Text

Proposed Tech Specs 3/4.5.3.2.1 & 3/4.5.2 Modifying Presently Specified 18-month Surveillance Frequencies to New Specified Frequencies of Once Each 24-months
	ML20138A689
Person / Time
Site:	Davis Besse
Issue date:	04/18/1997
From:	; CENTERIOR ENERGY
To:	;
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ML20138A317	List: ML20138A312; ML20138A320; ML20138A689;
References
	NUDOCS 9704280179
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_

LAR 96-0014 Paga 23 INSTRUMENTATION ACD!il0NAL OW!GfS PREVIOWil t

PROPOSE 0 SY LETIER 3/4.3.2 SAFETY SYSTEM INSTRUMENTATION Serial No. 22.05 Date #1/4 l9/,

SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.2.1 The Safety Features Actuation System (SFAS) functional units shown in Table 3.3-3 shall be OPERABLE with their trip setpoints set consistent with the values shown in the Trip Setpoint column of Table 3.3-4.with the_ exception ofInstrument Strines Funclional Units d and e and Interlock Channels Functional Unit a which shall be2et consistent with the Allowable Value column of Table 3.3-4. and with RESPONSE TIMES as shown in Table 3.3-5.

APPLICABILITY: As shown in Table 3.3-3.

ACTION:

With a SFAS functional unit trip setpoint less conservative than the value shown in the a.

Allowable Values column of Table 3.3-4, declare the functional unit inoperable and apply the applicable ACTION requirement of Table 3.3-3, until the functional unit is restored to OPERABLE status with the trip setpoint adjusted consistent with Table 3.3-4. the-T+ip Setpeint-value:

b.

With a SFAS functional unit inoperable, take the action shown in Table 3.3-3.

SURVEILLANCE lEQUIREMENTS 4.3.2.1.1 Each SFAS functional unit shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CIIANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST during the MODES and at the frequencies shown in Table 4.3-2.

4.3.2.1.2 The logic for the bypasses shall be demonstrated OPERABLE during the at power CHANNEL FUNCTIONAL TEST of functional units affected by bypass operation. The total bypass function shall be demonstrated OPERABLE at least once per 18 months during CllANNEL CALIBRATION testing of each functional unit affected by bypass operation.

4.3.2.1.3 The SAFETY FEATURES RESPONSE TIME of each SFAS function shall be demonstrated to be within the limit at least once per 18 months. Each test shall include at least one functional unit per function such that all functional units are tested at least once every N times 18 months where N is the total number of redundant functional units in a specific SFAS function as shown in the " Total No. of Units" Column of Table 3.' 3.

DAVIS-BESSE, UNIT I 3/43-9 Amendment No.

9704280179 970418 PDR ADOCK 05000346 p

PDR

Tills PAGE PROVIDED FORINFORMATION ONLY f *.

E l

o 3

TABLit 3.3-3 p

SAFETY FEATimtS ACTUATION SYSTEN INSTRUMENTATION

[

N HINIMUN TOTAL NO.

13(ITS 19117 5 APPLICABLE

[

FlatCTICISAL la6IT OF tBIITS TO TRIP OPERABLE MODES ACTION 1.

INSTRialENT STRIIIGS i

s.

Contalement Radiation -

Eigh 4

2 3

1,2,3,4,6****

lui l

b.

Containment Pressure -

i Bigh 4

2 3

1, 2, 3 103 l

c.

Containment Pressure -

Eigh-Sigh 4

2 3

1, 2, 3 103 e

i d.

RCS Pressure - Lov 4

2 3

1, 2, 3*

101 l

e.

RCS Pressure - 14w-Low 4

2 3

1, 2, 3**

108 f.

BUST tavel - tav-taw 4

2 3

1, 2, 3 108 2.

outtur IAGIC o

' a.

Incident Level 01:

i costalement Isolation 2

1 2

1,2,3,4,6****

11 1;

b.

Incident Level 02:

[

Eigh Pressure Injection 7

and Starting Diesel Generators 2

1 2

1, 2, 3, 4 11 l :.

c.

Incident Level 03:

tav Pressure Injection 2

1 2

1, 2, 3, 4 11 l[

d.

Imeldent Level 04:

g Containment Spray 2

1 2

1, 2, 3, 4 11 i[

e.

Incident Level $$s l

t l

Contalmeest Sump Recirculation Permissive 2

1 2

1,2,3,4 11 1[

l s

k l

DilS PAGE PROVIDE FORINFORMAT10N DNLY e

C 3

TABLE 3.3-3 (Continued)

~

SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION MINIMUM TOTAL NO.

UNITS UNITS APPLICABLE FUNCTIONAL UNIT OF UNITS TO TRIP OPERABLE MODES ACTION 3.

MANUAL ACTUATION w

a.

SFAS (except Containment

'A Spray and Emergency Sump Recirculation) 2 2

2 1,2,3,4,6****

12 w

b.

Containment Spray 2

2 2

1,2,3,4 12 4.

SEQUENCE LOGIC CHANNELS a.

Sequencer 4

2/ BUS 2/ BUS 1,2,3,4 15#

l b.

Essential Bus Feeder J

Breaker Trip (90%)

4*****

2/ BUS 2/ BUS 1,2,3,4 15!

l 05 c.

Diesel Generator Start,

,L F Load shed on Essential p*

Bus (59%)

4 2/ BUS 2/ BUS 1,2,3,4 15#

l i

h*

5.

INTERLOCK CHANNELS r

a.

Decay Heat Isolation Valve 1

1 1

1,2,3 13!

U b.

Pressurizer Heaters 2

2 2

3******

14

LAR 96-0014 Page 26 TABLE 3.3-3 (Continued)

TABLE NOTATION

)

Trip function may be bypassed in this MODE with RCS pressure below 1800 psig.

Bypass shall be automatically removed when RCS pressure exceeds 1800 psig.

Trip function may be bypassed in this MODE with RCS pressure below M0_600 psig. Bypass shall be automatically removed when RCS pressure exceeds MQ_600 psig.

DELETED This instrumentation, or the containment purge and exhaust system noble gas monitor (with the containment purge and exhaust system in operation), must bc OPERABLE during CORE ALTERATIONS or movement ofirradiated fuel withm containment to meet the requirements of Technical Specification 3.9.4. When using i

the containment purge and exhaust system noble gas monitor, SFAS is not required to be OPERABLE in MODE 6.

All functional units may be bypassed for up to one minute when starting each Reactor Coolant Pump or Circulating Water Pump.

When either Decay Heat Isolation Valve is open.

The provisions of Specification 3.0.4 are not applicable.

ACTION STATEMENTS ACTION 10 - With the number of OPERABLE functional units one less than the Total Number of Units, STARTUP and/or POWER OPERATION may proceed provided both of the following conditions are satisfied; The inoperable functional unit is placed in the tripped condition within one a.

hour.

b.

The Minimum Units OPERABLE requirement is met; however, one additional functional unit may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1.

ACTION 11 - With any component in the Output Logic inoperable, trip the associated components within one hour or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

DAVIS-BESSE, UNIT 1 3/4 3-12 Amendment No. 28, 37,52, 102,135,159 186,211,

LAR 96-0014 Page 27 IABLE 3.3-3 (Continued)

ACTION STATEMENTS ACTION 12 - With the number of OPERABLE Units one less than the Total Number of Units, restore the inoperable functional unit to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least IIOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

ACTION 13 - a.

With less than the Minimum Units OPERABLE and indicated reactor coolant pressure 232fL438 psig, both Decay Ileat Isolation Valves (DH11 and DH12) shall be verified closed.

b.

With Less than the Minimum Units OPERABLE and indicated reactor coolant pressure < 32fL438 psig operation mey continue; however, the functional unit shall be OPERABLE prior to increasing indicated reactor coolant pressure above 321438 psig.

ACTION 14 - With less than the Minimum Units OPERABLE and indicated reactor coolant pressure < 32fL438-psig, operation may continue; however, the functional unit shall be OPERABLE prior to increasing indicated reactor coolant pressure above 32fL438 psig, or the inoperable functional unit shall be placed in the tripped state.

ACTION 15 - a.

With the number of OPERABLE units one less than the Minimum Units j

Operable per Bus, place the inoperable unit in the tripped condition within one hour. For functional unit 4.a the sequencer shall be placed in the tripped condition by physical removal of the sequencer module. The inoperable ftmetional unit may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1.

b.

With the number of OPERABLE units two less than the Minimum Units Operable per Bus, declare inoperable the Emergency Diesel Generator associated with the functional units not meeting the required minimum units OPERABLE and take the ACTION required of Specification 3.8.1.1.

DAVIS-BESSE, UNIT 1 3/4 3-12a Amendment No. 28,52,102, 135,211,

O><

i{

7 TABLE 3.3-4 g

6 SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION TRIP SETPOINTS gh W

Oo

[U FUNCTIONAL UNIT -

TRIP SETPOINT ALLOWABLE VALUES Z

E

}

INSTRUMENT STRINGS a.

Containment Radiation

< 4 x Background at RATED

< 4 x Background at THERMAL POWER RATED THERMAL POWER #

b.

Containment Pressure - High s 18.4 psia s 18.52 psia #

c.

Containment Pressure - High-High s 3R 4 psia s 38.52 psias a

d. RCS Pressure - Low 21520.75 psig NJA]

21576]2,1515.75 psiges e.

RCS Pressure - Low-Low 2 420.75 ps g N_A]

2 MIi42 4M-76 psig##

f.

BWST Level 2 89.5 and s 100.5 in H2O 2 88.3 and s 101.7 in H20#

SEQUENCE LOGIC CHANNELS 8.

a.

Essential Bus Feeder Breaker Trip (90%)

2 3744 volts for 2 3558 volts P.

s 7.8 see s 7.8 sec Z

Oy b.

Diesel Generator Start, Load Shed on 2 2071 and s 2450 volts a 2071 and s 2450 y

Essential Bus (59%)

for 0.5 0.1 sec volts for 0.5

0.1 sec#

Ta

~$

INTERLOCK CHANNELS o

'y Decay Heat Isolation Valve

< CS psigN A]

< 328 443 psiges*

a.

and Pressurizer Heater

' Allowable Value for CHANNEL FUNCTIONAL TEST and CHANNEL CALIBRATION

Referenced to the RMP_qjnstrunnentatiotitap. untd:n; cf DIII1 and DII!2.

"M! W M Ee @ M FUN _CTIp M M

.--.-.__--_-_._._..-______.___------_-__._._.--__-_----_..____---__-----__,__-._.___n_

7 TlilS PAGE PROVIDED cr" FORINFORMATON DN TABLE 3.3-5 SAFETY FEATURES SYSTEM REPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS 1.

Manual a.

Fans 1.

Emergency Vent Fan NA 2.

Containment Cooler Fan 3

NA b.

HV & AC Isolation Valves 1.

ECCS Room NA 2.

Emergency Ventilation NA 3.

Containment Air Sample NA 4.

Containment Purge NA 5.

Pentration Room Purge NA Control Room HV & AC Units c.

NA d.

High Pressure Injection 1.

High Pressure Injection Pumps NA 2.

High Pressure Injection Valves NA Component Cooling Water e.

1.

Component Cooling Water Pumps NA 2.

Component Cooling Aux. Equip. Inlet Valves NA 3.

Component Cooling to Air Compressor Valves NA f.

Service Water System 1.

Service Water Pumps NA 2.

Service Water From Component Cooling Heat Exchanger Isolation Valves NA g.

Containment Spray Isolation Valves NA h.

Emergency Diesel Generator NA 1.

Containment Isolation Valves 1.

Vacuum Relief NA 2.

Norma 1 Sump _

NA 3.

RCS Letdown Delay Coil Outlet NA 4.

RCS Letdown High Temperature NA DAVIS-BESSE, UNIT 1 3/4 3-14

THIS PAGE PROVIDED LAR 96-0014 TABLE 3.3-5 (

SAFETY FEATURES SYSTEM RESPONSE TIMES INITIATING SIGNAL AND FUNCTION i

RESPONSE TIME IN SECONDS i.

Containment Isolation Valves (cont'd) 5.

Pressurizer Sample NA 6.

Service Water to Cooling Water 4

NA 7.

Vent Header 1

i NA 8.

Drain Tank NA 9.

Core Flood Tank Vent NA 10.

Core Flood Tank Fill

}

l NA 11.

Steam Generator Sample NA 12.

Quench Tank NA 13.

Emergency Sump i

I NA 14 RCP Seal Return i

15.

Air Systems NA NA 16.

N System 2

NA 3

17.

Quench Tank Sample NA 18.

RCP Seal Inlet NA 19.

Core Flood Tank Sample 20.

RCP Standpipe Demin Water Supply NA 4

NA 21.

Containment H Dilution Inlet NA 3

22.

Containment Dilution Outlet NA i

j.

BWST Outlet Valves NA k.

Low Pressure Injection 1.

Decay Heat Pumps NA

~2.

Low Pressure Injection Valves NA 3.

Decay Heat Pump Suction Valves NA 4.

Decay Heat Cooler Outlet Valves NA 5.

Decay Heat Cooler Bypass Valves-NA

~

1.

Containment Spray Pump NA Component Cooling Isolation valves m.

1.

Inlet to Containment NA 2.

Outlet from containment NA 3.

Inlet to CRDN's NA 4

CRDM Booster Pump Suction NA 5.

Component Cooling from Decay Heat Coolers NA DAVIS-BESSE, UNIT 1 3/4 3-15 Amendment No. I!2. MA 135

THIS PAGE PROVIDS FORINFORMAIl0N DK TABLE 3.3-5 (Contiaued)

SAFETY FEATURES SYSTEM RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS t

2.

Containment Pressure - High a.

Fans 1.

Emergency Vent Fans 2.

Containment Cooler Fans 5 25*

1 45*

4 b.

HV & AC Isolation Valves 1.

ECCS Room

< 75*

2.

Emergency Ventilation j75*

3.

Containment Air Sample 4

Containment Purge 1 30*

5.

Penetration Room Purge i 15*

1 75*

Control Room KV & AC Units c.

i 10*

d.

High Pressure Injection 1.

High Pressure Injection Pumps 1 30*

2.

High Pressure Injection Valves 1 30*

Component Cooling Water e.

1.

Component Cooling Water Pumps i 180*

2.

Component Cooling Aux. Equip. Inlet Valves 1 180*

3.

Component Cooling to Air Compressor Valves

< 180*

f.

Service Water System

~

1.

Service Water Pumps 1 45*

2.

Service Water From Component Cooling Heat Exchanger Isolation Valves

< NA*

g.

Containment Spray Isolation Valves

< 80*

b.

Emergency Diesel Generator i 15*

DAVIS-BESSE, UNIT 1 3/4 3-16 Amendment No. 114

LRR 96-0014 Page 32 TABLE 3.3-5 (Continued) 1 SAIITY FEATURES SYSTEM RESPONSE TIMES INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS 2.

Containment Pressure - High (Continued)

}

i.

Containment Isolation Valves 1.

Vacuum Relief 5 30*

2.

Normal Sump i 25*

3.

RCS Letdown Delay Coil Outlet i 30*

4.

RCS Letdown High Temperature 1 30* g 5.

Pressurizer Sample 1 48-5 45* yE 6.

Service Water to Cooling Water 1 15* g O f

7.

Vent Header 8.

Drain Tank 5 15* >

9.

Core Flood Tank Vent i 15* @

10.

Core Flood Tank Fill i 15* g 11.

Steam Generator Sample 1 15* g i

12.

Quench Tank i 15*

13.

Emergency Sump NA*

y 14.

RCP Seal Return 5 45* gg 15.

Air System 1 15* g 16.

N2 System 5 15* g j

17.

Quench Tank Sample 1 35*

g 18.

RCP Seal Inlet

< 17*

=

l 19.

Core Flood Tank Sample 1 15* Ng 20.

RCP Standpipe Demin Water Supply 1 15*

gg

)

21.

Containment H2 Dilution Inlet i 75*

p ba 22.

Containment H2 Dilution Outlet

_ 75*

j.

BWST Outlet Valves NA*

k.

Low Pressure Injection 1.

Decay Heat Pumps 5 30*

2.

Low Pressure Injection Valves 5 NA*

3.

Decay Heat Pump Suction Valves 5 NA 4.

Decay Heat Cooler Outlet Valves

$ NA*

5.

Decay Heat Cooler Bypass Valves

_ NA*

3.

Containment Pressure--High-High a.

Containment Spray Pump

_ 80*

b.

Component Cooling Isolation Valves

~

1.

Inlet to Containment 1 25*

2.

Outlet from Containment i 25*

DAVIS-BESSE, UNIT 1 3/4 3-17 Amendment No. YY7,JU.

l

TulTPIGDit0VIDED

't""

FORINFORMAIDN DNJ TABLE 3.3-5 (Continued)

SAFETY FEATURES SYSTEM RESPONSE TIMES INITIATING SIGNAL AND RINCTION RESPONSE TIME IN SECONDS b.

Component Cooling Isolation Valves (Continued) 3.

Inlet to CRDM's

< 35*

4 CRDM Booster Pump Suction Component Cooling from Decay Heat Cooler 535*

5.

i NA*

4.

RCS Pressure-Low I

4 a.

Fans 1.

Emergency Vent Fans 2.

Containment Cooler Fans 5 25*

5 45*

b.

HV & AC Isolation Valves 1.

ECCS Room

< 75*

2.

Emergency Ventilation 3.

Containment Air Sample 575*

4.

Containmen*, Purge 5 30*

I 5.

Penetration Room Purge 5 15*

1 75*

j c.

Control Room HV & AC Units 5 10*

d.

High Pressure Injection 1.

i High Pressure Injection Pumps 2.

High Pressure Injection Valves 1 30*

5 30*

i Component Cooling Water e.

i l

1.

Component Cooling Water Pumps 2.

Component Cooling Aux. Equipment Inlet

~< 180*

Valves

< 180*

3.

Component Cooling to Air Compressor Valves 5180*

f.

Service Water System 1.

Service Water Pumps 1 45*

2.

Service Water from Component Cooling Heat Exchanger Isolation Valves 1 NA*

g.

Containment Spray Isolation Valves 5 80*

h.

Emergency Diesel Generator 5 15*

DAVIS-BESSE, UNIT 1 3/4 3-18 Amendment No.

114

LAR 96-0014 Page 34 j.

TABLE 3.3-5 (Continued)

SAFETY FEATURES SYSTEM RESPONSE TIMES l

INITIATING SIGNAL AND FUNCTION RESPONSE TIME IN SECONDS 4.

RCS Pressure-Low (continued) 1.

Containment Isolation Valves 1.

Vacuum Relief

<3'*

J 2.

Normal Sump 525*

3.

RCS Letdown Delay Cof1 Outlet 5 30*

4.

RCS Letdown High Temperature 1 30*

5.

Pressurizer Sample 1 45*

6.

Service Water to Cooling Water 1 45#

7.

Vent Header

< 15*

8.

Drain Tank 7 15* O

,,,A 9.

Core Flood Tank Vent i 15* W 515* O_ g 10.

Core Flood Tank Fill g

11.

Steam Generator Sample 1 15*

5 15* p 12.

Quench Tank 13.

Emergency Sump NA* g 14.

Air Systems 1 15* g p 15.

N2 System 5 15*

16.

Quench Tank Sample

< 35*

17.

Core Flood Tank Sample i 15*

18.

RCP Standpipe Demin Water Supply 2 15*

2 Dilution Inlet 7 75* 4 O 19.

Containment H 2 Dilution Outlet 5 75* b 20.

Containment H NA* M = M

==

j.

BWST Outlet Valves 5.

RCS Pressure--Low-Low Low Pressure Injection a.

1.

Decay Heat Pumps i 30*

2.

Low Pressure Injection Valves i NA*

3.

Decay Heat Pump Suction Valves

,5 NA*

4.

Decay Heat Cooler Outlet Valves i NA*

5.

Decay Heat Cooler Bypass Valves i NA*

b.

Component Cooling Isolation Valves 1.

Auxiliary Equipment Inlet 5 90*

2.

Inlet to Air Compressor 1 90*

3.

Component Cooling from Decay Heat Cooler 5 NA*

Containment Isolation Va'lves c.

1.

RCP Seal Return 1 45*

2.

RCP Seal Inlet 1 17*

DAVIS-BESSE, UNIT 1 3/e 3-19 Amendment No. hh.444. 44/. 135

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

_ -. ~,...

/

LAR 96-0014 Page 35 THIS PAGE PROV DED FORINFORNIATION ONLY i

j TACLE 3.3-5 (Continued)

SAFETY FEATURES SYSTEM RESPONSE Ti!!ES i

INITTAT!!!G SIGNAL AND FUNCTION RESPONSE T!!1E IN SECONOS i

6.

Containment Radiation - High

,1 a.

Emergency Vent fans i

< 25*

b.

HV & AC Isolation Valves 1.

ECCS Room

< 75*

j 2.

Emergency Ventilation 7 75*

3.

Containment Air Sample 7 30*

i 4

Containment Purge 7 15*

5.

Penetration Room PJrge 7 75*

i l

c.

Control Room HV & AC Units

)

10*

i l

TABLE NOTATION Diesel generator starting and sequence loading delays included wher.

applicable.

Response time limit includes movement of valves and j

attainment of pung w blower discharge pressure.

,t j

' DAVIS-BESSE. UNIT 1 3/4 3-20 Amendment No. 40

THIS PAGE PROVIDED y

g FOR INFORMATION DNLY 1A.L".>->

Y' SAFLTY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REQUIREMENTS o

N t

12

.M CHANNEL MODES IN UllICil t

g CRANNEL CHANNEL FUNCTIONAL SURVEILLANCE Q

FUNCTIONAL UNIT CHECK CALIBRATION TEST REQUIRED i

1.

INSTRUMENT STRINGS I

a.

Containment Radiation - High S

R M

1,2,3,4,61 l

b.

Containment Pressure - High S

R M(2) 1, 2, 3 c.

Containment Pressure - High-High S

R M(2) 1, 2, 3

(

d.

RCS Pressure - Low S

F.

M 1, 2, 3 e.

RCS Pressure - Low-Low S

R H

1,2,3

,f.

BUST Level - Low-Low S

R M

1, 2, 3 2.

DUTPttr IACIC Y

u, U

a.

Incident Level Ilt Containment h

y Isolation S

R M

1,2,3,4,68 5

5?

b.

Incident Level B2: !!!gh Pressure P,@

Injection and Starting Diesel g g =,

Generators S

R

.H 1, 2, 3, 4 x3m

}

c.

Incident Level 83: 14v Pressure 0,M 9 Injection S

R H

1,2,3,4 Wo$

j E

d.

Incident Level 14: Containment SE S

(

Spray S

R H

1,2,3,4 r- [

a w

o.

Incident Level 85: Containment

%3m O

Sump Recirculation Permissive S

R H

1,2,3,4 9

c-f 3.

MANUAL ACTUATION hy

,D s.

SFAS (Except Containment Spray NA NA M(1) 1,2,3,4,68 i

g and Emergency Susp Recirculation) b.

Containment Spray NA N4 M(1) 1, 2, 3

(

Q t

f..

SEQUENCE LOGIC CHANNELS S

NA H

1, 2, 3, 4 l

M l

(

THIS PAGE PROVIDED FORINFORBil0N ON hn g

TABLE 4.3-2 (Continued)

.5y SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SURVEILLANCE REOUIREMENTS A

[M CHANNEL MODES IN WHICH c

CHANNEL CHANNEL FUNCTIONAL

-SURVEILLANCE FUNCTIONAL UNIT

_ CHECK CALIBRATION TEST RE0VIRED z

5.

INTERLOCK CHANNELS a.

Decay Heat Isolation Valve S

R b.

Pressurizer Heater S

R 1, 2, 3 3 ##

- See Specification 4.5.2.d.1 w

Jh TABLE NOTATION m

h (1)

Manual actuation switches shall be tested at least once per 18 months during shutdown.

All other circuitry associated with manual safeguards actuation shall receive a CHANNEL FUNCTIONAL TEST at least once per 31 days.

(2)

The CHANNEL FUNCTIONAL TEST shall include exercising the transmitter by applying either vacuum or pressure to the appropriate side of the transmitter.

These surveillance requirements in conjunction with those of Section 4.9.4 apply during CORE

.yg ALTERATIONS or movement of irradiated fuel within the containment only if using the STAS area J

radiation monitors listed in Table 3.3-3, Items la,~ 2a, and 3a, in lieu of the con'.alnmeat purge and gg exhzust system noble gas monitor.

2 02 When either Decay Heat Isolation Valve is open.

.?

A0 Dill 0NAL CliAt:GE5 PREVIOUSLY PROFOSE0 Bi LETTER E

Serial No. 24 05

. Date 81/"l%

- s

i 11118PAGE PROVIDED l

Page 38 FORINFORNIATION ONIY EMERGENCY CORE COOLING SYSTEMS

_ECCS SUBSYSTEMS - T......, A 280*F I

[

L1HITING CONDITION FOR OPERATION 3.5.2 Two independent ECCS subsystems shall be OPERABLE with each subsystem comprised of:

I One OPERABLE high pressure injection (HPI) pump.

a.

b.

One OPERABLE low pressure injection (LPI) pug, i

c.

One OPERABLE decay heat cooler, and d.

An OPERABLE flow path capable of takirg suction from the borated water stora e tank (BWST) on a safety injection signal and manually transf rring suction to the containment sump during the recirculation phase of operation.

APPLICABILITY: HOCES 1, 2 and 3.

ACTION:

With one ECCS subsystem inoperable, restort the inoperable a.

subsystem to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or be in HOT 9

SHUTDOWN within the next 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

b.

In the event the ECCS is actuated and injects water into the j

Reactor Coolant System, a Special Report shall be prepared and submitted to the Comission pursuant to Specification 6.9.2 within 90 days describing the circumstances of the actuation l

and the total accumulated actuation cycles to,da,te.

SURVE!LLANCE REOUIREMENTS l

1 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

At least once per 31 days by verifying that each valve (manugl.

a.

power operated or autoratic) in the flow path that is not locked.

sealed or otherwise se'.:ured in position. is in its correct position.

DAY!S-BESSE. UNIT 1 3/4 S.3 Amendment No. L 182 i

]

Revised by NRC Letter Dated m gg_ggg Page 39 June 6,1995 SURVEILLANCE REQUIREMENTS (Continued) c b.

At least once each REFUELING INTERVAL, or prior to operation after ECCS piping has been drained by verifying that the ECCS piping is full of water by venting the ECCS pump casings and discharge piping high points.

By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in c.

the containment which could be transported to the containment emergency sump and cause restriction of the pump suction during LOCA conditions. This visual inspection shall be performed:

1.

For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and 2.

For all areas of containment affected by an entry, at least once daily while work is ongoing and again during the final exit after completion of work (containment closcout) when CONTAINMENT INTEGRITY is established.

d.

At least once each REFUELING INTERVAL per 18 months by:

1.

Verifying that the interlocks:

a)

Close DH-11 and DH-12 and deenergize the pressurizer heaters, if either DH-11 or DH-12 is open and a simulated reactor coolant system pressure which is greater than the Allowable Value trip setpcint (<323_448 psig) is applied. The interlock to close DH-11 and/or DH-12 is not required if the valve is closed and 480 V AC power is disconnected from its motor operators.

.14 m.tR b)

Prevent the opening of DH-11 and DH-12 when a simulated or actual reactor coolant j $4 system pressure which is greater than the Allowable Value trip +,etpsa (<328_448 psig)

E Tf$

is applied.

EE3

$[

2.

a)

A visual inspection of the containment emergency sump which verifies that the y

subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

5gg%n AE

@Ey b)

Verifying that on a Borated Water Storage Tank (BWST) Low-Low Level interlock trip, s5 with the motor operators for the BWST outlet isolation valves and the containment Si j

emergency sump recirculation valves energized, the BWST Outlet Valve HV-DH7A (HV-DH7B) automatically close in s75 seconds after the operator manually pushes the control switch to open the Containment Emergency Sump Valve HV-DH9A (HV-DH9B) which should be verified to open in s75 seconds.

3.

Deleted DAVIS-BESSE, UNIT 1 3/45-4 Amendment No. 3,25,28,40,77,135, 182,195,196,208,214

r Tills PAGE PROVIDED Page 40 FORINFORMAIl0N DNLY EMERGENCY CORE COOLING SYSTEMS SURVEllIANCE REQUIREMENTS (Continued) 4.

Verifying that a minimum of 290 cubic feet of trisodium l

phosphate dodecahydrate (TSP) is contained within the TSP storage baskets.

5.

Deleted l

6.

Deleted

[

e.

At least once per 18 months, during shutdown, by 1.

Verifying that each automatic valve in the flow path actuates to its correct position on a safety injection test signal.

2.

Verifying that each HPI and LPI pump starts automatically upon receipt of a SFAS test signal.

f.

By performing a vacuum leakage rate test of the watertight enclosure for valves DH-Il and DH-12 that assures the motor operators on valves DH-11 and DH-12 will not be flooded for at least 7 days following a LOCA:

1.

At least once per 18 months.

2.

After each opening of the watertight enclosure.

3.

After any maintenance on or modification to the watertight enclosure which could affect its integrity.

g.

By verifying the correct position of each mechanical position stop for valves DH-14A and DH-148.

1.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following completion of the opening of the valves to their mechanical position stop or following completion of maintenance on the valve when the LPI system is required to be OPERABLE.

2.

At least once per 18 months.

~

ADDlil0NAL CHANGES PREVIOUSLY PROPOSED BY LEliER Serial No1LLs Date Lin4/91 DAVIS-BESSE, UNIT 1 3/4 5-5 Amendment No.-Gh

~-40 H 91, 207

LAR 96-o014 THIS PAGE PROVIDED

~"

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued) h.

