ML20088A272

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Authorizes Use of Encl 761201 Affidavit Re Withholding Proprietary Westinghouse Info from Public Disclosure
ML20088A272
Person / Time
Site: Wolf Creek, Callaway, 05000000
Issue date: 04/03/1984
From: Wiesemann R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML19268E760 List:
References
CAW-84-28, NUDOCS 8404110303
Download: ML20088A272 (85)


Text

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     ,s Water Reactor                             Box 355 Westinghouse                                                       PittsburghPennsyfvania15230 Electric Corporation    Divisions April 3,1984 CAW-84-28 Mr. Harold R. Denton Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Phillips Building 7920 Norfolk Avenue '

Bethesda, Maryland 20014 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DIS 10SURE

SUBJECT:

Reactor Coolant System Flow Measurement Uncertainty for SNUPPS REF: Letter from SNUPPS to'NRC (Petrick to Denton), April,1984

Dear Mr. Denton:

The proprietary material transmitted by the reference letter for which withholding is being requested by the Standardized Nuclear Unit Power Plant

              . System (SNUPPS) is of the same technical type as that proprietary material previously submitted by Westingnouse concerning-Reactor Protection System / Engineered Safety Features Actuation System Setpoint Methodology. The previous application for withholding, AW-76-60, was accompanied by an affidavit signed by the owner of the proprietary information, Westinghouse Electric Corporation. Further, the affidavit submitted to justify the previous material was approved by the Ccanission on April 17, 1978, and is equally applicable to the subject material. The subject proprietary material is being submitted by the Standardized Nuclear Unit Power Plant System (SNUPPS) for the Kansas City Power and Light Company _ and Kansas Gas & Electric Company's Wolf Creek Unit (STN          -

50 482) and the Union Electric Company's Callaway Unit (STN 50 483). Dit O$ p A

Mr'. H rold R. Denton April 3, 1984 Accordingly, this letter authorizes the utilization by SNUPPS of the previously  ! furnished affidavit. A copy of the affidavit, AW-76-60, dated December 1, 1976, is attached. i Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference CAW-84-28 and should i be addressed to the undersigned. Very truly yours, Robert A. Wiesemann, Manager Regulatory & Legislative Affairs

           /dr Attachment.

cc: E. C. Shomaker, Esq. Office of the Executive Legal Director, NRC S 8 da l I

AW-76-60

                                  ~

AFFIDAVIT C0ff.OlnlEALTH OF PEllNSYLVANIA: ss COUNTY OF ALLEGHEllY: Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-poses and says that he is authorized to execute this Affidavit on behalf of W"estinghouse Electric Corporation (" Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:' , k1L (f d.lLUt.D&t _

                                                              . Robert A. Wiesemann, Manager Licensing Programs Sworn to and subscribed                                         ~

before,methis/ day of'$$ltarblL) 1976.

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              /        Notary Public .,

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                                                                                                                                                 --                     AW-76-60 i

(1) I am Manager, Licensing programs, in the Pressurized Water Reactor i Systems Division, of Westinghouse Electric Corporation.and as such,

                               '                     I have been specifically delegated the function of reviewing the proprietary information sought to be withheld frcm public dis-clEsure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized                                   a to apply for its withholding
                                                      'on behalf of the Westinghouse , Watere Reactor Divisions.
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(2) I am making this Affidavit in conf'ormance with the provisions of

                                                .                  s.            .
                                                       ]O,CFR Section 2.M0 of the Commissien's regulat'icns and in con-junction with the Westinghouse application *for ' withholding ac-
                                                                          ^           '
                                          .             companying this Affidavit.

L,  ; . (3) I?have.per'sonal knowledge of the criteria an'd procedbres . utilized

                              ,a                          .

by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential commercial or financial information.

                                                                                                                     .                             c.

Pursuant to the provisions of paragraph (b)(4) of Section 2.790 (4) ' of the Commission's regulations, the following i,s furnished for l consideration by the Commission in determining'Jhether the in-

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                                       ~ ] formation sought to be withheld from public disclosure should be                                                    '
                                                    .:    Withh41d.                                                                                          >

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The iriformation sought to be. withheld from public disclosure , (i)

                                                                      'is owned and has been lield in confidence by Westinghouse.
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AW-76-60 (ii) The information is of a type customarily held in confidence by Westinghouse and no't 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 ap-plication of that system and the substance of that system constitutes Westinghouse policy and provides the rat.fonal basis required. Under that system, information is held in confidence if it

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falls in one or more of several types, the release of which might result in the loss of an existing or potential com-petitive advantage, as follows: (a) The information reveals the distinguishing aspects of a . process (or component, structure, tool, method, etc.) where preventio'n of its use by any of Westinghouse's

                                                                               ~

j competitors without license from Westinghouse constitutes a competitive economic advantage over other companies. i. (b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the' application of which data s'ecures a competitive economic advantage, e.g. , by optimization or

                                   -  improved marketability.                                         -

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_. _ . .. - - - - . ,. . - - = = - . - _ _ . . - . - - . --

              '                                                                                                                 AW-76-60 (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 cap-

  • acities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) ' It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse. t (f) It contains patentable ideas, for which patent pro- . taction may be desirable. It is not the property of Westinghouse, but must bc

                                                     .(g)
                                                                 . treated as proprietary. by Westinghouse according to agreements witti the owner.           ,
                                                               ~.

There are sound policy reasons behind the Westinghouse

                                                      system which include the following:

f (a)' The use of such information by Westinghouse gives Westinghouse a competitive advantage over its com-i

                                                                   ' petitors . It is,' therefore, withheld from disclosure to protect the Westinghouse competitive position.

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AW-76-60 e i (b) It is information which 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 s information. . (c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of. resources at our expense. * (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 infor-mation, any one component may be the key to the entire

            *                  -             puzzle thereby depriving Westinghouse of a competitive advantage.                                           ~

Unrestricted disclosure would jeopardize the position (e)

                                           ' of prominence of Westinghouse in the world market,
                                            - and thereby give a market advantage to the competition

! in 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.

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      * . I AW-76-60 (iii)            The information is being transmitted to the Comission in i:onfidence and, under the provisions of 10 CFR Section 2.790, it is to be received in confidence by the Comission.            ,

(iv) The information is not available in public sources to the best of our knowledge and belief. ,

                                 ' ('v )    The proprietary information sought to be withheld in this sub-                          ,

mittal is that which is appropriately marked in the attach-ment to Westinghouse letter number NS-CE-1298, Eicheldinger to Stolt, dated December 1,1976, concerning information relating to NRC review of WCAP-8567-P and WCAP-8563 cntitled, " Improved , ' Thermal Design Procedure," defining the sensitivity of DNB ratio to various core parameters. The letter and attachment are being submitted in response to the NRC request at the October.29, 1976 NRC/ Westinghouse meeting. t Thjs information enables Westinghouse to: I (a) Justify the Westinghouse design. (b) Assist its customers to obtain l'icenses. (c) Meet warranties'.

                               .                (d)  Provide greater operational flexibility to customers assuring them of safe and reliable operation.

(e) Justify increased power capability or operating margin l for plants while assuring safe and reliable operation.

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AW-76-60 e (f) Optimize reactor design and performance while maintaining a high level of fuel integrity. 1 Further, the information gained frcm the improved thermal design procedure is of significant commercial value as follows: -

                                  -          (a) Nestinghouse uses the information to perform and justify analyses which are sold to customers.

(b) Westinghouse sells analysis services based upon the , experience gained and the methods developed. Public disclosure of this information concerning design pro-cedures is likely to cause substantial harm to the competitive position of Westinghouse because competitors could utilize this information to assess and justify ttiair own designs without commensurate, expense. The parametric analyses performed and their evaluation represent a cdnsiderable amount of highly qualified development effort. This work was contingent upon a design method development pro-l gram which has been undensay during the past two years. Altogether, a substantial amount of money and effort has been i . expended by Westinghouse which could only be duplicated by a competitor if he'were to invest similar sums of money and pro-I vided he had the appropriate talent available. 1 Further the deponent sayeth not. f , (- s' . . .

Attachment 1 STATUS OF TECHNICAL SPECIFICATION OPEN ISSUES SPECIFICATION SUBJECT ISSUE ACTION Tab. 2.2-1 Reactor Trip and ESFAS Provide final values for Wolf Creek Wolf Creek values should Tab. 3.3-4 Setpoints be forwarded by 7/1/84. 3.1.2.1 Boration Systems This specification, applicable in Modes Included in Attachment 2 3.1.2.5 4, 5, 6, refers to Specification 3.1.2.5 3.1.2.6 which is applicable in modes 5 and 6 only. 3.1.2.7 The volumes and boron concentration in 3.1.2.5 need to be revised to make the specification applicable in Mode 4 also. 3.2.3 RCS Flowrate The NRC requested that SNUPPS provide back- Included in Attachments ground information on how the 2.0% RCS flow 2 and 3. The writeup in uncertainty in this specification was ob- attachment 3 is applicable tained. In a 3/19/34 telecon with the to Callaway only until Callaway Project Manager (J. Holonich) Wolf Creek confirms its SNUPPS reported that the 2% figure was maintenance and test derived using the sane methodology as was equipment errors. Wolf used for Seabrook, Catawba, and McGuire. Creek's submittal will The methodology used is a generic one whose be forwarded under results envelope the SNUPPS design. separate cover. Tab 3.3-7 Seisnic Instrumentation The triaxial response spectrum recorders Included in Attachment 2 require setpoints on each of the three axes. Tab 3.3-10 Accident Monitoring The RCS radiation monitor is not part of Possible appeal issue Tab 4.3-7 Instrumentation the SNUPPS design and its inclusion therein has not been committed to by SNUPPS. Tab 3.3-13 Radioactive Gaseous It is not necessary to place requirements Included in Attachment 2 Tab.4.3-9 Effluent Monitoring on the containment purge system sanplers since these are not the final monitors on the effluent discharge path. Tab 4.3-8 Radioactive Liquid Effluent Revise the wording in item 2d. Included in Attachment 2 Monitoring

Attachment 1 . SPECIFICATION SUBJECT ISSUE ACTION 3.4.9.3 RHR. Suction Relief Valves Justify use of the RHR suction relief Possible appeal item 3.8.1.2 valves for cold overpressurization pro-3.8.2.2 tection. The NRC will allow credit to be 3.8.3.2 taken for only one RHR relief valve at a time - combined with one PORV. 3.5.5 Boron Injection Tank Justification has been provided for dele- NRC complete review on tion of this specification based on a the SNUPPS submittal revised minimum boron concentration. 4.6.1.2.c Containment Type A A recent version of the Technical Speci- NRC Project Managers for Supplemental Leak Tests fications changed the acceptance criteria SNUPPS will follow this for the supplemental tests and removed issue to assure the reference to reduced pressure testing. specification is corrected. The NRC (J. Huang) has agreed that the specification is incorrect 'as presently stated. 3.6.1.4 Containment Pressure Limits Provide the operating pressure limits for included in Attachment 2 this specifica, tion. 3.6.1.6 Containment Structural The NRC changed its position on the pre- Possible appeal issue Integrity viously agreed upon specification. The NRC position is that the proposed speci-fication allows too much time for action after identifying possible structural integrity problems and that the surveil-lances contain action requirements. 3.6.3.b,c Containment Isolation Valves The exclusion of the requirements of spec- Possible appeal issue ification 3.0.4 was recently deleted by the NRC. This puts the plants in a posi-tion where an upward mode change cannot be made if an isolation valve is inopera-ble, even if the affected penetration is isolated. 4.7.6.e.2 Control Room Emergency. Delete reference to a high smoke density Included in Attachment 2 Ventillation test signal.

Attachment 1 , SPECIFICATION SUBJECT ISSUE ACTION .3.7.10.1 Fire Suppression Water Change water supply tank volume require- Included in Attachment 2 ' System ments - Callaway only. 3.7.11 Fire Barrier Penetrations The present LC0 has a typographical error Included in Attachment 2 that makes identification of " fire rated assembly penetrations" uncertain. In addi-tion, a clarification is required to show that." cable tray" vice " cable" penetrations are the items of concern. 4.8.1.1.1.b Fire Suppression for ESF SNUPPS contends that the surveillance for Included in Attachment 2 Transformers these fire protection systems should be located with the applicable fire protection specifications 3.3.3.7 and 3.7.10. 4.8.1.1.2 Solid State Load Sequencer SNUPPS contends that this surveillance Included in Attachment 2 Testing should be located with the other ESFAS instrumentation in Specification 3.3.2. This wou,ld place the requirements in their proper context. In addition, a note should be added indicating that the Actuation Logic Test does not include a continuity check. 4.8.1.1.3 Diesel Generator Voltage Expand allowable voltage range. Included in Attachment 2 Requirements Tab 3.8-1 Containment Penetration Correct table values for 13.8 kV switch- Included in Attachment 2 Conductor Overcurrent gear. Protection Devices Fig 6.2-1 Organizational Charts Provide up-to-date versions of the organ- Included in Attachment 2 Fig 6.2-2 izational charts for Callaway. JHR/dck/2a3,4,6 Attachment 2 PROPOSED TECHNICAL SPECIFICATION CHANGES AND JUSTIFICATIONS ? i

REACTIVITY CONTROL SYSTEMS 3/4.1.2 BORATION SYSTEMS -"*i FLOW PATH - SHUTDOWN LIMITING CONDITION FOR OPERATION 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE and i:apable of being powered from an OPERABLE emergency power source:

a. A flow path from the Boric Acid Storage System via a boric acid transfer pump and a centrifugal charging pump to the Reactor Coolant System if the Boric Acid Storage System in Specification 3.1.2.5a(uct/es Ses#y 9

er Spudunb. 4 is OPERA 8LE; or ,

        '4. i.7.t, o. (latte 4)
b. The flow path from the refueling water storage tank via a centrifugal charging pump to the Reactor Coolant System if the refueling water storage tank in Specification 3.1.2.5b is OPERABLE.

