ML20138J379

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Requests Withholding Proprietary Info from Public Disclosure (Ref 10CFR2.790)
ML20138J379
Person / Time
Site: Callaway Ameren icon.png
Issue date: 12/11/1985
From: Wiesemann R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
Shared Package
ML19276D023 List:
References
CAW-85-087, CAW-85-87, NUDOCS 8512170506
Download: ML20138J379 (83)


Text

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Nuclear Technology 0ivision 00$e Water Reactor WOStin@

Electric Corporation Divisions Box ass i

Pittsburgh Pennsylvania 15230 0355 December 11, 1985 CAW-85-087

! Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Connision

~ Washington, D.C. 20555 i

APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DIS 1 0SURE  :

Subject:

NRC Request for Additional Information on OFA Submittal

Reference:

Union Electric Company Letter, Schnell to Denton, Docket No. 50-483, November,1985

Dear Mr. Denton:

The proprietary material for which withholding is being requested in the reference letter by Union Electric Company is further identified in an '

affidavit signed by the owner of the proprietary information, Westinghouse Electric Corporation. . The affidavit, which accompanies this letter, sets forth i the basis on which the information may be withheld from public disclosure by I the Conmission and addresses with specificity the considerations listed in i

paragraph (b) (4) of 10CFR Section 2.790 of the Conrnission's regulations.

The proprietary material for which withholding is being required is of the same l technical type as that proprietary naterial previously submitted with Application for Withholding AW-76-60.

Accordingly, this letter authorizes the utilization of the accompanying affidavit by Union Electric Company.

Correspondence with respect to the proprietary aspects of the application for withholding or the Westinghouse affidavit should reference this letter, CAW-85-087, and should be addressed to the mdersigned.

Very truly yours, N

e p '/.egulatory R rt A. Wiesemann, Manager

& Legislative Affairs

/kar Enclosure (s) -

cc: E. C. Shoemaker, Esq.

Office of the Executive Legal Director, NRC >

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PROPRIETARY INFORMATION NOTICE l

l TRANSM:TTED HDEWITH ARE PROPRIETARY AND/OR NON-PROPRIETARY VERSIO  ;

DOCUMENTS MIRNISHED 70 THE NRC IN CONNECTION WITH REDUGTS FOR PLANT SPECIFIC REVIEW AND APPRWAL.

IN CEER 10 CONFORM 701HE RQUIREMENTS OF 10CTR2.790 & THE COMMISSIO RCULATIONS CONCERNING THE PROTECTION OF PROPRIETARY INFORMATIO 70 THE NRC,1HE INFORMATION WHICH IS PROPRIETARY IN 1HE PROPRIETARY VERSIONS IS CONTAIND WITHIN BRACKETS AND WHDE 1HE PROPR2TARY INFORMATION HAS BE '

  • DE.ETD IN W.E NON-PROPRIITARY VDSIONS GC.Y THE BRACKETS REMAIN, THE -

IhTORMATION THAT WAS CONTAING WITHIN THE BRACXETS IN THE PROPRIET ,

HAVIN3 BEIN DE.ETE. THE JUSTIFICATION FOR CLAIMING THE INFORMATION 30 t

DES:DNATED AS PROPRIETARY IS INDICATED IN BCTIH VERSIONS BY MEANS O ,

r LEITERS (a) THROUGH (g) CONTAINED WITHIN PARENTH5ES LOCATED AS A RJPERSCRIPT j,

j IMMEDIATELT PDLLOWING THE BRACKETS INCI.05ING EACH ITEM 0F INFORMATIO '

IDENTIFIED AS PROPRIETARY OR IN 1HE MARGIN OPPOSITI RJCH INFORMATION. T LWER CASE LETTDS REFER 10 THE TTPES OF INFORMATION WESTINGHOUSE CU '

HOLES IN CONFIDENCE IDENTIFIED IN SECTIONS (4)(11)(a) through (4)(11)(g) 0F THE AFFICAVIT ACCOMPANYING THIS TRANSMITTAL PURSUAhT 1010CFR2.790(b)(1).