By performing a flow balance test, during shutdown, following completion of modifications to the HPI or LPI subsystems that alter the subsystem flow characteristics and verifying the following flow rates:

HPI System - Single Pump

~

Injection Leg 1-1 1 375 gpm at 400 psig*

Injection Leg 1-2 1 375 gpm at 400 psig*

Injection Leg 2-1 3

1 75 gpm at 400 psig*

Injection Leg 2-2 1 375 gpm at 400 psig*

LPI System - Single Pump Injection Leg 1 12650 gpm at 100 p,sig**

Injection Leg 2 12650 gpm at 100 psig**

Reactor coolant pressure at the HPI nozzle in the reactor coolant pump discharge.

Reactor coolant pressure at the core flood nozzle on the reactor vessel.

DAVIS-BESSE, UtilT 1 3/4 5-Sa Amend.T.en t tio. 20

t LAR 96-0014 P gs 42 3/4.3 INSTRUMENTATION BASES 3/4.3.1 and 3/4.3.2 REACTOR PROTECTION SYSTEM AND SAFETY SYSTEM INSTRUMENTATION The OPERABILITY of the RPS, SFAS and SFRCS instrumentation systems ensure that 1) the associated action and/or trip will be initiated when the parameter monitored by each channel or combination thereof exceeds its setpoint,2) the specified coincidence logic is maintained,3) sufficient redundancy is maintained to permit a channel to be out of service for testing or maintenance, and 4) sufficient system functional capability is available for RPS, SFAS and SFRCS purposes from diverse parameters.

The OPERABILITY of these systems is required to provide the overall reliability, redundance and diversity assumed available in the facility design for the protection and mitigation of accident and transient conditions. The integrated operation of each of these systems is consistent with the assumptions used in the accident analyses.

The surveillance requirements sp 4 ified for these systems ensure that the overall system functional capability is maintained comparable to the original design standards. The periodic surveillance tests performed at the minimum frequencies are sufficient to demonstrate this capability.

For the RPS. SFAS_ Table 13-LFunctional Unit Instrument Strings d and e2nd Interlock _ Channel a. and SFRCS Table 3.3-12 Functional Unit 2:

Only the Allowable Value is specified for each Function. Nominal trip setpoints are specified m the_setpoint analysis,_Ihe nominal tripactpoints are selected to ensure the_setpoints. measured _by CHANNEL FUNCTIONAL TESTS do not exceed the Allowable Value if the bistable is performing as required. Operation with a trip sc1 point less conservative than the nominal trip setpoint. but within its Allowable Value. is acceptable provided that operation and testing 2re consistentwitlL1he assumptions ofibs_ specific setpoint calculations. Each Allowable Value g

sp.ecified is more conservative than the analytical limit assumed in the safety analysis to account

,d Y

for. instrument uncertaintienppropriate_to_thg_ trip parameter. Iilese_ uncertainties are defined in thelpeciRc setpoint analysis.

W$2 c-3 E A CHANNEL FUNCTION AIJEST is performed on eacluequircichannel to ensure that the C >-

entire _ channel will oerform the intended function. Setooints must be fe.und within the soccified

$$[

Allowah]e Values. 'Any selpoint adjustment.shall be consistent with the assmnptions of the 5W current specific selpointanalysis.

d$*"

A CHANNEL CAllBRA110N is a complete check of thtjnstrunlent channekincludiog_the g g:,

sensor. The test verifies that the channel responds to the measured parameter within the E

E h]

necessary rarigt aniaccuracy. CHANNEL CAllBilAllON. leaves the channel adjusteilo a

account for instrument drift _to ensure that the instrument channel remains operational between successive tests. CHANNEL CALIBRATION shall find that measurement errors and bistable setooint errors are within the assumplions of the setooint analysis. CHANNEL CALIBRATIONS must be perfornted consistent with the assumptions _of the setpoint anablis.

TheftequencylsiustiDed by the assumption of an 18_or 24 month calibration interval in the determmatiqn of theanagnitude of equipment drift in the_setpointlnaly315.

DAVIS-BESSE, UNIT I B 3/4 3-1 Amendment No.

( Next page is B3/4 3-la)

LAR 96-0014 PEge 43 3/4.3 INSTRUMENTATION 1

BASES j

3/4.3.1 and 3/4.3.2 REACTOR PROTECTION SYSTEM AND SAFETY SYSTEM INSTRUMENTATION (Continued.)

The measurement of response time at the specified frequencies provides assurance that the RPS, SFAS, and SFRCS action function associated with each channel is completed within the time limit assumed in the safety analyses. No credit was taken in the analyses for those channels with response times indicated as not applicable.

Response time may be demonstrated by any series of sequential, overlapping or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either 1) in place, onsite or offsite test measurements or 2) utilizing replacement sensors with certified response times.

The actuation logic for Functional Units 4.a.,4.b., and 4.c. of Table 3.3-3, Safety Features Actuation System Instrumentation, is designed to provide protection and actuation of a single train of safety features equipment, essential bus or emergency diesel generator. Collectively, Functional Units 4.a.,4.b., and 4.c. function to detect a degraded voltage condition on either of the two 4160 volt essential buses, shed connected loads, disconnect the affected bus (es) from the offsite power source and start the associated emergency diesel generator. In addition, if an SFAS actuation signal is present under these conditions, the sequencer channels for the two SFAS channels which actuate the train of safety features equipment powered by the affected bus will automatically sequence these j

loads onto the bus to prevent overloading of the emergency diesel generator. Functional Unit 4.a.

has a total of four units, one associated with each SFAS channel (i.e., two for each essential bus).

]

Functional Units 4.b. and 4.c. each have a total of four units, (two associated with each essential bus); each unit consisting of two undervoltage relays and an auxiliary relay.

An SFRCS channel consists of 1) the sensing device (s),2) associated logic and output relays (including Isolation of Main Feedwater Non Essential Valves and Turbine Trip), and 3) power sources.

The SFRCS response time for the turbine stop valve closure is based on the combined response times of main steam line low pressure sensors, logic cabinet delay for main steam line low pressure signals and closure time of the turbine stop valves. This SFRCS response time ensures that the auxiliary feedwater to the unaffected steam generator will not be isolated due to a SFRCS low pressure trip during a main steam line break accident.

Safety-grade anticipatory reactor trip is initiated by a turbine trip (above 45 percent of RATED THERMAL POWER) or trip of both main feedwater pump turbines. This anticipatory trip will operate in advance of the reactor coolant system high pressure reactor trip to reduce the peak reacter coolant system pressure and thus reduce challenges to the pilot operated relief valve. This

~

anticipatory reactor trip system was installed to satisfy Item II.K.2.10 of NUIEG-0737. The justification for the ARTS turbine trip arming level of 45% is give in BAW-1893, October,1985.

DAVIS-BESSE, UNIT 1 B 3/4 3-la Amendment No. 73,125,128,135,

211,

Ul3 PAGE PROVIDED

~ "

FORINFORMAIl0N ON 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

BASES 3/4.5.1 CORE FLOODING TANKS The OPERABILITY of each core flooding tank ensures that a sufficient volume of borated water will be immediately forced into the reactor vessel in the event the RCS pressure falls below the pressure of the tanks. This initial surge of water into the vessel provides the initial 1

cooling mechanism during large RCS pipe ruptures.

The limits on volume boron concentration and pressure ensure that the assumptions used for cor,e flooding tank injection in the safety analysis l

are met.

The tank power operated isolation valves are considered to be

" operating bypasses in the context of IEEE Std. 279-1971 which requires i

that bypasses of a protective function be removed automatically whenever permissive conditions are not met.

In addition valves fall to meet single failure criteria, rem; oval of power'to theas these tank isolation.

yalves is required.

The one hour limit for operation with a core flooding tank (CFT) inocerable for reasons other than boron concentration not within limits minimizes the time the plant is exposed to a possible LOCA event occurring with failure of a CFT, which may result in unacceptable peak cladding temperatures.

With boron concentration for one CFT not within limits, developed the condition must be, corrected within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months limit was considering that the effects of reduced boron concentration on core subcriticality during reflood are minor. Bolling of the ECCS water in the core during reflood concentrates the boron in the saturated liquid that remains in the core.

In addition the volume of the CFTs is still t

a'.ailable foi injection. Since the bor,on requirements are based on the average boron concentration of the total volume of both CFTs the consequences are less severe than they would be if the conten,ts of a CFT were not available for injection.

The completion times to bring the plant to a MODE in which the Limiting Condition for Operation (LCO) does not apply are reasonable based on operating experience. The completion times allow plant conditions to be changed in an orderly manner and without challenging plant systems.

CFT boron concentration sampling within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months after an 80 gallon volume increase will identify whether inleakage from the RCS has caused a reduction in boron concentration to below the required limit. It is not necessary to verify boron concentration if the added water inventory is 1

from the bora~ted water storage tank (BWST)lon requirements because the water contained in the BWST is within CFT boron concentrat 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS The operability of two independent ECCS subsystems with RCS average l

temperature 2 280 F ensures that sufficient emergency core cooling capability will be available.in the event of a LOCA assuming the loss of one subsystem through any single failure consideration. Either subsystem operathg in conjunction with the core flooding tanks is capable of supplying sufficient core cooling to maintain the peak cladding temperatures within acceptable limits for all postulated break sizes ranging from the double ended break of the largest RCS cold leg pipe 4

downward.

In addition, each ECCS subsystem provides long term core-cooling capability in the recirculation mode during the accident recovery period DAVIS-BESSE, UNIT 1 B 3/4 5-1 Amendment No. 40,191

=="

THIS PAGE PROVIDED EMERGENCY CORE COOLING SYSTEMS BASES With the RCS temperature.below 280*F, one OPERABLE ECCS subsystem is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the limited core cooling requirements.

The Surveillance Requirements provided to ensure OPERABILITY of each component ensures that, at a minimum, the assumptions used in the safety analyses are met and that subsystem OPERABILITY is maintained.

The function of the trisodium phosphate dodecahydrate (TSP) contained in baskets located in the containment normal sump or on the 565' elevation of

' containment adjacent to the normal sump, is to neutralize the acidity of the post-LOCA borated water mixture during containment emergency sump recirculation.

The borated water storage tank (BWST) borated water has a nominal pli value of approximately 5.

Raising the borated water mixture to a pH value of 7 will ensure that chloride stress corrosion does not occur in austenitic stainless steels in the event that chloride levels increase D

E r*

as a result of contamination on the surfaces of the reactor containment S

Also, a pH of 7 is assumed for the containment emergency sump

$ cc: d building.

for iodine retention and removal post-LOCA by the containment spray system.

e$q r4 The Surveillance Requirement (SR) associated with TSP ensures that the o-y a minimum required volume of TSP is stored in the baskets.

t2 >

The minimum 52 m required volume of TSP is the volume that will achieve a post-LOCA borated water mixture pH of 2 7.0, conservatively considering the maximum possible E 9 to O8+$

sump water volume and the maximum possible boron ccncentration. The amount of TSP required is based on the mass of TSP needed to achieve the required

tg; pH.

However, a required volume is verified by the SR, rather than the g g:

mass, since it is not feasible to weigh the entire amount of TSP in e,

25 5I containment. The minimup required volume is based on the manufactured E

ji density of TSP (53 lb/ft ).

Since TSP can have a tendency to agglomerate wl from high humidity in the containment, the density may increase and the volume decrease during normal plant operation, however, solubility characteristics are not expected to change.

Therefore, considering possible agglomeration and increase in density, verifying the minimum volume of TSP in containment is conservative with respect to ensuring the capability to achieve the minimum required pH.

of TSP to meet all anglytical requirepents is 250 ft.Thepinimumrequiredvolume The surveillance requirement of 290 ft ingludes40ft of spare TSP as margin. Total basket capacity is 325 ft.

Surveillance requirements for throttle valve position stops and flow balance testing provide assurance that proper ECCS flows will be maintained in the event of a LOCA. Maintenance of proper flow resistance and pressure drop in the piping system to each injection point is necessary to:

(1) prevent total pump flow from exceeding runout conditions when the system is in its minimum resistance configuration, (2) provide the proper flow split between injection points in accordance with the assumptions used in the ECCS-LOCA analyses, and (3) provide an acceptable level of total ECCS flow to all injection points equal to or above that assumed in the ECCS-LOCA analyses.

DAVIS-BESSE, UNIT 1 8 3/4 5-2 Amendment No. 20rl23r182+

191d95i207 i

LAR 96-0014 Paga 46 EMERGENCY CORE COOLING SYSTEMS BASES (Continued)

Containment Emergency Sump Recirculation Valves DH-9A and DH-9B are de-energized during MODES 1,2,3 and 4 to preclude postulated inadvertent opening of the valves in the event of a Control Room fire, which could result in draining the Borated Water Storage Tank to the Containment Emergency Sump and the loss of this water source for normal plant shutdown. Re-energization of DH-9A and DH-9B is permitted on an intermittent basis during MODES 1,2,3 and 4 under administrative controls. Station procedures identify the precautions which must be taken when re-energizing these valves under such controls.

Borated Water Storage Tank (BWST) outlet isolation valves DH-7A and DH-7B are de-energized during MODES 1,2,3, and 4 to preclude postulated inadvertent closure of the valves in the event of a fire, which i

could result in a loss of the availability of the BWST. Re-energization of valves DH-7A and DH-7B is permitted on an intermittent basis during MODES 1,2,3, and 4 under administrative controls. Station procedures identify the precautions which must be taken when re-energizing these valves under such controls.

The Decay Heat Isolation Valve and Pressurizer Heater Interlock setnoint is based on preventing over-pressurization of the Decay Heat Removal System normal suction line piping. The value stated is the RCS pressure at the sensine instrument's tan. It has been adiusted to reflect.the elevation difference between the sensor's location and the pipe of concent 3/4.5.4 BORATED WATER STORAGE TANK The OPERABILITY of the borated water storage tank (BWST) as part of the ECCS ensures that a sufficient supply of borated water is available for injection by the ECCS in the event of a LOCA. The limits on the BWST minimum volume and boron concentration ensure that:

1) sufficient water is available within containment to permit recirculation cooling flow to the core following manual switchover to the recirculation mode, and j

2)

The reactor will remain at least 1% ak/k suberitical in the cold condition at 70 F, xenon free, while only crediting 50% of the control rods' worth following mixing of the BWST

]

and the RCS water volumes.

These assumptions ensure that the reactor remains subcritical in the cold condition following mixing of the i

BWST and the RCS water volumes.

With either the BWST boron concentration or BWST borated water temperature not within limits, the condition must be corrected in eight hours. The eight hour limit to restore the temperature or boron i

concentration to within limits was developed considering the time required to change boron concentration or j

temperature and assuming that the contents of the BWST are still available for injection.

The bottom 4 inches of the BWST are not available, and the instrumentation is calibrated to reflect the j

available volume. The limits on water volume, and boron concentration ensure a pH value of between 7.0 and 11.0 of the solution sprayed within the containment after a design basis accident. The pH band minimizes the evolution ofiodine and minimizes the effect of chloride and caustic stress corrosion cracking on mechanical systems and components.

i DAVIS-BESSE, UNIT 1 B 3/4 5-2a Amendment No. 191,207,

LAR 96-0014 Page 1 Review Summarv

$9.E Surveillance Recuirement 4.3.2.1.1.

Table 4.3-2.

Functional Units 1.d and 1.e 1.

A.

Technical Specification (TS) 3/4.3.2.1, " Safety Features Actuation System Instrumentation," Surveillance Requirement (SR) :

4.3.2.1.1, Table 4.3-2, Instrument Strings:

Functional Unit 1.d, RCS Pressure - Low Functional Unit 1.e, RCS Pressure - Low-Low Noter Channel Calibrations for Functional Units 1.a, 1.b, 1.c, 1.f, and 2.a through 2.e are proposed to remain on an 18 month surveillance interval, as discussed in License Amendment Request 95-0027 (DBNPS letter Serial Number 2405, dated December 11, 1996), and are not affected by this License Amendment Request.

B.

Systems or Components:

Safety Features Actuation System Instrumentation C.

Updated Safety Analysis Report (USAR) Sections:

4.3.5.2 Safety Features Actuation System Instrumentation (SFAS) 6.3.1.4 System Short-and Long-Term Capability 7.3 Safety Features Actuation System (SFAS) 2.

Licensing Basis Review:

A.

Technical Specification SR 4.3.2.1.1 requires that a Channel Calibration be performed for the Safety Features Actuation System (SFAS) functional units, at the frequencies shown in TS Table 4.3-2.

TS Table 4.3-2 presently specifies a Channel Calibration frequency of at least once per 18 months for Functional Unita 1.d and 1.e.

Technical Specification 4.0.2 is applicable, which allows increasing the surveillance interval on a non-routine basis from 18 months to 22.5 months.

It is proposed that a new definition for the "R" notation be applied in TS Table 4.3-2 for Functional Units 1.d, and 1.e.

License Amendment Request (LAR) 95-0027 (DBNPS letter Serial Number 2405, dated December 11, 1996) proposes that the "R" notation be defined as "At least once per 24 months."

This is consistent with the guidance provided by Generic Letter 91-04, j

" Changes in Technical Specification Surveillance Intervals to j

Accommodate a 24-Month Fuel Cycle," dated April 2, 1991.

q Technical Specification 4.0.2 would continue to apply which would allow increasing the new surveillance interval on a non-routine j

basis from 24 months to 30 months.

l

)

LAR 96-0014 Page 2 As described in the Safety Assessment and Significant Hazards Consideration (SASHC), and as shown on the attached marked-up Technical Specification pages, the Allowable values for TS Table 3.3-4, " Safety Features Actuation System (SFAS) Instrumentation,"

Instrument String Functional Unit d (RCS Pressure - Low) and Instrument String Functional Unit e (RCS Pressure - Low-Low) are proposed for revision based on the results of the instrument l

drift study. The associated Trip Setpoints in TS Table 3.3-4 for these same functional units are also proposed for deletion. The t

new Allowable Values have been calculated in accordance with ISA S67.04, Part I - 1994 "Setpoints for Nuclear Safety-Related Instrumentation," and ISA RP67.04, Part II - 1994, " Methodologies for the Determination of Setpoints for Nuclear Safety-Related I

Instrumentation," and encompass the Channel Functional Test.

The proposed Allowable Values are to be defined as applicable to the Channel Functional Test only by the application of a new "##"

footnote in TS Table 3.3-4 which will read " Allowable value for Channel Functional Test."

These changes are consistent with NUREG-1430, Revision 1,

" Standard Technical Specifications, Babcock and Wilcox Plants," dated April, 1995.

In addition, related to this change, footnote "**" to TS Table 3.3-3, Safety Features Actuation System Instrumentation, which applies to Instrument String Functional Unit 1.e, RCS Pressure Low-Low, is proposed for revision. This footnote presently allows the trip function to be bypassed in Mode 3 (Hot Standby) with RCS pressure below 600 psig, and specifies that the bypass shall be automatically removed when RCS pressure exceeds 600 psig.

The proposed change would revise the 600 psig value to 660 psig for both the bypass permissive and the reset.

As also described in the SASHC, and as shown on the attached marked-up Technical Specification pages, the TS 3.3.2.1 Limiting Condition for Operation (LCO) and Action Statement 3.3.2.1.a are proposed for revision to reflect the proposed changes to the SFAS Trip Setpoints and Allowable Values.

In addition, TS Bases 3/4.3.1 and 3/4.3.2, " Reactor Protection System and Safety System Instrumentation," is proposed to be revised to reflect the proposed changes to the Trip setpoints and Allowable Values.

B.

The design goal of the Safety Features Actuation System (SFAS) is to automatically prevent or limit fission product and energy release from the core, to isolate the containment vessel and to initiate the operation of the Engineered Safety Features (ESF) equipment in the event of a loss-of-coolant accident (LOCA).

The SEAS will automatically sequence the protective action by loading equipment in steps to the Emergency Diesel Generators (EDGs) if normal or reserve power is not available to the 4.16kV essential bus (es) coincident with an SFAS initiation signal. As described in the DBNPS Updated Safety Analysis Report (USAR) Section 6.3.1.4,

" System Short-and Long-Term Capability," the Emergency Core Cooling System (ECCS) design basis assumes simultaneous loss of normal and reserve power with a LOCA.

i LAR 96-0014 J

Page 3 The SFAS instrumentation and controls extend from the generating i

station variables to the input terminals of the safety features actuation control devices such as motor controllers and solenoid valves. The SFAS is divided into initiating or sensing channels, logic channels, and actuating channels.

The Safety Features Actuation System (SFAS) is described in DBNPS USAR, Section 7.3, " Safety Features Actuation System."

The SFAS consists of four identical redundant sensing and logic channels and two identical redundant actuation channels.

Each sensing channel includes analog circuits with analog isolation devices, I

and each logic channel includes trip bistable modules with digital isolation devices. The isolated output of the trip bistable module is used to comprise coincidence matrices with the j

terminating relays within the actuation channel of the SFAS.

The trip bistables monitor the station variables and normally feed continuous electrical signals into two-out-of-four coincidence j

matrices.

Should any of the station variables exceed their trip setpoints, the corresponding bistables in each of the four channels will trip and cease sending output signals.

Should two of the four channel bistables monitoring the same station variable cease to send output signals, the corresponding normally energized terminating relays on all channels will trip. The terminating relays of sensing and logic Channels 1 and 3, must both be deenergized to activate safety actuation Channel 1.

Similarly, sensing and logic Channels 2 and 4 are deenergized to activate actuation Channel 2.

The terminating relays act on the actuation control devices such as motor controllers and solenoid

)

valves.

Generating station conditions which require protective actions:

1.

Loss of coolant accident (LOCA) 2.

Steam line break

3. High radiation level inside the containment vessel The current initiating circuits of the SFAS are the sensing circuits monitoring the following station variables:

1.

Containment vessel radiation level.

2.

Containment vessel pressure.

3. Reactor Coolant pressure.

4.

Borated Water Storage Tank level.

LAR 96-0014 Page 4 The SEAS is a fail-safe (de-energize-to-trip) system. Therefore, if power supply is lost to a channel, that channel will trip, reducing the system coincidence matrices from two-out-of-four to one-out-of-three mode.

In the event that a module which performs a protective function is removed from its cabinet, that SFAS channel will trip unless it is bypassed. No cingle failure can prevent the SFAS from performing its protective function.

Each sensing and logic channel of SFAS includes two operating bypasses, one for the Reactor Coolant System (RCS) Pressure - Low signal, and the other for the RCS Pressure Low-Low signal. These bypasses allow depressurization of the RCS without initiating the RCS pressure trips. The bypasses consist of eight push-buttons located at the main control console, two for each channel, and related sensing channel components. These bypasses can only be actuated manually and only when the RCS pressure is below i

1800 psig or 600 psig respectively. The bypasses are automatically reset before the RCS pressure exceeds 1800 psig or 1

600 psig respectively. As noted above, this LAR proposes to revise the Low-Low bypass permissive and reset setpoints from l

600 psig to 660 psig.

{

i 4

The SFAS is not an initiator, nor a contributor, to the initiation of an accident described in the Updated Safety Analysis Report.

C. The current surveillance interval of 18 months was based on the guidance of NUREG-0103, Revision 0, dated June 1, 1976, " Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors," during the initial licensing of the DBNPS.

As I

discussed above, the proposed change follows the guidance of Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle,"

dated April 2, 1991.

D. As a result of the above review, it is concluded that the licensing basis of the Safety Features Actuation System will not be invalidated by increasing the Technical Specification SR 4.3.2.1.1, Table 4.3-2, Functional Unit 1.d, RCS Pressure -

Low, and Functional Unit 1.e, RCS Pressure - Low-Low, Channel Calibration surveillance interval from 18 months to 24 months and by continuing to allow application of Technical Specification 4.0.2 on a non-routine basis.

E.

References:

1.

Davis-Besse Nuclear Power Station (DBNPS) Unit No.

1, Operating License NPF-3, Appendix A, Technical Specifications, through Amendment 214.

LAR 96-0014 Page 5 ii.

Generic Letter 91-04, " Changes in Technical Specifications Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2,

1991, iii.

" Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors," NUREG-0103, Revision 0, dated June 1, 1976.

iv.

NUREG-0136, Safety Evaluation Report for The Davis-Besse Nuclear Power Station, Unit 1, dated December 1976 and Supplement No.

1.

v.

NUREG-1430, Revision 1,

" Standard Technical Specifications, Babcock and Wilcox Plants," dated April, 1995.

vi.

USAR Section 4.3.5.2,

" Safety Features Actuation System Instrumentation (SFAS), " through Revision 19.

vii.

USAR Section 6.3.1.4,

" System Short-and Long-Term capability," through Revision 19.

viii. USAR Section 7.3,

" Safety Features Actuation System J

(SFAS)," through Revision 19.

3.

Instrument Drift Study Analysis:

A. Enclosure 2 of Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Support a 24-Month Fuel Cycle", dated April 2, 1991, identifies seven issues to be addressed in justifying increased surveillance intervals to accommodate a 24 month fuel cycle.

The following sections address, by number, the first six of the seven issues, specified in Enclosure 2 of Generic Letter 91-04, necessary to justify a cycle extension from 18 to 24 months. The seventh issue is discussed in the main body of this license amendment application.

For the purposes of the Drif t Study, each of the four SEAS RCS pressure channel strings, consisting of a transmitter, converter and bistables, was analyzed twice; once with the RCS Pressure Low bistable and once with the RCS Pressure Low-Low bistable. The strings are discussed separately below.

SFAS RCS Pressure - Low 1.

A review of the as-found and as-left calibration data for the SFAS RCS pressure channels, was made from Technical Specification Surveillance Procedures, Maintenance Work Orders, Instrumentation and Controls Maintenance Shop Records, and the System Performance Book Chronological Logs.

Review of the as-found data indicates that there were no occurrences where the data was outside the present Technical Specification Allowable value.

LAR 96-0014 Page 6 2.

Utilizing a one-sided tolerance factor and not taking credit l

for a conservative mean (since the drift data contained a conservative bias that may not always exist), the 95/95%

historical drift value for the SFAS RCS Pressure - Low trip function was determined to be 28.806 psig of the 2500 psig instrument string span. This value was conservatively calculate i as simply the tolerance factor times the standard deviation.

3.

Although the conservative mean provided some evidence of a conservative drift with increasing time, the majority of the available data points were at the present refueling interval of approximately 18 months and adjustments interrupted what may have been poor data points over longer intervals.

Based on this, time dependency was conservatively assumed, and the 30 month projected drift was determined to be 38.453 psig using linear extrapolation. Again, no credit was taken for the conservative mean.

4.

The projected 30 month projected drift value of 38.453 psig was found to be larger than the previously assumed design basis / reference uncertainty used in the setpoint analysis, 27.857 psig. Based on this, and as discussed in the body of this LAR, the analytical value was acceptably lowered to maintain operating margin between the SFAS RCS low pressure block and low pressure trip setpoints. A new Allowable Value was determined and is proposed in this LAR.

5.

This SEAS RCS Pressure - Low trip instrument string does not control any plant parameters in an analog fashion, but rather provides protective action signals to initiate operation of actuated equipment. Therefore, this question is not applicable.

6.

The present revision of the setpoint analysis supports the analytical value necessary for the safety analysis, as discussed in the body of this LAR.

During implementation of this LAR, procedure changes will be made to reflect a new field setpoint and a revised calibration method.

Confirmation that the conditions and assumptions of the revised setpoint analysis are reflected in the surveillance procedures will be repeated as part of the LAR implementation process.

\\

l 1

LAR 96-0014 Page 7 SFAS RCS Pressure Low-Low 1.

A review of the as-found and as-left calibration data, for the SFAS RCS pressure channels, was made from Technical Specification Surveillance Procedures, Maintenance Work orders, Instrumentation and Controls Maintenance Shop Records, and the System Performance Book Chronological Logs.

Review of the as-found data indicates that there were no occurrences where the data was outside the existing Technical Specification Allowable value.

2.

Utilizing a one-sided tolerance factor and not taking credit for a conservative mean (since the drift data contained a conservative bias that may not always exist), the 95/95%

historical drift value for the SFAS RCS Pressure - Low trip function was determined to be 27.353 psig of the 2500 psig instrument string span. This value was conservatively calculated as simply the tolerance factor times the standard deviation.

3.

Although the conservat$..nean provided some evidence of a conservative drift w.

. increasing time, the majority of the available data poir. c were at the present refueling interval of approximately 18 months and adjustments interrupted what may have been poor data points over longer intervals. Based on this, time dependency was censervatively assumed, and the 30 month projected drift was determined to be 31.698 psig using linear extrapolation. Again, no credit was taken for the conservative mean.

4.

The projected 30 month projected drift value of 31.698 psig was found to be larger than the previously assumed design basis / reference uncertainty used in the setpoint analysis, 27.857 psig. Based on this, and as discussed in the body of this LAR, naintaining the previously acceptable analytical value, the Allowable Value for the SFAS RCS Pressure Low-Low trip was raised and the SFAS RCS low-low pressure block was correspondingly raised to maintain operating margin between the low-low pressure block and the low-low pressure trip settings. The new Allowable Value and block setpoint were determined and are proposed in this LAR.

5.

This SFAS RCS Pressure Low-Low trip instrument string does not control any plant parameters in an analog fashion, but rather provides protective action signals to initiate operation of actuated equipment. Therefore, this question is not applicable.

_._...m__

LAR 96-0014 4-Page 8 6.

The present revision of the setpoint analysis supports the

. analytical value necessary for the safety analysis, as discussed in the body of this LAR.

