - Low > 90 % of minimum measured flow* per loop >.89.8 % of minimum measured flow* per loop e Mininmum Measured Flow Per Loop = 89,800 gpm per loop for Unit I and 90,625 gpumper loop for Unit 2.

Application of the Setpoint Methooology February 2003 611 6NP.doc-031403 Revision 5

A-3 Table 2.2-1 (continued)

Reactor Trip System Instrumentation Irip Setpoints Functional Unit Nominal Trip Setpofnt Allowable Values

13. Steam Generator Water Level - Low-Low > 15.0 % of narrow range instrument span - each Ž 14.8 % of narrow range instrument span - each steam generator steam generator Coincident with:
a. RCS Loop AT Equivalent to Power RCS Loop AT variable input < 50 % RTP RCS Loop AT variable input c 50.7 % RTP

<. 50 % RATED THERMAL POWER With a time delay (TD) c TD (Note 5) c (1.0o1) TD (Note 5)

OR

b. RCS Loop AT Equivalent to Power RCS Loop AT variable input > 50 % RTP RCS Loop AT variable input > 50.7 % RTP

> 50 % RATED THERMAL POWER With no time delay TD =0 TD=0

14. DELETED
15. Undervoltage - RCP  ? 8050 V each bus > 7877 V each bus
16. Underfirequency- RCP 554.0 Hz each bus > 53.9 Hz each bus
17. Turbine Trip
a. Low Autostop Oil Pressure >. 50 psig > 45 psig
b. Turbine Stop Valve Closure >. I % open > I % open
18. Safety Injection Input from ESF NA NA
19. RCP Breaker Position Trip NA NA
20. Reactor Trip Breakers NA NA
21. Automatic Trip and Interlock Logic NA NA Appicationl 01theCSepoint miemodoiogy February 2003 61 16NP.doc.03 1403 Revision 5

A-4 Table 2.2-1 (continued)

Reactor Trip System [nstrumentation Trip Setpoints Functional Unit Nominal Trip Setpolnt Allowable Values

22. Reactor Trip System Interlocks
a. Intermediate Range Neutron Flux, P-6 a I x10Y' 0 amps >8x lIV" amps
b. Low Power Reactor Trips Block, P-7 I. P-10 input I0 % of RATED THERMAL POWER > 8.8 %, S 11.2 % of RATED THERMAL POWER
2. P-13 input S 10 % RATED THERMAL POWER Turbine < 10.2 % RATED THERMAL POWFR Turbine Impulse Pressure Equivalent Impulse Pressure Equivalent
c. Power Range Neutron Flux, P-8 c 35 % RATED THERMAL POWER S 362 % RATED THERMAL POWER
d. Power Range Neutron Flux, P-9 c 50 % RATED THERMAL POWER S 51.2 % RATED THERMAL POWER
e. Power Range Neutron Flux. P-10 10 % of RATED THERMAL POWER  ? 8.8 %, S 11.2 % ofRATED THERMAL POWER
f. Turbine Impulse Chamber Pressure, S 10 % RATED THERMAL POWER Turbine < 102 % RATED THERMAL POWER Turbine P-13 Impulse Pressure Equivalent Impulse Pressure Equivalent
23. Seismic Trip c 0.35g c.0.43g nft..n Qatn-JfEU.. ivv.thiA n 61 n1.^a.i.

-- -1403 - -6N"-0 February 2003 61 16NP.doc4031403 Revision 5

A-5 Table 2.2-1 (contInued)

Reactor Trip System Instrnmentation Trip Setpoints Table Notations Note 1: OVERTEMPERATURE AT AT < AT, (KI -K

>)1+.C, 2 (I+X S)[T-T'I+K 3 (P-P')-fl (AT) where:

AT Measured AT by Reactor Coolant System Instrumentation I + C4S Lead-lag compensator on measured AT I + -T5S T4, 'CS Tine constants utilized in the lead-lag controller for AT, T4 = 0 secs., TS = 0 secs.

AT. Loop specific indicated AT at RATED THERMAL POWER K, (nominal) 1.20 K2 (nominal) 0.0 I82/ 0 F I+ -t1 S The function generated by the lead-lag compensator for T.,, dynamic compensation I +C2S Time constants utilized in the lead-lag controller for T.. T, = 30 secs., C2= 4 secs.