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AW-76-60 AFFIDAVIT-COMM0!iWEALTH OF PENNSYLVANIA:

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COU!iTY OF ALLEGHEliY:

Before me, the undersigned authority, personally appeared Robert A. Wiesemann, who, being by me duly sworn according to law, de-I poses and says that he is authorized to execute this Affidavit on behalf of W'estinghouse Electric Corporation (" Westinghouse") and that the aver-ments of fact set forth in this Affidavit are true and correct to the best of his knowledge, information, and belief:'

L !KAfU '

- Robert A. Wiesemann, Manager Licens.ing Programs .

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Sworn to and subscribed '

before,methis/ day

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of /Wrdid 1976.

/ //d. M4 es .

/ Notary Public O

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AW-76-60 (1) I am Manager Licensing Programs, in the Pressurized Water Reactor Systems Division, of Wes'tinghouse Electric Corporation and as such,

,1 have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public dis-closure in connection with nuclear power plant licensing or rule-making proceedings, and am authorized to apply for its withholding bn behelf of the Westinghouse Water Reactor Divisions.

(2) , I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.790 of the Commission's regulations and in con-junction with the Westinghouse application for withholding ac- ~

companying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse Nuclear Energy Systems in designating information as a trade secret, privileged or as confidential comercial or financial information.

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

. withheld.'

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

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--- -- -- .. -. - - - - - y- ,.--,,-, e v,--.- .

AW-76-60 (ii) The information is of a type customarily held in confidence by Westinghouse and no't customarily disclosed to the public.

Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The ap-plication of that system and the substance of that system constitutes Westinghouse policy and provides the rational basis required. ,

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

(a) The information reveals the distinguishing aspects of a process (or component, stru:ture, tool, method, etc.)

where prevention of its use hy any of Westinghouse's competitors without license from Westinghouse constitutes

' a competitive economic advantage over other companies.

(b) . It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive econom'ic advantage, e.g., hy optimization or

-- improved marketability.

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AW-76-60

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

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

(e) It reveals aspects of past, present, or future West-inghouse or customer funded development plans and pro-grams of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent pro-tection may be desirable. .

(g) It is not the property of Westinghouse, but must be treated as proprietary hy Westinghouse according to agreements with the owner. '

. ~.

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

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

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- - - - - _ _ - _ - _ . - _ _ - _ . - , - . _ . , _ - _ - , _ _ __ , - . , , .,_.n_., . . , . . . - . - -- _ e , , _ . ,m-. - - - -

AW-75-60 (b) It is information which is marketable in many ways.

The extent to 'which nch infonnation is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information. .

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

(d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary infor-mation, any one component may be the. key to the entire

~

puzzle, thereby depriving Westinghouse of a conipetitive advantage.

(e) Unrestricted disclosure would jeopardize the pos.ition

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

. in those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success .

- in obtaining and maintaining a competitive advantage.

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AW-76-60 l l

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(iii) The information is being transmitted to the Commission in considence and, under the provisions of 10 CFR Section 2.790,  ;

it is to be received in confidence.by the Commission.

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

' (v) The proprietary information sought to be withheld in this sub-mittal is that which is appropriately marked in the attach-ment to Westinghouse letter number NS-CE-1298, Eiche1dinger to Stolz, dated December 1,1976, concerning information relating to NRC review of WCAP-8567-P and WCAP-8568 entitled, " Improved Thermal Design Procedure," defining the sensitivity of DNB ratio to various core parameters. The letter and attachment '

are being submitted in response to the NRC request at the October 29, 1976 NRC/ Westinghouse meeting.

This information enables Westinghouse to:

(a) Justify the Westinghouse design.

(b) ~ Assist its customers to obtain licenses.

(c) Meet warranties. ,

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

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

7 -- AW-76-60 l

(f) Optim'ize reactor design and performance while main'taining ,  !

a high level of fuel integrity.

Further, the infomation gained from the improved thermal design procedure is of significant comercial value as follows:

  • l

. (a) Westinghouse uses the information to perform and justify analyses which are sold to customers'. j

. (b) Westinghouse sells analysis services based upon the

-experience gained and the methods developed..

Public disclosure of this information concerning design pro-cedures is likely to cause substantial ham to the competitive position of Westinghouse because competitors could utilize this information to assess _and justify their own designs

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without commensurate expense.