During implementation of

[

this LAR, procedure changes will be made to reflect a new field setpoint and a revised calibration method.

Confirmation that the conditions and assumptions of the l

setpoint analysis are reflected in the surveillance procedures will be performed as part of the LAR implementation process.

l 4.

Surveillance Data and Maintenance Records Review:

1 Consistent with the guidance of Generic Letter 91-04, " Changes in j

Technical Specification Surveillance Intervals to Accomodate a j

24-Month Fuel Cycle," dated April 2, 1991, a historical maintenance and surveillance data review is not re"uired, given that 4

instrumentation drift is evaluated for the applicable

. instrumentation.

l i

LAR 96-0014 Page 1 Review Summary 1.9.E Surveillance Recuirement 4.3.2.1.1.

Table 4.3-2, Functional Units 5.a and 5.b.

ag,4 Surveillance Recuirement 4.5.2.d.1 j

1.

A. Technical Specification (TS) 3/4.3.2.1, " Safety Features Actuation System Instrumentation," Surveillance Requirement (SR) :

4.3.2.1.1, Table 4.3-2, Interlock Channels:

Functional Unit 5.a, Decay Heat Isolation Valve Functional Unit 5.b, Pressurizer Heater Note Channel Calibrations for Functional Units 1.a, 1.b, 1.c, 1.f, i

and 2.a through 2.e are proposed to remain on an 18 month

)

surveillance interval, as discussed in License Amendment Request 95-0027 (DBNPS letter Serial Number 2405, dated i

December 11, 1996), and are not affected by this License Amendment Request.

4 l

Technical Specification (TS) 3/4.5.2, " Emergency Core Cooling Systems - ECCS Subsystems - Tavg 2 280*F," Surveillance Requirement:

4.5.2.d.1.a 4.5.2.d.1.b 4

Note: Several additional license amendment applications submitted to the NRC, also affect SR 4.5.2.d.

This license amendment application (LAR 96-0014), affects only SR 4.5.2.d.1, l

B.

Systems or Components:

4 Safety Features Actuation System Instrumentation and RCS d

pressure switch PSHRC2B4, including Decay Heat Isolation valve and Pressurizer Heater interlocks.

C. Updated Safety Analysis Report (USAR) Sections:

5.2.2.3 Overpressure Protection 6.3.2.16 Decay Heat Removal System Valve Control Circuit 7.6.1.1 Normal Decay Heat Removal Valve Control System 7.6.2.1 Analysis - Normal Decay Heat Removal Valve Control System 9.3.5 Decay Heat Removal System 2.

Licensing Basis Review:

A. Technical Specification SR 4.3.2.1.1 requires that a Channel Calibration be performed for the Safety Features Actuation System (SFAS) functional units at the frequency shown in TS Table 4.3-2.

TS Table 4.3-2 presently specifies a Channel Calibration i

a

I I

LAR 96-0014 Page 2 frequency of at least once per 18 months for Functional Units 5.a

[

and 5.b.

Technical Specification 4.0.2 is applicable which allows increasing the surveillance interval on a non-routine basis from 18 months to 22.5 months.

It is proposed that a new definition for the "R" notation be i

applied in TS Table 4.3-2 for Functional Unit 5.a and 5.b.

License Amendment Request (LAR) 95-0027 (DBNPS letter Serial Number 2405, dated December 11, 1996) proposes that the "R"

notation be defined as "At least once per 24 months."

This is consistent with the guidance provided by Generic Letter 91-04.

Technical Specification 4.0.2 would continue to apply which would l

allow increasing the new surveillance interval on a non-routine basis from 24 months to 30 months.

I Technical Specification SR 4.5.2.d.1, which is referenced by TS Table 4.3-2 Functional Units 5.a and 5.b for Channel Functional Test frequency, requires that at least once per 18 months a l

Channel Functional Test be performed to verify that the associated interlocks close DH-11 and DH-12 and deenergize the pressurizer heaters if either DH-11 or DH-12 is open and a i

simulated reactor coolant system pressure greater than the trip setpoint is applied.

}

Technical Specification SR 4.5.2.d.1 also requires that at least once per la months a test be performed to verify that the j

associated interlocks prevent the opening of DH-11 and DH-12 when a simulated or actual reactor coolant system pressure which is greater than the trip setpoint is applied.

Relative to TS SR 4.5.2.d.1.a and TS SR 4.5.2.d.1.b, it is proposed that in TS SR 4.5.2.d the words "At least once per 18 months" be replaced with "At least once each REFUELING INTERVAL."

The term " Refueling Interval" is defined by TS Definition 1,42 as "a period of time s 730 days " This is consistent with the guidance provided by Generic Letter 91-04,

" Changes in Technical Specification Surveillance Intervals to j

Accommodate a 24-Month Fuel Cycle," dated April 2, 1991.

Technical Specification 4.0.2 would continue to apply which would allow increasing the new surveillance interval on a non-routine basis from 24 months to 30 months, i

As described in the Safety Assessment and Significant Hazards Consideration (S ASHC), and as shown on the marked-up Technical Specification pages, the Allowable Value for TS Table 3.3-4, l

"Saf ety Features Actuation System (SFAS) Instrumentation" Interlock Channel Functional Unit a,

" Decay Heat Isolation Valve and Pressurizer Heater," is proposed for revision based on the results of the instrument drift study and re-evaluation of the design basis. The associated Trip Setpoint in TS Table 3.3-4 for this same functional unit is also proposed for deletion. The new Allowable Value has been calculated in accordance with ISA S67.04, Part I - 1994 "Setpoints for Nuclear Safety-Related t

LAR 96-0014 Page 3

)

i Instrumentation," and ISA RP67.04, Part II - 1994, " Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation," and encompass the Channel Functional Test, using a graded approach. The proposed Allowable value is to be defined as applicable to the Channel Functional Test only, by the application of a new "##" footnote in TS Table 3.3-4 which will read " Allowable Value for Channel Functional Test."

These changes are consistent with NUREG-1430, Revision 1,

" Standard Technical Specifications, Babcock and Wilcox Plants," dated April, 1995.

As also described in the SASHC and as shown on the marked-up Technical Specification pages, the TS 3.3.2.1 Limiting Condition for Operation (LCO) and Action Statement 3.3.2.1.a are proposed for revision to reflect the proposed changes to the Trip 4

Setpoints and Allowable Values.

In addition, TS Bases 3/4.3.1 l

and 3/4.3.2, " Reactor Protection System and Safety System Instrumentation," is proposed to be revised to reflect the proposed changes to the Trip Setpoints and Allowable Values.

Also, TS Table 3.3-3 Actions 13 and 14 are proposed for revision to reflect the change to the Allowable Value for the SFAS Interlock Channel Functional Unit a, and SR 4.5.2.d.1 is proposed for revision to reflect the change in Allowable Value.

B.

The operability of the Decay Heat Removal (DHR) and Pressurizer Heater interlocks ensures that double valve protection is established between the Reactor Coolant System (RCS) and the DER / Low Pressure Injection (LPI) system prior to raising the RCS pressure above the DHR system design pressure. These interlock channels prevent pressurizer heater operation if either DH-11 or DH-12 is off its closed seat while the RCS pressure is above the interlock setpoint and prevents DH-11 and DH-12 from being opened until RCS pressure is below the DHR system design pressure.

The interlocks meet the guidance provided in Branch Technical Position EICSB 3,

" Isolation of Low Pressure System from The High Pressure Reactor Coolant System."

The automatic closing signal to one of the valves (DH-12) is derived from an RCS pressure switch (PSHRC2B4) located in RCS loop 1.

The automatic closing signal to the other valve (DH-11) is derived from a signal comparator located in the Safety Features Actuation System (SFAS) cabinet. The signal comparator receives its RCS pressure signal from the RCS loop 2 wide-range pressure transmitter (PTRC2A3) that supplies the signal to the SFAS.

The pressurizer heater trip interlocks are derived from the signal comparators located in the SFAS cabinets. The signal comparators receive their RCS pressure signal from the RCS loop 1 or 2 wide range pressure transmitters (PTRC2A3 and PTRC2B4) that supplies the signal for the corresponding SFAS cabinet.

._-. - -... - + ---

LRR 96-0014 Page 4 The control circuits are designed such that any single failure will not prevent proper protective action when required.

Failure to close one valve will not prevent the closure of the other valve. One closed valve is sufficient to ensure that the Decay Heat Removal System will not be subjected to pressure in excess of design conditions.

The Decay Heat Isolation Valve Interlocks provide overpressure protection of the Decay Heat Removal System. The Decay Heat Isolation Valve Interlocks are not an initiator, nor a contributor, to the initiation of an accident described in the Updated Safety Analysis Report, i

J C. The current surveillance interval of 18 months for the Decay Heat j

Isolation valve Interlocks was based on the guidance of NUREG-0103, Revision 0, June 1, 1976, " Standard Technical Specifications for Babcock and Wilcox Pressurized Water j

Reactors," during the initial licensing of the DBNPS.

1 Requirements for the Pressurizer Heater Interlocks including the 18 month surveillance interval, were added by Amendment No. 28 to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear

)

Power Station, dated July 25, 1980.

Amendment 28 also revised j

the interlock Allowable Value and trip setpcint to <443 psig and e438 psig respectively. The requirement for Decay Heat Isolation I

l Valve and Pressurizer Heater interlocks to be operable in Modes 4 and 5 was removed by Amendment No. 159 to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, dated August 14, 1991.

]

l i

l As discussed above, the proposed changes follow the guidance of Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accommodate a 24-Month Fuel Cycle,"

l dated April 2, 1991.

l

(

D.

As a result of the above review, it is concluded that the j

' licensing basis of the Decay Heat Isolation Valve and Pressurizer Heater Interlock Channels will not be invalidated by increasing the Channel Calibration surveillance interval and the Channel Functional Test surveillance interval for SR 4.3.2.1.1, Table 4.3-2, Functional Unit 5.a and Functional Unit 5.b and SR 4.5.2.d.1 from 18 months to 24 months and by continuing to allow the application of TS 4.0.2 on a non-routine basis.

E.

References:

i.

Davis-Besse Nuclear Power Station (DBNPS) Unit No.

1, Operating License NPF-3, Appendix A, Technical i

l Specifications, through Amendment 214.

1

.(

f LRR 96-0014 Page 5 11.

Generic Letter 91-04, " Changes in Technical Specifications Surveillance Intervals to Accommodate a 24-Month Fuel Cycle," dated April 2, 1991.

iii.

" Standard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors," NUREG-0103, Revision 0, dated June 1,

1976, iv.

USAR Section 5.2.2.3, " Overpressure Protection," through Revision 19.

t v.

USAR Section 6.3.2.16,

" Decay Heat Removal System Valve Control Circuit," through Revision 19.

vi.

USAR Section 7.6.1.1,

" Normal Decay Heat Removal Valve Control System," through Revision 19.

vii. USAR Section 7.6.2.1,

" Analysis - Normal Decay Heat Removal Valve Control System," through Revision 19.

viii. USAR Section 9.3.5,

" Decay Heat Removal System," through Revision 19.

ix.

Amendment No. 28 to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, dated July 25, 1980.

x.

Amendment No. 159 to Facility Operating License No. NPF-3 for the Davis-Besse Nuclear Power Station, dated i

August 14, 1991.

l xi.

NUREG-1430, Revision 1,

" Standard Technical Specifications, Babcock and Wilcox Plants," dated April, 1995.

3.

Instrument Drift Study Analysis:

A. of Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Support a 24-Month Fuel Cycle", dated April 2, 1991, identifies seven issues to be addressed in justifying increased surveillance intervals to l

accommodate a 24 month fuel cycle.

1 The following sections address, by number, the first six of the I

seven issues, specified in Enclosure 2 of Generic Letter 91-04, necessary to justify a cycle extension from 18 to 24 months. The seventh issue is discussed in the main body of this license amendment application.

For purposes of the Drift Study performed on the SFAS instrument i

strings (first of two Drift Study Analyses discussed below), four i

l.

SFAS RCS pressure channel strings, consisting of a transmitter, i

I

LAR 96-0014 1

Page 6 1

converter and bistables, were analyzed, even though only two support the Decay Heat Isolation Valve / Pressurizer Heater functions. Justification for including the other two instrument strings are discussed in Attachment 3 of this LAR.

SFAS RCS Pressure - Decay Heat Isolation Valve (DH-11) and Pressurizer Heaters Interlock 1.

A review of the as-found and as-left calibration data for the SFAS RCS pressure channels, was made from Technical Specification Surveillance Procedures, Maintenance Work orders, Instrumentation and Controls Maintenance Shop Records, and the System Performance Book Chronological Logs, i

Review of the as-found data indicates that there were no j

occurrences where the data was outside the existing Technical Specification Allowable value.

2.

Utilizing a one-sided tolerance factor, the 95/95% historical drift value for the SFAS RCS Pressure Decay Heat Isolation Valve / Pressurizer Heater function was determined to be 39.098 psig of the 2500 psig instrument string span. Due to an existence of a non-conservative mean for this increasing pressure interlock, this value was calculated as the tolerance factor times the standard deviation, then added to the mean.

3.

Since the non-conservative mean provided some evidence of a non-conservative drift with increasing time, the majority of the available data points were at the present refueling interval of approximately 18 months, and adjustments interrupted what may have been poor data points over longer intervals, time dependency was assumed. The 30 month projected drift was determined to be 51.200 psig using linear extrapolation.

4.

The projected 30 month projected drift value of 51.200 psig was found to be slightly larger than the previously assumed design / basis reference uncertainty used in the previously existing setpoint documentation, 51.000 psig.

Based en the 30 month projected drift value, and a reevaluation t4 the design basis for this function, as discussed in the body of this LAR, a new, lower Allowable Value was calculated within the setpoint analysis and is proposed in this LAR.

Operating margin was maintained between the field setpoint and the operating limit (minimum NPSH for the Reactor Coolant Pumps).

LRR 96-0014 Page 7 5.

These SFAS RCS Pressure Decay Heat Isolation Valve /

Pressurizer Heater Interlock instrument strings do not control any plant parameters in an analog fashion, but rather provide protective action signals to initiate operation of actuated equipment (or for pressurizer heaters, deenergize J

them). Therefore, this question is not applicable.

6.

The present revision of the setpoint analysis supports the analytical value necessary to support the safety function, as discussed in the body of this LAR.

During implementation of j

this LAR, surveillance procedure changes will be made to reflect a new Allowable Value and revised calibration method.

Confirmation that the conditions and assumptions of the setpoint analysis are reflected in the surveillance procedures will be performed as part of the LAR implementation process.

RCS Pressure - Decay Heat Isolation Valve (DH-12) Interlock l

1.

A review of the as-found and as-left calibration data, for this RCS pressure switch, was made from Technical Specification Surveillance Procedures, Maintenance Work j

Orders, Instrumentation and Controls Maintenance Shop Records, and the site records management database. This review indicates that there were no occurrences where the data was outside the existing Technical Specification trip setpoint value or the proposed (and more conservative)

Technical Specification Allowable Value.

2.

Utilizing a one-sided tolerance factor, the 95/95% historical drift value was determined to be 16.746 psig for this pressure switch with a range of 100 to 500 psig. This value was conservatively calculated as simply the tolerance factor times the standard deviation, then added to the mean.

3.

With evidence that drift is time dependent but in a conservative direction, linear extrapolation was initially used to determine a 30 month projected drift value. Because of fairly large data points at short test intervals, the 95/95% maximum value was extraordinarily large and unacceptable for the function. Alternatively, based on the conservative drift with increasing time, and the typically nonconservative values at short intervals, it was decided to utilize the larger of the 95/95% historical drift value for all data points or the 95/95% historical drift value for all points under six months between tests. The 95/95% historical drift value for all pointe under six months was larger and became the 30 month projected drift value, 19.194 psig.

4.

The projected 30 month projected drift value of 19.194 psig was found to be smaller than the design basis / reference uncertainty used in the previously existing setpoint

LAR 96-0014 Page 8 documentation, 51.000 psig. Based on this, no changes to existing settings or analyses was necessary. However, since this interlock function for valve DH-12 shares Technical Specification wording for the trip setpoint (and proposed Allowable Value in place of the trip setpoint), the value in the Technical Specifications is being changed for consistency with the SFAS RCS - Decay Heat Isolation Valve (DH-11) and Pressurizer Heaters Interlock Allowable Value described above. This proposed use of the Allowable value derived from the SFAS RCS pressure channel uncertainties is conservative for this RCS pressure switch since the uncertainties for this RCS pressure switch are smaller.

5.

This RCS pressure switch does not control any plant parameters in an analog fashion, but rather provides protective action signals to initiate operation of actuated equipment. Therefore, this question is not applicable.

6.

The present revision of the setpoint analysis supports the analytical value necessary to support the safety function, as discussed in the body of this LAR.

The assumptions in the present setpoint analysis, including the field setpoint (which did not require change even though the Technical l

Specification value was lowered), are presently reflected in the surveillance test.

4.

Surveillance Data Review:

l l

Technical Specification 4.5.2.d.1 A.

The 18 month Technical Specification (TS) surveillance test results data for DH-11 and DH-12 interlock tests were reviewed for the period of the Fifth Refueling Outage (SRFO) through 9RFO.

This time period was selected because it reflects the major plant l

improvements after June 1985, and covers five refueling outages l

and four operating cycles of test results.

The following components were evaluated: Decay Heat Isolation valves DH-11 and DH-12, and RCS Prescurizer Heater Bundles WMB1, WMB2, and WMB3, Consistent with the guidance of Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accomodate a 24-Month Fuel Cycle," dated April 2, 1991, a l

surveillance data review is not required for the RCS Loop 1 Hot Leg Narrow Range pressure switch (PSHRC2B4), and the RCS Loop 1 and Loop 2 Wide Range pressure transmitters (PTRC2A3 and PTRC2B4),

given that instrument drift is evaluated for this instrumentation, i

B.

The test results indicated no actual TS failures over this time period for the components.

In SRFO, testing was suspended because DH-11 would not open.

The valve was declared inoperable but was closed with the plant in l

Mode 5 (Cold shutdown). Decay Heat Isolation Bypass Valves DH-22 3

I

LAR 96-0014 Page 9 and DH-23 were open.

The DH-11 and DH-12 interlock is not required in Mode 5. The failure was attributed to a loose L56 seal-in contact on breaker BF1130. The L56 seal-in was reseated and the valve performed as required. Test results were satisfactory. No root cause for the problem with the L56 seal-in was identified.

C.

Based on the review of the 18 month surveillance test results data, no additional actions are necessary or recommended to support this increase in the present surveillance interval.

D.

Based on no surveillance failures; the low potential for significant increases in failure rates of these components over an increased interval; and no known additional failure modes, it is concluded that the surveillance interval for TS 4.5.2.d.1 can be increased from 18 months to 24 months, and that there is no adverse effect en nuclear safety.

Furthermore, it remains acceptable to allow the continued application of TS 4.0.5 on a non-routine basis.

E.

References:

1.

DBNPS Procedure DB-SP-03130, " Decay Heat Removal System Isolation Test" 5RFO through 9RFO (includes superseded procedures).

ii.

Potential Condition Adverse to Quality (PCAQR) 88-0755.

iii. Maintenance Work Order (MWO) 7-88-0755-01.

5.

Maintenance Records Review:

A.

A review was performed on refueling maintenance records that could affect DH-11 or DH-12 interlock testing for the period of the Fifth Refueling Outage (5RFO) through 9RFO.

This time period was j

selected because it reflects the major plant improvements after i

June 1985, and covers five refueling outages and four operating j

cycles of maintenance activities.

Consistent with the guidance of Generic Letter 91-04, " Changes in Technical Specification Surveillance Intervals to Accomodate a 24-Month Fuel Cycle," dated April 2, 1991, a maintenance records review is not required for the RCS Loop 1 Hot Leg Narrow Range pressure switch (PSHRC2B4),

and the RCS Loop 1 and Loop 2 Wide Range pressure transmitters

]

(PTRC2A3 and PTRC2B4), given that instrument drift is evaluated for this instrumentation.

B.

Review of current planned maintenance activities indicate that all 18 month planned maintenance activities are required to be performed in a refueling outage.

LAR 96-0014 Page 10 Decay Heat Isolation Valves DH-11 and DH-12 No failures were identified for DH-11 or DH-12 that would make the valves TS inoperable, although several system changes were made to improve system reliability and prevent adverse degradation. The motor heaters were disconnected for environmental qualification (EQ) reasons.

In addition, live loaded packing was installed on DH-11 and DH-12 to reduce valve etem leakage. Some leakage has t

been identified since that time but has been min'or in nature and would not adversely impact the interlock feature. Thrust range i

adjustments have been made as a result of Generic Letter 89-10 testing.

1 During 6RFO, DH-11 was inspected for an inservice inspection and several indications were found. A gouge was identified on the valve body and bonnet gasket seating surface. The upset metal was removed.

In addition, the valve stem was replaced due to gouging 1

and several studs were replaced due to galling. No new indications were observed during the 10RFO inservice inspection.

3 None of these problems would have prevented the valve from performing its design function.

i Plant Modification 93-016 was implemented in 10RFO to address a potential pressure locking concern for DH-11 and DH-12.

Since pressure locking can prevent a closed valve from opening but is not a concern with respect to closing an open valve, a pressure locking condition would not have had an adverse impact on the DH-11 and DH-12 interlock function.

j Pressurizer Heater Bundles No failures were found that would affect the ability of the interlocks to trip the heate.rs as necessary.

i C.

Based on the review of 18 month maintenance records, no additional actions are necessary or recommended to support this increase in the present surveillance interval.

No conditions were identified which would have impacted the ability of the components to perform their design function.

4 i

D.

Based on the historical good performance of the applicable components, the low potential for significant increases in failure rates of these components under a longer interval, and no known new failure modes, it is concluded that it is acceptable to in-crease the surveillance interval of SR 4.5.2.d.1 from 18 months to 24 months, and that there is no adverse effect on nuclear safety.

Furthermore, it remains acceptable to allow the continued application of TS 4.0.2 on a non-routine basis.

E.

References:

1.

DBNPS Maintenance Work Order Records.

LAR 96-0014 ATTACHMENT 1 FOR LICENSE AMENDMENT REQUEST NUMBER 96-0014 (19 pages follow)

~-

3 in~strument Drift Data Analysis page Revison Methodology' nd Assumptions 1 of is 01 a

Title:

Instrument Drift Data Analysis Methodolony and Assumotions l

Prepared by:

eft U26-%

Date Reviewed by:

NW O-4-2&-94 Date i

Approved by: _

V/lV/9 6 Manager-Plant Engineering Date Approved by:

O.k 5/fI/4

~

Irector-Engineering and Services

' bate m

0(70Qt>5e

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

Y m vision 3

Instrument Drift Data Analysis Peo.

Methodology and Assumptions 2 of 15 01 i

i Table Of Contents 4

i P.ast Methodology and Assumptions 3

i References 12 I

List of Affected Instrument Strings 14 i

Schedule 16 j

Standard Review Form 17 j

Instrument Drift StudyFlowchan 19

)

4

)

- - ~ -

i j

instrument Drift Data Analysis P.se R***n j

Methodology and Assumptions a of is et i

1. Select the Technical Specifications (TS) section to be evaluated using the list of affected l

instrument strings and the schedule (copy of each for phase I attached).

I

2. Identify all redundant channels associated with that TS section and any identical instrument i

strings not associated with that TS section.

3. Obtain surveillance test procedures, data packages, drawings, etc. as needed to create a block I

diagram, showing all components in the instrument string used to perfonn the TS required i

function, for each redundant channel. Identify the surveillance test procedure used for each

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component in the block diagram.

4. Verify that all individual components are identical (have the same make, model number, and j

range) to their counterparts in the redundant channels.

i

a. If they are not all identical, then either the data from each channel has to be analyzed i

separately or a written justi6 cation must be prepared for combining the data from the non-identical channels.

5. Obtain historical as-found/as-left calibration data from Surveillance / Periodic Tests 4

(STs/ pts), Maintenance Work Orders (MWOs), and IAC shop records. Enter applicable datainto the spreadsheet.

Note: The data is entered into an Excel spreadsheet. The spreadsheet template contains the l

algorithms that determine the values used for this evaluation. The general underlying algorithms and lookup tables were independently veri 6ed to be correct. This verification consisted of formula checks, checking basic statistics against an independent Lotus 123 version, and line by line veri 6 cation of the lookup tables as well as checking against hand 1

calculations.

1

a. If a feld change was performed (e.g., a transmitter was changed to one of a different j

make or model mraer), then only enter data obtained subsequent to the most recent i

6eid change for Gt group of redundant channels.

I

b. If the channel performs an automatic protective action, then there will only be " trip" and/or " reset" data to record for each test. If the channel provides indication of a process i

variable (flow, pressure, temperature, etc.), then several (up to nine) different data pcints will be recorded for each test. Data taken at x% of span (increasing) and x% of span (decreasing) will be treated separately an:1 not lumped together because they do not provide independent drift information when analyzed from one test to another.

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instrument Drift Data Analysis Poe.

n. vision Methodology and Assumptions 4efto ot-6 l

c. String data (as opposed to component data) should be used in most cases This is because Davis-Besse's calibration procedures are generally structured such that if the

]

string check satisfies all acceptance criteria, then the surveillance test is considered

. complete, and no data is taken on individual components within the string.

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d. Some channels are functionally tested at more frequent intervals than once every 18 l

months. These tests provide greater amounts of data on all non-sensor components than l

do the calibrations performed on the entire channel each refueling outage. For this reason, these strings may be analyzed using cah% ration data for the sensor by itself and l

channel functional test data for the rest of the string. This requires a sufficient amount of j

data to be available for the sensor alone. Sensors of the same make, model number, and i

range that are used in other applications with similar operating environments may be l

used to provide additional data. This approach should be used with caution because data j

may only be available for some sensors for instances when they are out of tolerance, and this would skew the results (making them worse than the actual sensor performance).

i j

e. The percent (s) of span at which data was taken may have changed at some point (s) in time (e.g., data taken at 10, 30, 50, 70, and 90% of span previously is now taken at 5, 25, 50,75, and 95% of span). In these cases, a data column may be " shifted" to align with another data column that is within *10% of span in order to increase the sample size for j

that data point. If shining of more than 10% of span is done, justification must be j

provided. When shining data "up" use a ratio of percents of span (e.g., muhiply drift l

values for 90% of span by (95/90) to obtain drift values for 95% of span). When shiRing i

data "down" use a straight biasing approach (e.g., a driA value at 10% of span stays the same when shifted to 5% of span).

1 Note: After shining data columns, as-found data from one test need not be compared

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with as-left data from another test when the two tests took data at different percents of span, however, it is acceptable to do so.

6. Calculate the drift that occurred between pairs of consecutive tests in either % span (typically) or process units (rarely). Segregate the results by data point for instrument strings l

providing process variable indication.

i

7. Calculate basic statistics for the drift values calculated in item 6 - sample mean (x), sample standard deviation (s), number of sample data points (n), 95/95% tolerance factor (k), and i

95/95% toleranceinterval(xiks).

)

a. For innrument strings providing process variable indication there will be a set of basic j

statistics for each data point.

b For some instrument strings, measurement uncertainty in only one direction is of i

concem (e.g., reactor coolant flow measurement uncertainty for input to RPS is only of I

a

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i-Instrument Drift Data Analysis Peo.

Revision j

Methodology and Assumptions s of to 01 i

concem if measured flow is greater than actual flow because 'the RPS l

power /imbal==> flow trip occurs on a decreasing flow signal, therefore a higher measured flow than actual flow delays the trip). For these single side ofinterest strings a l

one-sided tolerance factor may be used to determine the 95/95% tolerance interval.

I Justification for use of a one-sided tolerance factor must be provided.

j

8. Identify any potential outliers among the data by performing the T-Test as described in ANSI / ASTM E178-1994, " Standard Practice for Deshng With Outlying Observations".

4 j

9. Send a copy of the spreadsheet, the block diagram, and a standard review fonn (copy I

attached) to the System Engineer.

a. Resolve all comments resulting from the System Engineer's review.

b. The standard review form must be signed by the System Engineer and kept with the file for that instrument string.

1 t

10. Utilizing the System Engineer's input, provide written justi6 cation for any outlying data point that is removed from the sample set. Unless clear evidence exists to demonstrate that j

the outlier is not representative of actual instrument drift (e.g., a failure or data entry error occurred), the outlier should be retained in the sample set.

11. Recalculate the basic statistics if any spreadsheet data was changed as a result of either the System Engineer's review or the analysis of outliers.