T Average temperature, OF To Nominal loop specific indicated T,,, at RATED THERMAL POWER K3 (nominal) 0.000831/ppsig P. Pressurizer pressure, psig Pt 2235 psig (Nominal RCS operating pressure)

S Laplace transform operator, sec' Application otnme Setpoint Methodology February 2003 61 16NP.doc.031403 Revision 5

A-6 Table 2.2-1 (continued)

Reactor Trip System Instrumentation Trip Setpoints Table Notations (continued) and fi (Al) is a function of the indicated difference between top and bottom detectors of the power range nuclear ion chambers; with gains to be selected based on measured instrument response during plant startup tests such that:

(1) For qt - qb between -19 % and +7 %, fl (Al) = 0 (where qt and qb are percent RATED THERMAL POWER in the top and bottom halves of the core respectively, and qt + qb is total THERMAL POWER in percent of RATED THERMAL POWER);

(2) For each percent that the magnitude of (qt - qb) exceeds -19 %/6,the AT Trip Sctpoint shall be automatically reduced by 2.75 % of its value at RATED THERMAL POWER; and (3) For each percent that the magnitude of (qt - qb) exceeds +7 %, the AT Trip Setpoint shall be automatically reduced by 2.38 % of its value at RATED THERMAL POWER.

Note 2: The Channel's maximum trip setpoint shall not exceed its computed trip setpoint by more than 0.45 % AT span for hot leg or cold temperature inputs, 0.14 % AT span for pressurizer pressure input, or 0.19 % AT span for Al inputs.

Application of the Setpoint Methodology February 2003 61 16NP doc-031403 Revision S

A-7 Table 2.2-1 (continued)

Reactor Trip System Instrumentation Trip Setpolnts Table Notations (continned)

Note 3: OVERPOWER AT AT (U -cAT. {K4 -K 5 (l +XST - K 6 [T -T] - f2 (A)}

where:

AT = Measured AT by Reactor Coolant System Instnnmentation 1+'r4 S = Lead-lag compensator on measured AT I + 15S X4, TS = Time constants utilized in the lead-lag controller for AT, r4 = 0 sees., ¶s= 0 secs.

AT, = Loop specific indicated AT at RATED THERMAL POWER K4 (nominal) = 1.072 K5 (nominal) = 0.01 74/1F for increasing average temperature and 0 for decreasing average temperature

'93S = The function generated by the rate-lag compensator for T,,g dynamic compensation T Tme constants utilized in the rate-lag controller for To, t3 = 10 secs.

Tn=

K6 (nominal) = 0.001 45/0 F for T > T" and 0 for T < rw T = Average temperature, IF V < Nominal loop specific indicated Ti,, at RATED THERMAL POWER S = Laplace transform operator, sect f2 (A) = Ofor all Al Note 4: The Channel's maximum trip setpoint shall not exceed its computed trip setpoint by more than 0.46 % AT span.

Application o0din Setpoint MethodOIogy February 2003 611 6NP.doc-031403 Revision 5

A-8 Table 2.2-1 (continued)

Reactor Trip System Instrumentation Trip SetpoInts Table Notations (continued)

Note 5: Steam Generator Water Level Low-Low Trip Time Delay TD = B1(P) 3 + B2(P)2 + B3(P) + B4 where:

P = RCS Loop AT Equivalent to Power (% RTP), P < 50 % RTP TD = Time delay for Steam Generator Water Level Low-Low Reactor Trip (in seconds)

BI =-0.007218 B2 = +0.8099 B3 = -31.40 B4 = +464.1 I iI laVLIWulm IVIVWvuology 1pimJIJnflIVII U VI February 2003 611I6XP.doc-031403 Revision 5

A-9 Table 3.3-4 Engineered Safety Features Actuation System [nstrumentatfon Trip Setpoints Functional Unit Nominal Trip Setpolnt Allowable Values

1. Safety Injection (Reactor Trip, Feedwater Isolation.

Start Diesel Generators. Containment Fan Cooler Units, and Component Cooling Water)

a. Manual Initiation NA NA
b. Automatic Actuation Logic NA NA
c. Containment Pressure - High <3 psig < 3.12 psig
d. Pressurizer Pressure - Low > 1850 psig > 1847.5 psig
e. DELETED
f. Steamline Pressure - Low >.600 psig (Note 1) >. 597.6 psig (Note 1)
2. Containment Spray
a. Manual Initiation NA NA
b. Automatic Actuation Logic and NA NA Actuation Relays
c. Containment Pressure - High-High e 22.0 psig c 22.12 psig

-&L-4tLP1II1akIuU VI uIII avyIfIUIU xvictnuuuoigy February 2003 61 I6NP.doc-0-1 1403 Revision 5

A-10 Table 3.3-4 (continued)

Engineered Safety Features Actuation System Instrumentation Trip Setpoints Functional Unit Nominal Trip Setpofnt Allowable Values