Thir parametric analyses performed and their evaluation nipresent a considerable amount of highly qualified :fevelopment effort.

This work was contingent upon a design method development pro-gram which has been underway during the past two years.

Altogether, a' substantial amount of money and effort has been' expended by Westinghouse which could only be duplicated by a competitor if he were to invest similar sums of money and pro-

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vided he had the appropriate talent available.

Further. the deponent sayeth not.

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ENCL 0SURE 3 CHANGES TO CALLAWAY TECHNICAL SPECIFICATION BASES SECTION 2.1

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., 2.1 5AFETY LIMITS BASES 2.1.1 REACTOR CDRE The restrictions of this safety limit prevent overheating of tne fuel and possible cladding perforation which would result in the release

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of fission products to the reactor coolant. Overheating of the fuel cladding is prevented by restricting fuel operation to within the nucleate boiling regime dere the heat transfer coefficient is large and )

the cladding surface temperature is slightly above the coolant satura-tion temperature. 3 Operation above the upper boundary of the nucleate boiling regime cculd result in excessive cladding temperatures because of the onset of  ;

departure fran nucleate boiling (DN8) and the resultant sharp reduction in heat transfer coefficient. DN8 is not a directly measurable para-meter during operation and therefore THERMAL POWER and Reactor Coolant Temperature and Pressure have been related to DN8. This relation has been developed to predict the DN8 flux and the location of DNS for axi-ally uniform and non-uniform heat flux distributions. The local DNS heat flux ratio, DN8R, defined as the ratio of the heat flux that would cause-DNS at a particular core location to the local heat flux, is indi- I cative of the margiri to DNS. '

The DN8 design basis is as follows: there must be at least a 95 percent probability that the minimum DNBR of the limiting rod during

{ Condition I and II events is greater than or equal to the DNBR limit of ,

j the DNS correlation being used (the WRB-1 correlation in this applica- i tion). The correlation DNBR 1.imit is established based on the entire i

applicable experimental data set such that there is a 95 percent pro-bability with 95 percent confidence that DN8 will not occur d en the I 4 /cf j

r g f .jec -tSt. W C8 -i Co reg l Ah h8

  • minimum ADN8R D .TAISERT A&fE is at the DNBR limit (l,Av nest FSM c7nakse:d In meeting this design basi , nu(certainties in plant operating para- '

t meters, nuclear and themal p ameters, and fuel fabrication oarameters Ja9f#

are considered statistically such that. there is at least/p 952confidenceP that the minimum DN8R for the limiting rod is greater than or equal to thtfanald.4 W rx j DNBR limit. The uncertainties in the above plant parameters are used to detemine the plant DN8R uncertainty. This DN8R uncertainty, combined with the correlation DNBR limit, establishes a design DN8R value which must be met in plant safety analyses using values of input parameters 1

without uncertainties. For Oth , A ck, D 4 84. 4 W O tite. M f.1 2.

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  • 3 4 401- Thw %< ryJ,The curves cute , N or pointsFigure of 2.1-1 show oT THERitt.

the loci hw.L PDWER,-Reactor Coolant System pressure and average temperature below which the calculated DNBR is no less than th'e design DNBR value or the l

' average enthalpy at the vessel exit is less than the enthalpy of satu-  ! '

rated liquid.

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D ddddu n,f7ht /L t.a fun m cwn}Q.ustd. Lv U $fr <p-( dnt Wby a w SQ ctssMy L)N8g LU,els f dz *t

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INSERT A:

For the few anticipated transients where reactor conditions may b'#

fall outside the range of applicability for the WRB-1 Correlation, Ocick x the W-3 (" O..J', correlation is used. The correlation limit (cor- R-(rI'd/

responding to a 95% probability at a 95% confidence level that DNB will not occur) is a 1.30 for the W-3-(" C-id).

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where a es'fe/istice/ cppyoge), jS for He FSA2 CBSe5

/k>f cPpphed, e fixed velae meUtod w& plant' e co u n fe d f , ,y y uncerlainhes are disfy}

BB/cu/ahw is usec).