12. Verify that the assumption of drift data being normally distributed is not unreasonable by j

performing the W test (for sample sizes less than or equal to 50) or the D' test (for sample j

sizes greater than 50), as described in ANSI N15.15-1974," Assessment of the Assumption of Normality (Employing Individual Observed Values)".

f

a. When performing the W or D' test, use the 0.05 significance level. This means that if the l

sample data is randomly selected from a population that is normally distributed, there is less than a 5% probability that the test will reject the assumption of normality for that 4

i sample.

i i

b. To supplement the applicable normality test, create a histogram which plots number of j

drift data points versus the number of standard deviations from the mean A group of

" bins" will be defined, with each one including a range of values for number of standard deviations from the mean Each bin will display two bars - one representing the actual

}

number of drift data points contained in that bin and the other representing the number of data points that bin would contain if the sample distribution were perfectlynormal.

ij 5

i J

l Instrument Drift Data Analysis Pee.

n. m n f

Methodology and Assumptions e of to ot.

i l,

1 I

l I

I Comparison of the two bars in each bin provides additional evidence as to whether or not the driR data is normally distributed. The smaller the sample size the fewer the number j

ofbins. For example, with only ten data pomts, the bins are:

l

1. More than 2 standard deviations below the mean j

2. Between 2/3 and 2 standard deviations below the mean

3. Within 2/3 standard deviations of the mean i

4. Between 2/3 and 2 standard deviations above the mean l

5. More than 2 standard deviations above the mean

?

i

c. If the applicable test indicates that the assumption of normality should be rejected, then j

the histogram should be used to verify that the driR data is bounded by a normal j

distribution. This requires that ~95% or more of the driA data be contained within 2 i

standard deviations of the mean To facilitate making this comparison, the bin sizes and j

locations should be chosen carefully to ensure that a bin " boundary" exists at exactly 2 i

standard deviations above and below the mean (It is expected that all samples of driR j

1 data will be nonnal or bounded by the assumption of normality).

j

d. For instrument strings which have data taken at multiple points, these normality assessment tools may be used on the sum of all data points and/or on individual data points. At a minimum, the worst case individual point should be assessed.

i

13. Evaluate time dependency of the driR data. No single test or technique can be used to i

determine whether or not an instrument string's driA will increase with time. A variety of -

l tools must be used to build a case for or against a given instrument string's driR being time j

dependent. If the results are inconclusive, then default to the assumption that some time 2

dependency exists. The various tools for performing this evaluation are described below.

a. Plot driA vs. time since last test for all data points. Plots may also be made for individual data points,if applicable.

b. Plot driR vs. time since last adjustment for all data points. Plots may also be made for individual points, if applicable.

Dria vs. time since last adjustment plots must be interpreted carefully. Although they can provide driA information for intervals longer than the normal calibration interval, that data could be misleading if the instrument string was regularly adjusted.

Adjustments " set the clock" back to " time =0",

thereby preventing the creation of a possibly large driR value at a long time interval, i.e., only

" good data" avoids adjustment long enough to achieve a long time interval. Adjustments must be relatively rare to justify this approach to support a claim of time-independence.

1 Instrument Drift Data Analysis P o.

nev6.i4n i

Methodology and Assumptions 7 of to ot.

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c. The plots generated for items 13a and 13b can be redone using absolute value of drift instead of drift.

t

d. The plots generated for items 13a and 13b can be used to evaluate sample mean and i

sample standard deviation at various cah) ration intervals The data in a given plot is l

, divided into several groups, each repr==*iag a range of calibration intervals The mean and standard deviation are computed for each group and the results displayed in tabular l

form. 22.5 months is a helpful calibration interval to use as a boundary betw groups i

since it is the maximum permitted by Tech Specs for instrument strings with a nominal j

calibration interval of18===*h l

e. Hypothesis testing can be used to help determine whether or not the variations in i

standard deviation observed among the different groups in hem 13d are due to drift time-l dependence. Sample standard deviations are used to evaluate the likelihood that two different samples were drawn from the same population. Results indicating that the same l

population produced all the samples constitute evidence that the drift is not time-dapaaha*

To implement this, use the F statistic for testing the equality of two j

variances The hypothesis to be tested is o,2 - o:2, and the alternative is o 2 > o2, where 2

l oi is the variance for the range oflonger calibration intervals, and a 2 is the variance for 2

j the range of shorter calibration intervals. The test statistic is si'/sa$ and is an observed j

value of a random variable which has an F-distribution with (ni-1, n:-1) degrees of l

freedom, provided the hypothesis is true. The critical value is found from a table of values of a random variable, z, which has an F-distribution with (m,n) degrees of i

freedom for which the distribution function, F(z), has the value 0.95. This corresponds j

to a significance level of 0.05, which means that there is a 5% probability that a true hypothesis will be rejected. If the test statistic is less than or equal'to the critical value, then the hypothesis is not rejected, but if the test statistic is greater than the critical value, then the hypothesis is rejected. See references 4 and 23 for further discussion of the F statistic.

I j

f. Regression analysis can be performed on the plots generated for items 13a and 13b to see-

)

if a meaningful correlation exists. Based upon the results we've obtained on some actual drift data and those discussed in EPRI TR-103335, " Guidelines for Instrument Calibration Extension / Reduction Programs", it is expected that regression analysis will

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rarely, if ever, show a significant correlation between drift and calibration interval. If the 2

2 1

R correlation its close to 1, then a meaningful drift rate can be calculated. If the R correlation is closer to 0, then the lack of correlation may be used as evidence that the

)

drift is not time-dependent.

14. Determine the projected 95/95% tolerance interval for the expected 30 month drift.

l j

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instrument Drift Data Analysis page Revision Mettlodologyand Assumptions a of19 01

a. If the driR has been determined to be time-independent, th en the 95/95% tolerance interval previously calculated (see item 7 or item 11, as applicable) applies to a 30 month calibration interval.

b. If the dria could not be demonstrated to be time-independent, then extrapolate each individual driR data point that was calculated for a calibration interval ofless than 30 months to 30 months. If the distribution is clearly time dependent or there is insuf5cient evidence to assess the time dWaey, use linear extrapolation and multiply each driR j

1 30 moaths sincelast test data point by 8 months since last test

c. If the driR could not be demonstrated to be time-independent, but the degree of time dependence is less than linear, then extrapolate as in item 14b, but multiply the driR since M

30 months last test by (# months since last test Providejustification for using this method of extrapolation instead of the linear method

d. Some data sets may contain several as-found vs. as-leR driR values with short test-to-test intervals. When extrapolated, these data po'mts may cause the results to be overly conservative and ua=cceptable. In such cases, these driR data pomts with short test-to-test

~

intervals may be deleted from the extrapolation process The " months since last test" value selected as the threshold for driR data deletion must bejustified.

e. For each new, extrapolated data set (which includes driR data points calculated for calibration intervals greater than or equal to 30 months in addition to the extrapolated driR data points), perform the following:

1. Calculate the basic statistics

2. Identify and analyze potential outliers

3. Recalculate the basic statistics if any outliers were deleted

4. Verify that normality is not an unreasonable assumption

15. Evaluate the results (i.e., the 30 month driR 95/95% tolerance interval) against the design basis for the instrument string.

a. For instrument strings that perform an automatic protective action this requires an analysis of the calculation that establishes the setpo' t.

For instrument strings that m

provide process vanable indication this requires verification that they can still be used to effect a safe plant shutdown. A calculation may not exist for these process variable indicationinstrument strings.

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i instrument Drift Data Analysis ree.

Revision Methodology and Assumptions e of is 01 1

b. Since as-found vs. as-leR calibration data includes several sources of uncertainty in I

addition to "true drift", these uncertainty tenns are contained in the 95/95% tolerance intervals obtained through the analysis of as-found vs. as-leR calibration data. For this i

project only three terms will be used when comparing design basis information with I

these 95/95% tolerance intervals.

They are driR, reference accuracy, and MATE l

uncertainty. Obtain values for these terms from the associated calculation, if one exists.

If not, use either the equipment specification or vendor supplied information.

i i

c. Combine the uncertainties obtained in item 15b for all components in the string that as-l' found/as-left data was collected for. These terms must be combined in the same manner as in the calculation (e.g., square-root-sum-of-the-squares, algebraic, etc. ). If no l

calculation applies, then combine them as would be done if a calculation were being created.

l

d. Verify that the as-found minus as-left historical data has not exceeded the total uncertainty obtained in item 15e except on rare occasions. If applicable, also confirm i

that as-found data has not exceeded its Tech Spec Allowable Value on more than rare occasions. If this cannot be confirmed, then venfy that corrective action has been taken j

to prevent future violations of the Allowable Value.

f

e. If the total uncertainty obtained in item 15c bounds the 30 month drift 95/95% tolerance i

i interval, then extension of the surveillance interval for calibration from 18 to 24 months is justified. Typically, for process variable indication instrument strings and automatic 1

protective action instrument strings for which the sensor is analyzed separately (see item 5d), the worst case data point should be chosen to represent the drift characteristic (i.e.,

to provide the 30 month driA 95/95% tolerance interval). In some cases, depending on j

the instrument string's function, a " critical" portion of the string's range may be identified i

that best represents the drift characteristic (e.g., those data points near a trip setpoint).

Writtenjustification must be provided when utilizing this concept of the " critical" portion l

of a string's ran8e. Also, caution must be used because a setpoint could be changed such l

that the " critical" portion no longer envelops the setpoint. Therefore, " critical" portions must be chosen so they cover reasonably expected changes in setpoints.

f. If the 30 month drift 95/95% tolerance interval exceeds the total uncertainty obtained in l

item 15c, then further evaluation is required. When a calculation exists or needed to be

[

created, send a Request For Assistance (RFA) to the supervisor of the unit responsible for i

the calculation. The RFA must provide the results of the instrument string's drift data I

analysis, including the comparison with design basis information. Ask the responsible organization to make whatever changes are necessary to the calculation so it adequately i

addresses the drift data analysis results. If they detennine the calculation is acceptable as i

is, the basis for that conclusion must be documented thoroughly in the calculation. When i

4 1

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i i

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i instrument Drift Data Analysis ree.

n. vision i,

Methodology and AssumptNms 10 of 19 01 i

b l

no calculation exists, contact Nuclear Enp=ig and Operations, providing the results i

of the driA data analysis and soliciting input regarding use of the subject instrument string (s) to effect a safe plant shutdown. Ask Nuclear Er@-:-:ig to look at use of the instrument string (s) as described in the Updated Safety Analysis Report. Ask Operations to look at use of the instrument string (s) as directed by the Emergency Procedure (DB-l j

OP-02000). The thrust of each ois as.Gon's review should address the acceptability of j

the projected 30 month driA 95/95% tolerance interval for each decision or action that would be based on information provided by the instrument string (s). Use these responses i

and the expertise of the System F=p-to evaluate the acceptability of using instrument strings that provide control or indication only functions to safely shut down i

the plant.

g. Review existing surveillance test procedures (channel checks, channel functional tests, l

and channel calibrations) for the instrument string (s) to verify that their acceptance i

criteria appropriately reDect all applicable conditions and assumptions of any associated j

setpoint and safety analyses. If an instrument string is not addressed in any existing setpoint or safety analysis, then this review is not applicable.

4 t

i Note: DeSciencies found during this review should be brought to the driA study team's attention to be evaluated for possible initiation of a Potential Condition Adverse to j

Quality Report (PCAQR).

16. Prepare a written overall result summary that addresses the 6rst six of the seven issues i

described in NRC Generic Letter 91-04, Enclosure 2.

a. Any calculation revisions resulting from item 15f do not have to be complete before writing this result summary. Once the revisions are complete, those results will be j

incorporated into the appropriate License Amendment Request (LAR) submittal, and the i

overall result summary will be updated.

l

b. All instrument string components not providing driA data (e.g., RTDs) must be i

qualitatively discussed as part of the justification for increasing the surveillance interval j

to 24 months.

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c. To provide consistency among the result summaries, the phrase "30 month projected l

driA" should be used to identify the driA study result for a particular instrument string, and the phrase " design basis / reference uncertainty" should be used to identify the l

appropriate combination of drift, reference accuracy, and M&TE uncertainty (see items 15b and 15c) to which the drin study result is compared (see items 15e and 15f).

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d. Each written overall result summary will be signed and dated by both the preparer and a reviewer.

4 1

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I

Instrument Drift Data Analysis Page Revieic'n Methodology and Assumptions 11ofis 01

e. The seventh issue from NRC Generic Letter 91-04, Enclosure 2 requires us to " provide a summary description of the program for monitoring and assessing the effects ofincreased calibration surveillance intervals on instrument drift and its effect on safety" This is being addressed under a separate document.

1 i

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instrument Drift Data Analysis Peo.

Revision Methodology and Assumptions 12 of to 01-Instrument Drift Study References

1. Eisenhart, Hastay, and Wallis, Techniques ofStatistical Analysis, McGraw-Hill,1947.

l 2.

Lieberman, Gerald J., Tablesfor One-SidedStatistical Tolerance Dmits, Industrial Quality l

Control, April 1958 l

3.

ANSI N15.15-1974, Assessment of the Assungtion ofNormality (EmployingIndividual Observed Values).

4.

Kreyszig, Erwin, AdmncedEngineeringMathematics, Fourth Edition, Wiley,1979 l

S.

Odeh, R.E. and Owen, D.B., Tablesfor Normal Tolerance Dmits, Sampling Plans, and Screening, Marcel Dekker, Inc.,1980 i

Beggs, William J., Statisticsfor Nuclear Engineers and Scientists, Part 1: Basic Statistical 6.

Inference, DOE Research and Development Repon No. WAPD-TM-1292, February 1981.

l 1.

Regulatory Guide 1.97, Instrumentationfor Dght-Water-CooledNuclear Power Plants to j

Assess Plant andEnvirons Condition During andFollowing an Accident, Revision 3, May 1983.

i

s. NUREGICR-5560, Aging ofNuclear Plant Resistance Temperature Detectors, June 1990.

9.

NRC Generic Letter 91-04, Changes in TechnicalSpecipcation Surveillance Intervals to Accommodate a 24-Month Fuel Cycle, dated April 2,1991.

10. Letter from R. P. Zimmerman, NRC, to H. B. Ray, Southern California Edison Company, dated April 12,1991.

11. Letter from D.F. Kirsch, NRC, to H.B. Ray, Southern California Edison Company, dated April 26,1991,

12. Letter from H. B. Ray, Southern California Edison Company, to NRC, dated May 21,1991.

13. Letter from R. P. Zimmerman, NRC, to H. B. Ray, Southern California Edison Company, dated June 14,1991.

14. Toledo Edison Memorandum NEN-91-10459 from R. C. Zyduck to J. H. Lash, dated October 23,1991.

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Instrument Drift Data Analysis p.e.

. newon I

Methodology and Assumptions la of to 01.

l

15. Webb, R. C. and Beuchel, B. E., A GradedApproach to Setpoint Calculation Programs, Proceedings of the Thirty-fifth Power Instrumentation Symposium of the Instrument Society I

of America,1992.

i i

16. Letter from T. G. Broughton, GPU Nuclear Corporation, to NRC, dated June 24,1992.

j

17. Letter from T. G. Broughton, GPU Nuclear Corporation, to NRC, dated May 28,1993.

i

18. Letter from R. W. Hernan, NRC, to T. G. Broughton, GPU Nuclear Corporation, dated June l

23,1993.

s l9. EPRI TR-103457, Non-Process Instrumentation Surveillance and Test Reduction, December i

1993.

20. ANSIIASTM E 178-1994, StandardPracticefor Dealing with Outlying Observations.

21. ISA-S67.04, Part I-1994, Sepointsfor Nuclear Safety-RelatedInstrumentation.

12. ISA-RP67.04, Past 11-1994, Methodologiesfor the Determination ofSetpointsfor Nuclear

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Safety-Relatedinstrumentation.

23. NUREG-1475, Applying Statistics, February 1994.

l

24. EPRI TR-103335, Guidelinesfor instrument Calibration ExtensiontReduction Programs, March 1994.

25. EPRI TR-103099, Efects ofResistance Temperature Detector Aging on Cross-Calibration Techniques, June 1994.

26. Toledo Edison Memorandum NED-95-40001 from J. H. Lash to R. C. Zyduck, dated January 18,1995.

27. Letter from G. L. Boldt, Florida Power Corporation, to NRC, dated May 31,1995.

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EE Tech Spec Instrument Drift Study /24-Month Fuel Cycle 8.a h$

List of Affected Instrument Strings:

g*

(Note: Only first component in string is listed.)

< U'2-g Phase 1 (Must do to implement 24-month fuel cycle.)

32 Make/Model Cal Test /PM U

>N Instro f/Name Tech spec IT RCIAL tRCS Flow) 4.3.1.1.1. Tabie 4.3-1, item 4, Note 7 Rosemount 1153HD6 MI 3061 rf RCIA2 (RCS Flows 4.3.1.1.1 Table 4.3-1, item 4, Note 1 Rosemount 1153HD6 MI 3062 FT RCIA3 (RCS Flowl 4.3.1.1.1. Table 4.3-1, item 4. Note 7 Rosemount 1153HD6 MI 3063 C)

FT RCIA4 (PCS Flow) 4.3.1.1.1. Table 4.3-1, Item 4 Note 7 Rosemount 1153HD6 MI 3064 33 L

FT RCIB1 (RCS Flow) 4.3.1.1.1. Table 4.3-1, Item 4, Note 7 Rosemount 1153HD6 MI 3065 13 E.

i' h" Th FT PC182 tRCS Flow) 4.3.1.1.1, Table 4.3-1. Item 4. Note 7 Rosemount 1153HD6 MI 3066 FT RC193 (RCS Flow) 4.3.1.1.1, Table 4.3-1, Item 4, Note 7 Rosemount 1153HD6 MI 3067 FT RC194 (RCS Flowl 4.3.1.1.1. Table 4.3-1. Item 4. Note 7 Rosamount 1153HD6 MI 3069 r

LIT 4617 (CTMT sump levell 4.3.3.6. Table 4.3-10, Item 15s 4.4.6.1.b Transamerles Delaval TD/RE-36562 MI 3722

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LIT 4619 (CTNT sump levell 4.3.3.6. Table 4.3-10, item 15s 4.4.6.1.b Transamerica Delaval XM-54852-te-2700 MI 3721 LT 4594 (CTMT wtr levell 4.3.3.6 Table 4.3-10. Item 16 Rosemount 1153AD7 MI 1726 LT 4595 (CTNT wtr levell 4.3.3.6, Table 4.3-10 Item 16 Rosemount 1153AD7 MI 3725 LT 5449A (RCS het leg levell 4.3.3.6, Table 4.3-10, Item 19 Rosemount 1153HD6 MI 3712

[

i LT 5449B (RCS hot leg levell 4.3.3.6, Table 4.3-10. Item 19 Rosemount 1153HD6 MI 3711 LT RC14-1 (pressurizer levell 4.3.3.5.1. Table 4.3-6 Item 4s 4.3.3.6, Rosemount 1153HD5 MI 3640

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Table 4.3-10, item 4 LT PC14-3 fpressurtrer levell 4.3.3.5.1. Table 4.3-6, Item 4s 4.3.3.6, Rosemount 1153HD5 MI 3641 Table 4.3-10, Item 4 LTSP9A3 (SG 1evell 4.3.3.5.1, Table 4.3-6, Item 6: 4.3.3.6, Rosemount 1153DD5 MI 3653, MI 3650 Table 4.3-10 Item Ss 4.7.1.2.1.d Rosemount 1153DD5 MI 3655, Mt 3660 l

LTSP9A4 (SG levell 4.7.1.2.1.d LTSP9A6 (SG 1evell 4.3.2.2.1. Table 4.3-11, Item ib, 4.3.3.6, Rosemount 1152DP5 MI 3237 Table 4.3-10. Item 5 LTSP9A7 (SG level) 4.3.2.2.1. Table 4.3 11, Item 1b Rosemount 1152DP5 MI 3238 LTSP9At (SG 1evell 4.3.2.2.1. Table 4.3 11, Item Ib Rosemount 1152DP5 MI 3239 LTSP9A9 (SG 1evel) 4.3.2.2.1. Table 4.3-11, Item Ib Rosemount 1152DP5 M1 3240 LTSP983 ISG 3evel) 4.3.3.5.1, Table 4.3-6, item 6s 4.3.3.6, Rosemount 1153D05 MI 3654 MI 3659 Rosemount 1153DD5 MI 3656, MI 3661 l

I' Table 4.3-10. Item 5: 4.1.1.2.1.d LTSP984 (SG 1evell 4.7.1.2.1.d LTSP996 ISG 1evel) 4.3.2.2.1. Table 4.3-11, Item Ib Rosemount 1152DP5 MI 3241 g

4.3.3.6 Table 4.3-10 Item 5 LTSP987 (SG 1evell 4.3.2.2.1, Table 4.3-11, Item Ib Rosemount 1152DP5 MI 3242 LTSP988 (SG tevell 4.3.2.2.1, Table 4.3-11, Item Ib Rosemount 1152DP5 MI 3243 LTSP999 ISG level) 4.3.2.2.1. Table 4.3-11, item ib Rosemount 1152DP5 MI 3244 SOR 9tA-84-NX-C1A-JJTTX6 PM 2655 SP 3130 PSM RC294 (RCS pressurel 4.5.2.d.1 SOR 6TA-94-NX-C1A-JJTTX12 MI 3903 PSL 106A (AFPT inlet st press) 4.7.1.2.2 SOR ETA-94-NX-C1A-JJTTX12 MI 3903 PSL 1068 (AFPT Inlet et press) 4.7.1.2.2 SOR 6TA-94-NX-CI A-JJTTX12 MI 3903 PSL 106C (AFPT inlet st pressl 4.7.1.2.2 SOR 6TA-84-NX-CIA-JJTTX12 MI 3903 PSL 106D (AFPT inlet st press) 4.7.1.2.2 SOR 6TA-94-HX-C1A-JJTTX12 MI 3906 PSL 107A (AFFT inlet st press!

4.7.1.2.2 SOR 6TA-B4-NX-CI A-JJTTX12 MI 3906 PSL 107B (AFFT inlet st press) 4.7.1.2.2 SOR 6TA-84-NX-CIA-JJTTX12 MI 3906 PSL 101C (AFFT inlet st press!

4.7.1.2.2 SOR 6TA-84-NX-CI A-JJTTX12 MI 3906 PSL 101D (AFPT inlet st press) 4.7.1.2.2 Fs.

o *T s

c

E3 instru 9/Mame Tech Spec

2 Mate / Mod =1 isL 4920A (AFP suction pressi 4.7.1.2.1.e Cat Test /PM 72 SOR 12V2-E4-M2-CIA-LLTTK3 M1 3901 O

FSL 49288 (AFP suction press) 4.7.1.2.1.e SCR 12V7-E4-N4-81A-TTLLK3 HI 3901 r$L 49294 (AFP suction press) 4.7.1.2.1.e son 12y2-gg.M2.c1R-LLTTK3 MI 3904 6 *3 I

rSL 49298 (AFP suction pressi 4.7.1.2.1.e SOR 12V2-E4-M2-C1A-LLTTK3 MI 3904 83 tsL 4930A (AFP suction pressi 4.7.1.2.1.e SoR 12y2-E4-M2-C1A-LLTTK3 MI 3902 4k FSL 49308 (AFP suction press) 4.s.t.2.1.e Son 12y2-g4-M2. CIA-LLTTK3 MI 3902 88 y rst 4931A (AFP suction press) 4.7.1.2.1.e SOR 12V2-E4-M2-C1 A-LLTTK3 MI 3905 k

rst 49318 (AFP suction presst 4.7.1.2.1.e SOR 12V2-E4-M2-CIA-LLTTK3 MI 3905 U

FT 4507 (CTMT pressurel 4.3.3.6. Table 4.3-10. Items 16 s 17 Rosemount 1153AD7 MI 3723

>h rt 4508 (CTMT pressure) 4.3.3.6, Table 4.3-10 Items 16 a 17 Rosemount 1153AD7 MI 3724 E

rf 6365A (RCS pressure) 4.3.3.5.1. Table 4.3-6 Item 3s 4.3.3.6 Rosemount 1154GP9 MI 3733

-3 )3 C

Table 4.3-10, Item 3 FT 63658 (RCS pressurel g.3.3.5.1. Table 4.3-6 Item 33 4.3.3.6 Rosemount 1154GP9 MI 3734 3S Table 4.3-10 Item 3 yj FT RC2A1 (RCS pressure]

4.3.1.1.1. Table 4.3-1. Items 5,6,7.14 Rosemount 1152GP9 MI 3054 "E

3 FT RC2A2 (RCS pressurel 4.3.1.1.1. Table 4.3-1. Items 5.6.7.143 4.4.3 Rosemount 1152GP9 Mt 3052, MI 3742 FT PC2A3 IRCS pressure) 4.3.2.1.1. Table 4-3.2.

Items Id, le.

Foxboro NE11GM-IIM2 MI 3134 h

Sa s $bs 4.5.2.d.1 FT PC2A4 (RCS pressure) 4.3.2.1.1. Table 4-3.2 Items Id. le roxboro NE11GH-IIM2 MI 3132. M1 3702 4.3.3.6, Table 4.3-10 Items 3, 10 and 19 FT PC281 1RCS pressure) 4.3.1.1.1, Table 4.3-1. Items 5.6.7.14 Rosemount 1152GP9 MI 3053 FT PC282 (RCS pressure) 4.3.1.1.1. Table 4.3-1. Items 5.6.7,143 Rosemount 1152GP9 Mt 3051. MI 1742 4.4.3 FT RC283 (RCS pressure]

4.3.2.1.1. Table 4-3.7 Items Id, te, Sb roxboro NE11GH-IIM2 MI 3133 l

FT IC284 (RCS pressure]

4.3.2.1.1, Table

4.2 Items Id, t e, 5b roxboro NE11GH-IIM2 MI 3111. M1 3701 l

4..

a. vsM ;. 3-10. Items 3, 10, and 19s 4.5.2.d.1 FT SP12A2 (SG outlet st pressi e.3.3.5.1. Table 4.3-6 Item 5 Foxboro NE11GM-HIE 2 MI 3651 4.3.3.6. Table 4.3-10, Item 1 TT SP1281 (SG outlet st press) 4.3.3.5.1. Table 4.3-6 Item $s 4.3.3.6, Foxboro NE1194-HIE 2 MI 3652 Table 4.3-10, Item 1 PE 4596A (CTMT radiation) 4.3.3.6. Table 4.3-10 Item 6a General Atomics RD-23 (0360-2062-01 Rev D)

MI 3407 PE 45968 (CTNT radiationi 4.3.3.6, Table 4.3-10, Item sa General Atomics RD-23 (0360-2062-01 Rev DI MI 3400 TE RC3A2 (RCS Temperature) 4.3.1.1.1 Table 4.3-1, Items 3 s ?

Rosemount 177t#4 MI 3054. SC 4111 TE RC3A4 (RCS Temperaturel 4.3.1.1.1. Table 4.3-1. Items 3 s 7: 4.3.3.5.1 Rosemount 1771st HI 3052, SC 4111 l

Table 4.3-6, item 2 TE RC382 (RCS Temperature]

4.3.1.1.1, Table 4.3-1. Items 3 s 7s 4.3.3.5.1 Rosemount 117t#4 MI 3051. SC till sp.e Table 4.3-6 Item 2 O

TE RC384 (RCS Temperaturel 4.3.1.1.1. Table 4.3-1, Items 3 s ?

Rosemount 1771#8 HI 3053, SC 4111 3

TTRC3A5 (RCS Temperature]

4.3.3.6. Table 4.3-10 Items 2, 10. s 19 roxboro N-2Al-P2V MI 3701 e

TTRC3A6 (RCS Temperature]

4.3.3.6. Table 4.3-10 Items 2,10 roxboro N-2Al-P2V MI 3702 TTRC385 (RCS Temperature]

4.3.3.6. Table 4.3-10, Items 2. 10, s 19 roxboro N-2AI-P2V MI 3701 TTRC386 (RCS Temperature) 4.3.3.6 Table 4.3-10 Items 2. 10 roxboro N-2AI-P2V MI 3702 TT54498 tacs het leg lev temp cemps 4.3.3.6, Table 4.3-10 Item 19 Alison control A888-R103 MI 3712 7754508 tRes het tog lov to p eempt 4.3.3.6. Table 4.3-10. Item 19 Alison control A888-R103 MI 3711 2T 4263 (PORY positice) 4.3.3.6, Table 4.3-10 Item 11 TEC 504A MI 3743 ZT 4264 (PORY posittent 4.3.3.6. Table 4.3-10 Item 11 TEC 504A MI 3744 ZT 4265 (PRZR saf valve position) 4.3.3.6. Table 4.3-10, item 13 TEC 504A MI 3743 ZT 4266 (PRZR saf valve position]

4.3.3.6. Table 4.3-10, Item 13 TEC 504A MI 3744 27 4267 (PRZR saf ealve positiont 4.3.3.6. Table 4.3-10, Item 13 TEC 504A MI 3743 T 4268 (PR2R sat valve positioni 4.3.3.6, Table 4.3-10 Item 13 TEC 504A MI 3744 5.

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Instrument DriA Data Analysis Pass Revision Methodology and Assenptions 17 ers9 on TO:

FROM: 24-Month Fuel Cycle Instrument Drift Study Team DATE:

SUBJECT:

Review and Verification ofData Collection Accuracy l

i Attached is a copy of the data collected pertaining to the following:

l Tech Spec Surveillance Requirement (s):

Functional Unit (s):

Applicable Sensor (s):

Calibration Document (s):

The data has been entered into a spreadsheet and formatted to calculate drift in percent i

span (usually) or process units (rarely) using the "as-found minus as-left" approach. This l

data was obtained from STs/ pts, MWOs, and IAC shop records. A block diagram for each instrument string is also attached.

i l

Please review all the attached information, in accordance with the criteria sheet, making any comments on a document review form. Once all comments have j

been resolved, sign and date the statement below.

i j

I have reviewed the attached block diagram (s) and spreadsheet information in accordance with the criteria sheet and have foand them to be correct.