APPLICABILITY: MODES 4, 5, and 6. l ACTION: (thetEs Sc,\d 6) c' D MO 3

  • l.2.Gb hBM h O Witi, none of the aeove fiow paths OeERABtE or capanie of being powered from an OPERABLE emergency power source, suspend all operations involving CORE ALTERATIONS or positive reactivity changes.

SURVEILLANCE REQUIREMENTS 4.1.2.1 At least one of the above required flow paths shall be demonstrated OPERABLE at least once per 31 days by verifying that each valve (manual, ! power-operated, or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position. l Y. ! CALLAWAY - UNIT 1 3/4 1-7 l

REACTIVITY CONTROL SYSTEMS SORATED WATER SOURCE - m Moots 5 MD 6 LIMITING CONDITION FOR OPERATION 3.1.2.5 As a minimum, one of the following borated water sources shall be OPERA 8LE:

a. A Boric Acid Storage System with:
                                                                     .A465
1) A minimum contained borated water volume of-e WF gallons,
2) Between 7000 and 7700 ppe of baron, and
3) A minimum solution temperature of 65'F.
b. The refueling water storage tank (RWST) with:

SSo4 %

1) A minimum contained borated water volume of 53,500 gallons,
2) A minimum boron concentration of 2000 ppm, and
3) A minimum solution temperature of 37'F.

APPLICABILITY: MODES 5 and 6. ACTION: With no borated water source OPERABLE, suspend all operations involving CORE ALTERATIONS or positive reactivity changes. SURVEILLANCE REQUIREMENTS 4.1.2.5 The above required borated water source shall be demonstrated OPERABLE:

a. At least once per 7 days by:
1) Verifying the boron concentration of the water,
2) Verifying the contained borated water volume, and
3) Verifying the Boric Acid Storage System solution temperature when it is the source of borated water,
b. At least once per 24 hours by verifying the RWST temperature when it is the source of borated water and the outside air temperature is less than 37'F.

CALLAWAY - UNIT 1 3/4 1-11

      ~

REACTIVITY CONTROL SYSTEMS

                                                                                                                                 "*    i                       f BORATED WATER SOURCES - 6PERAffte Mott. 4 LINITING CONDITION FOR OPERATION one of 3.1.2.6 As a minimum.dthe following borated water source (s) shall be OPERABLE as required by Specification 3.1.2.'1:

I

a. A Boric Acid Storage System with:

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1) A minimum contained borated water volume of 16;44e gallons,
2) Between 7000 and 7700 ppa of boron, and
                                                                                          ~
3) A minimum solution temperature of 65'F.
b. The refueling water storage tank (RWST) with:
1) A minimum contained borated water volume of 394,000 gallons,
2) Between 2000 and 2100 ppa of boron, ,
3) A minimum solution temperature of 37'F, and ,
4) A maximum solution temperature of 100*F.

APPLICABILITY: MODE /1,2,0,::d4. ACTION: A'. With the c Acid S rage System i able and being used as one . of the above r borated water rc store the s ' age system to OPE us within ours or b at 1 t HOT TANDBY wi- the next u and borated to a SH MARGIN eq 1 to at least 1% 200*F; restore e Bor id Sto e stem to OPE status in the xt 7 days or be SHUT withi he next 30 hours. Ao ben:ted ucter hece. 09EQAfM.Es R5 tare. cac Doftted water he<. C. 4- K With',th: ~.?:T in:;:2 1 , r;;t r; th t::t to OPERABLE status within i h:: ;r h; ir :t 1 ::t TT STf?"'Y dtW the next 6 hours % in COLD SHUTDOWN within the following 46-hours. oc be M ! - hamu.n a c.E QEowAEMc4TS d.t.a.G. T he. obwe. re p red borded atec Source. shan be. demowstratel OPERAG E by the- performa.nc.c of Coch of the rqwremots of spec.ification 4.1, a. S t CALLAWAY - UNIT 1 3/4 1-12 l - - . . . . . . .

I

  • REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES -4PERAHNG MODES t, a, A4 3 LIMITING CONDITION FOR OPERATION 7

3.1.2.E As a minimum, the following borated water source (s) shall be OPERABLE as required by Specification 3.1.2.2:

a. A Boric Acid Storage System with:

i'/ 3658

1) A minimum contained borated water volume of=10,l'2 gallons,
2) Between 7000 and 7700 ppa of boron, and
3) A minimum solution temperature of 65'F.
b. The refueling water storage tank (RWST) with:
1) A minimum contained borated water volume of 394,000 gallons,
2) Between 2000 and 2100 ppm of boron,
3) A minimum solution temperature of 37'F, and
4) A maximum solution temperature of 100'F.

(ad APPLICABILITY: MODES 1,2,A3femHk ACTION:

a. With the Boric Acid Storage System inoperable and being used as one of the above required borated water sources, restore the storage system to OPERABLE status within 72 hours or be in at least HOT STANDBY within the next 6 hours and borated to a SHUTDOWN MARGIN equivalent to at least 1% Ak/k at 200*F; restore the Boric Acid Storage System to OPERABLE status within the next 7 days or be in COLD SHUTDOWN within the next 30 hours.
b. With the RWST inoperable, restore the tank to OPERABLE status within 1 hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

CALLAWAY - UNIT 1 3/4 1-12

REACTIVITY CONTROL SYSTEMS

 -s     SURVEILLANCE REQUIREMENTS 4.l.L 7 4::2::24 Each borated water source shall be demonstrated OPERABLE:
a. At'least once per 7 days by:
1) Verifying the boroa concentration in the water,
2) Verifying the contained borated water volume of the water source, and
3) Verifying the Boric Acid Storage System solution. temperature when it is the source of borated water.
b. At least once per 24 hours by verifying the RWST temperature when the outside air temperature is either less than 37'F or greater than 100*F.

8 O l l 1 l l \ e CALLAWAY - UNIT 1 3/4 1-13

REACTIVITY CONTROL SYSTEMS BASES MDOERATOR TEMPERATURE C0 EFFICIENT (Continued) The most negative MTC value equivalent to the most positive moderator density coefficient (M C), was obtained by incrementally correcting the MDC used in the FSAR analyses to nominal operating conditions. These corrections involved subtracting the incremental change in the E C associated with a core condition of all rods inserted (most positive EC) to an all rods withdrawn condition and, a conversion for the rate of change of moderator density with temperature at RATED THERMAL POWER conditions. This value of the MDC was then transformed into the limiting MTC value -4.1 x 10 4 Ak/k/*F. The MTC value of -3.2 x 10-4 Ak/k/*F represents a conservative value (with correc-tions for burnup and soluble boron) at a core condition of 300 ppe equilibrium boron concentration and is obtained by making these corrections to the limiting MTC value of -4.1 x 10 4 Ak/k/*F. ' The Surveillance Requirements for measurement of the MTC at the beginning and near the end of the fuel cycle are adequate to confirm that the MTC remains within its limits since this coefficient changes slowly due principally to the reduction in RCS boron concentration associ,ated with fuel burnup. 3/4.1.1.4 MINIMUM TEMPERATURE FOR CRITICALITY This specification ensures that the reactor will not be made critical with the Reactor Coolant System average temperature less than 551*F. This limitation is required to ensure: (1) the moderator temperature coefficient is within its analyzed temperature range, (2) the trip instrumentation is within its normal operating range, (3) the pressurizer is capable of being in an OPERABLE status with a steam bubble,.and (4) the reactor vessel is above its minimum RTET temperature.

             -3/4.1.2 BORATION SYSTEMS The Boration Systems ensure that negative reactivity control is available l

during each MODE of facility operation. The components required to perfom this function include: (1) borated water sources, (2) centrifugal charging pumps, (3) separate-flow paths, (4) boric acid transfer pumps, and (5) an emergency power supply from OPERABLE diesel generators. 350 With the RCS average temperature above 200*F, a minimum of two boron See, er't, in injection flow paths are required to ensure single functional capabilit the event an assumed failure renders one at the flow paths inoperable. e 6%e3 PS S 6m3i

  • boration capability of Y e r flow path is sufficient to provide a SHUT 00WN MARGIN from expected operating conditions of 1.3% Ak/k after xenon decay and cooldown to 200*F. The maximum expected boration capability requirement occurs at EOL from full power equilibrium xenon conditions and requires n,456 4erE7 gallons of 7000 ppe borated water from the boric acid storage tanks or h ys4 74;496 gallons of 2000 ppe borated water from the RWST.

CALLAWAY - UNIT 1 B 3/4 1-2

        ,      -. - .-.=::__=.=----                                       ; , _ -        _          _

Insert for page B 3/4 1-2 In MODE 4 one, and only one, flowpath is required to be OPERABLE as is necessary to assure that a mass addition pressure transient can be relieved by the operation of a single PORV or RHR suction relief valve. p._: .

DRAFT REACTIVITY CONTROL SYSTEMS BASES BORATION SYSTEMS (Continued) . With the RCS temperature below 200*F, one Boration System is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restrictions prohibiting CORE ALTERATIONS and positive reactivity changes in the event the single Boron Injection System becomes inoperable. The limitation for a maximum of one centrifugal charging pump to be OPERA 8LE and the Surveillance Requirement to verify all charging pumps except the required OPERA 8LE pump to be inoperable in' MODES 4, 5, and 6 provides assurance that a mass addition pressure transient can be relieved by the operation of a single PORV 3 er G2 wh yeM cru - The baron capability required below 200*F is sufficient to provide a SHUTDOWN MARGIN of 15 Ak/k after xenon decay and cooldown from 200*F to 140*F. ga11ons of 7000 ppe borated water from the This condition boric acid storage requires tanks or either 2tptt7 2 %' gab % of 2000 ppe borated water from th RWST. /q p?c, g,g The contained water volume limits include allowance for water not available . because of discharge line location and other physical characteristics. The limits on contained water volume and baron concentration of the RWST also ensure a pH value of between 8.5 and 11.0 for the solution recirculated within Containment after a LOCA. This pH band minimizes the evolution of i iodine and minimizes the effect of chloride and caustic stress corrosion on l mechanical systems and components. The OPERABILITY of one Boration System during REFUELING ensures that this system is available for reactivity control while in MODE 6. 3/4.1.3 MOVA8LE CONTROL ASSEMBLIES The specifications of this section ensure that: (1) acceptable power

          . distribution limits are maintained, (2) the minimum SHUTDOWN MARGIN is main-tained, and (3) the potential effects of rod misalignment on associated acci-dont analyses are limited. OPERA 8ILITY of the control rod position indicators is required to determine control rod positions and thereby ensure compliance with the control rod alignment and insertion limits. Verification that the Digital Rod Position Indicator agrees with the demanded position within 212 steps at 24, 48, 120 and 228 steps withdrawn for the Control Banks and 18, 210 and 228 steps withdrawn for the Shutdown Banks provides assurances that the Digital Rod Position Indicator is operating correctly over the full range of l             indication. Since the Digital Rod Position System does not indicate the actual shutdown rod position between 18 steps and 210 steps, only points in the indi-cated ranges are picked for verification of agreement wi.th demanded position.

CALLAWAY - UNIT 1 8 3/4 1-3 ausmuis e .m M

                                                            -w+--g-+=y

Specifications 3.1.2.1 3.1.2.5 3.1.2.6 - 3.1.2.7 B 3/4.1.2 Justification These changes are necessary in order to complete the Technical Specification revisions prompted by the SNUPPS cold overpressuri-zation mitigation system. The previous version of the above specifications did not accurately indicate mode requirements or borated water. volumes. m W T k l

                                                      !'+
  , d-k '

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   !     POWER DISTRIBUTION LIMITS 3/4.2.3 RCS FLOW RATE AND NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR LIMITING CONDITION FOR OPERATION 3.2.3 The combination of indicated Reactor Coolant System (RCS) total flow rate and R shall be maintained within the region of allo wable operation shown on Figure 3.2-3 for four loop operation:

Where: N Y AH

a. R
                          = 1. 49 [1. 0 + 0. 2 (1. 0 - P)]

b* THERMAL POWER , and P = RATED THERMAL POWER

c. Fh=MeasuredvaluesofFhobtainedbyusingthemovableincore detectors to obtain a power distribution map. The measured valuesofFhshallbeusedtocalculateRsinceFigure3.2-3 includes penalties for er. detect:d '--*=+=" ventur' feultg ;f 0.L'.' er.d Jor-seasurement uncertainties of 2.0% for flow and 4%

for incore measurement of F APPLICABILITY: MODE 1. ACTION: With the combination of RCS total flow rate and R outside the region of acceptable operation shown on Figure 3.2-3:

a. Within 2 hours either:
1. Restore the combination of RCS total flow rate and R to within .

l the above limits, or

2. Reduce THERMAL POWER to less than 50% of RATED THERMAL POWER and reduce the Power Range Neutron Flux - High Trip Setpoint to less than or equal to 55% of RATED THERMAL POWER within the next 4 hours.

f CALLAWAY - UNIT 1 3/4 2-8

Cau OAy POWER DISTRIBUTION LIMITS LIMITING CONDITION FOR OPERATION ACTION (Continued)

b. Within 24 hours of initially being outside the above limits, verify
 ,                    through incore flux mapping and RCS total flow rate comparison that the combination of R and RCS total flow rate are restored to within the above limits, or reduce THERMAL POWER to less than 5% of RATED THERMAL POWER within the next 2 hours, and
c. Identify and correct the cause of the out-of-1 fait condition prior to increasing THERMAL POWER above the reduced THERMAL POWER limit required by ACTION a.2. and/or b., above; subsequent POWER.0PERATION -

may proceed provided that the combination of R and indicated RCS total flow rate are demonstrated, through incore flux mapping and RCS total flow rate comparison, to be within the region of acceptable operation shown on Figure 3.2-3 prior to exceeding the following THERMAL POWER levels:

1. A nominal 50% of RATED THERMAL POWER, l 2. Anominal75%ofRATEDTHER%L, POWER,and
3. Within 24 hours of attaining greater than or equal to 95% of i

RATED THERMAL POWER. l SURVEILLANCE REQUIREMENTS l 4.2.3.1 The provisions of Specification 4.0.4 are not appifcable. 1 l ' 4.2.3.2 The combination of indicated RCS total flow rate and R shall be determined to be within the region of acceptable operation of Figure 3.2-3:

a. Prior to operation above 75% of RATED THEP. MAL POWER after each fuel loading, and
b. At least once per 31 Effective Full Power Days.