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t POWER DISTRIBUTION LlwlTS BASES rb wo /

3/4.2.2 and 3/4.2.3 HEAT FLUX HOT CHANNEL FACTOR NUCLEAR ENTHALP HOT CHANNEL FACTOR The limits on heat flux hot channel factor, and nuclear enthalpy rise hot channel factor ensure that 1) the design limits on peak local power density and minimum DNSR are not exceeded and 2) in the event of a LOCA the peak fuel clad temperature will not exceed the 2200'F E G5 acceptance criteria limit.

Each of these is measureable but will normally only be detemined periodically as specified in Specifications 4.2.2 anc 4.2.3. This ceriodic surveillance is sufficient to ensure that the limits are maintainec provicec:

a. Control rods ir a single groun r'ove together with no individual rod insertion differing by more inan + 12 steps, indicated, from the group dee.and position,
b. Control rod banks are secuenced with overlapping grou;s as described in Specification 3.1.3.6.
c. The control rod insert *ct. limits of Specification @ and 2.1.3.5 are m2.f r.ttir.ec.

,. d. Tne axial ocwer cistrioution, expresse:: in teres of A11AL FLUX

' C'F~IREt.CE, is caintaine: nr.ir. tr.1 limits.

F$g will be maintained within its limits provided conditions a. through

d. above are maintained. TherelaxationofF#g as a function of THERMAL POWER allows changes in the radial g shape for all permissible rod insertion limits.

PCwef When an Fo measurement is taken, an allowance for both experimental error and manufacturing tolerance must be made. An allowance of St is a;propriate for a full core map taken with the incore detector flux mapping system and a 3t allowance is appropriate for manufacturing tolerance.

WhenF1,'g is measured. (i.e., inferred), /10 add,4f uu af. h anao Att ww mz &> cc.v pau'c.m vin, m l'C's e 'n-4 H. r-:.

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u nut aa.o.ava. q 1% % % w cLM " %-

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M w m (i.q.t. w i.vr p r u D -L M f c d 4 ,

%gul% ) w 1A a % nu onex s O .3 e. M i. w b^ ^^ M A/tu b q cL. m %f ay t;,wMccA,aJ/ Q % )a m & .

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&M& 9 % DN6 monjW iS> 2 1 .grhsoy mainteinec-/ y] pic-,d d 4

._.- - . .c _ - - . - ~ m arrelaticW /imit and V)n 5de b: bag we gym)pik n I,mit in D >

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ENCLOSURE 1 FOR CALLAWAY WESTINGHOUSE OFA TRANSITION RELOADS Information addressing eleven plant specific items given on page 3 of NRC cover letter for NRC SER 'on WCAP-9500 (May 22,1981)

1. For th'ose plants using the Improved Thermal' Design Procedure-(ITDP), the .

conditions listed in the safety evaluation must be addressed and

. satisfied.

Response: This information is provided in Attachment A to this Enclosure 1 information.

2. A discussion in the Basis of Technical. Specifications of any generic or plant-specific margins that have been used to offset the reduction in DNBR due to rod bowing.

Response: Proposed changes in the Technical Specification Basics 3/4.2.2 and 3/4.2.3 defines plant-specific margins used to offset the reduction in DNBR due to rod bowing. Margin available to offset rod bow and transition core penalties is 7% (i.e., margin between design and safety ,

limit DNBRs when the statistical method is used; margin maintained above the correlation limit when a fixed value method is used).

A declaration in the Technical Specifications that prohibits N-1 loop

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3.

operation unless adequately justified in the plant-specific analysis.-

Response: The'Ca11away' Technical Specifications already prohibits N-1 loop operation in Section 3.4.1.1 which states "All reactor coolant loops shall be in operation."

4. Frequency and description of rod worth tests that would detect gross losses of reactivity worth from boron-containing control rods.

Response: This item is not applicable to the callaway Plant since boron-containing control rods are not used.

1

5, Confirmation that the predicted cladding collapse time exceeds the expected lifetime of the fuel.

Response: The Callaway 0FA fuel is designed utilizing the approved Westinghouse fuel performance model (a) and approved clad flattening model (b) . The OFA fuel is designed so that the calculated fuel rod clad flattening time is greater than the' maximum planned fuel irradiation time in the reactor.