I i

e System Engmeer Date DPH/ljk Attachment

~... _

1 b

]

Instrument Drift Data Analysis pass am n j

Methodology and Assumptions inerte on h

i Imb nentDrift Study Data Review Criteria l

I. Verify that a block diagrarc for all redundant instrument strings is attached. Identify 3

l any identical strings not included. If any non-identical ones are included, verify that either the data is analyzed seperately or writtenjusti6 cation for combining data from i

the non-identical strings is included.

l l

2. Verify that each block diagram is correct, showing all components in the instrument l

string used to perform the Tech Spec required function, and showing the correct j

procedure (or PM) used to calibrate each component. Components not used to j

comply with the Tech Spec requirment need not be included in the block diagram.

l

3. Verify completeness of the as-found/as-left calibration data. The dria study team l

reviewed STs/ pts, MWOs, and I&C shop record. At a minimum, please search the l

Nuclear Records Management database and the SPB to look for cases where l

calibration and maintenance activities were performed without the spreadsheet j

reflecting it. Consider the following during your review:

a. If a field change (FCR, MOD, FPR, etc.) was performed on any comprent in the instrument string, then only data obtained subsequent to the most recent field change is relevant unless written justification for claiming the field change had no significant impact on driR characteristics of the affected component (s) is included.

b. If an instrument string performs an automatic protective action, then only " trip" and/or " reset" data is recorded for each test. If an instrument string provides process variable indication, then several different data points are recorded for each test.

c. It miwance was performed on a component in the instrument string between complete string checks (e.g., a module in the Control Room was replaced, repaired, or adjusted with the plant on-line), then the spreadsheet will indicate "NA" for both as-found and as-leR data and will indicate an adjustment was made. If a string check (including sensor) was performed as post maintenance testing, then the spreadsheet will indicate "NA" for as-found data, record as-len data, and indicate an adjustment was made. These practices prevent use of as-found data from the subsequent outage minus as-left data from the previousoutage as a meaningful measure of drift for that string (since the difference reflects the effects of the maintenance performed in addition to the driR occurring over time).

4. Verify accuracy of the as-found/as-left calibration data by spot checking a small sample if spreadsheet data points. Enough po* ts should be checked to enable signirig the m

cover sheet statement with confidence. It is not necessary to check each and every piece of data. Each outlier (a data point signi6cantly different in value from the rest of the sample) identified on the spreadsheet should be checked for data entry error. If the outlier is not a data entry error, then maintenance records should be reviewed to see if the outlier can be explained.

I

\\

Insuument Drift Data Analysis rags R m mon Methodology and Assumptions 19 of19 01 l

Select TS Instrument D Stu

==nm to be evaluesed Flowchart 1

lesmufy all amaruussut strup to be eveausend 1

Cousca huanneal AF/ALessaireen shap records, Mwon.sTs, sac.

I c, - b.ase samanhas umas

(_

Test toTest poross driA desa (z. a,95/95%)

i c

p...beme H stahshss using omhers Idemairy poemanal g,,,,,,g

_ _ _ _ _,drin dasa a

=

- ti'as omhers

]

1 Repend I

Haw Sysnese s

i Fay *= mar review data Idenkfy and

&analym outlier, analyze possnual outliers y,,,,i,,,

Na easiers Renand Versydrik desais V*I *iA d "i' Nonnelsy a en unnuessable sonnalWy norminth dannbuisd or l

To be damarnuned sensapues (ass hkaly) w, laaer,only ir mormalny as e i

h wamapuan mace' mary j.

f Evanusee 1

/w buswasst DnA susy beTais W 1ssowsma Dnn s est Tuse Easrepolate driA Dupenessa desa to 30smessbs 1

Evaluase pnyenned 30 unautb driR

--)

agamut desip O

Revise design basis docammeras, as amosasary l

s, i

Pr. pare Resuhs Sunnusry Ad**==s OL9104 lasuas

LAR 96-0014 ATTACHMENT 2 FOR LICENSE AMENDMENT REQUEST NUMBER 96-0014 (40 pages follow)

-~__

.-~.. -..

ii 1

I RPS RC FLOW i

i The following overall result summary of the drift study performed for the RPS differential pressure transmitters and I/E converters is applicable to Technical Specification Surveillance Requirement 4.3.1.1.1, Table 4.3-1, Item 4, Note 7 (RPS Flux - A Flux - Flow).

Block diagrams for these instrument strings are shown on Attachments 1 through 4. The differential l

pressure transmitters were analyzed separate from the rest of the string, as were the I/E converters.

I j

These components are both subject to testing activities that will be performed less frequently after i

switching to a 24-month fuel cycle. The other components in the string - the square root extractor, I

buffer amplifier, function generator, and bistable modules - are tested quarterly with the plant on-i line. Since this test frequency is not affected by the increase in fuel cycle duration, these modules were not included in this drift study. They were, however, part of a previous drift study to support j

extending the on-line surveillance test interval from one to six-months. (See LAR 90 002, which resulted in License Amandment No. I85.)

Differential pressure transmitter data taken at approximately 25%, 50%, 75%, and 95% of span, in I

both the increasing and decreasing directions was utilized in this study. Data at the low end of the j

range was not utilized, as it is not relevant because the RPS flux-A flux-flow trip is not needed to show protection for loss of both reactor coolant pumps in the same loop. (ne RPS high l

flux / number of reactor coolant pumps on trip will automatically trip the reactor if both RCPs in the same loop are lost.) Since flow is proportional to the square mot of differential pressure,25% of j

differential pressure span corresponds to 50% of flow span, which is adequate to cover the lower i

portion of the n~>==ary range of the instrument string. Some minor data column " shifting," as i

described in item 5e of" Instrument Drift Data Analysis Methodology and Assumptions" (referred to as "the methodology document" henceforth), was performed W-the static pressure effect on each transmitter was slightly different, resulting in calibration data being taken at perwuts of span j

that varied a little among transmitters.

i All eight RPS differential pressure transmitters were replaced during 6RFO in response to the i

Rosemount transmitter loss of fill oil issue addressed by NRC Bulletin 90-01. He replacement

{

transmitters all have serial numbers above 500000, signifying that they were manufactured after July i

11,1989. Since these transmitters were built using an improved manufacturing process, data from p

transmitters installed previously was not used in this drift study.

f For all seven (after " shifting") test points, the sample mean (x) is less than 0.02% span, which can be i

considered to effectively be zem. He worst case 95/95% tolerance factor times sample standard deviation (k*s) is 0.95% span (rautom error). A one-sided tolerance factor was used because the RPS flux-A flux -flow trip occurs on a decreasing flow signal, so its uncertainty is of concern only if I

i.

measured flow exceeds actual flow. He supporting details for these results are shown on. These results were obtained after the removal of one outlier from the FTRCI A3 data.

j The percentage drift between the as-left data on March 16,1993, and the as-found data on October i

15,1994, was approximately -2% span for each test point and was affected by a sudden downward shift in transmitter output of about I mpph during the middle of 1993. Such a sudden shift in output d

4

~ - - -.

2 4

i is not representative of transmitter drift, but is reflective of some sort of abnormal transmitter l

behavior, therefore, this test's driA data is considered an outlier for each test point.

l The assumption that the data is normally distributed was tested by performing the D' test on the drift data for all test points and the W test on the drift data for test point #2, which was the worst case point. The assumption of normality was rejected by the D' test, with the D' value falling below the desired range of values. This indicates the distribution has a higher kurtosis than would be expected 4

i for a nonnal distribution (i.e., it's more sharply " peaked"). The assumption of nonnality was not I

l rejected by the W test. Attachment 6 summarizes the D' and W test results. Histograms were created, plotting the number of drift data points versus drift (in number of standard deviations from the mean), for all test points and for test point #2. The histogram for all test points demonstrates that j

the data distribution is indeed slightly more sharply " peaked" than a normal distribution, with 94.8%

)

of the drift data points within two standard deviations of the mean. 'Ibe histogram for test point #2

{

shows that the data distribution is approximately normal, with 95.5% of the drift datatoints within i

two standard deviations of the mean. The histograms and supporting detail are shown in Attachment

7. Taken together, these results support the assumption that the differential pressure tran-itter drift j-datais normally distributed.

l A drift versus time since last test plot for all points is shown in Attachment 8. Most of the drift data points are for test intervals between 15 and 20 months, so no strong evidence is provided to either l

support or refute the assertion that drift is independent of time. A drift versus time since last i

adjustment plot for all points is shown in Attachment 9. The drift data points for intervals longer j

than 30-months are all bounded by the worst case points for intervals betua 15 and 20 months, l

however, there were many cases where the differential pressure tran-itter was adjusted at an i

interval less than 20-months since its previous adjustment. Therefore, it cannot be concluded that l

drift is time independent for test intervals up to 30 months. On the other hand, it's also not clear that i

j drift increases linearly with time. To gain additional insight into the time dapaadat characteristics j

of differential pressure transmitter drift, the data for all (drift vesus time since last adjustment) l points was divided into three groups representing various ranges of calibration intervals, and the mean and standard deviation were computed for each group. The results, shown in Attachment 10, indicate that the data for intervals greater than 30-months is more conservative, with respect to both I

mean and standard deviation, than the 15 to 20-month interval data. These results also indicate that the mean value decreases with time since last adjustment. For this reason, a regression line was fit to i

the drift versus time since last adjustment plot for all points, and it is shown in Attachment 9. Its l

slope is small in magnitude (-0.007% span per month), and the correlation is low (R = 0.03). This 2

provides further evidence that the transmitters exhibit very little time depend =t driA.

t i

l Since there isn't strong evidence to support a conclusion of drift time depaadacy, but merely j

insufficient evidence to clearly demonstrate a lack thereof, the drift versus time since last test data was extrapolated to a 30-month interval using the square root method described in item 14c of the methodology document. The data for test intervals less than three months was excluded from the i

i extrapolation because the drift experienced during those short intervals would likely not have been representative of the drift occurring over the next (at least) 9 intervals of equal length. This can be l

verified by refening again to Attachment 8 and observing that extrapolation of the short interval data l

to an 18-month interval would produce results worse than what was obtained for the actual data with i

i n

..=,~.

.-m.,

3-j intervals between 15 and 20 months. For the extrapolated data, shown on Attachment 11, the sample mean (x) is slightly negative but close to zero (i.e., bet;;aa 0 and -0.1% span). Since negative drift is conservative for these differential pressure transmitters, and because the magnitude is small, the mean will be considered zero. The worst case 95/95% tolerance factor times sample standard deviation (k*s) is 1.34% span (random error). No outliers were removed from the extrapolated data t

se..

J The assumption that the extrapolated data is normally distributed was tested by performing the D' test on the drift data for all test points and the W test on the drift data for test point #2, which was again the worst case point. The assumption of normality was rejected by the D' test, with the D' a

value falling below the desired range of values once again. The assumption of normality was not rejected by the W test. Attachment 12 summarizes the D' and W test results. Histograms were created, plotting the number of drift data points versus drift (in number of standard deviations from the mean), for all test points and for test point #2. De histogram for all test points demonstrates that the data distribution is again slightly more sharply " peaked" than a normal distribution, with 93.2%

of the drift data points within two standard deviations of the mean. The histogram for test point #2 shows that the data distribution is approximately normal, with 94.7% of the drift data points within two standard deviations of the mean. De histograms and suypsting detail are shown in Attachment

13. Taken together, these results support the assumption that the differential pw.s-transmitter 1

extrapolated drift data is normally distributed.

I/E converter data was taken at 0%,25%, 50%,75%, and 100% of span, in both the increasing and decreasing directions. For all nine test points, the sample mean (x) is less than 0.02% span, which can be considered to effectively lie zero. Herefore, the entire error associated with the I/E converters is considered random. The worst case 95/95% tolerance interval maximum is 0.15%

spah. A one-sided tolerance factor was used for the same reason as in the differential pressure transmitter case. He supporting details for these results are shown on Attachment 14. No outlier candidates were identified by the T-Test.

The assumption that the data is normally distributed was tested by performing the W test on the drift data for test point #5, which was the worst case point. The assumption of normality was not rejected. Attachment 15 summarizes the W test results. A histogram was created, plotting the number of drift data points versus drift (in number of standard deviations from the mean), for test point #5. It demonstrates that the data distribution is approximately normal and shows that all the data is within two standard deviations of the mean. De histogram and supporting detail are shown in Attachment 16.

A drift versus time since last test plot for all points is shown in Attachment 17. Most of the drift data points are for test intervals between 15 and 20 months, so no strong evidence is provided to either support or refute the assertion that drift is independent of time. A drift versus time since last adjustment plot for all points is shown in Attachment 18. This plot contains plenty of data for intervals beyond 30-months, with some data at intervals as high as 70 months. The drift data points for intervals longer than 30 months are all bounded by the worst case points for intervals between 15 and 20 months. This demonstrates that I/E converter drift is not time dependent. To quantitatively support this observation, the data for all (drift versus time since last adjustment) points was divided

d 4'

1 into three groups representing various ranges of calibration intervals, and the mean and standard i

deviation were computed for each group. The results, shown in Attachment 19, indicate that the data for intervals between 30 and 40 months is equal to, with respect to mean, or better than, with respect to standard deviation, the data for intervals between 15 and 20 months. Based on the evidence j

discussed above, it is reasonable to conclude that I/E converter drift is independent of time.

The design basis / reference uncertainty is obtained from B&W document 32-1172392-00, Reactor Protection System String Error Calculations, dated 6/13/88. It lists the differential pressure transmitter's accuracy as 0.25% span (random error) and its drift as 0.25% span (random error). It also lists the I/E converter's accuracy as 0.25% span (random error). Combining the transmitter's two random terms using the square-root-sum-of-squares technique results in an overall random error of 0.35% span. Comparing these errors with the transmitter's 30-month projected drift of 1.34%

span reveals that the design basis / reference uncertainty does not bound the 30-month projected drift.

Therefore, even though the converter's design basis / reference uncertainty (0.25% span) bounds its 30-month projected drift (0.15% span), B&W will be asked to revise the RPS string error calculation document to incorporate the 30-month projected driA d**= iced for the differential pressure transmitter and for the I/E converter. 'Ibey will also be asked to calculate revised RPS Technical Specification Allowable Values, if waaary. The following uncertainty terms must be accounted for by B&W:

Differential Pressure Transmitter Accuracy, Drift, and M&TE Uncertainty

l.34% span Differential Pressure Transmitter Calibration Tolerance

0.25% span (ref.: DB-MI-03061 through-03068)

I/E Converter Accuracy, Drift, arid M&TE Uncertainty

0.15% span I/E Converter Calibration Tolerance

0.25% span (ref.: DB-MI-03061 through -03068)

Also, the other uncertainties accounted for in B&W document 32-1172392-00 that are not covered by the above list must continue to be accounted for in the revised RPS scing error calculation document.

Historical differential pressure transmitter drift has exceeded its design basis / reference uncertainty in the non<onservative direction (greater than 40.35% span) during Sve of the 22 calibrations for which data is available. Historical drift exceeded the design basis / reference uncertainty in the conservative direction (less than -0.35% span) during five other calibrations. These results suggest that the design basis value for differential pressure transmitter drift,0.25% span (random error), is not large enough to adequately characterize transmitter performance. PCAQR 96-0278 was initiated to address this condition. Of the ten cases where historical drift exceeded the design basis / reference uncertainty, none would have exceeded the 30-month projected drift. Furthermore, only one of the extrapolated drift data points exceeds the 30-month projected drift - and that in the conservative direction. Therefore, after the 30-month projected drift is incorporated into the RPS string error calculation document, it can reasonably be expected that differential pressure transmitter drift will rarely exceed acceptable limits.

Historical I/E converter drift did not exceed its design basis / reference uncertainty (*0.25% span) in any of the 27 calibrations for which data was reviewed.

5 l

Conditions and assumptions of the setpoint and safety analysis were identified by reviewing the 3

j following documents:

l Updated Safety Analysis Report B&W document 32-1172392-00, Reactor Protection System String Error Calculations Technical Specifications i

Toledo Edison Calculation C-ICE-58.01-008, Revision 0 l

The following surveillance and periodic test procedures were reviewed and verified to appropriately reflect all applicable conditions and assumptions of the setpoint and safety analyses:

DB-MI-03061, Channel Calibration of FT-RC01 A1, RCS Loop 2 i

Flow Transmitter to RPS Channel 1 l

DB-MI-03062, Channel Calibration of FT-RC01 A2, RCS Loop 2 l

Flow Transmitter to RPS Channel 2

{

DB-MI-03063, Channel Calibration of FT-RC01 A3, RCS Loop 2 Flow Transmitterto RPS Channel 3 l

DB-MI-03064, Channel Calibration of FT-RC01 A4, RCS Loop 2 Flow Transmitter to RPS Channel 4 DB-MI-03065, Channel Calibration of FT-RC01B1, RCS Loop 1 l

Flow Transmitter to RPS Channel 1 DB-MI-03066, Channel Calibration of FT-RC01B2, RCS Loop 1 Flow Transmitter to RPS Channel 2 DB-MI-03067, Channel Calibration of FT-RC01B3, RCS Loop 1 Flow Transmitter to RPS Chanyl 3 4

DB-MI-03%8, Channel Calibration of FT-RC01B4, RCS Loop 1 i

Flow Transmitter to RPS Channel 4 l

DB-MI-03057, RPS Channel 1 Calibration of Overpower, Power /hnh=1= ace > Flow, and Power / Pumps Trip Functions i

DB-MI-03058, RPS Channel 2 Calibration of Overpower, Power / Imbalance / Flow, and Power / Pumps Trip Fun::tions DB-MI-03059, RPS Channel 3 Calibration of Overpower, Power / Imbalance / Flow, and Power / Pumps j

Trip Functions DB-MI-03060, RPS Channel 4 Calibration of Overpower, Power / Imbalance / Flow, and Power / Pumps Trip Functions DB-SC-04117, RPS Channel 1 Flow Scaling Factor Determination l

DB-SC-04118, RPS Channel 2 Flow Scaling Factor Determination DB-SC-04119, RPS Channel 3 Flow Scaling Factor Determination DB-SC-04120, RPS Channel 4 Flow Scaling Factor Deterrninntion DB-OP-03006, Miscellaneous Instrument Shift Check i

l d

.,w m..

. -. ~ _

l 1

6.

l 4

l l

Some or all of these procedures may require alteration after the RPS string error calculation document is revised and any needed changes to RPS Technical Specification Allowable Values are determined.

Preparer:

S E/E'74 j

Signature /Date 3 ~/8 '76 Reviewer:

/ Signatur-JDate l

l I

I 1

1 I

Reactor Coolant Hot Leg Flow

~

Reactor Protection System Channel 1 Range = 0 to 80 mpph I-r- - -

7 l

I (foreachloop) l FTRC1A1 FYRC1A1 RPS1RC1404 (DifferentW Pressure (Current-to-Voltage TransmGer)

Converter) l (Square Root Extractor) l lI l

L_____q l

l 1 DB-MI-03061 Loop 2 I

I t______________1_____'

I FYRC1-1 l

l (Buffer Amplifier) i l

1 1

I

______________T----

J I

I FTRC181 FYRC1B1 I

RPS1RC1407 l

fferential Pressure (Current to-Voltag (Square Root Extractor)

Genera r a.id Bistable Modules t

l l

l DB-MI-03065 Loop 1 i

DB-MI-03057.I I

iu______________1______________a l

l w

~,

Reactor Coolant Hot Leg Flow Reactor Protection System Channel 2 Range = 0 to 80 mpph r--------T-----7 I

(for each loop)

I FTRC1A2 FYRC1A2 RPS2RC1404 (Differential Pressure (Current-to-Voltage l

Transmitter)

Converter) l (Square Root Extractor) l l

l L _ _ _ ___ _ q I DB-MI-03062 Loop 2 I

l L _ _ _ - _ _ _ _ _ _ _ _ _ _

--L _ _ _ _ _ '

l FYRC1-2 i

l I

(Buffer Amplifier)

I I

r T----

J l

l l

FTRC1B2 FYRC1B2 l

RPS2RC1407 l

ffer ial Pressure (Current to-Voltage (Square Root Extractor)

Genera and l

Bistable Modules i

I I

i DB-MI-03066 Loop 1 i

DB-MI-03058 I

u______________1______________a t

i Reactor Coolant Hot Leg Flow Reactor Protection System Channel 3 Range = 0 to 80 mpph I

p----------T-------7 (for each loop) g FTRC1A3 FYRC1A3 RPS3RC1504 (Differential Pressure (Current-to-Voltage l

Transmitter)

Converter) l (Square Root Extractor) l j

j L _ _ _ _ ____ q I DB-MI-03063 Loop 2 I

I u______________1_____'

l FYRC1-3 (Buffer Amplifier) i l

l I

l r

T-J l

l FTRC183 FYRC1B3 l

RPS3RC1507 I

(Square Root Extractor)

Genera and l

ns er) on r

Bistable Modules I

I I

DB-MI-03067 Loop 1 DB-MI-03059. I t________

_____1______________a i

t

~

Reactor Coolant Hot Leg Flow

~

Reactor Protection System Channel 4 l

Range = 0 to 80 mpph r--------T------7 (for each loop) l FTRC1A4 FYRC1A4 RPS4RC1504 I

I I

i (Differential Pressure (Current-to-Voltage l

Transmitter)

Converter) l (Square Root Extractor) l l

l l

L _ _ __ _ _ q I DB-MI-03064 Loop 2 I

I u_______________u_____'

FYRC1-4 I

l (Buffer Amplifier)

I I

T -

- --- - --~ J l

r-------------

I FTRC184 FYRC1B4 I

RPS4RC1507 I

t (Square Root Extractor)

Genera and ns er)

Con r

Bistable Modules t

i I

l DB-MI-03068 Loop 1 l

DB-MI-03060. I it_______________t_______________a

)

c

i Q

l R

I S

T U

V I

W X

Y I

Z AA A

B C

P 1

2 3

Instnanent Span:

1.6 Point #2 Point #3 Point #4 Point #5 4

Shafted Data Shyted Darn Shped Data Sh$ed Data 6

0.8 volts 1.2 volts 1.6 volts 2.0 volts S

AF Date AL Date Instnnnent As Found As Left Adiusted 7 As Found As Left Adjusted 7 As Found As ufl Adrusted 7 As Found As hft Adrasted 7 7

IT-RCO R AI 8

na 3/24/90 na 0.7980 y

na 1.1990 y

na 1.6000 y

na 1.9210 y

9 025n0 4/25/90 0.8030 0.7990 y

1.2040 1.2010 y

1.6060 1.6020 y

1.9270 1.9230 y

10 Wil/91 9/11/91 0.8110 0.7990 y

1.2110 1.1990 y

1.6110 1.6000 y

I.9300 1.9200 y

11 3/1663 3/16/93 0.8004 0.8004 n

1.2016 1.2016 n

1.6023 1.6023 n

1.9230 1.9230 n

12 10/13S 4 10/13/94 08010 0.8000 y

1.2020 1.2000 y

1.6020 1.6000 y

1.9230 1.9200 y

13 FT-RColB t 14 na 3/23/90 nn 0.7990 y

na 1.1990 y

na 1.5990 y

na 1.9190 y

15 5/24/90 5/24/90 0.8033 0 8007 y

1.2048 1.2024 y

1.6059 1.6024 y

I.9259 1.9226 y

16 W12S1 9/12M t 0.7960 0.8020 y

1.1970 1.2030 y

1.5960 1.6030 y

I.9160 1.9230 y

17 3/18/93 3/IS!93 0.8070 0.8000 y

1.2060 1.2000 y

1.6060 1.6010 y

E.9260 1.9200 y

18 FT-RCO1 A2 15 na 3/1360 nn 0.7990 y

na 1.1990 y

na 1.5990 y

na 1.9190 y

20 Wl?/91 9/17/91 0.8030 0.8000 y

1.2020 1.1990 y

1.6020 1.5990 y

1.9220 1.9190 y

21 3/15/93 3/15/93 0.8004 0.8004 a

1.2009 1.2009 a

1.6006 1.6006 a

1.9211 1.9211 n

22 10/13/94 10/13/94 0.7950 0.8000 y

1.1950 1.2000 y

1.5960 1.6010 y

1.9160 1.9210 y

23 FT-RColB2 24 na 5/23/90 nn 0.7980 y

na 1.1980 y

na 1.5980 y

na 1.9190 y

25 3/27/90 5/27/90 0.7940 0.7990 y

1.1940 1.1990 y

1.5930 1.6000 y

1.9150 1.9210 y

26 9/13/91 9/13/91 0.7990 0.7990 a

1.2000 1.2000 a

1.6000 1.6000 a

1.9200 1.9200 a

27 3/18/93 3/l&93 0.7920 0.8000 y

1.1940 1.2010 y

1.5980 1.6000 y

I.9180 1.9210 y

28 10/11/94 10/11/94 0.8030 0.8010 y

1.2030 1.2010 y

1.6040 1.6020 y

I.9250 1.9230 y

29 FT-RC01 A3 30 nn 3/29/90 nn 0.7990 y

na L2990 y

na L3980 y

na L9200 y

31 9/1861 9/l8/91

&8020_

08000 y

L2020 L1990 y

L6030 L3990 y

L9240 L9190 y

31 3/16/93 3/l6/93 0.7977 67977 n

LI961 Li961 n

L3963 L3963 n

L9169 I9169 n

33 10/13/94 10/15/94 0.7660

7980 y

Ll650 L1980 y

L3640 L3990 y

L8840 L9200 y

34 FT-RColB3 35 na 3/30/90 nn 08000 y

na Ef990 y

na L6000 y

na 1.9200 y

38 W16/91 9?t 6/91

7840 A8010 y

LI840 L2000 y

L3840 L6020 y

L9030 1.9200 y

31 3/l7/9) 3/11/93 0.7978

7978 n

Lf 974 L1974 n

L3984 L3988 n

L 9171 L 9871 n

38 FT-RCo t A4 l

39 na 3/31/90 nn 0.7990 y

na Ll990 y

na L3990 y

na L9200 y

40 9/17/91 9!!7/91 68090 68010 y

L2070 L2000 y

L6060 L6000 y

L9260 L9269 y

41 3/15/93 3/15/93 0.8001 0.8001 n

L2008 L2008 a

L6018 L6018 n

1.9234 L9234 n

42 FT-RColB4 43 na 3/31/90 nn 0.7990 y

na L1990 y

na L3990 y

na L9190 -

y 44 9/14/91 9/14191 6 7870 68000 y

L1880 L2010 y

LS890 L6020 y

1.9090 L9220 y

45 3/17/93 3/11/93

8013 0.1992 y

L2041 L1993 y

L6060 L6006 y

L 9278 1.9199 y

(cont)

A B

C AB AC AD AE AF AG AH Al AJ 1

2 3

Instrument Span-1.6 Point #6 Point #7 Point #8 4

ShiftedData Shijted Data ShiftedData 5

1.6 volts I.2 volts 0.8 volts 6

AF Date AL Date Instrument As Found As Left Adiusted 7 As Found As Left Adiosted 7 As Found As Left Adiusted 7 7

FT-RC01A1 8

na 3/24SO na 1.6000 y

na 1.1990 y

na 0.7990 y

9 4/25/90 4/25S 0 1.6060 1.6020 y

1.2050 1.2010 y

0.8030 0.7990 y

10 9/11/91 9/11/91 1.6120 1.6000 y

1.2120 1.1990 y

0.8120 0.7990 y

11 3/16/93 3/16/93 1.6031 1.6031 n

1.2016 1.2016 n

0.8004 0.5004 n

12 10/13/94 10/13/94 1.6020 1.6000 y

1.2020 1.2000 y

0.8010 0.8000 y

13 FT-RColBI 14 na 3/23/90 na 1.5990 y.

na 1.1990 y

nn 0.7990 y

15 5/24/90 5/24/90 I.6058 1.6027 y

12048 1.2020 y

0.8037 0.8009

_y.

16 9/12/91 9/12/91 1.5960 1.6030 y

1.1960 1.2030 y

0.7960 0.8020 y

17 3/18/93 3/18/93 1.6070 1.6010 y

I.2070 1.2000 y

0.8070 0.8000 y

18 FT-RC01 A2 19 na 3/15/90 na 1.6000 y

na 1.1990 y

ns 0.7990 y

20 9/17/91 9/l7/91 1.6020 1.5990 y

1.2020 1.1990 y

0.8030 0.8000 y

21 3/15 S 3 3/15/93 I.6010 1.6010 n

I.2002 1.2002 n

0.7999 0.7999 n

22 10/13/94 10/13/94 1.5960 1.6000 y

1.1950 1.2000 y

0.7950 0.8000 y

23 FT-RC0lD2 24 na 5/23/90 na 1.5980 y

na 1.1980 y

nn 0.7980 y

25 5/27/90 5/27/90 1.5950 1.6000 y

I.1950 1.2000 y

0.7940 0.7995 y

26 9/13/91 9/13/91 1.5990 1.5990 n

1.1990 1.1990 a

0.7990 0.7990 n

27 3/18/93 3/18/93 1.5960 1.6020 y

1.1950 1.2010 y

0.7930 0.8000 y

28 10/1164 10/11/94 1.6040 1.6020 y

1.2040 1.2020 y

0.8030 0.8010 y

29 FT-RC0 tA3 30 na 3/29/90 na 1.5990 y

na 1.1990 y

na A8000 y

31 9/Isi91 9/I8/9l 1.6030 1.5990 y

1.2020 1.1990 y

08020 08000 y

32 3/16/93 3/16/93 1.5768 1.5968 a

1.1963 1.1765 a

A 7976 0.79 76 a

33 10/1564 10/15S4 1.5640 1.5770 y

1.1650 1.1790 y

0.7660 A 7980 y

34 FT-RColB3 35 na 3/3060 na 1.6010 y

na 1.2000 y

na 68000 y

36 9/16/9E 9/16/91 1.5840 1.6010 y

1.1840 1.2000 y

0.7840 08010 y

37 3/17/93 3/17/93 1.5787 J.5587 a

1.1981 J.1981 n

a 7979 0.7979 a

38 FT-RC01 A4 39 na 3/31/90 na 1.5780 y

na 1.1780 y

nn 0.7990 y

40 9/l7S t 9/11/91 1.6060 1.6000 y

1.208C 1.2000 y

08090 08010 y

41 3/15/93 3/15/93 1.6020 1.6020 n

1.2005 1.2005 n

0.8002 0.8002 a

42 FT-RColB4 43 na 3/31/90 na 1.5990 y

na 1.1990 y

nn 0.7980 y

1 y

1.1880 1.2010 y

G 7870 08000 y

44 9/14/91 9/l4/9l 1.5890 1.6020 45 3/l?/93 3/l7/93 1.6066 1.6006 f y

1.2049 1.2005 y

0 8020 67993 y

I 1

l (cont.)