4.2.3.3 The indicated RCS total flow rate shall be verified to be within the region of acceptable operation of Figure 3.2-3 at least once per 12 hours when the most recently obtained value of R, obtained per Specification 4.2.3.2, is assumed to exist. 4.2.3.4 The RCS loop flow rate indicators shall be subjected to a CHANNEL CALIBRATION at least once per 18 months. 4.2.3.5 The RCS total flow rate shall be determined by precision heat balance I measurement at least once per 18 months. Lsut. A , b im.w3 pa g e. d.c.s 6 Lsert. G , GitWm3 pje CALLAWAY - UNIT 1 3/4 2-10

                                             . .. ..                                        -. ..-.; - - . =       .:
          ' Insert'A                                                                                                                                      .

4.2.3.5 (cont) Within seven days ' prior to performing the precision heat balance, the instrumentation used for determination of steam pressure, feedwater pressure, feedwater temperature, and feedwater venturi delta P in the calorimetric calculations, shall be calibrated. Insert B 4.2.3.6 The feedwater venturi shall be inspected for fouling and i . cleaned as necessary.at-least once per 18 months. I a a O J 4 x s t 9- M* r 19 5 P tg um -y=" e m9' g T 4m y e- FF=-%ppNb 8-eF# *W +e- 'I rumN- -"7T'9 9M wr**e-9p

                                                                                                                                                                                                                                         ~

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                                                         - ---                        . . . .= :.;:          ui:. :~; = ~ ;.

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                                  .:._n. . . - , _C A u A v4y
r a/4 2-s

f% Ce t. OAy POWER DISTRIBUTION LIMITS , BASES HEAT FLUX HOT CHANNEL FACTOR, and RCS FLOW RATE AND NUCLEAR ENTHALPY RISE HOT CHANNEL FACTOR (Continued) The Radial Peaking Factor, Fxy (Z), is measured periodically to provide assurance that the Hot Channel Factor, qF (Z), remains within its limit. The F xy limit for RATED THERMAL POWER (Fxy ) as.provided in the Radial Peaking Factor Limit Report per Specification 6.9.1.9 was determined from expectec power control maneuvers over the full range of burnup conditions in the core. WhenRCSflowrateandFharemeasured,noadditionalallowancesare necessary prior to comparison with the limits of Figure 3.2-3. Measurement errors of 2%offor determination theRCS designtotal DNBRflow rate and 4% for Fh have been allowed for in value. The measurement error for RCS total flow rate is based upon performing a precision heat balance and using the result to calibrate the RCS flow rate indicators. Potential fouling of the feedwater venturi which might not be on $n508#D*n detected conservative could bias Therefore,' manner. the result from the precision

p2.5fT.h'~fsr heat balance undetect:ff u. .ng in apf e h pev+eed c4- the feedwater. venturi 3 f: *n:1 d:d in Figer: 3.2-3.

a ny fee!'ng "ich -fght l ii th:~ RCff16.; 'rdte ::::;r =nt ;;r :ter th= 0.1% := be detected-by-monitor 4ng {% :nd tr= ding =ri::: p1=t perf = : p:r=:t:r:. If detected, actier sheH rch.li D. b: tch;n before perferring subsequent-precisien-heat-balance-seasveements,

            -1.0., eith:r th: Offect of the fouling 05:11 b: q =tif4ed =d c--~2. sated-for 4- the   ".CS #10" r:te-measuremet er the venturf 05:11 5: 01: =:d t:- 1f=inate-
            ..u    < . a 4 -,.
                                    /tdd insot. , Guw.n3 pa 5c.

The 12-hour periodic surveillance of indicated RCS flow is sufficient to detect only flow degradation which could lead to operation outside the acceptable region of operation shown on Figure 3.2-3. 3/4.2.4 QUADRANT POWER TILT RATIO The QUADRANT POWER TILT RATIO limit assures that the radial power distribution satisfies the design values used in the power capability analysis. Radial power distribution measurements are made during STARTUP testing and periodically during power operation. l The limit of 1.02, at which corrective action is required, provides DNB and linear heat generation rate protection with x y plane power tilts. A limit of 1.02 was selected to provide an allowance for the uncertainty associated with the indicated power tilt. I The 2-hour time allowance for operation with a tilt condition greater than 1.02 but less than 1.09 is provided to allow identification and correc-tion of a dropped or misaligned control rod. In the event such action does not correct the tilt, the margin for uncertainty on Fqis reinstated by reducing the maximum allowed power by 3% for each percent of tilt in excess of 1. l CALLAWAY - UNIT 1 B 3/4 2-5 l . .. .. . . . . _ . . . . _ _ . - . . - . . . . _ . _

Insert Page B 3/4 2-5 The instrumentation used in the performance of the calorimetric for the precision flow balance shall be calibrated within 7 days of performing the calorimetric.

Specification 3.2.3 Justification See attachment 3 to this letter. Note that either the specification surveillances or the basis, not both, should be revised as shown on the preceding pages. I r-

C m_ omy

                                       ~

TABLE 3.3-7 DRAFT

      ~

SEISMIC MONITORING INSTRUMENTATION MINIMUM MEASUREMENT INSTRUMENTS INSTRUMENTS AND SENSOR LOCATIONS RANGE OPERABLE

1. Triaxial Peak Recording Accelerographs
a. Radwaste Base Slab i 1.0 g i
b. Control Room i 1.0 g I
c. ESW Pump Facility i 1.0 g 1
d. Ctat Structure i 2.0 g i
e. Auxiliary Bldg. SI Pump Suetions i 1.0 g 1
f. SGB Piping i 2.0 g 1
g. SGB Support i 1.0 g 1
2. Triaxial Time History and Response Spectrum Recording System, Monitoring the Following Accelerometers (Active)
n. Ctat. Base Slab i 1.0 g i
b. Ctat. Oper. Floor i 1.0 g 1
c. Reactor Support " . , . i 1.0 g i
d. Aux. Bldg. Base Slab i 1.0 g i
e. Aux. Bldg. Control Room Air Filters i 1.0 g I
f. Free Field i 0.5 g 1
3. Triaxial Response-Spectrum Recorder (Passive)
a. Ctat. Base Slab i 1.0 g 1
4. Triaxial Seismic Switches ACCELERATION LEVEL / DiQEcrieg
a. OBE Ctat. Base Slab ~ .12 1
b. SSE Ctat. Base Slab 0. O g 1 l g 1 I c. OBE Ctat. Oper. F1. O.
d. SSE Ctat. Oper. F1. O g 1 .
                                                                         .01                                1                *
e. System Trigger '

l J NoRTM CA ST YEAN AL.,

                                                .I          o.          o.095                    009 3               c.62 g 6           o. 63 g                  o. W 3              o.ao S N            c.           o. c o q                 o.io S             o. s 3 9 d            o, t q ,                 o.a S              o.m 3 e           o.otg                     0.01 3              o.ol s i                                                         L CALLAWAY - UNIT 1                             3/4 3-44

_.=

e Cou Caty n TABLE 4.3-8

  ?

g RADI0 ACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS E ANALOG

   '                                                                                                                                   CHANNEL CHANNEL    SOURCE      CHANNEL   OPERATIONAL

+ E CHECK CHECK CALICRATION TEST Q INSTRUMENT _ i 1. Radioactivity Monitors Providing Alarm and Automatic Terminat. ion of Release

a. Liquid Radwaste Discharge Monitor (HB-RE-18) D P R(2) Q(1)
b. Steam Generator Blowdown Discharge Monitor D M R(2) Q(1)

(BM-RE-52)

c. Turbine Building Drain Monitor (LE-RE-59) D M R(2) Q(1)

R* d. Secondary Liquid Waste System D P R(2) Q(1) Y Monitor (HF-RE-45) . 3:

2. Flow Rate Measurement Devices D(3) N.A. R N.A.
a. Liquid Radwaste Discharge Line Steam Generator Blowdown Discharge Line 0(3) N.A. R N.A.

b. i 0(3) N.A. R N.A.

c. Secondary Liquid Waste System Discharge i Line Combmed N.A.

. d. ACooling Tower Blowdown-t4ne a.nd 0(3) N.A. R ! bjpas fle: a l

t . 4 TABLE 3.3-13 9 T E RADIDACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION ~ ' s s E ~ t t v . s. E s ~ MINIMUM CHANNELS .

              ,e                                                                                                             INSTRUMENT                                                           s  OPERABLE          _

APPLICABILITY ACTION c -s - 25 *

1. .WASTE GAS HOLDUP SYSTEM Explosive Gas- ,

j , s Monitoring System

s. . .

w x.  ; ,

a. Hydrogen Monitor,s
                                                                                                                                                                            .         i               1/recombiner                          "*                                  44
                                                                                                                                                                                                                                                **                       t
b. Oxygen Monitor 2/recombiner - 42
                                    .                                                                                x                                                                                               N
                                                    '                                                                                                                                                                            a
2. Un't Vent System .
                                                                                                                                                                                                                                                                , j                    ,
                                                                                                                           .q.                                                                                                               .(     _
                                                                                                                                                                                                                                                 *                               '40
            >                                                                                                  a.            Noble Gas Activity Monitor-1                                      -
                                                                                                                                                                                                                                                                                                       \-

5' Providing Alarm (GT-RE-21) , w ',\

  • 43 1 b. Iodine Sampler
s. ,

1 w E c. Particulate Samplerr 3 4

  • N . 1 * '43 to ,

s *L *

d. Flow Rate Monitor \ .y,i'2,~ , 1
  • 39 t
                                               .                                                              1                       N                 , ,
                                                                                                                                                                                                                 +                                                                           g
  • 39
e. - Sampler Flow Rats Monitor ., 1 =
3. bontainmentPurge,Systen'
                                                                                                                                     \                                                                     ,

n

                                                             +                                                           .               .                                    '. s                                                                                                   ,

I s . Noble Gas Activity Monitors- Providing __ )(. . Alarm and Automat.fc S rmination of Relence - ' x , (GT-RE-22, GT-RE G3) E  ; 1 *

                                                                                                                                                                                                                                                                         ' " . 41 ' , _

b Iedh: Ex.pler . 1 ,

                                                                                                                                                                                                                                                  *      [           ,

43 ' (

  • 43
c. ";rticalste L . picr 1
  • 39
d. Fis.; L ie L..ite:- 1
  • 39
                                             .                                                                    c.          C .pler Tl = " te W aita-                                                        1

TAB'LE 4.3-9 9 ' P RADI0 ACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS E E ANALOG i CHANNEL MODES FOR WHICH 'e CHANNEL SOURCE CHANNEL OPERATIONAL SURVEILLANCE 5 a INSTRUMENT CHECK CHECK CALIBRATION TEST IS REQUIRED

"            WASTE GAS HOLDUP SYSTEM Explosive 1.

Gas Monitoring System .

a. Inlet Hydrogen Monitor. D N.A. Q(4) M
b. Outlet Hydrogen -

Monitor D N.A. Q(4) M ,

c. Inlet Oxygen Monitor D N.A. Q(5) M
d. Outlet Oxygen Monitor D N.A. Q(6) M w

D 2. Unit Vent System Y a. Noble Gas Activity Monitor D M R(3) Q(2) M Providing Alarm (GT-RE-21) '.

b. Iodine Sampler W N.A. N.A. N.A.

N.A. *

c. Particulate Sampler W N.A. N.A.
                                                                                             ~
d. Flow Rate Monitor D N.A. R(7) Q
e. Sampler Flow Rate Monitor D N.A. R Q
3. Containment Purge System '
     ,       lit. Noble Gas Activity Monitor -                                                                                    ,

Providing Alarm and Automatic . Termination of Release D P R(3), Q(1) (GT-RE-22, GT-RE,-33)

  • Iedino Son. pier W N.A. N.A. N.A. ,
c. "crticulete S- ,,1sr W N.A. N.A. N.A.
d. Flew Ret L.. iter D N.A. R(7) Q j
e. S: pler Fle: ":te H M ter ~D N.A. R Q

l

                                        ~
                                                                                                                                   ~

Specifications Tables-3.3-13 and 4.3-9 Justification Justification for removing' the iodine sampler, particulate sampler, ilow rate' monitor and sampler flow rate. monitor from the containment ' purge system-is.as follows:

1) ~ All four. monitors obtain a sample of the containment discharge -

!' prior'to filtration. - These samples are therefore not represen- ~ tative of the iodines Land particulates being discharged from the site. I i

2) Containment pn ges exhaust via the Unit Vent. The Unit Vent
                                          . monitor has an todines- ampler and particulate sampler that is
isokinetic. . This is.the sample'that .is' representative of site discharges. - The Unit Vent. samplers are the ones that need to r- -be covered by Action items 43 and 39.

4 4

  • I . O I

l. 5 er

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  • b "d* ' '

x >

                               -s,            ,                 -         . .-                         .           ,, .              ,u,,,.,~__...a-...,,...,.,---,..,-._.-,,-,,,-,-.-....,

CONTAINMENT SYSTEMS INTERNAL PRESSURE

                                                                                  ~ '

LIMITING CONDITION FOR OPERATION 3,6.1.4 Primary containment internal pressure shall be maintained between {+1.5and-B.2osia.]

            -03        -

APPLICABILITY: MODES 1, 2, 3, and 4. ACTION: With the containment internal pressure outside of the limits above, restore the internal pressure to within the limits within 1 hour or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. t SURVEILLANCE REQUIREMENTS 4.6.1.4 The primary containment internal pressure shall be determined to be within the limits at least once per 12 hours.