(a) Miller, J.V., " Improved Analytical Models Used in Westinghouse Fuel Rod Design Computations," WCAP-8720 (Proprietary) and WCAP-8785 (Non-Proprietary), October 1976.

(b) George, R.A., (et al.), " Revised Clad Flattening Model," WCAP-8377 (Proprietary) and WCAP-8381 (Non-Proprietary), July 1974.

6. Supplemental ECCS calculations using NRC-supplied LOCA cladding models, until a generic resolution of this issue is obtained.

Response: This item is not applicable since a generic resolution of NRC concerns on clad ballooning and assembly flow blockage has been obtained. The Callaway LOCA analyses of the Westinghouse 0FA fuel use models which incorporate the generic resolution. NRC approval is given in WCAP-9220-P-A (Proprietary), Revision 1, 1981.

7. A determination that the appropriate seismic and LOCA forces are bounded by the cases considered in WCAP-9401 or additional analyses.

Response: An evaluation of fuel assembly structural integrity considering the lateral effects of a LOCA combined with a seismic accident has been performed for both the 0FA and LOPAR fuel assembly. A comparison of the SRSS* combined grid impact forces during the accident with data obtained from grid impact tests at operating temperature results in adequate safety margins. Reference (a) presents a bounding analyses of the mixed 0FA/LOPAR assembly and all-OFA cores. The analyses provides confirmation that the OFA and LOPAR assembly Zircaloy 2

I

and Inconel grids will not. crush due to the combined impact forces of a seismic /LOCA event. The stresses in the OFA and LOPAR fuel assembly components resulting from seismically induced deflections are within acceptable limits. NRC approval of the generic 17x17 mixed core seismic /LOCA analyses is given in Reference (b).

(a) Letter from E. P. Rahe (Westinghouse) to J. R. Miller (NRC) dated March 19, 1982, NS-EPR-2573,

Subject:

WCAP-9500 and WCAP-9401/9402 NRC SER Mixed Core Compatibility Items' .

(b) Letter from C. O. Thomas (NRC) to E. P. Rahe (Westinghouse), dated November 12, 1982,

Subject:

Supplemental Acceptance Number 1 for Referencing of Licensing Topical Report WCAP-9500-A.

8. A description of plants for on-line fuel system monitoring:

Response: Concerning the on-line fuel monitoring system refer to FSAR Section 11.5.2.2.2.6.

9. A description of plans for post-irradiation poolside surveillance of fuel.

Responses: No special surveillance requirements are necessary since Callaway is not a lead plant for using the 17x17 0FAs. McGuire Units 1 and Maanshan Unit 1 are the lead plants utilizing 17x17 0FAs. Other plants which have started up with 17x17 0FAs include: McGuire Unit 2, Byron Unit 1, Catawba Unit 1 and Maanshan Unit 2. Therefore, only the normal visual surveillance of a representative sample of irradiated 0FAs is planned during refueling shutdowns of the Callaway Plant.

10. For transients analyzed to determine fuel failure, DNBR as function of time (NVREG-1.70 requirement).

Response: In the FSAR Chapter 15 non-LOCA analyses, there are two events for which fuel failure is predicted - Locked Rotor and Rod Ejection.

The revised FSAR section 15.3.3 provided in the Callaway 0FA licensing submittal provides adequate information to justify that the Standard 3

Review Plan 15.3.3 accident analysis acceptance criteria are met. The design limits for the Locked Rotor Condition IV accident, consistent with the Standard Review Plan, includes peak clad temperature, peak system pressure and radiological consequences. The number of rods experiencing DNB is determined using the computer code generated transient statepoints. The DNBR used to predict the number of rod failures (i.e., number of rods below the DNB limit) is not calculated in the Loftran simulation of the Locked Rotor transient.

In the case examined ~ for WCAP-9500, the Locked Rotor plot of minimum DNBR vs time demonstrates that the DNBR does not drop below the limit.

The plot, therefore, adequately demonstrates that no fuel rods are expected to fail.