3. Containment Isolation
a. Phasc "A" Isolation
1) Manual Initiation NA NA
2) Automatic Actuation Logic and NA NA Actuation Relays
3) Safety Injection See Item I above for all Safety Injection Trip Setpoints and Allowable Values.
b. Phase "B" Isolation I) Manual Initiation NA NA
2) Automatic Actuation Logic and NA NA Actuation Relays
3) Containment Pressure - High-High 5 22.0 psig <22.12 psig
c. Containment Ventilation Isolation
1) Automatic Actuation Logic and NA NA Actuation Relays
2) DELETED
3) Safety Injection See Item I above for all Safety injection Trip Setpoints and Allowable Values.
4) Containment Ventilation Exhaust Per the ODCP Radiation-High (RM-44A and 44B)

A -CL- I VI rI11Laiu! Vr OqFpUt IViLVUIVUwlgy February 2003 6116NP.doc-03 1403 Revision 5

A-il Table 3.3-4 (continued)

Engineered Safety Features Actuation System [nstrumentatton Trip Setpoiuts Functional Unit Nominal Trip Setpoint Allowable Valves

4. Steam Line Isolation
a. Manual Initiation NA NA
b. Automatic Actuation Logic and NA NA Actuation Relays
c. Containment Pressure - High-High c 22.0 psig 5 22.12 psig
d. Steamline Pressure - Low 2 600.0 psig (Note 1)  ? 597.6 psig (Note 1)
e. Steam Line Pressure Negative Rate - < 100 psi (Note 3) < 102.4 psi (Note 3)

High S. Turbine Trip and Feedwater Isolation

a. Automatic Actuation Logic Actuation NA NA Relays
b. Steam Generator Water Level - C 75 % of narrow range instrument span c 75.2 % of narrow range instnrment span High-High each steam generator cach steam generator Appiication ortne Sotpoint Methodology February 2003 61 06NPdoc.031403 Revision 5
  • -S A-12 Table 3.3-4 (continued)

Engineered Safety Features Actuation System Instrumentation Trip Setpoints Functional Unit Nominal Trip Setpoint Allowable Values

6. Auxiliary Feedwater
a. Manual Initiation NA NA
b. Automatic Actuation Logic and NA NA Actuation Relays
c. Steam Generator Water Level - > 15.0 % of narrow range instrument span > 14.8 % of narrow range instrument span Low-Low each steam generator each steam generator Coincident with:

I) RCS Loop AT Equivalent to Power RCS Loop AT variable input < 50 % RTP RCS Loop AT variable input c 50.7 % RTP 550 0RTP With a time delay (TD) S TD (Note 2) 5 (1.01) TD (Note 2)

OR

2) RCS Loop AT Equivalent to Power RCS Loop AT variable input > 50 % RTP RCS Loop AT variable input > 50.7 % RTP

> 50 % RTP With no time delay TD=O TD=0

d. Undervoltage RCP > 8050 volts 2 7877 volts C. Safety Injection See Item I above for all Safety Injection Trip Setpoints and Allowable Values.

Application of the Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

Af A-l3 Table 3.3-4 (continued)

Engineered Safety Features Actuation System [nstrumentation Trip Setpoints Functional Unit Nominal Trip Sctpofnt Allowable Values

7. Loss of Power (4.16 kV Emergency Bus Undervoltage)
a. First Level l) Diesel Start TBD by PG&E TBD by PG&E
2) Initiation of Load Shed TBD by PG&E TBD by PG&E
b. Second Level I) Diesel Start TBD by PG&E TBD by PG&E
2) Initiation of Load Shed TBD by PG&E TBD by PG&E
8. Engineered Safety Features Actuation System Interlocks
a. Pressurizer Pressure, P-1 I c 1915 psig c1917.5 psig
b. DELETED
c. Reactor Trip, P-4 NA NA
  • 1.--!--. .- -a. n- ..- ... fl-t. - -

A~ppIicaion o11110 SetpoiIt Methool0ogy February 2003 61 I6KP.doc-03 1403 Revision 5

I . I- -- - - -

A-14 Table 3.34 (continued)

Engineered Safety Features Actuation System Instrumentation Trip Setpolnts Table Notations Note 1: The time constants utilized in the lead-lag controller for Steam Pressure - Low are T. = 50 seconds and T2 = 5 seconds.