          .      t
  • g & e CALLAWAY - UNIT 1 3/4 6-6

PLANT SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

c. At least once per 18 months, or (1) after any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:
1) Verifying that the Control Room Emergency Ventilation System satisfies the in place penetration and bypass leakage testing acceptance criteria of less than 1% and uses the test procedure guidance in Regulatory Positiens C.S.a C.S.c, and C.S.d of ,

Regulatory Guide 1.52, Revision 2, March 1978, and the system l flow rate is 2000 cfm + 10% for the Filtration System and 2000 cfm i 10% for the Pressurization System with 500 cfm t 10% going through the Pressurization System filter adsorber unit;

2) Verifying, within 31 days after removal, that a laboratory analysis of a representative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 1%; and
3) Verifying a system flow rate of 2000 cfm + 10% for the Filtration '

System and 2000 cfm t 10% for the Pressurization System with 500 cfm

  • 10% going through.the Pressurization System filter adsorber unit during system operation when tested in accordance with ANSI M510-1975.
d. After every 720 hours of charcoal adsorber* operation by verifying within 31 days after removal, that a laboratory analysis of a represen-tative carbon sample obtained in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, meets the laboratory testing criteria of Regulatory Position C.6.a of Regulatory Guide 1.52, Revision 2, March 1978, for a methyl iodide penetration of less than 1%;

l l e. At least once per 18 months by:

1) Verifying that the pressure drop across the combined HEPA filters and charcoal adsorber banks is less than 5.4 inches l

Water Gauge while operating the system at a flow rate of i 2000 cfm + 10% for the Filtration System and 500 cfm i 10% for the Pressurization System filter adsorber unit; ' l 2) Verifying that on a Control Room Ventilation Isolation = " ipr l Pt %.uit, test signal, the system automatically switches into a recirculation mode of operation with flow through the HEPA filters and charcoal adsorber banks; l 3) Verifying that the system maintains the control room at a positive pressure of greater than or equal to 1/8 inch Water Gauge at less than or equal to a pressurization flow of 400 cfm l relative to adjacent areas during system operation; and

4) Verifying that the Pressurization System filter adsorber unit heaters dissipate 15 + 2 kW in the Pressurization System when tested in accordance with ANSI N510-1975.

l l CALLAWAY - UNIT 1 3/4 7-15 2 . .: _

r ..~r = T T_~ ~;

Sp;cificaticn 4.7.6.e.2 Justification Reference to the high smake density test signal was deleted from this surveillance because in.the SNUPPS design this signal only ca'uses an alarm, it'doesn't switch control room ventillation into the recircula-

 '- tion : node of operation.

JHR/mjd/1al~

PLANT SYSTEMS 3/4.7.10 FIRE SUPPRESSION SYSTEMS FIRE SUPPRESSION WATER SYSTEM C %. OAy. m LIMITING CONDITION FOR OPERATION 3.7.10.1 The Fire Suppression Water System shall be OPERABLE with:

a. At least two fire suppression pumps, each with a capacity of 1500 gpm, with their discharge aligned to the fire suppression header;
b. Two separate water supply tanks, each with a minimum level of 49r5 feet (250,000 gallons); and m.o A%oce
c. An OPERABLE flow path capable of taking suction from both fire water storage tanks and transferring the water through distribution piping with OPERABLE sectionalizing control or isolation valves to the yard hydrant curb valves, the last valve ahead of the water flow alarm device on each sprinkler or hose standpipe, and the last valve ahead of the deluge valve on each Deluge or Spray System required to be OPERABLE per Specifications ,3.7.10.2, and 3.7.10.4.

APPLICABILITY: At all times. ACTION:

a. With one of the two required pumps and/or one water supply inoperable, restore the inoperable equipment to OPERABLE status within 7 days or provide an alternate backup pump or supply. The provisions of Speci-fications 3.0.3 and 3.0.4 are not applicable.
b. With the Fire Suppression Water System othe mise inoperable establish a backup Fire Suppression Water System within 24 hours.

SURVEILLANCE REQUIREMENTS 4.7.10.1.1 The Fire Suppression Water System shall be demonstrated OPERABLE:

a. At least once per 7 days by verifying the water level in each fire water storage tank exceeds 49:5 feet (f50T000 gallons),

As.o i%wo

b. At least once per 31 days on a STAGGERED TEST BASIS by starting the electric motor-driven pump and operating it for at least 15 minutes on recirculation flow,
c. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path is in its correct position, CALLAWAY - UNIT 1 3/4 7-27

1

               - Specification 3.7.'10.1.b.

Justification: Minimum water supply tank capacity is that required to provide maximum sprinkler demand in a safety-related area (1160 gpm) plus 1000 gpm for hose streams, for a period of-2 hours. This represents a minimum tank

                . capacity of. 259,200 gallons which exceeds the current required capacity of. 250,000 gallons.

E r l-I. f I-i r:

                             .n-~
  ,   , ,         ,~      ~       ,     ,   e -     --.,<,. . i- , .     .-         ,,-,., m..,.... nn.,-a

PLANT SYSTEMS h as 3/4.7.11 FIRE BARRIER PENETRATIONS LIMITING CONDITION FOR OPERATION 3.7.11 All fire barrier penetrations (walls, floor / ceilings, cable tray

          . enclosures, and other fire barriers) separating safety related fire areas or separating portions of redundant systems important to safe shutdown within a fire area and all sealing devices in fire rated assembly penetrations (fire
           -doors; fire windows, fire dampers; cable,, piping, and ventilation duct penetrationseals)shallbeOPERABLE.                                 hy
           ' APPLICABILITY:                         At all times.

( ACTION: I a. With one or more of the above required fire barrier penetrations inoperable, within 1 hour establish a continuous fire watch on at least one side of the affected penetration, or verify the OPERABILITY of fire detectors on at least one side of the inoperable fire barrier and establish an hourly fire watch patrol.

b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

! SURVEILLANCE REQUIREMENTS 4.7.11.1 At least once per 18 months the hbove required fire rated assemblies i and penetration sealing devices shall be verified OPERABLE by performing a visual inspection of:

a. The exposed surfaces of each fire rated assembly, l

l b. Each fire window / fire damper and associated hardware, and l c. At least 10% of each type (electrical and mechanical) of sealed pene-l tration. If apparent changes in appearance or abnormal degradations are found, a visual inspection of an additional 10% of each type of sealed penetration shall be made. This inspection process shall continue until a 10% sample with no apparent changes in appearance or abnormal degradation is found. Samples shall be selected such that each penetration seal will be inspected every 15 years. l l '4.7.11.2 Each of the above required fire doors shall be verified OPERABLE by inspecting the automatic hold-open, release and closing mechanism and latches at least once per 6~ months, and by verifying: l a. The OPERABILITY of the Fire Door Supervision System for each electri-l cally supervised fire door by performing a TRIP ACTUATING DEVICE OPERATIONAL TEST at least once per 31 days,

b. That each locked closed fire door is closed at least once per 7 days, c.- That doors with automatic hold-open and release mechanisms are free of obstructions at least once per 24 hours and performing a functional test at least once per 18 months, and
d. That each unlocked fire door without electrical supervision is closed at least once per 24 hours.

CALLAWAY - UNIT 1- 3/4 7-36

Specification 3.7.11 Justification-

This change is required to correct' a typographical error (the closed parenthesis) and to accurately reflect the fact. that. cable-trays, not

{,' cables, are the fire barrier penetrations.

E 4

4 e # e k' s I~ i 3

      .I               .

t t t 'L . r 4 i

                   ,                 .,      ,      . . - , .     . - - . .         , .. , - . . . . . . , - . . - - . . ~ . . , . . _ . . . . - , . . ,- ..

ELECTRICAL POWER SYSTEMS LIMITING CONDITION FOR ODERATION ACTION (Continued) ~ '

2. When in MODE 1, 2, or 3, the steam-driven auxiliary feedwater pump is 0PERABLE.

If these conditions are not satisfied within 2 hours be in at least  ; HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

d. With two of the above required offsite A.C. circuits inoperable, demonstrate the OPERABILITY of two diesel generators by performing Specification 4.8.1.1.3a.4) within I hour and at least once per 8 hours thereafter, unless the diesel generators are already operat-ing; restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours or be in at least HOT STANDBY within the next 6 hours. With only one offsite source restored, restore at least two offsite circuits to OPERABLE status within 72 hours from time of initial loss or be in at least HOT STANDBY within the next
6 hours and in COLD SHUTDOWN within the following 30 hours.
e. With-two of the above required d'iesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by perform-ing Specification 4.8.1.1.1 within 1 hour and at least once per 8 hours thereafter; restore at least one of the inoperable diesel generators to OPERABLE status within 2 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. Restore at least two diesel generators to OPERABLE status within 72 hours from time of initial loss or be in least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours.

l SURVEILLANCE REQUIREMENTS i 4.8.1.1.1 Each of the above required independent circuits between the offsite transmission network and the onsite Class IE distribution system shall-be:

a. . Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availability, and
                         )(.             Demon                 atedOPERABi.                      n accordance                                    the OPERAIEh Y of the A 3e5 w                              7pplicab                              Fire Detectio                              nstrumentatio                      pecification                   3.3.7) t
        =g                          . and the app                                   able Fire Sup                            ssion Systems                     cification . 10)                                                     ,/

l fbr the ESF tr formers, XNB0 d XNB02.

See 4. 8.1.1. 2 -T olid-state load uenc logic sha e demonstrated OP LE ~ ~ J l%, by perfo , g an ACTUATION TESTA [ndaMAS RELAY TEST at leas nce per li po j e 31 and a SLAVE RE EST at least onc er 92 days.

! % t'kt4

               .CALLAWAY.- UNIT 1                                                                               3/4 8-2
       ,     ,      ,,,e       _ . . . . . , . . , _ . . -        . , . , _ . _ _ ,    ,_    ,-, . . . _ . . _ , . . . ,                . - . . . . . .  . . .   . , . - - _ . - . , . . . , . . . . , - . . _ . - . . _ . . . . . - .

DRAFT PLANT SYSTEMS SPRAY AND/OR SPRINKLER SYSTEMS LIMITING CONDITION FOR OPERATION 3.7.10.2 The following Spray and/or Sprinkler Systems shall be OPERABLE:

a. Wet Pipe Sprinkler Systems Building Elevation Area Protected Auxiliary 2000 North Electric Cable Chase Auxiliary 1988/2000 South Electric Cable Chase Control 1974 - 2073 Vertical Electrical Chases Control 1974 Pipe Space and Tank Room Control 1992 Cable Area Above Access Control
b. Pre-Action Sprinkler Systems Building Elevation Area Protected Auxiliary 1974 Cable Trays
  • Auxiliary 2000 Cable Trays
  • Auxiliary 2026 Cable Trays
  • Control 2032 Lower Cable Spreading Room Control 2073 Upper Cable Penetration Area Reactor 2026 North Cable Penetration Area Reactor 2026 South Cable Penetration Area Diesel Gen. (E) 2000 Eait Diesel Generator Room Diesel Gen. (W) 2000 West Diesel Generator Room
c. Water Sprays Systems Building Elevation Area Protected
          $"N"dr*.2nues.

0 Nn,0L gx ary Feedwater Pump Turbine

                       ^

l APPLICAIILITY:Nh'eneker YquIpment prote$teNy the Spray / Sprinkler System is j required to be OPERABLE. ACTION:

a. With one or more of the above required Spray and/or Sprinkler Systems inoperable, within 1 hour establish a continuous fire watch with backup fire suppression equipment for those areas in which redundant systems or components could be damaged; for other areas, establish an hourly fire watch patrol.
b. The provisions of Specifications 3.0.3 and 3.0.4 are not applicable.

SURVEILLANCE REQUIREMENTS 4.7.10.2 Each of the above required Spray and/or Sprinkler Systems shall be demonstrated OPERABLE:

a. At least once per 31 days by verifying that each valve (manual, power-operated, or automatic) in the flow path is in its correct position;
  • Areas contain redundant systems or components which could be damaged.

CALLAWAY - UNIT 1 3/4 7-30

   ^

A TABLE 3.3-11 (Continued) FIRE DETECTION INSTRUMENTS TOTAL NUMBER OF INSTRUMENTS

  • INSTRUMENT LOCATION ZONE HEAT FLAME SMLXE (x/y) 57f7 57f7 6202-Elec. Equipment Rs. 601 3/0 6203-Air Handling Equip. Rs. 601 3/0 6301-Fuel Bldg. 2047'6" Gen. Flr. 602 2/0 6303-Fuel Bldg. Exh. Filt. Absorb. Rm. A 601 2/0 6304-Fuel Bldg. Exh. Filt. Absorb. Rs. B 601 2/0
            -North ESW Pumphouse                          002                           3/0
            -South ESW Pumphouse                          001                           3/0
            -ESW Cooling Tower                            001                           1/0
            -ESW Cooling Tower                            002                           1/0
            -ESP h45FoR44 W Gol                           Ot t,    c[G mr*rdoRMcA. xDA
             -t.SF
               !                                          067      o/3 TABLE NOTATIONS
       *(x/y): x is number of Function A (early warning fire detection and notification only) instruments.

y is number of Function B (actuation of fire suppression systems and early warning and notification) instruments. l **The fire detection instruments located within the containment are not required to be OPERABLE during the performance of Type A containment leakage rate tests. (1) Zone is associated with a Halon protected spac=.. Each space has two I separate detection circuits (zones). One zon , in its entirety, needs to remain operable. (2) Line-type heat detector. CALLAWAY.- UNIT 1 3/4 3-61

TABLE 3.3-3 (C:ntinued) ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION r-h MINIMUM

         $                                                            TOTAL NO. CHANNELS        CHANNELS        APPLICABLE
                                                                                                                                 , ACTION i FUNCTIONAL INE                                           OF CHANNELS    TO TRIP         OPERABLE           MODES c

5 8. Loss of Power

         )      a. 4 kV Bus Undervoltage
                     -Loss of Voltage 4/ Bus         2/ Bus          3/ Bus          1, 2, 3, 4       19*          l I
b. 4 kV Bus Undervoltage 4/ Bus 2/ Bus 3/ Bus 1, 2, 3, 4 19*
                     -Grid Degraded Voltage
            -9. Control Room Isolation
a. Manual Initiation 2 1 2 All IB i
,               b. Automatic Actuation                                     2             1             2              All           14         O R          Logic and Actuation                                                                                                         M
       -
  • Relays (SSPS) >

Y '. g c. Automatic Actuation Logic ij and Actuation Relays  ;

.,                  (BOP ESFAS)                                             2             1             2              All           14 jj                                                                                                -                                                  '
d. Phase "A" Isolation See Item 3.a. above for all Phase "A" Isolation initiating functions and requirements.
10. Engineered Safety Features  !