Although the general behavior of the WCAP-9500 plot is representative of the Callaway Locked Rotor transient, plant specific calculations indicate that the DNBR does drop below the safety analysis limit. In this case additional calculations are peformed with the limiting transient statepoints to determine the number of rods in DNB. For Callaway, the percentage of rods experiencing DNB is reported in the revised FSAR section 15.3.3.

In conclusion, the information provided in the Callaway revised FSAR section 15.3.3 is consistent with the Standard Review Plan requirements.

In the analysis of the Rod Ejection event, calculations are based on the assumption that fuel rods experience DNB early in the transient. The DNBR is not calcualted. The design limits for this condition IV accident, consistent with the Standard Rview Plan, include peak clad temperature, fuel centerline melting, average fuel energy, peak sywtem pressure and radiological consequences.

11. Initial fuel conditions (i.e., stored energy or centerline temperature) utilized in the transient and accident analyses (as per NUREG-1.70 requirements).

Response: Attachment B to this Enclosure 1 presents a curve of fuel peak (centerline) temperature ( F) as a function of local rod power 4

i *

, Kw/ft). For the various accidents presented in Attachment C (non-LOCA)

[ and D (LOCA) to the Callaway 0FA transition submittal to the NRC, local rod power can be determined for the information provided. Local rod L . power may then be converted to peak (centerline) temperature by use of the Attachment B figure.

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ATTACHMENT A ITDP Instrmient Uncertainties Calculations (Kon-Proprietary)

1 WESTINGHOUSE PROPRIETARY CLASS 3 THE IMPROVED THERMAL DESIGN PROCEDURE (ITDP) USES AS PART OF IT'S INPUTe THE INSTRUMENT UNCERTAINTIES FOR THE MEASUREMENT OR CONTROL OF PRESSURIzzR PRESSUREe TAvG (ROD CONTROL)e REACTOR POWERe AND RCS FLOW.

WESTINGHOUSE CALCULATES THESE' UNCERTAINTIES USING THE GENERIC METHODOLOG'Y NOTED IN APPENDIX A. FOR EACH PLANT SPECIFIC APPLICATION, WESTINGHOUSE CALCULATES THE FOUR UNCERTAINTIES USING PLANT SPECIFIC ,

DATA WITH REGARDS TO PARTICULAR TRANSMITTERS OR METHODS OF CALIBRATION OR MEASUREMENT. THESE SAME CALCULATIONS WERE PERFORMED FOR.CALLAWAY AND ARE SUPPLIED AS APPENDIX B.

ON PAGE 3 OF APPENDIX A ARE THE VARIDUS EQUATIONS USED TO CALCULATE THE INSTRUMENT UNCERTAINTIES. FOR THE CALLAWAY SPECIFIC CALCULATIONSe AN ADDITIONAL TERM WAS ADDED TO THE [ 3*A.c ANo TO THE [ J***c WHEN [ 3***c WERE USED. THIS ADDITIONAL TERM WAS THE ACCURACY OF THE [

3+^.c. THIS APPROACH IS CONSISTENT WITH THAT USED IN THE REPORT " WESTINGHOUSE SETPOINT METHODOLOGY FOR PROTECTION SYSTEMS - CALLAWAY." THIS REPORT DOCUMENTS THE INSTRUMENT UNCERTAINTY CALCULATIONS PERFORMED FOR THE REACTOR PROTECTION AND ENGINEERED SAFETY FEATURES ACTUATION SYSTEMS.

ANOTHER AREA SPECIFIC TO CALLAWAY IS THE INTERACTION BETWEEN STEAM PRESSURE AND FEEDWATER PRESSURE IN THE RCS FLOW CALORIMETRIC AND POWER CALDRIMETRIC UNCERTAINTIES NOTED IN APPENDIX B. THIS STATISTICAL DEPENDENCE IS DUE TO THE PLANT INFERRING FEEDWATER PRESSURE FROM MEASURED STEAM PRESSURE INSTEAD OF MEASURING FEEDWATER PRESSURE DIRECTLY. THIS CREATES A STATISTICAL DEPENDENCE BETWEEN THE TWO PARAMETERS THAT DOES NOT EXIST IN THE GENERIC APPROACH. THIS IS ACCOUNTED FOR TH40 UGH THE ARITHMETIC SUMMING OF THE THREE UNCERTAINTIES FOR FEEDWATER PRESSURE AND STEAM PRESSURE BEFORE CARRYING OUT THE REST OF THE TOTAL UNCERTAINTY CALCULATION.