4 l

i I

1 A

B C

AO l

AP AQ AR AS AT AU 1

Months Since Last Test 4

2 3

Instrument Span:

1.6 0

l f

6 AF Date AL Date liou-sra Point #2 Point #3 Point #4 Point #5 Point #6 Point #7 Point #8 j

7 FT-RC01A1 8

na 3/24/90 9

4/25/90 4/25/90 1.051 1.051 1.051 1.051 1.051 1.051 1.051 10 9/11/91 9/11/91 16.559 16.559 16.559 16.559 16.559 16.559 16.559 11 3/16/93 3/16/93 18.136 18.136 18.136 18.136 18.136- - 18.136 18.136 l

12 10/13/94 10/13/94 18.924 18.924 18.924 18.924 18.924 18.924 18.924 i

13 FT-RC01B1 5

14 na 3/23/90 16 5/24/90 5/24/90 2.037 2.037 2.037 2.037 2.037 2.037 2.037 16 9/12/91 9/12/91 15.639 15.639 15.639 15.639 15.639 15.639 15.639 17 3/18/93 3/18/93 18.168 18.168 18.168 18.168 18.168 18.168 18.168 I

18 FT-RColA2 l

19 na 3/15/90 20 9/17/91 9/17/91 18.103 18.103 18.103 18.103 18.103 18.103 18.103 l

l 21 3/15/93 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 22 10/13/94 10/13/94 18.957 18.957 18.957 18.957 18.957 18.957 18.957 f

23 FT-RC01B2 24 na 5/23/90

}

26 5/27/90 5/27/90 0.131 0.131 0.131 0.131 0.131 0.131 0.131 j'

26 9/13/91 9/13/91 15.573 15.573 15.573 15.573 15.573 15.573 15.573 l

27 3/18/93 3/18/93 18.136 18.136 18.136 18.136 18.136 18.136 18.136 I

28 10/11/94 10/11/94 18.793 18.793 18.793 18.793 18.793 18.793 18.793 29 FT-RColA3 30 na 3/29/90 j

l 31 9/18/91 9/18/91 17.676 17.676 17.676 17.676 17.676 17.676 17.676 32 3/16/93 3/16/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 33 10/15/94 10/15/94 18.990 18.990 18.990 18.990 18.990 18.990 18.990 l

34 FT-RC01B3

{

36 na 3/30/90 2

36 9/16/91 9/16/91 17.577 17.577 17.577 17.577 17.577 17.577 17.577 I

37 3/17/93 3/17/93 18.004 18.004 18.004 18.004 18.004 18.004 18.004 j

38 FT-RC01A4 l

39 na 3/31/90 jl 40 9/17/91 9/17/91 17.577 17.577 17.577 17.577 17.577 17.577 17.577 1

41 3/15/93 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906

}l j

42 FT-RC01B4 43 na 3/31/90 44 9/14/91 9/14/91 17.478 17.478 17.478 17.478 17.478 17.478 17.478 46 3/17/93 3/17/93 18.070 18.070 18.070 18.070 18.070 18.070 18.070 I

4 d

(cont.)

BX BY i BZ CA l CB l CC l CD l CE CF I CG 1

Percent Dnft Smee 1.ast Test one meded m.tarval

]

2

)

3 instrurnent Span:

1.6 4

6 l

6 AF Date AL Date inarument Pomt#2 Point #3 Pomt84 Point #5 Pomt #6 Pomt#7 Pomt#8 7

FT-RC01A1 8

na 1/24/90 9

4/25/90 4/25/90 0.3125 03125 0375 0.375 0.373 0.375 0.25 10 9/11/91 9/11/91 0.75 0.625 0.5625 0.4375 0.625 0.6875 0.8125 11 3/16/93 3/16/93 0.0875 0.1625 0.14375 0.1875 0.19375 0.1625 0.0875 12 10/13/94 10/13/94 0.0375 0.025

-0.01875 0

-0.06875 0.025 0.0375 13 FT-RCU1B1 14 na 3/23/90 15 5/24/90 5/24SO 0.26875 03625 0.43125 0.43125 0.425 03625 0.29375 16 9/1261 9/12 S1 0.29375 03375

-0.4

-0.4125

-0.41875

-0.373

-0.30625 17 3/18S3 3/18S3 03125

'0.1875 0.1875 0.1875 0.25 0.25 03125 18 FT-RC01 A2 19 na 3/15/90 20 9/17/91 9/17/91 0.25 0.1875 0.1875 0.1875 0.125 0.1875 0.25 21 3/15/93 3/15/93 0.025 0.11875 0.1 0.13123 0.123 0.075

-0.00625 22 10/13/94 10/13/94 0.3373

-036873

-0.2875

-031873

-03125

-0 325

-0.30625 23 FT-RC01B2 24 as 5/23 S 0 25 5/27SO 5/27/90

-0.25

-0.25 0.1875

-0.25

-0.1875

-0.25 26 9/13/91 9/13/91 0

0.0625 0

0.0625

-0.0625

-0.03125 27 3/18S3 3/18/93

-0.4375

-0375

-0.125

-0.1873

-0.25

-0375 28 10/11/94 10/11/94 0.1875 0.125 0.25 0.25 0.125 0.1875 0.1875 29 FT-RC01 A3 30 na 3/29/90 31 9/18/91 9/18/91 0.1875 0.1875 03125 0.25 0.25 0.1875 0.825 32 3/16S 3 3/1663

-0.14375

-0.18125

-0.15625 0.13125

-0.1375

-0.16875

-0.15 33 10/15 S 4 10/15/94 1.98125 l.94375

-2.03123

-105625

-105 1.95625 1.975 34 FT-RC01B3 35 na 3/30/90 36 9/16/91 9/16/91 1

-0.9373 l

1.0623

-1.0625 1

1 37 3/17S3 3/17/93

-0.2

-0.1625

-0.1375

-0.18125

-0.14375

-0.11875

-0.19375 38 FT RC01 A4 39 as 3/31SO 40 9/17/91 9/17/91 0.625 0.5 0.4375 DJ75 0.5 0.625 0.625 41 3/15S 3 3/15S 3

-0.05625 0.05 0.1825 0.2125 0.123 0.03125 0.03 42 FT RC01B4 43 as 3/31 S 0 44 9/14/91 9/14/91

-0.75 0.6875 0.625

-0.625 0.625

-0.6875

-0.6875 45 3/17/93 3/17S 3 0.09375 0.19373 0.25 03625 0.2875 0.24375 0.125 46 27

~48 49 60 Mese

-0.101

-0093

-0.070

-0.080

-0.075

-0.097 61 Saad 0.570 0.544 0.560 0.568 0.573 0.562 0.566 62 Count 23 23 23 23 23 23 23 63 k (ans aded) 2328 1328 2328 2328 2328 2328 2 328 64 k*s 1.327 1.267 1305 1321 1335 1309 1.318 65 95/95 Max 1.226 1.174 1.234 1.241 1.255 1.234 1.221 66 57 68 Outher Analyss SS T

2.62 2.62 162 2.62 2.62 2.62 2.62 60 x Ts

-1.594

-1.519 1.539

-1.567

-1.583

-1.548

-1.580 61 x+Ts 1393 1.333 1398 l.407 1.422 1398 1386 62 Outhers i

1 1

l 1

63 Mean

-0 015

-0009 0.019 0.0 to 0.009 0.010

-0.011 64 Said 0.405 0.374 0371 0378 0 389 0.394 0.400 65 Count 22 22 22 22 22 22 22 66 k (one aded) 2.349 2.349 2.349 2.349 2349 2.349 2.349 67 k*s 0.952 0.879 0.872 0.888 0.914 0.925 0.939 68 95/95 Max 0.937 0.870 0.890 0.898 0.923 0.933 0.928 69 I

l l

i (cont.)

A B

C BG l

BH l

Bl BJ BK BL BM 1

Months Since Last Adjustment 2

3 Instrument Span:

1.6 4

5 6

AF Date AL Dgte Instmmen1 Point #2 Point #3 Point #4 Point #5 Point #6 Point #7 Point #8 7

FT-RC01A1 8

na 3/24/90 9

4/25/90 4/25/90 1.051 1.051 1.051 1.051 1.051 1.051 1.051 10 9/11/91 9/11/91 16.559 16.559 16.559 16.559 16.559 16.559 16.559 4

11 3/16/93 3/16/93 18.136 18.136 18.136 18.136 18.136 - 18.136 18.136 12 10/13/94 10/13/94 37.060 37.060 37.060 37.060 37.060 37.060 37.060 13 FT-RColBI 14 na 3/23/90 15 5/24/90 5/24/90 2.037 2.037 2.037 2.037 2.037 2.037 2.037 16 9/12/91 9/12/91 15.639 15.639 15.639 15.639 15.639 15.639 15.639 17 3/18/93 3/15/33 18.168 18.168 18.168 18.168 18.168 18.168 18.168 18 FT-RCO1A2 19 na 3/15/90 20 9/17/91 9/17/91 18.103 18.103 18.103 18.103 18.103 18.103 18.103 21 3/15/93 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 22 10/13/94 10/13/94 36.862 36.862 36.862 36.862 36.862 36.862 36.862 23 FT-RC01B2 24 na 5/23/90 25 5/27/90 5/27/90 0.131 0.131 0.131 0.131 0.131 0.131 0.131 26 9/13/91 9/13/91 15.573 15.573 15.573 15.573 15.573 15.573 15.573 27 3/18/93 3/18/93 33.708 33.708 33.708 33.708 33.708 33.708 33.708 28 10/11/94 10/11/94 18.793 18.793 18.793 18.793 18.793 18.793 18.793 29 FT-RC01A3 30 na 3/29/90 31 9/18/91 9/18/91 17.676 17.676 17.676 17.676 17.676 17.676 17.676 32 3/16/93 3/16/93 17.906 17.9 %

17.906 17.906 17.906 17.906 17.906 33 10/15/94 10/15/94 36.895 36.895 36.895 36.895 36.895 36.895 36.895 34 FT-RC01B3 35 na 3/30/90 36 9/16/91 9/16/91 17.577 17.577 17.577 17.577 17.577 17.577 17.577 37 3/17/93 3/17/93 18.004 18.004 18.004 18.004 18.004 18.004 18.004 38 FT-RC01 A4 39 na 3/31/90 40 9/17/91 9/17/91 17.577 17.577 17.577 17.577 17.577 17.577 17.577 41 3/15/93 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 42 FT-RCO1B4 43 na 3/31/90 44 9/14/91 9/14/91 17.478 17.478 17.478 17.478 17.478 17.478 17.478 45 3/17/93 3/17/93 18.070 18.070 18.070 18.070 18.070 18.070 18.070 (cont.)

A B

C BP l

BQ l

BR BS BT BU BV 1

Percent Drift Since Last Adjustment 2

3 Instrument Span:

1.6 4

5 A Date AL Date Instrument Point #2 Point #3 Point #4 Point #5 Point #6 Point #7 Point #3 F

6 7

FT-RC01A1 8

na 3/24/90 9

4/25/90 4/25/90 0.3125 0.3125 0.3750 0.3750 0.3750 0.3750 0.2500 10 9/11/91 9/11/91 0.7500 0.6250 0.5625 0.4375 0.6250 0.6875 0.8125 11 3/16/93 3/16/93 0.0875 0.1625 0.1437 0.1875 0.1937 0.1625 0.0875 12 10!!3/94 10/13/94 0.1250 0.1875 0.1250 0.1875 0.1250 0.1875 0.1250 13 FT-RColB1 14 na 3/23/90 15 5/24/90 5/24/90 0.2637 0.3625 0.4313 0.4312 0.4250 0.3625 0.2937 16 9/12/91 9/12/91 0.2937

-0.3375

-0.4000

-0.4125

-0.4187

-0.3750 0.3062 17 3/18/93 3/18/93 0.3125 0.1875 0.1875 0.1875 0.2500 0.2500 0.3125 18 FT-RCOIA2 19 na 3/15/90 20 9/17/91 9/17/91 0.2500 0.1875 0.1875 0.1875 0.1250 0.1875 0.2500 21 3/15/93 3/15/93 0.0250 0.1188 0.1000 0.1312 0.1250 0.0750

-0.0062 22 10/13/94 10/13/94

-0.3125

-0.2500

-0.1875

-0.2500

-0.3125 23 FT-RC01B2 24 na 5/23/90 25 5/27/90 5/27/90

-0.2500

-0.1875 0.2500

-0.1875 0.1875

-0.2500 26 9/13/91 9/13/91 0.0000 0.0625 0.0000

-0.0625 0.0625 0.0625 0.0312 27 3/18/93 3/18/93

-0.4375

-0.3125 0.1250

-0.1875

-0.2500

-0.3125

-0.4062 28 10/11/94 10/11/94 0.1875 0.1250 0.2500 0.2500 0.1250 0.1875 0.1875 29 FT-RCotA3 30 na 3/29/90 31 9/18/91 9/18/91 0.1875 0.1875 0.3125 0.2500 0.2500 0.1875 0.1250 32 3/16/93 3/16/93 0.1437

-0.1812 0.1562

-0.1313

-0.1375

-0.1687

-0.1500 33 10/15/94 10/15/94 2.1250 2.1250

-2.1875

-2.1250

-2.1250 34 FT-RC01B3 35 na 3/30/90 36 9/16/91 9/16/91

-1.0000

-0.9375

-1.0000

-1.0625

-1.0000

-1.0000 37 3/17/93 3/17/93

-0.2000

-0.1625 0.1375

-0.1812

-0.1437

-0.1188 0.1937 38 FT-RC01 A4 39 na 3/31/90 40 9/17/91 9/17/91 0.6250 0.5000 0.4375 0.3750 0.5000 0.6250 0.6250 41 3/15/93 3/15/93

-0.0563 0.0500 0.1125 0.2125 0.1250 0.0312

-0.0500 42 FT-RColB4 43 na 3/31/90 44 9/14/91 9/14/91

-0.7500

-0.6875

-0.6250

-0.6875

-0.6875 45 3/17/93 3/17/93 0.0938 0.1937 0.2500 0.3625 0.2875 0.2437 0.1250 De D'=T/S value of $23.02 for a 0.05 significance level of normality should fall between approximately 529 and 546.

The D' value for this test is less than the values it should fall in, which shows it has a high kurtosis.

l A high kurtosis says that the data came from a distribution that is more sharply

peaked" than the normal distntution.

The assumption of normality is rejected at the 0.05 significance level.

I FIRCIAI - B4 all points The D' Test i

Ordered Xi stdev's count:

154 T - term 1

-1.0625

-2.8004 S^2:

22.09842 81.2813 2

-1.0625

-2.8004 80.2187 3

-1

-2.6360 T:

2458.66250 74.5 4

-1

-2.6360 D'=T/S:

523.02007 73.5 5

-1

-2.6360 72.5 6

-1

-2.6360 average.

0.0018 71.5 7

-0.9375

-2.4715 stdev:

0.3800 66.0937 8

-0.75

-1.9781 52.125 9

0.6875

-1.8137 47.0938

. (cont.)

l l

F1RCI A1 - B4 l

{

W test for normality - FTRCI AI - B4 point #2 step #

1 4.2.2 S^2=

3.447 4.23 0.8033 j

0.4590 1

1.7500

=

2 13750 03156 0.434

=

0.1928 0.2571 3

0.7500

=

0.1385 4

0.6500 0.2131

=

0.0992 5

0.5625 0.1764

=

6 0.5000 0.1443

=_

0.0722 0.0446 7

03875 0.1150

=

0.0291 8

03312 0.0878

=

0.0093 9

0.1500 0.06I8

=

0.0032 10 0.0875 0.0368

=

0.0002 l

11 0.0125 0.0122

=

0 12 0.0000

=

0 13 0.0000

=

0 14 0.0000

=

0 15 0.0000

=

0 16 0.0000

=

0 17 0.0000

=

0 18 0.0000

=

0 19 0.0000

=

0 20 0.0000

=

0 21 0.0000

=

0 f

22 0.0000

=

0 23 0.0000

=

0 24 0.0000

=

0 25 0.0000

=

b=

1.82620 4.2.4 b^2=

333502 W=b^2/S^2=

0.% 740 (test statistic) 1 W critical value 0.9110 The assumption of normaility is NOT rejected at the.05 level.

l l

4 i

j n

154 average 0.002 stdev 0.380 Bin Descnption Unner Bound Expected Observed i

I

(-e,X-20)

-0.76 3.50 7

2 (X-2c,X-(4/3)o) 0.50 10.54 7

3 (X-(4/3ks,X-(2/3)o)

-0.25 24.84 17 4

(X-(2/3)a,X) 0.00 38.12 37 5

(X,X+(2/3)o) 0.26 38.12 54 6

(X+(2/3)e,X+(4/3)o) 0.51 24.84 23 7

(X+(4/3)o,X+2a) 0.76 10.54 8

8 (X+2a,X+m) 9999.00 3.50 1

U *'*d

~

Verifiestion of Normality - Binning Method

~

FTRCI Al-B4 - All Points m

d Z

f 1

j l4 g

!=

d g

i=

s

=

V t

$gS 30 m

fL NNT I

l l

I i

l I

N (cont.)

n 22 average

-0.015 stdev 0.405 Din Desenption Unoer Bound Expected Dbslrlid 1

(-e,X-2a)

-0.83 0.50 1

2 (X-2a,X.6670)

-0.29 5.05 4

~--

3 (X.667a,X+.667o) 0.26 10.90 12 4

(X+.667a,X+2c) 0.80 5.05 5

5 (X+2a,+e) 9999.00 0.50 0

Verification of Noranslity - Blaming Method FTRCIA1-B4 - Point #2 12

= _ - _ -

4 w-n 3

Ndis m

~

~ k6 o

d I

t

=

~

4 2

y g m- =

. 53 M

i + --, i o,

w -u) a-u.x-uns a-a u,x+a us a uus+us a<u.->

~

Ben Ramp

~

[

i 0

2 l

>!s [

6*

4 8

,8 1

4 e*.

,66 e-

#4*

6 1

.^

4 I

2 1

t

)

s )s ns et o

Tni M

me t o saP

(

8 Ll c

l t

e eA r

tn c(

0 t

e n4 1

s m

m iSB I

hc e -

ec a

m1 n

t i

A s

t i

A Tt e

. o e

h vC T

f R t

8 iT rDF 6

4

>g 2

0*+

0 0

0 8

6 4

2 M

2 4

6 8

0 2

0 0

1 0

0 0

0 O

0 0

I 1

11]k$!

04 7

,4 7

4 3

1 0 6 9

5 3

+ 2 x 0 0

e. g 1

7

=

002 R 0-

=

y 0

3 5

2 t,

)s n

h e

tn m) oM t

s s

t

(

u n t

ji n

d o e

AP m

9 t

t l

s l

t s

u n

aA 0

jd e

L(

2 A

m 4

e t

h cB s

a i -

4

,4 a

c n

L t

SI

,e i.

e tA eA 4*

4

,44

+0 4 i

cn mI S

iC e

R

#4*

T. T im F

e-i g,

T v

tf 5

i 1

rD 0

1 0 4

44 h >

0 0

8 6

4 2

0 2

4 6

8 0

2 1

0 0

0 4

0 1

1 7E0;ig ex

. 0 I

Binnino Method - Percertt Drift Big Months Months Count Mean Sid

[0,10)

>0

<=3 21 0.16 0.28 MDalbs Months l

[10,30]

>l5

<=20 112 0.01 0.41 Months Months

[30.50)

>30

<=40 21

-0.13 0.21 Drift v. Time Since Last Adjustment FTRCI A1 - 84 (All Points) 1.00

~

^

~

0.30 0.60

^

~

0.40 k

0.20

~

3 0.00

F E

.0.20

,G..o,o

.a I

8

.60 0.80

~

.i.00 5

-1.20

~

0 5

10 15 20 25 30 35 40

~~

Time Since Last Adjustment (Months)

Attactwnent 11 BX !

BY I BZ l CH l Cl l CJ l CK CL l CM CN 1

Peru:nt Dnft Smoe Las Tem j

2 extrapolated to 30 months vm square root method 3

lastmrnent Span:

I.6 (all tes-tes antervals <3 months neglectad) 4 6

6 AF Date AL Date Instrument Pomt#2 Pomt#3 Pomt#4 Pomt#$

Point #6 Pomt#7 Pomt#8 7

FT-RCot Al 8

as 3/24SO 9

4/25/90 4/25SO 10 9/IISI 9/11/91 1.010 0.841 0.757 0 *89 0.841 0 925 1.094 11 3/16S3 3/16/93 0.113 0.209 0.185 0.241 0 249 0.209 0 113 12 10/11/94 10/13/94 0.047 0.031

-0.024 0.000

-0.087 0.031 0.047 13 F7 RColBI 14 na 3/23/90 16 S/24/90

$/24SO 16 9/1291 9/12/91

-0 407

-0 467 0.554

-0.571

-0.580

-0.519

-0.424 i

17 3/18/93 3/18S 3 0.402 0.241 0.241 0.241 0.321 0321 0.402 18 FT-RC01 A2 19 na 3/ISSO 20 9/17&l 9/87/91 0322 0.241 0.241 0.241 0.161 0.241 0322 21 3/15S3 3/ISS3 0.032 0.154 0.129 0.170 0.162 0.097

-0.008 22 10/13/94 10/13/94

-0.425

-0.464

-0362 0.401

-0.393

-0.409

-0385 23 FT-RColB2 24 na S/23/90 25

$/27SO S/17190 26 9/13/91 9/13SI 0 000 0.087 0.000 0.087

-0.087 0.087

-0.043 j

27 3/18S3 3/18/93

-0.563

-0.482

-0.161

-0.161 0.241

-0.322

-0.482

)

28 10/11/94 10/11/94 0.237 0.158 0316 0.316 0.158 0.237 0.237 I

29 l'T-RC01 A3 30 na 3/29 S0 i

31 9/IlWI 9/18S1 0.244 0.244 0.407 0.326 0.326 0.244 0.163 32 3/16S3 3/16/93

-0.1 86

-0.235

-0.202

-0.170 0.178

-0.218

-0.194 33 10/ISS4 10/15/94 34 FT-RC01B3 35 na 3/30/90 36 9/1661 9/1661

-1.306 1.225

-1306 1.388 1,388 1.306

-1.306 37 3/17/93 3/17/93

-0.254

-0.210

-0.177

-0.234

-0.186 0.153

-0.250 38 FT RC01 A4 39 na 3/31/90 40 9/17Si 9/17/91 0.817 0.653 0.572 0.490 0.653 0.817 0.817 41 3/15/93 3/15/93

-0.073 0.063 0.146 0.275 0.162 0.040

-0.065 42 FT-RColi!4 43 na 3/31/90 44 9/14/91 9/14/91

-0.983

-0.901

-0819

-0.819 0.819

-0.901

-0.908 45 3/I7S3 3/I7/93 0.121 0.250 0322 0.467 0370 0314 0.161 46 47 48 43 60 Mean 0.045

-0 043 0.015

-0.025

-0.029

-0.023

-0.037 61 Sad 0.553 0.501 0.493 0.499 0.519 0.531 0.548 62 Count 19 19 19 19 19 19 19 63 k (one aded) 2.423 2.423 2.423 2.423 2.423 2.423 2.423 64 k's 1.339 1.214 1.193 1.209 1.259 1.287 1.328 66 95/95 Max 1.294 1.172 1.178 1.184 1.230 1.264 1.291 66 67 68 Outher Analyas 69 T

2.53 2.53 2.53 2.53 2.53 2.53 2.53 60 n 7s 1444

-1.310

-1.261

-l.287

-1343

-1.367

-1.424 61 r+7s 1.353 1.225 1.231 1.237 1.285 1.321 1.350 62 Outhers 0

0 1

1 1

0 0

63 Mean

-0 043

-0 043 0 057 0.051 0.046

-0.023

-0.037 64

$std 0.S $3 0.501 0392 0.385 0.414 0 $31 0.548 65 Count 19 19 18 18 IS 19 19 66 k (one nded) 2 423 2.423 2.453 2.453 2.453 2.423 2 423 67 k's 1340 1.214 0 961 0 944 I.015 1.287 1.329 68 95SS Max 1.295 1.172 1.017 0.995 1.061 1.264 1.292 69 I

i i

i

..~__..

_.- 2 The ly=T/S value of 417.04 for a 0.05 significance level of normality should fall between approximately 423.6 and 439.l.

The 17 value for this test is less than the values it should fall in, which shows it has a high kurtosis.

l A high kurtosis says that the data came horn a distribution that is more sharply " peaked" than the normal distribution.

The assumption of normality is rejected at the 0.05 significance level.

I I

l FTRCl Al - B4 all points extrapolated to 30 months via sc uare root method (all intervals < 3 months neglected)

The IF Test i

Ordered Xn sedmfs count:

133 T - term 1 -l3 880885

-2.6649 S^2:

34.22917 91.6138427 2 -l3 880885

-2.6649 90.2257542 3 -l3064363

-2.5046 T:

2439.95627 83.6119206 4 -13064363

-2.5046 IY=T/S:

417.04593 823 054844 5 -13 064363

-2.5046 80.9990481 6 -13064363

-2.5046 average.

-0.0310 79.69261IB 7

-1.224784

-23442 sidev:

0.5092 73.48703 %

8

-0.982586

-1.8686 57.9725729 I

- I

~

g g e g g g g o o o o o o o o o o o o o o o o g

e e g k

lcE,

% G 8

R O R n

8 o o 8 2

M :

C E 8

-: n n o e o o o o o o M-

~

m 8 m I

. m H 8

$ 8 w

e o o o o o o o o o m

i I

1

.i a

i a

_ l g

R

?s a

f E 5 5! ! 5 ! $ $ $ $! ! l l ! ! I I ! l ! ! l !

j ! E o o o o o o o o o o o o o o o o o o o o o o o o 2 n

.k

_ {

1 E

l E

a C C 0 8 S I S $ 5 N N N N U

e 3

A A )

1 1

5 m

E. l V ] *e s.

a n

~

n

- p u u

i l

1 3 4

4 n

133 average

-0.031 stdev 0.509 gin Descrintion LwrBDund Expected Observed I

(-e,X-20)

-1.05 3.03 7

1 2

(X-2o,X-(4G)o)

-0.71 9.11 7

3 (X-(40)o,X-(2/3)o)

-0.37 21.45 16 1

4 (X-(2/3)o,X)

-0.03 32.92 26 5

(X.X+(2/3)o) 0.31 32.92 48 6

(X+(2S)o,X+(4G)o) 0.65 21.45 18 7

(X+(4/3)o,X+2a) 0.99 9.! l 9

8 (X+20,X+e) 9999.00 3.03 2

1 0W 1

Verification af Normality - Binning Method

}

FTRCIAl-B4 - All Points 45

~

10 i

j 35 I

2 3

hh

[

}

]

j so g

Y 3

1

,1 e

is t-M e

1 10 f

t

~

b b.St I

I I

i l

l 1

1 3 (cont.)

i 1

n 19 average

-0.045 stdev 0.553 Din Descrintion Unner Bound Expected Qhacrynd I

(-e,X-20)

-1.15 0.43 I

2 (X-2o,X.667o)

-0.41 436 3

3 (X.667a,X+.667c) 032 9.41 12 4

(X+.667a,X+2c) 1.06 436 3

5 (X+2a,+m) 9999.00 0.43 0

f Verification of Norma:ity - Binning Method DExpeced FTRCI Al-B4 - Point #2 sobserved i

extrapolated to 30 months via squan root method (latervals<3 months excluded)

)

12.00 10 00,

~~

a.