Actuation System Interlocks

a. Pressurizer Pressure, 3 2 2 1,2,3 20 P-11
b. Reactor Trip, P-4 4-2/ Train 2/ Train 2/ Train 1, 2, 3 22 e g ,

Se p . e e t

TABLE 3.3-3 (Continued) ACTION STATEMENTS (Continued) ACTION 18 - With the number of OPERABLE channels one less than the Minimum Channels OPERABLE requirement, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within the next 6 hours and in COLD SHUTDOWN within the following 30 hours. ACTION 19 - With the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

a. The inoperable channel is placed in the tripped condition within 1 hour, and
b. The Minimum Channels OPERABLE requirement is met; however, the inoperable channel may be bypassed for up to 2 hours for surveillance testing of other channels per Specification 4.3.2.1.

ACTION 20 - With less than the Minimum Number of Channels OPERABLE, within I hour determine by observation of the associated permissive annunciator window (s) that'the interlock is in its required state for the existing plant condition, or apply Specification 3.0.3. ACTION 21 - W1.th the number of OPERABLE Channels one less than the Minimum Channels OPERABLE requirement, be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following 6 hours; however, one channel may be bypassed for up to 2 hours for surveillance testing per Specification 4.3.2.1 provided the other channel is OPERABLE. ACTION 22 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours or be in at least HOT STANDBY within 6 hours and in at least HOT SHUTDOWN within the following , 6 hours. ! ACTION 23 - With the number of OPERABLE channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE e status within 48 hours or declare the associated valve inoperable and take the ACTION required by Specification 3.7.1.5. l ACTION 24 - With the number of OPERABLE Channels one less than the Minimum Channels OPERABLE requirement, declare the affected auxiliary feedwater pump inoperable and take the ACTION required by ! Specification 3.7.1.2. l l ACT'M 15 - Se.e. N e<-t on fol(ewq M e. CALLAWAY - UNIT 1 3/4 3-21 l 1

-~ -

h Insert for Page 3/4 3-21

                                                                                          -i 25 With the number of OPERABLE Channels one less than the Minimum Channels
                 ' OPERABLE requirement, declare the affected Diesel Generator and off-site Power. Source Inoperable and take the ACTION required by Specifi-cation 3.8.1.1.

t

O TABLE 3.3-4 (Continued) 9 ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATIO {6< e TOTAL Z SENSOR ERROR (S) TRIP SETPOINT ALLOWARLE VALUE ALLOWANCE (TA) g FUNCTIONAL UNIT '

                       ~U     8.       Loss of Power (Continued) w

! b. 4 kV Undervoltage

                                                       -Grid Degraded                                                                                                N.A.      104.SV          104.5+2.6 -DV N.A.            N.A.                                    (120V Bus)

Voltage (120V Bus) 11.6s delay w/119s delay w/119

9. Control Room Isolation N.A.

N.A. N.A. N.A. Manual Initiation N.A.

a. N.A.

H.A. N.A. N.A. Automatic Actuation N.A. R b. -

  • Logic and Actuation

T Relays (SSPS) ' U

c. Automatic Actuation N.A.

Logic and Actuation N.A. N.A. N.A. Relays (POP ESFAS) N.A. Isolation Trip Setpoints and Allowable

d. Phase "A" Isolation See Item 3.a. above for all Phase "A" Values.

i

10. Engineered Safety i

Features Actuation > System Interlocks

a. Pressurizer Pressure, N.A. 1 1970 psig i 1981 psig N.A. N.A.

P-11 N.A. N.A. N.A. N.A. Reactor Trip, P-4 N.A. b. gg, g,4 ll- M'd h'lc bd N.A. nJ,4 g,4,

                                                           %gue.se.e.c

TABLE 4.3-2 (Continued) l {- ENGINEERED SAFETY FEATURES ACTUATION SYSTEM INSTRUNENTATION

               .         ,                                    SURVEILLANCE REQUIRENENTS

( f: TRIP E . I ANALOG ACTUATING MODES Z CHANNEL DEVICE MASTER SLAVE FOR WHICN w CHANNEL CHANNEL OPERATIONAL OPERATIONAL ACTUATION RELAY RELAY SURVEILLANCE-FUNCTIONAL UNIT CHECK CALIBRATION TEST TEST LOGIC TEST TEST TEST IS REQUIRED

8. Loss of Power (Continued)
b. 4 kV Undervoltage- N.A. R N.A. M N.A. N.A. N.A. 1,2,3,4 Grid Degraded Voltage
9. Control Room Isolation j a. Manual Initiation N.A. N.A. N.A. R N.A. N.A. N.A. All w

i ) .b. Automatic Actuation N.A. N.A. N.A. N.A. M(1) M(1) Q(3) All l w Logic and Actuation g Relays.(SSPS) ,

c. Automatic Actuation Logic and Actuation Relays (BOP ESFAS) N.A. N.A. N.A. N.A. M(2) N.A. N.A. All
d. Phase "A" Isolation See Item 3.a. above for all Phase "A" Isolation Surveillance Requirements.

j_ 10. Engineered Safety Features ! Actuation System Interlocks

a. Pressurizer Pressure, N.A. R M N.A. N.A. N.A. N.A. 1,2,3
;                 P-11

. b. Reactor Trip, P-4 N.A. N.A. N.A. R N.A. N.A. N.A. 1,2,3 it Std State. Load m A. d A- N^ d A- M O,a-) d A- 4 4- 1,a,3A w TABLE NOTATIONS i (1) Each train shall be tested at least every 62 days on a STAGGERED TEST BASIS. l 2 L,Cpntinuity check may be exc.luded_.from the ACTUATION LOGIC TEST. .. j .(3), Eyce'pI Rilaps K602, K62D, K622, K624 K635, K740, and ~K741, sfili:h-'shall b2 tested at legst.once per 18 months during refueling and during each COLD SHUTDOWN exceeding 24 hours unless they have been tested within the previous 90 days. i

                                                   ~ . _ _ _ _                _ _ . -     - -
                                                                                                              ~

4

Specifications 4.8.1.1.1.b and 4.8.1.1.2
      ~

Justification SNUPPS proposes that these surveillances be moved to the specifications to which they most logically belong. The appropriate action statement for ESFAS instrumentation has been charged -according to NRC requirements. O

  • 4

? 4 s

  ^
    <~---.,,'        ,s.~e   , , - , - ~               -, w,,,~+e-s,- - -, -- -  , , . , - -, , ,, -, , - - - - - - ,

P ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

2) Verifying the fuel level in the fuel storage tank, Verifying the fuel transfer pump starts and transfers fuel from 3) the storage system to the day tank,
4) Verifying the diesel starts from ambient condition and accele-rates to at least 514 rpm in less than or equal to 12 seconds.*

The generator voltage and frequeny shall be 4000 3 800 ToTU~~ 30.o and 60 1 1.2 Hz within 12 seconds after the start signal. The diesel generator shall be started for this test by using one of ' the following signals: a) Manual, or , b) Simulated loss-of-offsite power by itself, or c) Safety Injection test signal.

5) Verifying the generator is synchronized, loaded to greater than orequalto6201kWatthemaximumpracticalrate? operate; with a load greater than or equal to 6201 kW for at least "

60 minutes, and

6) Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

e

b. At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to I hour by checking for and removing accumulated water from the day tanks;
c. At least once per 31 days by checking for and removing accumulated water from the fuel oil storage tanks;

! d. At least once per 92 days and from new fuel oil prior to its addition to the storage tanks by verifying that a sample obtained in accordance with ASTM-D270-1975 meets the following minimum requirements in accordance with the tests specified in ASTM-D975-1977:

1) A water and sediment content of less than or equal to 0.05 volume percent;
2) A kinecatic viscosity of 40*C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes;
3) A specific gravity as specified by the manufacturer at 60/60'F of greater than or equal to 0.83 but less than or equal to 0.89 or an API gravity at 60*F of greater than or equal to 27 degrees but less than or equal to 39 degrees;
  • bv.e. t ow et. , 6, ttu.3 ,page CALLAWAY - iMIT 1 3/4 8-3

INSERT t These diesel generator starts from ambient conditions shall be performed only once per 184 days in these surveillance tests and all other engine starts for the purpose of this surveillance testing shall be preceded by an engine prelube period and/or other wamup procedures recommended by the manufacturer so that the mechanical stress and wear on the diesel engine is minimized.

ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

4) An impurity level of less than 2 mg. of insolubles per 100 m1 when tested in accordance with ASTM-D2274-70; analysis shall be completed within 7 days after obtaining the sample but may be performed after the addition of new fuel oil; and
5) The other properties specified in Table 1 of ASTM-D975-1977 and Regulatory Guide 1.137, Revision 1, October 1979, Position 2.a., when tested in accordance with ASTM-0975-1977, analysis shall be completed within 14 days after obtaining the sample but may be performed after the addition of new fuel oil, l

i e. At least once per 18 months, during shutdown, by:

1) Subjecting the diesel to an inspection in accordance with .

procedures prepared in conjunction with its manufacturer's recommendations for this class of standby service;

2) Verifying the diesel generator capability to reject a load of greater than or equal to 1352 kW (ESW pump) while maintaining voltage at 4000 g volts and frequency at 60 t 5.4 Hz;
3) Verifying the diesel generator capability to reject a load of 6201 kW without tripping. The generator voltage shall not exceed 4784 volts during and.following the load rejection;
4) Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the emergency buries and load shedding from the emergency busses, and b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected shutdown loads through the shutdown sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4000 2 3ao 400- volts and 60 t 1.2 Hz ' during this test.

5) Verifying that on a Safety Injection test signal without loss-l of-offsite power, the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The generator voltage and frequency shall be 3" ~ 4000 ~200 volts and 60 t 1.2 Hz within 12 seconds after the auto-start signal; the gerierator steady-state generator voltage and frequency shall be maintained within these limits during this test; I

CALLAWAY - UNIT 1 3/4 8-4

l ELECTRICAL POWER SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

6) Simulating a loss-of-offsite powu in conjunction with a Safety Injection test signal, and a) Verifying deenergization of tl emergency busses and load shedding from the emergency busses; b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 12 seconds, energizes the auto-connected emergency (accident) loads through the LOCA sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with emergency loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4000 2 -29& volts and 60 i 1.2 Hz during this test; and aao c) Verifying that all automatic diesel generator trips, except high jacket coolant temperature, engine overspeed, low lube oil pressure, high crankcase pressure, start failure relay, and generator differential, are automatically bypassed upon loss of voltage on the emergency bus concurrent with a Safety Injection Actuation signal.
7) Verifying the diesel generator operates for at least 24 hours.

During the first 2 hours of this test, the diesel generator shall be loaded to greater than or equal to 6821 kW and during the remaining 22 hours of this test, the diesel generator shall be loaded to greater than or equal to 6201 kW. The cenerator 3ao voltage and frequency shall be 4000 2 -20rvolts and 60 + 1.2,-3 Hz within 12 seconds after the start signal; the steady state gene-rator voltage and frequency shall be maintained within 4000 + -200- 3ao volts and 60 + 1.2 Hz during this test. Within 5 minutes after completing thTs 24-hour test, perform Specification 4.8.1.1.2e.6)b)*;

8) Verifying that the auto-connected loads to each diesel generator do not exceed 6635 kW; l
9) Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restora-tion of offsite power, l b) Transfer its loads to the offsite power source, and l c) Be restored to its standby status. j

10) Verifying that with the diesel generator operating in a test mcde, connected to its bus, a simulated Safety Injection signal overrides the test mode by: (1) returning the diesel generator to standby operation, and (2) automatically energizing the emergency loads with offsite power;
  *If Specification 4.8.1.1.2e.6)b) is not satisfactorily completed, it is not necessary to repeat the preceding 24-hour test. Instead the diesel generator may be operated at 6201 kW for 1 hour or until operating temperature has stabilized.

CALLAWAY - UNIT 1 3/4 8-5 _ --- - o.

sNOPts SROEILLAUCE d 8.L 1. 2. Changing of the Diesel Generator starting voltage tolerance from 3;200 volts to

  + 323 volts is required in order to accomodate instrument loop and meer calibra-cion tolerances as well as diesel generator performance variations.