PROVIDED IN APPENDIX B ARE TABLES FOR EACH STEP OF THE CALC 0LATIONS PERFORMED TO DETERMINE THE FOUR UNCERTAINTIES. TABLE 1 IDENTIFIES THE UNCERTAINTIES USED TO DETERMINE THE ACCURACY OF THE PRESSURIZER ,

PRESSURE CONTROL SYATEM. THE CALCULATION RESULTS IN A CONTROLLER SIGMA OF [ 3*A.c, ,

TABLE 2 IS THE ACCURACY OF THE ROD CONTROL SYSTEM WHEN UTILIZING THE TAVG INPUT. AS NOTED'ON TABLE 2e THE ACCURACY OF THE CONTROL SYSTEM 10 APPROXIMATELY [

3 4.c I

WESTINGHOUSE PROPRIETARY CLASS 3 l 1

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[ ]+Aec. THE INCORPORATION OF THE CONTROL SYSTEM DEADBAND l IN THE CALCULATION IS EXACTLY THE SAME AS NOTED IN APPENDIX A. '

TASTES 3 4 AND 5 PROv!DE THE INSTRUMENT UNCERTAINTIESe PARAMETEP SENSITIVITIES AND COMPONENT MEASUREMENT UNCERTAINTIES FOR THE SECONDARY $1DE POWER CALORIMETRIC. FOR THESE MEASUREMENTS IT WAS ACSUMED ( AND VERIFIED BY THE PLANT) THAT THE PLANT PROCESS CDMPUTER WOULD BE USED. THE ADDITIONAL UNCERTAINTIES NECESSARY TO REFLECT THIS ARE NOTED ON TAsLE 3. TAeLE 4 REFLECTS THE SPECIFIC OPERATIONAL CHARACTERISTICSe E.G.. FEEDWATER TEMPERATURE. FEEDWATER PRESSURES ETC.e OF CALLAWAY. TAsLE 5 REFLECTS THE STATISTICAL DEPENDENCE OF FEEDWATER PRESSURE AND STEAM PRESSURE AND NOTES THE RESULTING

COMPONENT UNCERTAINTIES WITH A CALCULATED SIGMA OF [
]+A.c, ,

TABLES 6e7 AND 8 NOTE THE INSTRUMENT UNCERTAINTIESe PARAMETER SENSITIVITIES AND COMPONENT MEASUREMENT UNCERTAINTIES FOR THE RCS FLOW CALORIMETRIC. FOR THESE MEASUREMENTS IT WAS ASSUMED (AND VERIFIED BY THE PLANT) THAT PRECISION MEASUREMENTS WOULD BE MADE FOR THIS ONCE PER CYCLE MEASUREMENT. CALLAWAY PROVIDED TO WESTINGHOUSE UNCERTAINTIES FOR THE SPECIFIC HARDWARE USED FOR THIS MEASUREMENT. THESE UNCERTAINTIES ARE NOTED ON TABLE 6. TABLE 7 REFLECTS THE PLANT SPECIFIC OPERATIONAL CHARACTERISTICS FOR CALLAWAY. TAeLE 8 NOTES THE RESULTING COMPONENT UNCERTAINTIES AND REFLECTS THE STATISTICAL DEPENDENCE BETWEEN THE FEEDWATER PRESSURE AND STEAM PRESSURE UNCERTAINTIES.

THE FINAL N LOOP UNCERTAINTY IS CDMBINED WITH THE COLD LEG EteoW TAP UNCERTAINTY ON TABLE 9. THIS TABLE NOTES THE UNCERTAINTY OF THE EteOW TAP AFTER NORMALIZATION WITH THE PRECISION FLOW CALOR! METRIC. THE RESULTING TOTAL FLOW MEASUREMENT UNCERTAINTY FOR THE PLANT IS t. 2.1 %

FLOW. THE RCS FLOW UNCERTAINTY SIGMA USED IN THE ITDP CALCULATIONS IS

[ , 3***c.