8 00 i

2 0

E 6 00 <

k M

==

REM 4 00 x'

n y

B

.^

0 00 A -

(-= X-2o)

(X-2a.X-Wh)

(X-m b,X+ m b)

(x+ M h,X+2e)

(x+2e, )

We Range l

l l

4 A

B C

l M

I N

I O

I P

Q R

I S

T I

U 1

2 3

Instrument Span:

10 4

5 DATE Point #1 0.00%

Point #2 25.00%

Point #3 50.00 % ;

6d usted As Found AlscJ Dsted 6

As Found As Left instrument As Found As [xft Adiusted As Found As left l

7 FY-RC01A1 8

3/22/90 3/22/90

-0.001 0

y 2.4%

2.492 y

5 4.988 y

9 5/25/90

$/25/90 0

0 n

2.492 2A92 n

4.988 4.988 n

10 9/11/91 9/11/91 0.003 0.003 n

2.497 2.497 m

4.997 4.997 n

11 3/16/93 3/16/93 0

0 n

2.492 2.4 92 n

4.994 4.994 n

12 FY-RC01B1 13 3/22/90 3/22/90 0.003 0.003 n'

2.504 2.504 n'

5.007 5.007 n'

14 5/24/90 5/24/90 0.003 0.002 y

2.506 2.498 y

5UT 4.997 y

15 5/26/90 5/26/90

-0.001

-0.001 n

2.497 2.497 n

4.996 4.996 n

16 9/12/91 9/12/91 Ogl 0.001 n

2.501 2.501 n

5.001 5.001 n

17 3/18/93 3/18/93

.9

-0.002 n

2A98 2A98 n

4.998 4.998 n

18 FY-KC01 A2 19 3/9/90 3/9/90 0

0 n*

24%

2A%

n' 4.9%

4.996 n'

20 6/1/90 6/1/90 0

0 n

2A96 24%

n 4.996 4.996 n

21 9/17/91 9/17/91

-0.005

-0.005 a

2A97 2A97 n

4.997 4.997 n

22 3/15/93 3/15/93 0.0008 0.0008 n

2A962 2.4%2 n

4.9968 4.9968 a

23 FY-RC01B2 24 10/15/88 10/15/88 0.008 0

y 2.51 2A95 y

5.015 4.993 y

25 3/10/90 3/10/90 0.001 0.001 n

2A98 2A98 a

4.998 4.998 n

26 6/1/90 6/1/90 0.001-0.001 a

2A99 2A99 n

4.998 4.998 n

27 9/13/91 9/13/91 0.002 0.002 n

2A99 2A99 n

5 5

n 28 3/18/93 3/18/93 0.002 0.002 n

2A99 2A99 m

5 5

n 29 10/11/94 10/11/94 0.002 0

y 2.5 2.496 y

5.001 4.994 y

30 FY-RC01A3 31 3/28/90 378/90 0.001 0.001 n'

2 499 2.499 n'

4.997 4.997 n'

32 5/24/90 5/24/90 0

0 a

2A96 2A96 n

4.995 4.995 n

33 9/18/91 9/18/91 0

0 n

2 497 2A97 n

4.999 4.999 a

34 3/16/93 3/16/93 0

0 n

2.501 2.501 n

5 5

n 35 FY RColB3 36 3/28/90 308/90

-0 002

-0.002 n'

2A96 2A96 n*

4.994 4.994 n'

37 5/24/90 5/24/90 0

0 a

2A96 2A96 n

4.995 4.995 n

38 9/16/91 9/16/91

-0.001

-0.001 a

2A97 2A97 n

4.998 4.998 a

39 3/17/93 3/17/93

-0.001

-0.001 o

2.496 2A96 n

4.996 4.996 n

40 FY-RC01A4 41 3/30/90 3/30/90

-0.001

-0.001 n'

2A94 2 494 n'

4.992 4.992 n'

42 5/28/90 5/28/90

-0.002

-0.002 n

2 493 2A93 n

4.991 4.991 n

43 9/17/91 9/17/91

-0.005 0

y 2.489 2 497 y

4.988 4.997 y

44 3/1$/93 3/15/93 0.003 0.003 n

2.503 2.503 n

5.004 5.004 n

45 FY-RColB4 46 3/30/90 3/30/90 0

0 n'

2 495 2.495 n'

4.994 4.994 n'

47 5/28/90 5/28/90 0

0 n

2 496 2A96 n

4.994 4.994 n

48 9/14/91 9/14/91

-0.001

-0.001 n

2 492 2A92 n

4.992 4.992 n

49 3/17/93 3/17/93 0

0 n

24?5 2A95 n

4 993 4.993 n

50 51 n* andscates no adjustment was snade, 52 but the test is used as a *last ad ustment' i

53 potat for calculanon purposes

Attachmint 14 (cont.)

A I

B 1

C l

V l

W X

1 Y

I 4

AA I

AB l

AC AD 1

2 3

instrument Span:

10 4

d DATE Point #4 75.00 %

Point #5 100.00 %

Point 86 75.00 %

As Found As_pf instrument As Found As left A_d_tu_s_te_d As Found As 1.2ft Adiusted As Found As left Ad tusted

't FY-RC01A1 8

3/22/90 3/22/90 7.51 7A92 y

10.026 10 y

7.511 7A92 y

9 5/25/90 5/25/90 7A91 7.491 n

9.999 9.999 n

7A92 7.492 n

10 9/I1/9I 9/II/91 7.503 7.503 n

10.009 10.009 n

7.501 7.501 n

11 3/16/93 3/16/93 7A98 7A98 n

10.008 10.008 n

7A98 7.498 n

Y FY-RC01B1 13 3/22/90 3/22/90 7.511 7.511 n'

10.013 10.013 n'

7.512 7.512 n'

14 5/24/90 5/24/90 7.514 7.5 y

10.025 10 y

7.5T4 7A98 y

15 5/26/90 5/26/90 7A98 7A98 n

9.996 9.996 n

7A93 7.498 n

16 9/12/91 9/12/91 7.503 7.503 n

10.007 10.007 n

7.503 7.503 n

17 3/18/93 3/18/93 7A99 7A99 n

10 10 n

7.5 7.5 n

18 FY RC01A2 19 3/9/90 3/9/90 7A98 7A98 n*

10.004 10.004 n'

7A99 7A99 n'

20 6/1/90 6/1/90 7.5 7.5 n

10.005 10.005 n

7.5 7.5 n

21 9/17/91 9/17/91 7.503 7.503 n

10.008 10.008 n

7.503 7.503 n

22 3/15/93 3/15/93 7.4994 7A994 n

10.0094 10.0094 n

7.5008 7.5008 a

23 FY-RCO1B2 24 10/15/88 10/15/88 7.522 7A96 y

10.03 10 y

7.524 7.508 y

25 3/10/90 3/10/90 7.502 7.502 a

10.01 10.01 n

7.502 7.502 n

26 6/1/90 6/1/90 7.502 -

7.502 n

10.007 10.007 n

7.502 7.502 n

27 9/I3/9I 9/13/91 7.504 7.504 n

10.01 10.01 n

7.504 7.504 n

28 3/18/93 3/18/93 7.503 7.503 a

10.0I i0.01 n

7.502 7.502 n

29 10/11/94 10/11/94 7.504 7A96 y

10.011 10 y

7.505 7A96 y

30 FY-RC01A3 31 3/28/90 3/2&/90 7.503 7.503 n'

10.009 10.009 n'

7.504 7.504 n'

32

$/24/90

$/24/90 7A98 7A98 n

10.002 10.002 n

7.497 7A97 n

33 9/18/91 9/18/91 7.503 7.503 n

10.009 10.009 n

7.504 7.504 n

34 3/16/93 3/16/93 7.504 7.504 n

10.012 10.012 n

7.505 7.505 n

35 FY-RColB3 36 3/28/90 3/28/90 7A99 7A99 n*

10.006 10.006 n'

7A99 7A99 n'

37 5/24/90 5/24/90 7A99 7.499 n

10.003 10.003 n

7A97 7A97 n

38 9/16/91 9/16/91 7.503 7.503 n

10.012 10.012 n

7.504 7.504 n

1 f

39 3/17/93 3/17/93 7.503 7.503 a

10.007 10.007 n

7.503 7.503 a

40 FY-RCX)l A4 41 3/30/90 3/30/90 7A91 7A91 n'

9.992 9.992 n'

7.492 7A92 n'

42 5/28/90 5/28/90 7A91 7A91 a

9.991 9.991 n

7 A91 7A91 n

43 9/17/91 9/17/91 7 485 7A98 y

9.987 9.999 y

7A87 7A98 y

44 3/15/93 3/15/93 7.507 7.507 n

10.009 10.009 n

7.507 7.507 n

l 45 FY-RColb4 46 3/30/90 3/30/90 7A95 7A95 n'

9.999 9.999 n'

7A96 7.496 n'

j 47 5/28/90 5/28/90 7A95 7 495 n

9.998 9.998 n

7 495 7A95 n

I l

48 9/14/91 9/14/91 7 492 7 492 n

9.994 9.994 n

7A92 7A92 n

49 3/17/93 3/17/93 7A94 7A94 n

9.997 9.997 n

7.494 7A94 n

50 i

51 n+ andicates no adjustment was made, i

52 but the test ts used as a 'last adjustment' l

53 point for calculataon purposes I

i l

Attachm:nt 14 (cont.)

A B

I C

AE j

AF AG I

All Al I AJ j

AK AL AM i

2 3

Instrument Span:

10 4

5 DATE Point #7 50.00 %

Point #8 25.00 %

Point 89 0.00 %

6 As Found As Left Lnspument As Found As Left Musted As Found As Left Adiusted As Found As i. eft Ad!usted 7

FY-RC01A1 s

3/22/90 3/22/90 5.001 4.989 y

2.497 2.492 y

-0.001 0

y 9

5/25/90 5/25/90 4.989 4.989 n

2.493 2.493 n

0 0

n 10 9/11/91 9/11/91 4.997 4.997 n

2.497 2.497 n

0.003 0.003 n

11 3/16/93 3/16/93 4.994 4.994 n

2.494 2.494 n

0 0

n 12 FY-RC0181 13 3/22/90 3/22/90 5.008

$.008 n'

2.505 2.505 n'

O.003 0.003 n'

14 5/24/90 5/24/90 5.01 4.999 y

2.506 2.498 y

0.003-

-0.001 y

15 5/26/90 5/26/90 4.997 4.997 n

2.497 2.497 n

-0.001

-0.001 n

16 9/12/91 9/12/91 5.001 5.001 n

2.501 2.501 n

0.001 0.001 n

17 3/18/93 3/18S3 5

5 m

2.49b 2.498 n

-0.001

-0.001 n

18 FY-RC01 A2 19 3/9/90 3/9/90 4.995 4.995 n*

2.496 2.4%

n*

O O

n' 20 6/1/90 6/1/90 4.996 4.996 n

2.4%

2.496 n

0 0

n i

21 9/17/91 9/17/91 4.999 4.999 n

2.498 2.498 n

0 0

a 22 3/15/93 3/15/93 4.9981 4.9981 n

2.4983 2.4983 n

0.0005 0.0005 n

23 FY-RC01B2 24 10/15/88 10/15/88 5.013 4.994 y

2.508 2.495 y

0.007 0.001 y

25 3/10/90 3/10/90 5.003 5.003 n

2.502 2.502 n

0.002 0.002 n

26 6/1/90 6/1/90 4.999 -

4.999 n

2.499 2.499 n

0.002 0.002 a

27 9/13/91 9/13/91 5.002 5.002 n

2.502 2.502 n

0.003 0.003 n

28 3/18/93 3/18/93 5

5 n

2.5 2.5 n

0.001 0.001 n

29 10/11/94 10/11/94 5.001 4.994 y

2.501 2.496 y

0.002 0

y 30 FY-RC01A3 31 3/28/90 3/28/90 4.998 4.998 n'

2.499 2.499 n'

O O

n*

32 5/24/90 5/24/90 4.994 4.994 n

2.4%

2.496 n

0 0

a 33 9/18/91 9/18/91 4.999 4.999 n

2.498 2.498 n

-0.002

-0.002 a

34 3/16/93 3/16/93 4.999 4.999 n

2.499 2.499 n

0 0

n 35 FY-RColB3 36 3/28/90 3/28S0 4.994 4.994 n'

2.4%

n' 0,001

-0.001 n'

I 37 5/24/90 5/24/90 4.994 4.994 n

2.4%

2.496 n

0 0

n 38 9/16/91 9/16/91 4.999 4.999 n

2.498 2.498 n

0 0

n 39 3/17/93 3/17/93 4.997 4.997 a

2.496 2.496 n

-0.001

-0.001 n

40 FY-RC01A4 41 3/30/90 3/30/90 4.993 4.993 n'

2.494 2.494 n'

-0.001

-0.001 n'

42 5/28/90 5/28/90 4.992 4.992 n

2.494 2.494 n

-0.002

-0.002 n

43 9/17/91 9/17/91 4.989 4 997 y

2.491 2.498 y

-0.004 0

y 44 3/15/93 3/I5/93 5.004 5.004 n

2.503 2.503 n

0.003 0.003 n

45 FY-RColB4 46 3/30/90 3/30/90 4.995 4.995 n'

2.496 2.496 n'

O O

n' 47 5/28/90 5/28/90 4.994 4.994 n

2.496 2.4%

n 0

0 n

48 9/14/91 9/14/91 4.992 4.992 n

2.493 2.493 n

-0.002

-0.002 n

49 3/17/93 3/17/93 4.993 4.993 a

2.495 2.495 n

0 0

n 50 51 n* andicates no adlustment was made, 52 but the test is used as a 'last adjustment' 53 point for calculation purposes 4 (cont.)

AQ I AR AS l AT I AU l AV i

A l

B l

C l

AN l AO l AP l

i 1

Months Smce Last Test 3

3 Instrument Span-10 4

5 DAlli 6

As Found as left instrument Pomt # 1 Pomt #2 Pomt #3 Pomt #4 Pomt # 5 Point #6 Pomt #7 P_oint #8 Poin_tf.9 7

W-RC01A1 8

3/22/90 3/22/90 9

5/25/90 5/25/90 2.103 2.103 2.103 2.103 2.103 2.103 2.103 2.103 2.103 10 9/I1/91 9/11/91 15.573 15.573 15.573 15.573 15.573 15.573 15.573 15.573 15.573 11 3/16/93 3/16/93 18.136 18.136 18.136 18.136 18.136 18.136 18.136 18.136 18.136 12 W RC01B1 13 3/22/90 3/22/90 14 5/24/90 5/24/90 2.070 2.070 2.070 2.070 2.070 2.070 2.070 2.070 2.070 15 5/26/90 5/26/90 0.066 0.066 0.066 0.066 0.066 0.066 0.066 0.066 0.066 16 9/12/91 9/12/91 15.573 15.573 15.573 15.573 15.573 15.573 15.573 15.573 15.573 17 3/18/93 3/18/93 18.168 18.168 18.168 18.168 18,168 18.168 18.168 18.168 18.168 18 W-RC01A2 1

E 3/9/90 3/9/90

~

6/1/90 6/1/90 2.760 2.760 2.760 2.760 2.760 2.760 2.760 2.760 2.760 33 21 9/17/91 9/17/91 15.540 15.540 15.540 15.540 15.540 15.540 15.540 15.540 15.540 22 3/15/93 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.906 23 W-RC01B2 24 10/15/88 10/15/88 25 3/10/90 3/10/90 16.789 16.789 16.789 16.789 16.789 16.789 16.789 16.789 16.789 26 6/1/90 6/1/90 2.727 2.727 2.727 2.727 2.727 2.727 2.727 2.727 2.727 37 9/13/91 9/13/91 15.409 15.409 15.409 15.409 15.409 15.409 15.409 15.409 15.409 28 3/18/93 3/18/93 18.136 18.136 18.136 18.136 18.136 18.136 18.136 18.136 18.136 29 10/11/94 10/11/94 18.793 18.793 18.793 18.793 18.793 18.793 18.793 18.793 18.793 30 W-RC01A3 31 3/28/90 3/28/90 32 5/24/90 5/24/90 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 33 9/18/91 9/18/91 15.836 15.836 15.836 15.836 15.836 15.836 15.836 15.836 15.836 34 3/16/93 3/16/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.906 35 W-RColB3 36 3/28/90 3/28/90 37 5/24/90 5/24/90 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 38 9/i6/91 9/16/91 15.770 15.770 15.770 15.770 15.770 15.770 15.770 15.770 15.770 39 3/17/93 3/17/93 18.004 18.004 18.004 18.004 18.004 18.004 18.004 18.004 18.004 40 W-RC01A4 41 3/30/90 3/30/90 42 5/28/90 5/28/90 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 43 9/17/91 9/17/91 15m671 15.671 15.671 15.671 15.671 15.671 15.671 15.671 15.671 44 3/15/93 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.9 M i7.906 45 W-RC01B4 46 3/30/90 3/30/90 47 5/28/90 5/28/90 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 48 9/14/91 9/14/91 15.573 15.573 15.573 15.573 15.573 15.573 15.573 15.573 15.573 49 3/17/93 3/17/93 18.070 18.070 18.070 18.070 18.070 18.070 18.070 18.070 18.070 50

Attadsnent 14 (conL)

EX L BY BZ u

CA l CB [ CC CD CL CF 1 CG l CH Cl i

1 Percent Dnft Srnce Imt Test 2

(One Suted buarval) 3 hstrurnant Spen:

10 4

6 DATE 6

As Emmd As left lnstrurnent Pomt #1 Pomt #2 Pomt #1 Pomt 84 Pomt #5 Pomt e6 Pomt #7 Pomt#8 Pomt#9 7

W.RC01 A1 6

342/90 1/22SO 9

5/2560 5/25/90 0.0000 0.0000 0.0000

-0.0100

-0.0100 0.0000 0.0000 0.0100 0.0000 80 9/1141 9/11/91 0.0300 0.0500 0.0900 0.1200 0.!000 0.0900 0.0400 0.0400 0.0300 at Vip 3 W16S3 0.0300 4 0500 40300 0.0500 40100 40300 4 0300 40300 0.0300 12 W.RColB1 L3 3/22SO 3/2260 le 5/24SO 5/24/90 0.0000 0.0200 0.0300 0.0300 0.1200 0.0200 0.0200 0.0100 0.0000 15 5/2mo 5/2mo 0.0300 0.0100 0.0100 40200 0.0400 0.0000 0.0200 0.0100 0.0000 to 9/12SI 9/12/91 0 0200 0.0400 0.0500 0h500 0.1100 0.0500 0.0400 0.0400 0.0200 37 3/it/93 3/1863

-0.0300

-0.0300 0.0300 40400 0.0700 0.0300

-04100 0.0300 4 0200 18 W4C01A2 19 3S/90 MSO 20

&lSO

&l/90 0.0000 0.0000 0.0000 0.0200 0.0100 0.0100 0.0100 0.0000 0.0000 28 9/17SI 9/17SI 0.0500 0.0100 0.0100 0.0300 0.0300 0.0300 0.0300 0.0200 0 0000 22 3/15N3 3/15N3 0.0580 0.0030 A0020 4 0360 0A140 0.0220 4 0090 0.0030 0.0050 23 W-RColB2 24 10/1544 10/15/58 2$

WiMO WlO90 0.0:00 0.0300 0.0500 0.0600 0.1000 4 0600 0.09(x) 0.0700 0.0100 26

&l/90

&nSO 0.0000 0.0100 0.0000 0.0000 40300 0.0000 0.0400 0.0300 0.0000 i

21 9/13/91 9/1361 0.0100 0.0000 0.0200 0.0200 0.0300 0.0200 0.0300 0.0300 0.0100 2a W18/93 3/18/93 0.0000 t,/1000 0.0000 0.0400 nnmn

-0.0200 0.0200 0.0200 40200 29 10/llS4 10/11/94 0.0000 0.0 %

0.0100 0.0100 0.0100 0.0300 0.0100 0.0100 0.0100 30 W-RColA3 At 3/28So 3/21/90 32 5/2490 5/24SO 0.0100 4 0300 0.0200

-0.05c0 4.0700 0.0700

-0.0400 4 0300 0.0000 i

33 9/14Si 9/last 0.0u00 0.0100 0.0400 0.0500 0.0100 0.0700 0.0500 0.0200 0.0200 34 3/iM3 1/1MJ 0.0000 0.0400 0.0100 0.0100 0.0300 0.0100 0.0000 0.0100 0.0200 36 W-RColB3 36 3J21SO 3/28 S 0 37 5/2490 5/2490 0.0200 0.0000 0.0100 0.0000 0.0300 4 0200 0.0000 0.0000 0.0100 as 9/lM1 9/IMI 0.0100 0.0100 0.0300 0.0400 0.0900 0.0700 0.0500 0.0200 0.0000 39 Fl?/93 Y17.93 0.0000 0.01(X)

-0 5200 0.0txX) 0.0500

-0.0100 4 0200 40200 0.0100 40 WAC01A4 di 3/3MO 3/3090 42 5/2L90 5/2L90 04l00

-0.0100 0.0100 0.0000

-0.0100 0.0100 0.0100 0.0000 0.0100 43 9/17sl W17&l 4 0300 0.0400 0.0300 4 0600 0.0400 4 0400 0.0300 0 0300 0 0200 44 V15/93 FliM 0.0300 0.0600 0.0700 0.0900 (L1000 0.0900 0.0hA) 0.0500 0.0300 45 W RColb4 de Y3e90 3/JQNO 47 5/2L90 5/2L90 0.0000 0.0100 0.00t10 0.0000 04100 4 0100

-0.0100 0.0000 0.0000 48 9/1491 9/1491 0.0100 4 0400 0.0200 0.0300 4 0400 4 0300 40200 0.0300

-0.0200 49 3/17/93 Fl?S3 0.0100 0.0.kX) 0.0100 0.0200 0.0300 0.0200 0.0100 0.0200 0.0200 50 St 52 L3 Mean 40ul 0.0u4 0.010 0.009 0.016 0.006 0.009 0.005 0.001 54 Estd 0.022 0.027 0.030 0.042 0.057 0.042 0.036 0.027 0.016 65 Count 27 27 27 27 27 27 27 27 27 64 a tans s 6sd) 2.26 2.26 2.26 2.26 2.26 2.26 2.26 2.26 2.26 i

51 k*s 0.050 0.062 0.069 0.096 0.130 0.094 0.081 0.061 0.036

$4 95/95 Man 0 049 0.006 0.07 0.105 0.146 0.100 0.090 0.066 0.036 59 7

61 Ouoner Analysts 62 T

2.66 2.66 2.66 2.66 2.66 2.66 2.66 2.66 2.66 63 m.Ts 4 060

.0 069 0.071 4 104 0.137 0.105 4 087 4 068 0.042 64 x+Ts 0.058 CET7 0.090 0.122 0.169 0.111 0.104 0.077 0.043 65 Ouourn 0

0 0

64 Meun 4 001 0 004 0 010 0.009 0.016 0.006 0.009 0.005 0.001 67 haui 0 022 0 027 0.0 n0 0.042 0.057 0.042 0.036 0.027 0.016 6a Cumt 27 27 27 27 27 27 27 27 27 69 k (ane maded) 2.26 2J6 2.26 2.26 2.26 2.26 2.26 2.26 2.26 70 k*:

0 050 0.062 0.069 0.096 0.130 0.094 0.081 0.061 0.036 71 91S$ Msx 0 049 0 066 0.078 0.105 0.146 0.100 0.090 0.066 0.036 72 i

I I

j l

Attaclanent 14 (cont.)

l l

l 1

A 1

B C

BF l BG l BH B1 i

ILI BK I BL BM BN I

Months Since Last Adjustment 2

3 Instmment Span-10 4

5 DATE 6

As Found As Left instrument Point #1 Pomt #2 Eoult_#J Egint #4 Point #5 Pomt #6 Pomt #7 Point #8 Point #9 7

W-RC01A1

^

8 3/22/90 3/22/90 9

5/25/90 5/25/90 2.103 2.103 2.103 2.103 2.103 2.103 2.103 2.103 2.103 10 9/11/91 9/11/91 17.676 17.676 17.676 17.676 17.676 17.676 17.676 17.676 17.676 11 3/16/9) 3/16/93 35.811 35.811 35.811 35.811 35.811 35.811 35.811 35.811 35.811 j

12 W-RC01B1 13 3/2200 3/22/90 l

14 5/24/90 5/24/90 2.070 2.070 2.070 2.070 2.070 2.070 2.070 2.070 2.070 3

15 5/26/90 5/26/90 0.066 0.066 0.066 0.066 0.066 0.066 0.066 0.066 0.066 4

16 9/12/91 9/12/91 15.639 15.639 15.639 15.639 15.639 15.639 15.639 15.639 15.639 17 3/18/93 3/18/93 33.807 33.807 33.807 33.807 33.807 33.807 33.807 33.807 33.807 18 W-RC01A2 19 3/9/90 3/9/90 20 6/1/90 6/1/90 2.760 2.760 2.760 2.760 2.760 2.760 2.760 2.760 2.760 I

21 9/17/91 9/17/91 18.300 18.300 18.300 18.300 18.300 18.300 18.300 18.300 18.300 22 3/15/93 3/15/93 36.205 36.205 36.205 36.205 36.205 36.205 36.205 36.205 36.205 23 W RC01B2 24 10/15/88 10/15/88 25 3/10/90 3/10/90 16.789 16.789 16,789 16.789 16.789 16.789 16.789 16.789 16.789 j

26 6/1/90 6/1/90 19.515 19.515 19.515 19.515 19.515 19.515 19.515 19.515 19.515 l

27 9/13/91 9/13/91 34.924 34.924 34.924 34.924 34.924 34.924 34.924 34.924 34.924 28 3/18/93 3/18/93 53.060 53.060 53.060 53.060 53.060 53.060 53.060 53.060 53.060 29 10/11/94 10/11/94 71.852 71.852 71.852 71.852 71.852 71.852 71.852 71.852 71.852 30 W-RC01A3 31 3/28/90 3/28/90 32 5/24/90 5/24/90 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 33 9/18/91 9/18/91 17.708 17.708 17.708 17.708 17.708 17.708 17.708 17.708 17.708 i

34 3/16/93 3/16/93 35.614 35.614 35.614 35.614 35.614 35.614 35.614 35.614 35.614 35 W-RC01B3 36 3/28/90 3/28/90 37 5/24/90 5/24/90 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 1.873 4

l 38 9/16/91 9/16/91 17.643 17.643 17.643 17.643 17.643 17.643 17.643 17.643 17.643 39 3/17/93 3/17/93 35.647 35.647 35.647 35.647 35.647 35.647 35.647 35.647 35.647 i

40 W RC01A4 41 3/30/90 3/30/90 43 5/2h/90. 5/28/90 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 4

43 9/17/9 I 9/17/91 17.610 17.610 17.610 17.610 17.610 17.610 17.610 17.610 17.610 44 3/15/93' 3/15/93 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.906 17.906 45 W-RColB4 4

46 3/30/90 3/30/90 47 5/28/90 5/28/9u 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 1.938 48 9/14/91 9/14/91 17.511 17.511 17.511 17.511 17.511 17.511 17.511 17.511 17.511 49 3/17/93 3/17/93 35.581 35.581 35.581 35.581 35.581 35.581 35.581 35.581 35.581 50

.* 4 (cont.)

B C

I BO l BP l BQ BR BS I

BT l 3U BV i

BW A

i 1

Percent Drift Since last Adjustment 2

3 lastrument Span:

10 4

5 DATE 6 As Found As Left instrument Point #1 Point #2 Point #3 Point #4 Roig #5 Point #6 Point #7 Point *8 Poin1#.9 7

FY-RC01Al 8

3/22/90 3/22/90

'9

$/25/90 5/25/90 0.0000 0.0000 0.0000

-0.0100

-0.0100 0.0000 0.0000 0.0100 0.0000 10 9/11/91 9/11/91 0.0300 0.0500 0.0900 0.1100 0.0900 0.0900 0.0800 0.0500 0.0300 11 3/16/93 3/16/93 0.0000 0.0000 0.0600 0.0600 0.0800 0 0600 0.0500 0.0200 0.0000 12 FY RColBI 13 3/22/90 3/22/90 14 5/24/90 5/24/90 0.0000 0.0200 0.0300 0.0300 0.1200 0.0200 0.0200 0.0100 0.0000 15 5/26/90 5/26/90

-0.0300

-0.0100

-0.0200

-0.0400 0.0000

-0.0200

-0.0100 0.0000 16 9/12/91 9/12/91

-0.0100 0.0300 0.0400 0.0300 0.0700 0.0500 0.0200 0.0300 0.0200 17 3/18/93 3/18/93

-0.0400 0.0000 0.0100

-0.0100 0.0000 0.0200 0.0100 0.0000 0.0000 18 FY-RC01A2 19 3/9/90 3/9/90 20 6/1/90 6/1/90 0.0000 0.0000 0.0000 0.0200 0.0100 0.0100 0.0100 0.0000 0.0000 21 9/17/91 9/17/91

-0.0500 0.0100 0.0100 0.0500 0.0400 0.0400 0.0400 0.0200 0.0000 22 3/15/93 3/15/93 0.0080 0.0020 0.0080 0.0140 0.0540 0.0180 0.0310 0.0230 0.0050 23 FY-RColB2 24 10/15/88 10/15/88 25 3/10/90 3/10/90 0.0100 0.0300 0.0500 0.0600 0.1000

-0.0600 0.0900 0.0700 0.0100 26 6/1/90 6/1/90 0.0100 0.0400 0.0500 0.0600 0.0700

-0.0600 0.0500 0.0400 0.0100 27 9/13/91 9/13/91 0.0200 0.0400 0.0700 0.0800 0.1000

-0.0400 0.0800 0.0700 0.0200 28 3/18/93 3/18/93 0.0200 0.0400 0.0700 0.0700 0.1000

-0.0600 0.0600 0.0500 0.0000 29 10/11/94 10/11/94 0.0200 0.0500 0.0800 0.0800 0.1100

-0.0300 0.0700 0.0600 0.0100 F FY-RC01A3 30 31 3/28/90 3/28/90 32 5/24/90 5/24/90

-0.0100

-0.0300

-0.0200

-0.0500

-0.0700 EFJO

-0.0400

-0.0300 0.0000 33 9/18/91 9/18/91

-0.0100

-0.0200 0.0200 0.0000 0.0000 6 ~X)0 0.0100

-0.0100

-0.0200 34 3/16/93 3/16/93

-0.0100 0.0200 0.0300 0.0100 0.0300 0.c 00 0.0100 0.0000 0.0000 35 FY-RCO1B3 36 3/28/90 3/28/90 37 5/24/90 5/24/90 0.0200 0.0000 0.0100 0.0000

-0.0300

-0.0200, 0.0000 0.0000 0.0100 38 9/16/91 9/16/91 0.0100 0.0100 0.0400 0.0400 0.0600 0.05001 0.0500 0.0200 0.0100 39 3/17/93 3/17/93 0.0100 0.0000 0.0200 0.0400 0.0100 0.0400 0.0300 0.0000 0.0000 40 FY-RColA4 41 3/30/90 3/30/90 42 5/28/90 5/28/90

-0.0100

-0.0100 0.0000

-0.0100

-0.0100 0.0000 4.0100 43 9/17/91 9/17/91

-0.0400

-00500

-0.0400

-0.0600

-0.0500

-0.0400

-0.0300

-0.0300 44 3/15/93 3/15/93 0.0300 0.0600 0.0700 0.0900 0.1000 0.0900 0.0700 0.0500 0.0300 45 FY RC01B4 46 3/30/90 3/30/90 47 5/28/90 5/28/90 0 0000 0.0100 0.0000 0.0000

-0.0100

-0.0100 0.0000 0.0000 48 9/14/91 9/14/91

-0.0100

-0.0300

-0.0200

-0.0300

-0.0500

-0.0400

-0.0300

-0.0200 49 3/I7/93 3/17/93 0.0000 0 0000

-0.0100

-0.0200

-0 0200

-0.0100 0.0000 50

_ 5 FYRCI Al - B4 l

l l

W test for normality - FYRCI Al - B4 point #5 step #

4.2.2 S^2=

0.086 4.2.3 0.082954 1

0.1900 0.4366

=

0.054324 2

0.1800 0.3018

=

3 0.1500 0.2522 0.03783

=

0.030128 0.2152 4

0.1400

=

0.025872 0.1848 5

0.1400

=

0.020592 6

0.1300 0.1584

=

0.01346 0.1346 7

0.1000

=

0.006768 0.1128 8

0.0600

=

0.003692 0.0923 9

0.0400

=

0.002912 0.0728 10 0.0400

=

0.00216 0.0540 II 0.0400

=

0.000859 0.0358 12 0.0240

=

0.000178 0.0178 13 0.0100

=

0

=

14 0.0000 0

=

15 0.0000 0

=

16 0.0000 0

=

17 0.0000 0

=

18 0.0000 0

19 0.0000

=

0

=

20 0.0000 0

=

21 0.0000 0

=

22 0.0000 0

=

23 0.0000 0

=

24 0.0000 0

25 0.0000

=

b=

0.28173 4.2.4 b^2=

0.07937 I

W=b^2/S^2=

0.92486 (test statistic)

I W critical value 0.9230 The assumption of nonnaility is NOT rejected at the.05 level.