Utilization of 4000 volts 3; 320 volts as acceptance criteria for Diesel Generator start will have no detrimental effect on the Diesel Generator or its associated components. Electrical equipment associated with the Diesel Generator includes bus, instrument transformers, relays and transducers. These components are capable of withstanding, continuously, a variation of 2 10% rated voltage. When the diesel 3:nerator breakers are closed, the emergency loads that are sequenced on step 0 cre energized. These loads consist of 4000 volt class IE motors, 460 volt class IE motors and 4000/480 volt distribution transformers. All of these components are espable, by industry standards, of operating continuously with a 3; 10% voltage v:riation at their terminals.- Based on these capabilities, expansion of the voltage tolerance acceptance criteria into Technical Specification section 4.8.1.1.2 remains within the design parameters of all associated components and is therefore acceptable. 5 i i l l l l l t l' I

              .                 - , . _ . _ _ ~ _ _ _

i 1

 )                                                                                             .

g TABLE 3.8-1 CONTAINMENT PENETRATION CONOUCTOR l

      )                                OVERCURRENT PROTECTIVE DEVICES 5                                                                                              '
U BREAKER
)     H PROTECTIVE DEVICE      TRIP                    RESPONSE TIME AT   POWERED e       NUMBER AND LOCATION    SETPOINT                MAX. SHORT CIRCUIT EQUIPMENT (Amperes)               (Sec/ Cycles)                             <
$       13.8-kV SWITCHGEAR s      Primary (P) 252PA0107  3600 (50)/                  . 0.1      Reactor Coolant Pump l                            372 (51) & 840 (51)                        DPBB01A
 !                             36oo
  . P-252PA0108           -St6S(50)/372 (51)                 0.1      Reactor Coolant Pump j   q                        & 840 (51)                                 DPBB01B

.I

  • 3&oo 9 P-252PA0205 3163 (50)/372(51) 0.1 Reactor Coolant Pump g

] g & 840 (51)' . DPBB01C P-252PA0204 M (50/372 (51) ' 0.1 Reactor Coolant Pump M

                               & 840 (51)                                 DPBB01D 480-V LOAD CENTER P-52NG0304             1200 (Inst.)                      0.05     Hydrogen Recombiner B-52NG0301             4320 (S.T.)                       0.5      SGS01A P-52NG404              1200 (Inst.)                      0.05     Hydrogen Recombiner B-52NG0401             4320 (S.T.)                       0.5      SGS01B

!' P-52PG2102 375 (Inst.) 0.025 Pressurizer Backup

! Through 52PG2112 Heater il B-350 A Fuse N.A.

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  • D 8E I
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4

  1. i Attachment 3 BACKGROUND INFORMATION ON THE REQUESTED CHANGE TO SPECIFICATION 3.2.3
           ~

(RCS Flowrate and Nuclear Enthalpy Rise Hot Channel Factor)' i

           ~          -

+ 6 4 ' L-t ., Ia t i n. l_ - . i t ', - g- , [ .' n. [ .- Y :. t i :- t .. i.

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                              = - * -        gr g-gg. - yg,e--,p-  7,.-9  9g   . eg   g.e-9 , ,,gv.y--
  • y c = w 'v? r 4-"tW--y- aw e et wef ew g M g *&95m wm-p y-wm- . - -wt v Wr ,-- y+ m- emy. p--

d

     ~

BACKGROUND During a telecon with the NRC Project Manager for Callaway.(J. Holonich,, 1 - SNUPPS was requestedito provide background information on the development of the'2% RCS flow uncertainty for Callaway. Then on' March 22, 1984, the

             -NRC forwarded a copy of an SER written for Catawba describing the following specific areas of concern:.
1) The licensee'shall either incorporate in its Technical Specifications a provision requiring that the measurement instruments be calibrated within seven days prior to the performance of calorimetric flow mea-surement or incorporate ~in its uncertainty analysis the drift effects
      -              of the measurement instrLmentations.
2) The licensee shall i$stitute a trending monitoring program capable of detecting feedwater ven. turi fouling of 0.1 percent.
                                                            \
3) The licensee shall identify any measurement instrumentation having an uncertainty value larger than the Westinghouse bounding value.

Responses to the above are contained herein or in the attached informa-tion from Westinghbuse. / The following are-Callaway's positions on the three items immediately above: p .=

1) Since incorporation of;this surveillance is a new issue, there is some confusion over whether_the requirement should be listed in the bases or
                                                       ~

as part of the specificathon itself. Therefope, Callaway has included changes for both specification 3.2.3 and its basis, and will leave the decision as to where to include the requirement up to the NRC. In either case, Callaway's comnitment is to calibrate the instrumentation used in the performance of tre pdecisio'n flow balance within seven days of the calorimetric. This commitment involves the instruments used for the following parameters: ~/

                    .a) steam pressure b).feedwater preisure c) feedwater temperature d) feedwater venturi delta P
2) In order to avoid having to take the 0.1 percent uncertainty for feed-water venturi fouling, Callaway has committed to a visual inspection of the feedwater vetturi every refueling to detect any buildup of fculing and correct the' situation before it can affect the delta P measurement.
                 , Thisl $nsp'ection can easily be performe/ through one of the handholes in
                  ' theyntyi itself.
                               ^

u 3i

       ' y?O) All of theuncertaint.ies of the instrumentation used by Callaway are g     /,boundeciby th'e %sjumpions           in the attached Westinghouse writeup with JQ        the exception 6f:          *-

s j ya) stear 1ine*p es'sur#e span yf s

                     ,b) primary idh temperatur'e measuremen'ts performed with a DVM

}; m m$ (

                                     \                                    !
          ^
                                                                      ' \ * , ,_   +

1 1'. . .

                                                                       'b C                       \

c _ ( ._

Background centinued c) feedwater flow delta P cell calibration d) feedwater flow delta P cell readout e) feedwater enthalpy temperature uncertainty, consisting of (1)RTDcalibration (2) RTD drift (3) DVM accuracy As documented in the Foreward of the attached Westinghoase writeup, Westinghouse has done an evaluation of these uncertainties and deter-mined that the changes in the parameter values have no significant impact on the final results. Attached hereto is the Westinghouse proprietary response to the issue of RCS flow uncertainty. The proprietary material for which withholding is being requested applies:to the Kansas City Power & Light Company and Kansas Gas and Electric Company's Wolf Creek Generating Station (STN 50-482) and the Union Electric Company's Callaway Plant (STN 50-483). Enclosed are: l '. 1 copy of the Reactor Coolant System Flow Measurement Uncertainty for SNUPPS (Proprietary).

2. 1 copy of the Reactor Coolant Systern Flow Measurement Uncertainty for SNUPPS (Non-Proprietary).

Also enclosed are:

1. 0ne (1) Application for Withholding (CAW-84-28). (Non-Proprietary)
2. One (1) copy of'the affidavit. (Non-Proprietary)

As this submittal contains information proprietary to Westinghouse Electric

      ' Corporation, it is supported by an affidavit signed by Westinghouse, the owners of the information. The affidavit 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 (b) (4)
       -of Section 2.790 of the Commission's regulations.

1 Accordingly, it is respectfully requested that the information which is

      . proprietary to Westinghouse be withheld from public disclosure in accord-ance with 10CFR Section 2.790 of the Commission'.s regulations. Correspon-dence with respect to the proprietary aspects of this application for
      ' withholding or the supporting Westinghouse affidavit should reference CAW-84-28 and sho'uld be addressed to R. A. Weisemann, Manager Regulatory and Legislative Affairs, Westinghouse Electric Corporation, P. O. Box 355, Pittsburgh, Pennsylvania 15230.

JHR/dck2a10

                           )
        ,r
  • k j ATTACHMENT 2 REACTOR COOLANT SYSTEM FLOW s

MEASUREMENT UNCERTAINTY: FOR SNUPPS b sh i T' 0 ~s N k

                   ~                                                '
          ..         .                                                                                  t

( FOREWORD

             - The following documents in a generic manner the Reactor Coolant System (RCS)

Flow Measurement Uncertainty for four loop plants with RdF RTDs. The instr ment uncertainties asstaned normally have sufficient conservatism to envelope all l plants. Base 'asstanptions made are:

1. All measurements are made with the most accurate means reasonably available; this generally involves the use of what Westinghouse has identified as "special test instrumentation",
2. The "special test instrumentation" is calibrated no more than seven '
days prior to the performance of. the'ineasurement, and 3 Pressurizer pressure measurements are performed using the protection system transmitters, thus an allowance has been made for drift effects.

Based on discussions with SNUPPS and Callaway, Westinghouse understands that the above assumptionswill be met. The uncertainties identified in Tables 1 and 2 are applicable with the following exceptions:

1. Steamline Pressure span is 1300 psi,
                                                                           ~
2. Primary side temperature measurements are performed with a DVM accuracy of to.15 F
3. Feedwater Flow op cell calibration is 2 75% 0 span, l
4. Feedwater Flow ap cell' readout is 20.75% span, and
5. Feedwater Enthalpy temperature uncertainty consists of the following:

RTD Calibration to.7 F RTD Drift 20 33 F  ; DVM Accuracy 20.5 F. Westinghouse has performed an evaluation based on these exceptions and has determined that the uncertainties identified in Table 2 remain unchanged, i.e.,

              . the change.in parameter values identified above have no signified' Mpact on the final results. It is Westinghouse's judgement that the RCS Flu i

Calorimetric Uncertainty of t .9%1 flow, and Total Flow Reasurement Uncertainty

              'for Calorimetric plus one elbow tap / loop of 12.0% flow are applicable to Callaway.

l It has been identified to Westinghouse that only the first exception applies to

              - Wolf Creek, thus the' conclusions stated for Callaway are also applicable to Wolf Creek.

l ~ . REACTOR COOLANT SYSTEM FLOW HEASUREftENT UNCERTAINTY , e I. INTRODUCTION RCS flow is monitored by the perfomance of a precision flow caloHmetMc measurement at the beginning of.each cycle. The RCS loop elbow taps can then be normalized against the precision caloM metM c and used for monthly . surveillance (with a small increase in total uncertainty) or a precision l flow caloMmetMc can be perfomed on the small surveillance schedule. The analysis presented in this report documents both measurements, f.e., the calorimatMc and the elbow tap nomalization uncertainties. Since 1978 Wesdnghouse has been deeply involved with the development of seversi techniques: to tmat instruentation uncertainties, errors, and I allonences. The earlier versions of these techniques have been docu-manted for seve el piants; one approach uses the methodology outlined in WCAP-8867 "Impmved Thomal Design Procedure"U'I'U which.is based on the conservative assuption that tdecertainties can be descHbed with l unifom probability distributions. The other apy.M is based on the more malistic assumption that the uncertaindes can be descMbed with nomal pabability distributions. Thiis asseption is also conservative .

                                            -             in that the " tails".of the nomal distribution are in reality ' chopped
  • at the extremos of. the: renge, i.es., thit. ranges for; uncertainties am Pfnits and thus, allowing for same pmbability in escess of the range limits is a conservettwe assuptio'n. This approach has been used to substantiate 'the wti.61Tity of the p..te i. ton system setpoints for several plants with a Westinghouse M333, e.g., D. 'C. Cook IIN , North Anna Unit 1, Saleur theit 2, Sogneyah unit 1,. Y. C. Sumer, and McGuim Unit.1.' Westinghouse now believes that the latter approach,can be ussd for the determination of the instruentation errors and allamences for all the parameters. The total instruentation errors presented in this "

masonse are based. on this appmach. II. MTHEICLDEY

                       -                                   The methodology used to enuhine the erme components for a channel is basically the approprf ate stattstical enmbinedon of those groups of camponents which am statistically indepencent, i.a., not interactive.

Those errort which are not independent are combined aMttentically to The fem independent; groups, which can then be systematically combined. statistical esubination techniges used by Westingnouse is the (

                                                                                                                                                                          )+a,c,e
                                                                                                           ,,__-_,,,,,,_~m.v.,--_-_,,w                -- n._ w..,n _,w             n v,,w-,
    .     ~-                      --_ .. .                                    - . -                     _ . . - _ _                                _ - - - - _ _ _ _ _ - -                                      .

[ [*'#'" of the ind w neution uncer-. t l tainties. The instamentation uncertainties are two sided distribu-tions. The se of both sides is equal to the range for that parameter, 1"'", the range for this j e.g., Rack DMft is typically C ' parameter is. C [*'" This. technique has been utilized befon ' 0'8 'N and vaM ous as noted above and has been endorsed by the staff industry standardsN ' II . The relationship between the error components and the statistical instrumentation error allowance for a channel is defined as follows:

1. - For parameter indication,f r the rocks using a. 0VM; 2.'

For parameter indication utilfhng the plant. process computert l .. l l

             ... w .                                                                                                    _

C3A = Channel Stattstical Allouenca PMA = Pmcass Measumment Accuracy PEA = Prfmary E! ament Accuracy SCA. = Senser Calibratfort Accuracy STE

  • SensorTemperatuit EfTects.

l SPE = Sensor Pressure Effects. ACA. = Rack Ca11brattor Accuracy RD = Rack Or4ft RTE = Rock Temperature Effects DVM, =. Digital Voltmeter Accuracy ID = Caguter Isolator Drift A/O = - Analog to Digital Conversion Accuracy i

                 ,-w
                            ,,----e-           -,v--,----,,,r-.---,,e--                   .w  . . , , - - + - - , , . ear-a- ,.e,- - - . ..-www--w,--                  v--w-wa--.wv-,.,,-,----,v----+ ..--- - - - ,,- . - --r , - - - -

l l The parameters above are as defined in reference 4 and are based on SAMA standard PMC-20-1973(10), 'However, for ease it understanding they are persparased below: l PMA - non-instrument related, measurement errors, e.g., tempera-ture stratificatior of a. fluid in a. pipe, l PEA - errorr due to metering devices, e.g., elbows, venturis, l orffices, t SCA - reference (calibration) accuracy for a sensor / transmitter, SD - change it input-output mlationship over a perfod of time at mference conditions for a. sensor / transmitter, STE - changer in input-output re!.-tionship due to a change in askiest temperature ?or a senser/ transmitters ! SPE - change in input-outpv.t m . iatiostskip due to a change in-I static pmssure for a A.p' cell,. l ICA - mfamace (ca11breden) accuracy for all rock, modules in Toegr orchassel assasik the loop or channel it tuned to f - tkts accuracy. 11ris assumptfor eliminatu any bias that .

                                                   ' could be set up tW calibration of indtvidual modules in the loop or channel             -

RD , - change in inputwnstpet: relationship over a period of time '- - a't dennO cond1hons foF the im:k modules, RTE change in input i,.t. relationship due to.a change in ambient temperature for the rock modules,

                      .        DVM            -        the measurement accuracy of a digital voltmeter or culti-aster on it's most accurata applicable range for the                                                                     ;

parameter measured, , III - change in inputwnstput mlationship over a. period of time at refersaca conditions for a control /prvG Lion signal 1 isolating device, allouence for c ....aton accuracy of an analog signal to A/D. - a digital signaT for process commter use, A more detailed explanatton of the Westinghouse methodo;ogy noting the ins. ston of several parameters is provided in mferenca 4.