Note 2: Steam Generator Water Level Low-Low Trip Time Delay TD = B I(P) 3 + B2(P)2 + B3(P) + B4 where:

P = RCS Loop AT Equivalent to Power (% RTP), P c 50 % RFP TD = Time delay for Steam Generator Water Level Low-Low Reactor Trip (in seconds)

BI = -0.007218 B2 = +0.8099 B3 = -31.40 B4 = +464.1 Note 3: The time constants utilized in the rate-lag controller for Negative Steam Line Pressure Rate -

High are '3 = 50 seconds and r4 = 50 seconds.

Application of the Setpoint Methodology February 2003 61 16NP.doc-03 1403 Revision 5

Enclosure 7 PG&E Letter DCL 03-111 Westinghouse Authorization Letter, CAW-03-1609

. Affidavit Proprietary Information Notice Copyright Notice.

Westinghouse WnguElmpan NuclearServices P.O. Box355 Pittsburgh, Pennsylvania 15230-0355 USA U.S. Nuclear Regulatory Commission Directtel: (412) 374-5282 Document Control Desk Direct faxc (412) 3744011 Washington, DC 20555-0001 e-mail: Sepplha~westinghouse.com Ourref CAW.03-1609 March 13, 2003 APPLICATION FOR WTHHMOLDING tROPRIETARY INFORMAJTION FROM PUBLIC DISCLOSURE

Subject:

WCAP-1 1082, Revision 6 "Westinghouse Setpoint Methodology for Protection Systems, Diablo Canyon Units 1 & 2, 24 Month Fuel Cycle Evaluation" (Proprietary)

WCAP-13705, Revision 5 "Westinghouse Setpoint Methodology for Protection Systems, Diablo Canyon Units I & 2, 24 Month Fuel Cycle Evaluation" (Non-propretary)

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-03-1609 signed by the owner of the proprietary information, Westinghouse Electric Company LLC. The affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (bX4) of 10 CFR Section 2.790 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Pacific Gas and Electric Company.

Correspondence with respect to the proprietary aspects ofthe application for withholding or the Westinghouse affidavit should reference this letter, CAW-03-1609 and should be addressed to the undersigned.

Very truly yours, H.A epp,Mage Regulatory and Licensing Engineering Enclosures cc: S. J. Collins G. ShuldaINRR A BNFL Group company

CAW-03-1609 A! IWA TJI COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF ALLEGHENY:

Before me, the undersigned authority, personally appeared H. A. Sepp, who, being by me duly sworn according to law, deposes and says that he is authorized to execute this Affidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse"), and that the averments of fact set forth in this Affidavitire true and correct to the best of his knowledge, information, and belief:

H. A. Sepp, M Regulatory and Licensing Engineering Sworn to and subscribed before me this L3 day of , 2003 Notary Public MM~ve8o'.A~e&unyotu, X I TMer.le Pernyhori Assocdagla OfNioes

2 CAW-03-1609 (1) I am Manager, Regulatory and Licensing Engineering, in Nuclear Services, Westinghouse Electric Company LLC ("Westinghouse"), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of the Westinghouse Electric Company LLC.

(2) 1 am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Conumissiont regulations and in conjunction with the Westinghouse application for withholding accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by the Westinghouse Electric Company LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.790 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

3 CAW-03-1609 Westinghouse's competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

4 CAW-03-1609 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iii) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Commission.

(iv) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge-and belief.

(v) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in WCAP-1 1082, Revision 6, "Westinghouse Setpoint Methodology for Protection Systems, Diablo Canyon Units I & 2, 24 Month Fuel Cycle Evaluation" (Proprietary), dated February 2003, being transmitted by the Pacific Gas and Electric Company letter and Application for Withholding Proprietary Information from Public Disclosure, to the Document Control Desk. The proprietary information as submitted for use by Westinghouse Electric Company LLC for Diablo Canyon Units I &

2 is expected to be applicable for other licensee submittals in response to certain NRC requirements for justification of changing plant Steam Generator level instrumentation setpoints.

This information is part of that which will enable Westinghouse to:

5 CAW 609 (a) Information in support of a plant license submittal.

(b) Provide plant specific calculations.

Further this information has substantial commercial value as follows:

(a) Westinghouse plans to sell the use of similar information to its customers for purposes of meeting NIRC requirements for licensing documentation associated with Steam Generator level setpoints.

(b) Westinghouse can sell support and defense of the technology to its customers in the licensing process.

(c) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar calculations and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

CAW-03-1609 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.790 of the Commission's regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). 'he justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4Xii)(a) through (4Xii)(f) of the affidavit accompanying this transmittal pursuant to 10 CFR 2.790(bXI).

A CAW-03-1609 COPYRIGHT NOTICE The reports transnitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.790 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.