I I

. 6 I

1

(

i n

27 average 0.016 i

stdev 0.057 l

Bin Descriotion Upper Bound Fynected Observed 1

(-co,X-20)

-0.10 0.61 0

2 (X-20,X.6670)

-0.02 6.20 8

3 (X.6670,X+.6670) 0.05 13.37 12 4

(X+.667o,X+20) 0.13 6.20 7

5 (X+2o,+e) 9999.00 0.61 0

Verification of Normality - Bioning Method SExpected FYRCIAl-B4-Point #5 mobserved

~

14.00 12.00 lii j

~

2 10.00

~

g

]

A R.00 e

6.00 4.00 i

e e

i 2.00

~

0.00 <

If " 1 M

}

(-a.x-2a)

(X-2a.X-m7o)

(X-m7e.x+m7e)

(x+m7a.X+2a)

(x+2a,+ )

l

~

Bis Rasse l

i

_ _ _ _. 7 Drift v. Time Since Last Test FYRCIA1-B4 - All Points 0.140 0.120 0

0 0.I00 0

0 0

44 0

4 0 010 0

O e

ONO O

g i

y U.

0 040 00 0

1 e

$ 0.020 0 :

0

^^ 2 0:

el

]

l 0.000 00 0

^^ O j O O

44

%O

-0.020 0

=

f0

-0 040

^

4 ^

i O

O d$

-0.060 0

0 e

4

-0020 0

2 4

6 8

10 12 14 16 18 20 Ttne since Imt Test (Mantle)

08

^'.

0 0

07 06 0

0 0

0 05 tn e

)s m

h s

t t

a ts n

e ui M

jo

(

daP tn 8

l e

1 t l i

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aA t

ts n

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u e

0 j m

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hc n

t i

s a

SI aL t

k 1

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A eA 0

0 t

e mI 0

0 O

n iC i

T. Y s

R 0

0 0

en v

h F

t T

f irD 03 0

0 0

0 2

0

.O

.O =

0 0

. 0 0

O O

. 0 0

0 0

0

. 0 3

0 1

0 0

4 0 e:

0 0

4 2

1 8

6 4

2 0

2 4

6 8

1 1

0 0

4 yQ Nt$ sg

j l

1 9 l

l Binnine Matand - Pi a Dnft Months Months Count Mgan Sid

[0,3J

>0

+3 72 0.00 0.02 Months Mondia

[]5,20)

>l5

20 90 0.02 0 04 l

Months Meaths

[30,40)

>30

<=40 63 0.02 0.03 Drift v.Tiene Since Last adjustement FYRCIAI -B4 - All Points 0.14 0.12 4

0.1 4

ee 0.08 444 4 e

e e

0.06 eeed 4

30m e

e

ed

=

E e

04.

e io.02

=

u 43 0

0 e.e

<>e oe oe 4 02 ;

<>e 4m:

e e

eD 4M

-1 e

0 10 20 30 40 50 60 70 80 _

Timw Sance last A4estment(Meaths) r a

r r

s i

i j

i s

7

l LAR 96-0014 ATTACHMENT 3 FOR LICENSE AMENDMENT REQUEST NUMBER 96-0014 (11 pages follow) 4 i

1 1

1 i

LAR 96-0014 Attachm:nt 3 Page 1 Summarv of Instrument Drift Study Z.9.E Surveillance Recuirement 4.3.2.1.1, Table 4.3-2.

Functional Units 1.d and 1.e Reactor Coolant Pressure - Low (PT-RC2A3, PT-RC2A4, PT-RC2B3, PT-RC2B4)

The original Foxboro E11GH transmitters were replaced with Environmentally Qualified Foxboro NE11GH transmitters in May and June of 1986.

Since the new transmitter's internal parts are different than the old transmitter's, and since the new transmitter has a performance uncertainty larger than the replaced transmitter, 0.65% of calibrated span vice 0.5%, it was conserva-tively decided to use only string test data obtained since the new transmitters were installed.

In order to document occurrences of string component adjustments that were not otherwise captured, the monthly functional tests were reviewed for dates from May 1986 through October 1991.

Since provisions in these tests were removed in October 1991 for making adjustments without reliance on the calibration procedure, dates past October 1991 were not checked.

Appropriate data from review of other historical information was also considered in the drift study analysis (i.e. Maintenance Work Orders, System Performance Book Chronological Logs).

Review of the as-found data indicates that there have been no occurrences outside the present Technical specification Allowable Value.

A single sided tolerance factor was utilized for the basic statistics since the function of the bistable is to trip on decreasing RCS pressure.

During the initial run of the basic statistics and plotting of drift vs.

time for Time Dependence, a few outlier data points were identified as typographical errors of data entry and ere corrected on the data base.

A T-Test was then run on the Percent Drift Since Last Test data (vice Since Last Adjustment data) with no outliers identified. Later, after the Time Dependence evaluation, the T-Test was run on the 30/18 Month Point by Point Extrapolated data.

One data point for Channel I was identified as an outlier.

Initially, it was thought that the point was out due the Test to Test interval being only 1.8 months and the extrapolation over amplified its drift. However, further investigation showed that, uncharacteristically, the data was taken during Plant Startup at the con-clusion of a refueling outage.

It is believed that the elevated ambient temperatures significantly affected the test results.

The W Test was performed on the eight Percent Drift since Last Test data points.

Since the test passed, there was no reason to reject the assumption of normality.

- _ ~

. - - - - -. ~_.

LAR 96-0014 Attschmsnt 3 Page 2 A supplemental check of plotting the number of data points versus the number of standard deviations from the mean was performed. A comparison to a normal distribution indicates that the data is approximately normal and bounded by two standard deviations. The center peak for the data is j

slightly larger than normal. However, this is considered conservative for the assumption of normality.

From the above two checks, it was concluded that the assumption of normality was acceptable.

The Percent Drift Since Last Test was plotted against the Months Since Last Test.

There was one point sufficiently past the 18 month interval and it was visually obvious that it is substantially off of the mean of the other j

points, providing some evidence that drift may be time dependent.

It was i

also determined that the mean is a positive value, representing an earlier than expected bistable trip on decreasing RCS Pressure. This positive mean is therefore conservative for this low pressure trip function.

Additionally, the Percent Drift Since Last Adjustment was plotted against Months Since Last Adjustment. This plot provided two points sufficiently past the 18 month interval. The data points were then divided into two bins, for Time Since Last Adjustment above and below 22.5 months.

Statistics were calculated on each of the bins. Comparison of the two means reflected a conservative drift with time. Comparisons of the standard deviations indicated the random nature of the drift may decrease

{

with time, although the significance of the standard deviation value for the two points past 22.5 months is minimal. Also, since the majority of the eight available data points were at the refueling interval value of approximately 18 months, the adjustments interrupted what may have been poor data points over longer intervals. With this evidence, it cannot be assumed that this Low RCS Pressure Trip is not time dependent.

Without clear indication that the drift is independent of time, each data point, Percent Drift Since Last Test, was linearly extrapolated to 30 months. Basic statistics were calculated and the 95/95 Min value generated based on the mean, standard deviation, and tolerance interval.

The Max value was not calculated since a one-sided tolerance factor was utilized. Since the " bias" represented by the mean may not be present immediately after the calibration test is completed, it will, conservatively, not be taken credit for in the 30 month drift projection.

Therefore, the projected drift becomes just the tolerance factor times the standard deviation and converts to 38.453 psig of the 2500 psig range.

The 30 month extrapolated data was checked for normality by the W test.

Although the W Test failed by a small margin, the values fell within two standard deviations. Therefore, the assumption of normality for this 30 month extrapolated data was not rejected.

Toledo Edison Calculation C-ICE-48.01-002 Revision 4, "SFAS Reactor Coolant Pressure Actuation Setpoints," does not provide a calculational basis for the existing values for Technical Specification Trip Setpoints and Allowable values, but rather provides Trip setpoints and Allowable values calculated using the guidance of ISA S67.04 - 1988 and RP67.04 Part II.

LAR 96-0014 Attachm:nt 3 Page 3 Since specific uncertainty terms are available within this calculation, the value projected for the 30 month drift was compared to the values given in the calculation. The design basis / reference uncertainty was determined by the sum of the squares of the calculation uncertainties to be 27.857 psig.

Since the projected 30 month drift of 38.453 psig is larger than the design basis / reference uncertainty the calculation was revised and the Allowable Value changed as proposed by this LAR.

During implementation of this LAR, surveillance procedure changes will be made to reflect a new field setpoint, Allowable Value, and revised calibration method.

Confirmation that the conditions and assumptions of the setpoint analysis are reflected in the surveillance procedures will be performed as part of the LAR implementation process.

Reactor Coolant System Pressure - Low-Low (PT-RC2A3, PT-RC2A4, PT-RC2B3, PT-RC2B4)

The original Foxboro E11GH transmitters were replaced with Environmentally Qualified Foxboro NE11GH transmitters in May and June of 1986.

Since the new transmitter's internal parts are different than the old transmitter's, and since the new transmitter has a " performance uncertainty" larger than the replaced transmitter, 0.65% of calibrated span vice 0.5%, it was conservatively decided to use only string test data obtained since the new transmitters were installed.

In order to document occurrences of string component adjustments that were not otherwise captured, the monthly functional tests were reviewed for dates from May 1986 through October 1991.

Since provisions in these tests were removed in October 1991 for making adjustments without reliance on the calibration procedure, dates past October 1991 were not checked.

Appropriate data from review of other historical information was also considered in the drift study analysis (i.e. Maintenance Work Orders, System Performance Book Chronological Logs). Review of the as-found data indicates that there have been no occurrences outside the present Technical Specification Allowable value.

A single sided tolerance factor was utilized for the basic statistics since the function of the bistable is to trip on decreasing RCS pressure.

During the initial run of the basic statistics and plotting of drift vs.

time for Time Dependence a few outlier data points were identified as typographical errors of data entry and were corrected on the data base.

Due to these RCS Pressure Low-Low strings sharing several components with the RCS Pressure-Low strings whose Drift Study was completed prior to this study, the outliers that may have been found via outlier analysis for this string were already corrected by the time this string's basic statistics were calculated. Regardless, a T-Test was run on the Percent Drift Since Last Test data -(vice Since Last Adjustment data) with no outliers identified. Similarly, the T-Test was run on the 30/18 Month Point by Point Extrapolated data.

Again, no outliers were identified.

LAR 96-0014 Attcchm;nt 3 Page 4 The W Test was performed on the fourteen Percent Drift Since Last Test data points.

Since the test passed, there was no reason to reject the assumption of normality.

A supplemental check of plotting the number of data points versus the number of standard deviations from the mean was performed. The comparison to a normal distribution indicated that the data is approximately normal and, with the exception of one data point, bounded by two standard deviations. The exception data point was at 2.0546 standard deviations from the mean.

The center peak for the data is as close as possible with this limited set of data points. Overall, the plot of sample data appeared close to normal.

From the above two checks, it was concluded that the assumption of normality was acceptable.

The Percent Drift Since Last Test was plotted against the Months Since Last Test. Of the four points sufficiently past the 18 month interval, it was visually cbvious that two were substantially off of the mean of the other points, providing some evidence that drift may be time dependent.

It was also observed from the plot, as calculated in the basic statistics, that the mean is a positive value, representing an earlier than expected bistable trip on decreasing RCS Pressure. This positive mean is therefore conservative for the RCS Pressure Low-Low trip function.

Additionally, the Percent Drift Since Last Adjustment was plotted against Months Since Last Adjustment.

This plot provided seven points sufficiently past the 18 month interval. The data points were then divided into two bins, for Time Since Last Adjustment above and below 22.5 months.

Statistics were calculated on each of the bins.

Comparison of the two means reflected a conservative drift with time.

Comparisons of the two standard deviations indicated the random nature of the drift may increase with time.

Also, since half of the fourteen available data points were at the present refueling interval value of approximately 18 months, the adjustments interrupted what may have been poor data points over longer intervals. With this evidence, it cannot be assumed that the RCS Pressure Low-Low trip is time independent.

Without clear indication that the drift is independent of time, each data point (Percent Drift Since Last Test) was linearly extrapolated to 30 months.

Basic statistics were calculated and the 95/95 Min value generated based on the mean, standard deviation, and tolerance interval.

The Max was not calculated since a one-sided tolerance factor was utilized.

Since the " bias" represented by the mean may not be present immediately after the calibration test is completed, it will, conservatively, not be taken credit for in the 30 month drift projection. Therefore, the 30 month projected drift becomes just the tolerance factor times the standard deviation and converts to 31.698 psig of the 2500 psig range.

The 30 month extrapolated data was checked for normality. The W Test passed and the drift values fell within two standard deviations.

Therefore, the assumption of normality for this 30 month extrapolated data was not rejected.

___._.m_.______.._

_ ~ _ _ _.

_____....._.._m

.m_

'l j

LAR 96-0014 Attachmant 3 Encl sure 1

.Page 5 l

Calculation C-ICE-48.01-002 Revision 4,

" SEAS Reactor Coolant Pressure Actuation Setpoints," does not provide a calculational basis for the existing values for Technical Specification Trip Setpoints and Allowable i

values, but rather provides Trip Setpoints and Allowable values calculated using the guidance of ISA S67.04 1988 and RP67.04 Part II.

Since specific uncertainty terms are available within this calculation, the

{

30 month projected drift value was compared to the values given in the l

calculation. The design basis / reference uncertainty was determined by the i

sum of the squares of the calculation uncertainties to be 27 857 psig.

I t

Since the design basis / reference uncertainty of 27.857 psig, is less than the projected 30 month drift of 31.698 psig the calculation was revised and the Allowable Value changed as proposed in this LAR.

During implementation of this LAR, surveillance procedure changes will be made to reflect a new I

field setpoint, Allowable value, and revised calibration method.

j confirmation that the conditions and assumptions of the setpoint analysis i

are reflected in the surveillance procedures will be performed as part of the LAR implementation process, i

i l

~ _.

LAR 96-0014 Attechm:nt 3 Page 1 i

^

Summary of Instrument Drift Study

$91.

Surveillance Recuirement 4.3.2.1.1.

Table 4.3-2, j

Functional Units 5.a and 5.b.

and Surveillance Recuirement 4.5.2.d.1.a and 4.5.2.d.1.b l

1 SFAS RCS Pressure - Decav Heat Isolation Valve DH-11 and Pressurizer Heater a

I Interlocks (PT-RC2A3, PT-RC2B4)

The Safety Features Actuation System Decay Heat (DH) Isolation Valve and i

~

Pressurizer Heater Interlock Channel Functional Units consist of two similar instrument strings. The sole purpose of the bistable (BA113) associated with pressure transmitter PTRC2B4 in Safety Features Actuation System Channel 1 and one of the purposes of the bistable (BA413) associated 4

with pressure transmitter PTRC2A3 in Channel 4 is, on increasing Reactor j.

Coolant System pressure, to prevent DH system overpressurization by i

deenergizing pressurizer heaters if either DH Isolation valves (DH-11 and l

DH-12) are open. The second purpose of the bistable in Channel 4 is to 1

close DH Isolation valve DH-11 and keep it from opening above the Technical I

Specification trip setpoint to prevent DH system overpressurization. A third purpose of the bistable in Channel 4 is to allow opening of DH Isolation valve DH-11 on decreasing RCS Pressure (bistable trips).

Since there are four similar channels of Safety Features Actuation System i

Reactor Coolant System Pressure string data taken during calibrations and only two of the four channels are utilized for fulfillment of the DH Isolation Valve and Pressurizer Heater Interlock Functional Units, it was i

decided to select a bistable from each of the two remaining SFAS channels whose data could be used to increase the number of sample points and de-crease the projected 30 month drift value. The Safety Features Actuation System Reactor Coolant System Pressure Low Low Block Bistables, used to bypass the Low Low Trip function on a normal system depressurization, are 1

the same type (Consolidated Controls model 6N82; trip bistables are 6N81) as those used for the DH Isolation Valve and Pressurizer Heaters Interlock Bistables. The remaining components in the strings are also the same types between channels.

The increasing setting (reset point of the bistable) of the DH Isolation Valve and Pressurizer Heater Interlock bistables (BA113 and BA413) is 301 PSIG.

The increasing setting (reset point of the bistable) of the RCS Pressure Low Low Block bistables is 562 PSIG.

The percent difference between there two settings is 10.44%.

The DBNPS Instrument Drift Data Analysis Methodology and Assumptions document (DBNPS Methodology) created for the drift study program only describes how data may be shifted up (or down) by up to 10% of span.

Since it is assumed that drift amplitudes may

l LAR 96-0014 Attechm:nt 3 Page 2 increase but do not decrease at values further up in the instrument's span, utilizing the drift values for the Low Low Block bistables is conservative.

The original Foxboro E11GH transmitters were replaced with Environmentally Oualified Foxboro NE11GH transmitters in May and June of 1986.

Since the new transmitter's internal parts are different than the former transmitter's and the new transmitter has a performance uncertainty larger than the former transmitter, 0.65% of calibrated span vice 0.5%, it was conservatively decided to use only string test data obtained since the new transmitters were installed.

In order to document occurrences of string component adjustments that were not otherwise captured, the monthly functional tests, which until October 1991 allowed adjustments within the test as it was performed, were reviewed for the period May 1986 through October 1991.

Appropriate data from other sources (e.g. System Performance Book Chronological Log, Maintenance Work Orders) was also utilized. Review of as-found data indicates that there have been no occurrences outside the present Technical Specification Allowable value.

A single sided tolerance factor was utilized for the basic statistics since the safety function of the bistables is to reset and automatically close DH-11 or deenergize the pressurizer heaters on increaring RCS pressure. On decreasing pressure, the deadband of approximately 50 psig ensures compliance with the same limiting Technical Specification value. The safety function of preventing DH-11 from opening when RCS pressure is above the Technical Specification trip setpoint is assured since the valve can only open when RCS pressure is lower than the bistable's reset point minus the deadband (i.e., the bistable trips).

Due to these Interlock and Low Low Block strings sharing several components with the Low Pressure strings whose Drift Study was already completed, the outliers that may have been found via outlier analysis for this string were already corrected by the time this string's basic statistics wer s i

calculated. Regardless, a T-Test was run on the Percent Drift rince Last Test data (vice Since Last Adjustment data) with no outliers identified.

Similarly, the T-Test was run on the 30/18 Month Point by Point Extrapolated data.

Again, no outliers were identified.

The W Test was performed on the nine data points for Percent Drift Since 1

)

Lest Test.

Since the test passed, there was no reason to reject the l

assumption of normality.

]

A supplemental check was performed by plotting the number of data points versus the number of standard deviations from the mean. Comparison with a normal distribution indicated that the data is approximately normal and bounded by two standard deviations.

From the above two checks, it was concluded that the assumption of normality was acceptable.

The Percent Drift Since Last Test was plotted against the Months Since Last Test.

Only one point was sufficiently past the 18 month interval and it was substantially off of the mean of the other points, providing some evidence that drift may be time dependent.

It was also observed from the

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LAR 96-0014 Attachmsnt 3 Page 3 i

plot that the mean is a positive value, representing a later than expected bistable reset on increasing RCS Pressure. This is non-conservative for the Decay Heat (DH) Isolation Valve and Pressurizer Heaters Interlock function.

Additionally, the Percent Drif t Since last Adjustment was plotted against I

the Months Since Last Adjustment. This plot provided two points

]

sufficiently past the 18 month interval. The data points were then divided i

into two bins, for Time Since Last Adjustment above and below 22.5 months.

i Statistics were calculated on each of the bins. Comparison of the two 5

means indicates a nonconservative drift with time.

Comparisons of the two standard deviations indicates the random nature of the drift may increase with time. Also, since seven of the available data points were at the I

present refueling interval value of approximately 18 months, the j

adjustments interrupted what may have been poor data points over longer i

intervals. With this evidence, it cannot be assumed that this Decay Heat j

(DH) Isolation Valve and Pressurizer Heaters Interlock is independent of j

time.

1 Without clear indication that the drift is independent of time, each data point, Percent Drift Since Last Test, was linearly extrapolated to 30 months. Basic statistics were calculated and the 95/95 Max value generated based on the mean, standard deviation, and tolerance interval.

The Min was not calculated since a one-sided tolerance factor was utilized.

The 30 month projected drift of 51.280 psig of the 2500 psig range is the (non-conservative) mean added to the product of the tolerance factor and the standard deviation.

The 30 month extrapolated data was checked for normality. The W Test passed and the drift values fell within two standard deviations.

Therefore, the assumption of normality for this 30 month extrapolated data was not rejected.

The projected 30 month projected drift value of 51.280 psig was found to be slightly larger than the previously assumed design basis / reference uncertainty used in the previously existing setpoint documentation, 51.000 psig. Based on the 30 month projected drift value, and a reevaluation of the design basis for this function, as discussed in the body of this LAR, a new, lower Allowable Value was calculated within the setpoint analysis and is proposed in this LAR.

Operating margin was maintained between the field setpoint and the operating limit (minimum NPSH for the Reactor Coolant Pumps). During implementation of this LAR, surveillance procedure changes will be made to reflect a new Allowable Value and revised calibration method. Confirmation that the conditions and assumptions of the setpoint analysis are reflected in the surveillance procedures will be performed as part of the LAR implementation process.

Reactor Coolant Pressure - Decav Heat Isolation Valve DH-12 Interlock (PSHRC2B4)

The Decay Heat (DH) Isolation Valve DH-12 Interlock Function consists of one pressure switch (PSHRC2B4) supplying a contact to automatically close

LAR 96-0014 AttachmLnt 3 Page 4 DH Isolation valve DH-12 and keep it from opening above the Technical Specification trip setpoint to avoid overpressurizing the DH System.

Subsequently, during normal plant shutdowns (i.e., decreasing RCS pressure; switch resets), the switch supplies a permissive to allow manual opening of DH-12 in order to operate the DH system.

The original Static-O-Ring model 8V2 pressure switch was replaced with an environmentally qualified Static-O-Ring model 9TA via FCR 82-168 on November 21, 1984.

Since the new switch is sufficiently different than the old, it was conservatively decided to use only historical test data obtained since the new switch was installed a

From a review of the test data, it became evident that each refueling j

outage, the surveillance test is performed in addition to a Preventive Maintenance (PM) Maintenance Work Order (MWO) which adjusts the switch if necessary. Although exceptions exist, the normal practice is to perform the calibration (PM) just prior to the surveillance test (DB-SP-3130 or ST-5051.02).

Review of the as-found data indicates that there have been no occurrences outside the Technical Specification setpoint of <438 PSIG (approximately 418 PSIG at the pressure switch elevation).

A T-Test was run on the Drift Since Last Test data vice Drift Since Last Adjustment data with no outliers identified.

The W Test was performed on the sixteen Drift Since Last Test data points.

Since the test passed, there was no reason to reject the assumption of normality.

i A supplemental check was performed by plotting the number of data points versus the number of standard deviations from the mean.

Comparison to normal distribution indicated that the data is approximately normal and, except for one point, bounded by two standard deviations. The one data point that was outside was very close to being within the two standard deviation limit, Possible explanations for this potentially bad data point were explored (such as test method or M&TE), but none were found.

Therefore, the data point was conservatively included. Overall, the plot of sample data appeared close to normal.

From the above checks, it was concluded that the assumption of normality was acceptable.

Drift Since Last Test was plotted against the Months Singe Last Test.

A linear regression line was plotted on the data and the R value determined.

The data and linear regression clearly indicated that the drift tends to be more negative (resegpointdecreases) with increasing time since last test.

A relatively high R value reinforced this conclusion.

This trend is conservative since the switch will reset earlier than expected for the increasing RCS Pressure function. The mean, however, at short test to test intervals, is non-conservative for the Decay Heat Isolation Valve Interlock function.

l LAR 96-0014 Attachm:nt 3 page 5 Additionally, the Drift Since Last Adjustment was plotted against the Months Since Lgst Adjustment. A linear regression line was plotted on the data and the R value determined. The plot provided additional confidence to the decreasing trend discovered in the Drift vs. Time Since Last Test plot described above.

The Drift Since Last Adjustment data points were then divided into two bins, for times above and below 22.5 months. Statistics were calculated on each of the bins. Comparison of the two means reflects the decreasing drift with time. Comparisons of the two standard deviations indicated the random nature of the drift may be decreasing with time.

Also, since majority of the available data points were at or below the present refueling interval value of approximately 18 months, the adjustments interrupted what may have been more data points exhibiting the decreasing trend. With this evidence it can be assumed that this Decay Heat Isolation Valve Interlock is time dependent but in a conservative direction for Technical Specification purposes.

With clear indication that the drift is time denercsnt each data point, Drift Since Last Test, was linearly extrapolated to 30 months. Basic statistics were calculated and the 95/95 Max value was generated based on the mean, standard deviation, and tolerance interval. The Min was not calculated since a one-sided tolerance factor was utilized. The 95 Max value was extraordinarily large due to the extrapolation of fairly large data points which occurred at short intervals.

If a setpoint calculation used this 30 month extrapolated 95 Max value for representation of drift, the resulting setpoint would be outside the range of the instrument.

Therefore, this value was acusidered unreasonable and not used for projecting the 30 Month Drift.

From the Drift Since Last Test plot, the data points naturally fall into two groupings, those occurring before 6 months (short test-to-test intervals) and after 15 months (long test-to-test intervals). The short interval data has a clearly positive (or nonconservative for the increasing pressure reset point) mean and the long interval data has a clearly negative (or conservative) mean and is more tightly grouped than the short interval data.

Although deleting the short interval data might have been justified (since engineering judgment considers large As-Left minus As-Found values at short intervals to be mainly influenced by testing inconsistencies and not instrument drift) and the remaining long interval data extrapolated to 30 months ae described in the Instrument Drift Data Analysis Methodology and Assumptions document, this was not performed.

The reason for this is that extrapolation of all negative valued long interval data would have produced values even more negative, thus influencing the 95 Max in an overly nonconservative manner. Additionally, this 95 Max value would not be reflective of the nonconservative phenomena (which may be due to a repeatable characteristic in the pressure switch after calibration) seen in the short interval data.

Alternatively, since the trend of drift with increasing time was found to be more conservative for the increasing pressure resetpoint, using the 95 Max value (not projected to 30 months) was considered. This value was non-conservatively influenced by the decreasing mean as time increased but

.. ~.

LAR 96-0014 Attechm:nt 3 Page 6 conservativaly influenced by a large standard deviation due to the same decreasing mean as time increased. Therefore, it was decided to compare this 95 Max value for all test to test points to a 95 Max value generat ed using only the points of short test intervals (chosen at less than 6 months, since this appeared to be a natural bin of the data).

The highest value would then be used as the 30 Month Projected Drift. The basic statistics were calculated on the short test interval points and the 95 Max value of this short data was determined to be 19.194 psig. This value was utilized as the 30 Month Projected Drift value.

The projected 30 month projected drif t value of 19.194 psig was found to be smaller than the design basis / reference uncertainty used in the previously existing setpoint documentation, 51.000 psig. Based on this, no changes to existing settings or analyses was necessary. However, since this interlock function for valve DH-12 shares Technical Specification wording for the trip setpoint (and proposed Allowable Value in place of the trip setpoint),

the value in the Technical Specifications is being changed for consistency with the SEAS RCS - Decay Heat Isolation Valve (DH-11) and Pressurizer Heaters Interlock Allowable Value described above. This proposed use of the Allowable Value derived from the SEAS RCS pressure channel uncertainties is conservative for this RCS pressure switch since the uncertainties for this RCS pressure switch are smaller. The assumptions in the present setpoint analysis, including the field setpoint, are presently reflected in the surveillance test.

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