                                                                                                                    /

4 ____________...____...1._..,___...-___,.4- , _ , , _ . , , , . . . _ _ _ , _ , . .

          ~          .

III. Instrumentation uncertainties Current NRC Technical Specifications (11) reauire an RCS flow measurement with i a high degree of accuracy. It is assumed for this arme analysis, that this~ flow nessurement is perfomed witMa seven days of calibrating the measurement instrumentation themfom, drift effects are not included (except where necessary due to sensor. location). It is -

               .also assumed that the calorimetric flow sensurement~is perfomed at the beginning of a cycle,. sa na allowances have been ende for feed-
              ' water venturf crud buildup.

The flow measurement is perfomed by detenrining the steam generator. themal output, corrected for the EP heat igut and the loop's shore of primary systes hostlosses, and the enthalpy rf se (Ah) of the primary coolast Assauf ng;that the. priumry and secondary sides , , an in equfTibrfus; the EZ totai vessel flow is the sum of the. l

                 . individual priman loop fTous, i~.e., . - -

l Mgg= E ( .. , (Eq. 3 ) The individual primary loop flows are'detenrfned by a,. . i.ing the themal output..et the steen generator for steam generater 61cudowr - - (if not secund), subtracting.the EP heat addition, adding the loop's sham of the primary side systma losses, dividing by tha primary side enthalpy rise,. and sus 1tiplying by the specific volume of the E3 cold leg. The equation for this. calculation is: l $ /Og i ) k *.IT) ) Ost - Op

  • M, / $N}

, e (Eq. 4) enn - ng whom; g - t.oop fTow (spel y = 0.1247 gym /(ft3 /hr) Q 3g = Steam Generator thermal output (Btu /hr) Q = EP heat adder (Etu/hr) P Q = Primary system not heat losses (Btu /hr) t Y, = Specific volten of the cold leg at TC(ftMb) M. . Neober of primary side loops l hy = Hot. leg enthalpy (Stu/lb)

I l The themal output of the steen generator is detemined by the same

'            calorimetrie measumment as for reactor power, which is defined as:

(Eq. 5) Q3 g. = (h s -h)Wf f where; = Steam enthalpy (5tu/1b) h, h = Feedsster enths.ipy (8tu/1b) _ f W = Feeduster flow- (1b/hr). f l The stsam anthalpy is based on measurement of steam generator outlet l The feessater enthalpy

    -         steam pressum, assuming saturatal conditions.

' is based on the measurement.of feeduster tagerature and an assumed The feed-feedenterpressum based on stameline pressure plus 100 psi. water flou'is.detenstned.by multipie esemrements and the some calcula- ' tion as used for reactor pomermeasurements, whicit is based on the fbi-lowing: - l i (Eq. 6) W p = (K) IFi){ V pf4 ,} l l whom; 10 =- Feeduster venturf fTow. factor

                                 = .f. e.e. duster... . . venturi corMon for thermal expansion
        ...       ...Fa- -        -
                       'ef        =          Feed M. densit/ (1b/fE.)

Feedenterventurf pressure drop (inches y). Ap = The feedwater' venturt flow coefficient is the p. At of a number of constants incliading as-built dimensions of the ;;..Gui and calibration tests performed by the vendor.

  • The themal expansion correction is based on tire coefffctent of expansioer of the venturi material and the difference betweest feedhetertemperature and.calibrstion temperature.

Feedwater density is based on. the.amasumment of feeduster temperature and- feedseter pmssum.. The venturi pmssure drop is obtained from the i output of the differential . pressure call connected to the venturi. (- .

                                                                                                     ~

The RCP heat adder it detentined by calculation, based on the best esti-mates of coolant fTow, pep head, and pop hydraulic efficiency. l The primary system not heat losses. are detensined by calculation, con-l siderfor the fo1 Towing system heat inputs and heat losses: R

Charging flow Latdown flow Seal injection flow RCP themal barrier cooler heat moval Pmssurizar spray flow-

              -     Pmssurf zar surge Tine fTow Camponent insuration heat Tosses Camponent support heat losses CRDft heat losses.

A single calculated sus for full power operation is used for these los-ses/ heat inputs.. The hot let and coid leg enthalpfes are based on the measurement of the hetlet temperature . cold Ter temperature and the pressurf zar pmssure. d measurement of the cold. leg The cold let specific votes is. hassL as l-temperature and pressurfzarpressum. The RCS flow measurement it thus based:or the following plant measure-eents:. Steanline pressure (P,) , 7 Feedwater pmssum- (Pf) l Feeduster venturi differential pressure ( Ap) Not leg tamp'erature (TH I . Cold leg temperature (TC I PMssurizer pressure (P,). Steaur generator blowdown (if not secured) and. on the following calculated valuas: Feedenter venturi flow. coefficients (K) Feedwater venturf themel expansion corvection (F,) Feedwater density (of) Feeduster enthalpy (hf) Steam enthalpy (h3) Moisture carryover (impacts h,) - Primary system not heat losses (7g) ,

                                                                                                                    .                    r IEP heat adder (G )

Hot leg enthalpy h) M - Cold leg enthalpy (hc.)* . These measumments and calculations are presented schematically on Figure 1.

                                                                                                    ~

l Starting off with the Equatfor & pammeters, the detailed. derivation of the measurement ermer is noted below, 1 Feedwater Flos Each of the feeduster-venturis is calibrated by the vendor in a hydrau-lies laboratory ader controlled; conditions to an accuracy of [ fM S of span. The calibratfour data which substantiatas this. accuracy is pmvided. for all oNthe plant venturis by the respec-tive venders. An additional. uncertEW factor of C, '3"' 8 5 is-included for installation. effects, resulting in an overall flow coef- . j ficient- (K) uncertsf aty of C 1 '# .* 5 Sinca LEE loop flow is ,

l. proportional to stees generator therweif' output whictr is proportional to feedwater flow, the flow coefficient. uncertainty is expressed as

[ . .f.'" 5 fl ow. . .,.. . The uncertainty applied. ta the feeduator venturi thermal expansion cor-mction (F,) is insed on the uncertainties of the measund feeduster

            ;    temperature and the coefficient of thermal expansion for the venturi material, usually 304 stainless steel. For this meterial, a change of l

12*F in the feedustee temperature range- changes F, by C f'#'" E and. the: steer generator thermal output by the same amount. For this derivation,. an uncertainty of C 3**'8 in feeduster temperature was assumed (detailed breakdown for this assump-tion is pavided in the feeduster enthalpy section). This results in a negligible impact in F, and steam generator output. Based on data. introduced into the ASE Code, the uncertainty .in F, for

                ,304 stainless. steel is. 3 5 %. This maults in an additional uncertainty                                    -

of [ f S in feeduster flow. A conservative value of [ f*~ +C.T is used;in this analysis. _ _ _. _ . _ _ _. _ _ - _ __ _ __. _ , _ . ,_ _..__ _ _ _ _ _ .. m __

Using the ASE Stoes Tables (1967) for compressed water, the effect of a [ 3**'8 error in feedsator temperature on the %is [ 7 5 in steam generator themat output. An error of C f*** fn foodneter pressure is, assumed in this analysis (detailed breakdown of this value is provided in the steer enthalpy section) . This results,it an uncertainty in %of C 3"'# % ist steam generator thermal output. The combined effect of the two results in a. total Quncertainty of [ 3" 5 in steaur generator therimai output It is assumed that tha ap cell (usually a. Barton or Rosemount) is read Toca11y and seoer after the ap cell and local meter are calibreted (within 7 days of calibration). This allows the elimination of process Therafore, the Ap rack. and sensor drift errors from. consideration. cell errors noted in this analysis are-[ ]+a,c 1 f or calibration and [ ]+a,c 5.for read:Ing error of the special high accuracy, local gauge. These two errors areYm.5 Ap span. In order to be useable in this analysis they must be translated into 1 feedwater flow r at full power conditions. This 1staccomplished by multiplying the erro' i in 1 Ap span by the. conversion f actaknoted. below: l 2

             ~-

m . f 1.j.h l'f ipar of feedwater' flowiuutransmitter. in vercent d acamal )

                                \ 7} \

For a feedwater flow transmitter span of [. pa,c 5 nominal flow, the conversion factor is [ ]+a,c (which is the value used.in this I analysis). , , As noted in TahTe I, the statisticar sum of the errors for feedwater flowis[ ]+a,c $ of stems generator thermal output Feedwater Enthalpy The next major error component is'the feedwater enthalpy used in Equa-tion F. For this. parameter the major contributor to the error is the uncertainty la the feedwater temperature.. It is assumed that the feed-water temperature 11 determined through the use of an RTD or thermo-l

                       . couple whose wtput is read by a digital voltaster (DW) or digita_ . _ _
            .                                                                                                                           t multimeter (mm) (at the output of' the RTD or by a Wheatstone Bridge for RTD's, or at the reference junction for themocouples). It is also assumed that the process components of the above are calibrated within 7
               . days prior to the measurement allowing the elimination of drif t eff ects for all but the RTDs. Theref ore, the error breakdown f or feedwater tamperature. is as noted on Table 1                                 The statistical combination of these errors results in a total feedwater tasperature error of                                                         !

[ 1+ac, i Using the ASIE Steam Table (1967) for compressed. water, the eff act of a [ j+a,c error in' f eedwater temperature on the feedwater enthalpy (hf ) is [ ]+a,c 1 in steam generator themal output. Assuming i a[ ]+ac error in feedwater pressure (detailed breakdown provided in the steam enthalpy section) results in a [ ]+a,c 5 affect in hf and steam generator thermal output. The combined effect of the two results in a totai hf uncertainty of [ J+4+C1 steam generator thermal output,. as. noted on Table 2..

                                                                              ~

Steam Enthalpy , The. steast enthalpy has two contributors ta the calorimetric error, steamline pressure and the moisture.' content For steamline pressure the error breakdown is as noted.on Table.1; This results in a total instru-

                                                                   .]+a,c 5, which. equ.al.s     [             ]+a,c f or a mentat. ion err.or of,.( .                                  ..
                                                                                                                                ']

For this analysis a conservative value of ( 1200 psi span 1s' assumed for the steamline pressure. The feedwater pressure is l assumed to be 100 psi higher than the steamline pressure with a conser-

                                                                                             ']+a,c. If f eedwater pres-               S vatively high measurement error of (

sure is measuredon the same b' asis as the steamline pressure (with a DVM) l j+a,c5. span,.whichequils.[ ]+a,c for a the error is. [ 1500 psi saan Thus,. an assuestion of an error of [ ]+a,cis very conservative. i Using. the ASIE Steam Tables (1967) f or saturated water and steam, the effect of a [ ]+a,c ([ 1+a,c) error in steamline pressure on the. steam enthalpy is. [ ]+a,c 1 in steaar gener.ator thermal Thus, a total instrumentation error of [ ]+a,c results l outp ut.. l l in an uncertainty of [ ]+a,c 1 in steam generator themal output, I l as noted on Table 2.

 -,          ~    ..._....__.m....._._,_.                                       C _ __._ _ _. __ _ ____ _._._ _ _

l The major contributor to ks uncertainty is moisture content. . The , nominal or best estimata perfomanca Tevel is assumed to be { pa c 1 The most . which 1,s the design limit to protect the high pressure turbine. conservat.ive asstantion that can be made in' regards to maximizing steam This conser-generator themel output is a steen moisture content of zero. vatism is introduced by. assigning an uncertainty of f f***5;tothe moisture content,. wMch is equivalent erough enthalpy change to [' . 7* % of thermal output. The cumbined effect of the- steenline I pressure and moisture content on the totalgh uncertainty is . [ 7 t in steam generator themal output. l Secondary 51de Loop Power 1 The loop power acertainty ir obtained by statistically' combining all of 4,4 (QSE I the error components noted for the staaet generator themal in tems. of 5tu/hr. WitMn.each loop mesa components are independent ' Technically, the feed-effects since ther are independsat usesurements. water tempenture and pressure unceEadnties are common to several of es errer componentr. However, ther are treated.as independent quantities because of the conservatiseri assumed ant the arittaustfc summation uncertaintfes before squaring themr hairne sipificant effect on me final msult. ... The only effectwMcti tends to be dependant, affecting all loops,'.would be the accumulation of crud or the fenduetor venturf s, eMch can affect the ' Althougir it is conceiveble that the crud accu.- ap for a specified flow sulatica could affect the static pressure distribution at the venturi - throat pmssum tap in a manner that would result in a Mgher flow for a specified ap,. the' reduction it throat arer msalting in a lower flow at IIe uncertainty has been the specified. Ap;.is the stronger effect. If venturi fouling is 46 d.

      '                                       included in the analysis for eis effect.

by me plasA the ventarf should be cleaned, prior to perforunace of the ' measurement. If the venturi is not cleaned, the effect of ee fouling on the detemination of ee feeduster flow, and thus, the steen generator power and 213 ffow, should be sensured and tueted as a bias, f.e., the error due to venturi fouling should be added to the statistical summation of the mst of the measurement ermes. 1

The not pump heat uncertainty is derived in the following menner. The primary ' system net heat losses and pump heat adder for a four loop plant are summarized as follows: System heat losses -2.0 mt - Component conductfon and convection losses .l .4 Pump heat adder +18.0 Net Heat input to RCS +14.6 Mt The uncertainties for these quantities an as follows: The uncertainty on systems heat. losses, which is essentially all due to charging and letdown flows, has been: estimated to ba C 1** C 1 of the calculated value Since dimet maawesents are not possible,. the uncertainty on ' component conduction and convection losses has been assumed to be [ 3+4*C s. of the caTculated. valGlk; neector coolant pump hydraulics are. known to a relatively high confidence level,. supported by the system hydraulics tests perfonned. at: Prairie Island II and by input power maa-surements from several plants, so 1ihe. uncertainty for the pump heat l, l adder is estimated to be [ 3**** 1,'of the best estimate value.- Consided. ng these permesters as one ipsantity which. is designated the net pump heat uncertainty, the combined uncertrf ntfer are less th'an 3+**C 5 of the total, whicfr is C 1**.C 1 of core power. [ The Total Secondary side Loop Power Uncertainty (noted in Table 2 as , ~ C 3+**C 5) is the statistical sum of the secondary side loop l 3"> C 5, and; the net. pump heat addi-power uncertainty (Q $ g}, [ tion,C 3***C s Primary side Enthalpy . The primary side enthalpy error contributors are TH and TC measun-ment errorr and the uncertainty in pressurizer pressure. The instrumen. l ! tation errors for T are as. noted on Table 1. These errors are based H 7 on the assumption that tne- DVM has been recently calibrated (w days prior to the measurement) and "the DVM is used. to rea

                                                                                                     ' "'***   I" O             '

_" ] * - "" _" -

the racks. The statistical combination of the abovo errors results in a total T H mortainty of [ 1"' C. also provides the instrumentation error breakdown for TC. The Table 1 errors are based on the same assumptions as foryT , resulting in a total T Cuncertainty 'of C 3"'#. A pressurizar pressure instrumentation errors are noted on Table 1 sensor drift allowance of C 3+e,c 5 it included due to the dif-l ficulty in calibrating while at power. It is assumed calibration is perfomed only as required by plant Technical Specifications. Statistically combining these errors results in the total pressurizer 3%C 5 of span, which equals . pressure uncertainty equaling [ ,1" ' C span. In this. analysis a [ 3+*..C for an [ conservative value,of C 3**** is used for the instrumentation error for pressurizer pressure. 1 1 The effect of an uncertainty of [ 3"'C in TH on hH is ~ [ 3%C % of* loop fTow. Thus, ar error of C 3**'C in~ Ty jef.* an uncertainty *of C 'lW percent in hy. An error of C 3+#'C in TC is worth,[ ]M C 5 in he. 1***C in Tg results ia an uncer-Therefore, Fan error.of { . tainty of C 3+e,c 5 in h e and loop flow. An mortainty of j [ 1+8.C in pressurizar pressure introduces an error of

                                                                 ~

Statistically f 3***C 5 in hy and [ 3"'C 5 in he . , combining the hot leg and cold leg tamperature and pressure uncertain-ties results in an hy uncertainty of.[ , .3**

  • C 5, an he uncer-tainty of [ 1+**CS ,. and. a. total uncertainty in Ah of C  ?** C %. in loop flow.

Statistica1Ty combining the Total Secondary Side Loop Power Uncertainty (in Stu/hr) with the primary side enthalpy uncertainty (in Stu/lb), l

      =                                                   , _ _

TABLE 1-TYPICAL INSTRUMENTATION UNCERTAINTIES

   -                                                      (using RdF RTDs)

Feedwater Feedwater Pressurizer Feedwater Steamline Pressure op Pressure Temperature Pressure T H T C Indication Indication Indication Indication Indication Indication Indication (DVH) (1) (Local) (1) (DVti) (1) (DVM) (1) '(DVM) (1) (DVM) (1) (DVM) (1)

                                                                                                                     +a c PMA PEA                                                                   ,

SCA SD STE , SPE RCA

RD .

RTE , DVM CSA

+

1500 psi 100% ap 800 psi 400*F 1200 psi 100*F 100*F i (1) % instrument span Corresponds to an accuracy of [ ] +a c (4) Determined using Eq. 1 (5 Determined using Eq. 2 , (6 Corresponds to an accuracy of [ (7 Corresponds to a drift of [ ]ta,[ac

l FIGURE 1 RCE F1.0W CALORDETRIC SQlEMATIC , l l l l l l l l 1 l . F, K g hg h, hp of l . 1 y - Ak F ~ l 1 r ,- 3 . q p F 19eesured C

                                                                                             .                                                         Calculated C
                                                                                                     *h

_ s .

                         ~

t. W .

Other Loops
                                                                   - n.
                   -. . .,-. . - . _-_.- -- - -. -. - - _ . m

TA8LE 2 , CALORIMETRIC RCS FLOW IEASUREMENT UNCERTAINTIES Flow Instrument Error (1) Uncertainty Camponent l

                                             ~

Feedwater Flow

                                                                                                                                &a,c Venturf, K Themal Expansion Coefficient Temperature                                                                                .

Material Dens 11;r Temperature Pmssure s . Instrimentation Ap CalT Calibration '.,. Ap Cell Gauge Readout *

             ' ' Tot'al insthmentation'Errifrh(e)2 Total Feedwater Flow Error          I(e)2 l

Feedwater Enthalpy l Temperature (E3ectronics) RTD Calfbratiost ! Sensor Drfft fWM Accuracy Total Temperature ErrorfI(e1 2 Pressure Total Feessater Enthalpy Error g r(e)1 s

s ' TABLE 2 (Cont)

           -                                                CALORI)ETRIC RCS FLOW IEASURDENT UNCERTAINTIES Flow Instrument Error (1)    Uncertainty Camponent                                                                                                                                         1 se e Steae Enthalpy Steamline Pressure- (Electronics)

Pressuk Call Calibration Sensor T.mperature. Effects Rack Calibration Rack Temperature Effects. D M Accuracy Total Electronics Error fE(e)2 - Staaeline Pressure Error Assume'd

                               .Mai sture Carryover Total Stama Enthalpy Error                                                         _

Secondary Side Loop Power Uncertainty fE(e12 ,

            ,          Net Ptse. Heat. Addition' Uncertainty Total Secondary Side Loco Power Ur.cartainty [I(e)2 Primary Side Enthalpy i                                                                                                                                                                 '

TH. (Electronies) , RTD. Calibration i Sensoe Drift. DVM Accuracy ' 2 Ty Instrumentation Error T, T er.ture St,e .i . E - r T Temperature Ernse f(e)2 N h

           . , . _ _ . . . , .    ..._-__,...,.._.._._,_,____,...._...___.___.___.._..._.,.__________._.___l_________
                                                                                                  .       TA8LE 2     (Cont)                                              ,

CALORIETRIC RCS FLOW EASURDENT UNCERTAINTIES Flow Instr uent Error (1) Uncertainty Caponent

                                                                                                                                                            +a c TC (Electronics)

RTD Calibration Sensor Drift DVM Accuracy l TC Instruentation Error f t(e)2 Pressurizar Pressure (Electronics) Pressure Ca1T Calibration Sensor Temperature Effects Sensor Drift . ,, Rack Calibration . Rack Temperature Effects 3 DVM Accuracy Total Pressurizer Pressun ' i

                                   .....Errorpie).2 Pressurizar Pmssure Error Assmed
                                . TH Pressure Effect l                                   TTotalErrorfE(e)2 y

T

C Pressure Effect l TTotalError[I(e)2 C

Total Ah Uncertainty [I(e)2 l Primary Side Loop Flow ' Uncertainty fr(e)E Total RCS Flow Uncertainty (( J/N h N = 4' loops 1

   *      '="--e----,-rn,,.-.

i NOTES FOR TABLE ?

1. Measurements perforised within 7 days after calibration thus Rack Drift, and idtere possible Sensor Drift, effects are not included in this analy-i si s.
2. Consonative assumption for value, particularly if steamlina pressure
                        + 100 psi is assamed- value. Uncartainty for steamline pressure noted in staae enthalpy.
3. To transform error in percent Ap span to percent of feedwater flow at l

1005 of nominal feedwater flow; sultiply the instroent error by: f - ([1/g) (Sean of feedwater 100 flow transmitter

                                                                                                                                                                           ) in pe 7

l l In this analysis; the feedwaterftow transudtter span is assised to be C 3+a c 5. of nominal flow.'

4. Reading error for multiple n sd n M *-

S'. Conservative asseption for . instrumentation: error for this analysis.

6. Maximum allowed soisture carryover to protect HP turbine.

7: Credit taken for the' 3 tao scoon RTU bypass loop in reducing uncertainties due to t'emperature streaming. , t; . Convoluted sum of TuTemperature Error and Tu Pressure Effect,

9. Convoluted sum of T C Instrumentation Error and T.C Pressure Effect.

l . Convoluted sum of Ty Total Error and TC Total Frrnr

 . -     --w     -

y-_. .w-___,-, , - _ , - - - - , - . ,, , ~. , , . . . . , , , , , _ . . . , . . . . . - - _ _ - - . _ _ _ , - , a

results in t Primary Side Loop Flow Uncertainty of C pa.cgtoop i flow. The RCS flow uncertainty is- the statistical combination of the primary side loop flow error and the maiber of primary side loops in the plant. As noted in Table 2 the RCS Flow uncertainty for 4 loops is 11.9% flow. N05ULI2ED ELBOW TAPS FOR RCI Ft.0W MEASUREMENT 1 Based on the results of Table 2, in order for a plant to assure operation within the analysis assimiptions an RC3 flow calorimetric would have to be perfomed onca every 31 EFPD. However, this is an involved procedure dich requirer considerable staff and setup time. Therefore, mary plants perform one flow calorimetric of the beginning of the cycle and nomalize the loop elbow taps. This allows the operator to quickly l datamine if there has been.t significant. reduction in loop flow on a , shift basis and te avoid a long monthly ,.m.e The elbow taps are forced. to read.1.4 in the-process rocks after perfomance of the full l power floin calorfmetric, thur, the eh tap and its a call are seeino nomal operating conditions at the tinea of calibration / noma 112ation and 1.0 corresponds. to the measured loop fTom at the time of the measuremene. For monthly surveillance to assum plant operation consistent with the

         -      .ITDp assumptions two means of.,detem1Ning the RCS f low are available.                                    ,   ,

One, to read. the loop. flows from the process computer, and two, to mea-sure the output of the elbow tap 5 calls in the process racks with a DVM. The uncertainties for both methods and their convolution with the I calorimetric uncertainty are presented below. . Assuming that only one elbow tap per Toop is: available to the process computer results in- the following elbow tap measurement uncertainty:

                         %Ap span                   % flow                    %Ap span      % ficw ha ,c
                                                                                                                +a,c pMA                                                  RCA RTE PEA RD SCA SPE ID STE                                                  A/D SD' Readout
     -'       ap span is convertad to flow on the same basis as provided in Nota 3 of Table 2 for an instmment rpan of (-                          ]+a,c Using Eq. 2 results
                                                         .]** '" flow per loop. The total uncer-inaloopuncertaintyof[

tainty for N loops is:  :

                                 ~
                                                  +a,c     f3 ,

N = 4 The instrumen measu t. uncertainties for normalized elbow tags and the flow calorimetric are statistically independent and are 95+% prob-ability values. Therefore, the statistical combination of the standard deviations results in the following total flow uncertainty at a 95+% probability: 4' loops = + 2.0 flow Another method of using normalized elbow taps is to take OYM readings in the process racks. of' all. thrwe elbow taps for each loop. This results irr average flows- for eacfr loop with a Tour instrumentation uncertainty for the total RCS flow The instrtmentaticer uncartainties for this measurement are:. .

                        %Ap span      1 flow                             1&p. span    % flow
                                                                       ~                     ~
                      ~                       ~'
                                                     +a c       s                              ta.c g  '

PEA ,RCA SCA RT'E SPE RD STE OVM

                      -                        --           Readout ap span'is converted to flow on the same basis as provided in Note 3 of Table 2. for an instrument span of [                            ]+a,c Using Eq.1 results in a channel uncertainty of [                     ]+"'" flow. Utilizing three elbow taps (whicfr are independent) results in a. loop uncertainty of (,                      ]**'C

' fTow per loop. The total uncertainty for N loops. is:

                                                     #8    flow-l                       N = 4 The. calwinstric and the above noted elbow tap uncertainties can be The 95+5 probability total

) statistically cambined as noted earlier. flow uncertainties, using three elbow taps per loop are: 4 loops. * + 1.95 flow Thg followf ng table sausartzes RCS flow measurement uncertainties.

        .a TABLE 3 TOTAL FLOW MEASUREMENT UNCERTAINTIES Loops         &

Calorimetric uncertainty ' t1.9 Total uncertainty 3 elbow taps / loop t 1.i Total uncertainty 1 elbow tap / loop 10 2

                                                                . . e e

e # e e 6 O e

                                                             #                  e e

e , o a 9 0 e l i . 9 1: .

                                    -   ._.        --=              -               _ _ _ .       .. _ _ _ -

[ t EFER NCES .

1. Westinghouse letter NS-CE-1583, C. Eicheidinger to J. F. stolz, NRC, l

dated 10/25/77.

2. Westinghouse letter NS;.PLC-6111, 7. M. Anderson to E. Case, NRC, dated I/30/78..
3. Westinghousa letter NS-TMA-1537. T.'N. Anderson to 5. Varsa, NRC,

! dated 6/23/78. 4.- Westinghouse letter NS-TML-1835, T M Anderson to E. Case, NRC, dated s/22/78. l 5. MNC 1etter, 5. A Varge; to L Delan, Indiana. and Michigan Electric l Campany, dated 2'/ T2/81.

  • i 6~.
                   .NUREG-0717 Supplement No. 4, Safety Evaluation Report related to            ,

the operation of VirgiT C. Summer Asclear Station Unit No.1, Docket 50-39E, August, 1982. ., NRC proposed Regulatory Guide 1.105 Rev. 2 "Instnanent Setpoints", 7. dated 12/81 for implementation 6/82. .

8. ANSI /ANS Standard 58.4-1979, Triteria for Technical Specifications
            -         for Nuclear Power Stations".

1982 *3atpoints for

9. ANSI /M717134 Standard $57.04,.

Nuclear safety-Aslated. Instreantation used in Nuclear Power Plants".

10. Scientific Apparatus Mansfacturers Association, standard
                   . Ptt-20-1-1973,. " Process Measurement and Control Teminology".
11. NUREG-0452 Rev. 4. Standard Technical Snee.ificatinns far Westinghouse Pressurized Water Reactors, Fall 1981.

l

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