IN

SUMMARY

, THE STANDARD DEVIATION VALUES USED FOR THE FOUR PARAMETERS ARE8

--- __ +AeC PRESSURIZER PRESSURE WITH A BIAS OF TAvG (ROD CONTROL)

WITH A BIAS OF REACTOR POWER (CALORIMETRIC)

WITH A BIAS OF RCS FLOW (COLD LEG EtsOW TAP)

, WITH A BIAS OF

WESTINGHOUSE PROPRIETARY CLASS 43 l

APPEND:;X A

l l

WESTINr.H0USE PROPRIETARY CLASS 3 Questions:

1. Provide and justify the variances and distributions for input

+

parameters,

2. Justify that the nominal conditions used in the analyses bound all pemitted modes of plant operation.
3. Provide a block diagram depicting sensor, processing equipment, computer, and readcut devices for each parameter channel used in the uncertainty analysis. Within each element of the block dia-gram identify the accuracy, drift, range, span, operating limits, and setpoints. Identify the overall accuracy of each channel transmitter to final output and specify the minimum acceptable accuracy for use with the new procedurs. Also identify the over-all accuracy of the final output value and maximum accuracy requirements fcr each input channel for this final output device.

Response ,

I. INTRODUCTION : RdF RTDs

~

Four operating parameter uncertainties are used in the uncertainty ana-lysis of the Improved Themal Design Procedure (ITDP). These operating parameters are pressurizer pressure, primary coolant temperaturw (T,,g), reactor power, and reactor coolant system flow. These para-meters are monitored on a regular basis and several are used for contrwl purposes. The reactor power is monitored by the perfomance of a secon-dary side heat balance (power calorimetric measuiwant) at least once every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The RCS flow'is monitored by the perfomance of a pre-cision flow calorimetric measurement'at the beginning of each cycle.

The RCS loop elbow taps can then be nomalized against the precision

~

calorimetric and used forsenthly surveillance (with a small increase in total uncertainty) or a precision flow calorimetric can be perfo,med on la ,

l WESTINGHOUSE PROPRIETARY CLASS 3 1 l

the same surveillance schedule. Pressurizer pressure is a controlled I

parameter and the uncertainty for the Improved Themal Design Procedum reflects the use of the control system. T ,, is a controlled para-meter through the use of the temperature input to the Control Rod con-trol system; the uncertainty presented here reflects the use of this control system.

Since 1978 Westinghouse has been deeply involved with the development of several techniques to treat instrumentation uncertainties, errors, and allowances. The earlier versions of these techniques have been docu-mented for several plants; one approach uses the methodology outlined in WCAF-8567 " Improved Thermal Design Procedum.O.2,0 which,is based on the conservative assumption that the uncertainties can be described with unifom probability distributions. The other approach is based on the more realistic assumption that the uncertainties can be described with nomal probability distributions. This assimption is also conservative in that the " tails" of the nomal distribution an in reality " chopped" at the extremes of the range, i.e., the ranges for uncertainties are finite and thus, allowing for some probability in excess of the range limits is a conservative assumption. This approach has been used to substantiate the acceptability of the protection system setpoints for several plants with a Westinghouse NS$$. e.g., D. C. Cook !!N, North A*na. Unit l', Salem Unit 2, Sequoyah Unit 1. V. C. Sumer, and McGuire Unit 1. Westinghouse now believes that the latter approach can be used for the detemination of the instrumentation errors and allowances for the ITDP parameters. The total instrumentation errors presented in this msponse are based on this approach. ,

!!. METHODOLOGY The methodology used to combine the error components for a channel is basically the appropriate statistical combination of those groups of components which are statistically independent, i.e., not interactive.

Those errors which are not independent are combined arittnetically to fom independent groups, which can then be systematically combined. The statistical combination technique used by Westinghouse is the [

2a

r WESTINGHOUSE PROPRIETARY CLASS 3

]+a.c.e of the instrumentation uncer-taintie s. The instrumentation uncertainties are two sided distribu-tions. The sum of both sides is equal to the range for that parameter, e.g., Rack Drift is typically [ ]**'", the range for thi s parameter is [ ]+a,c. This technique has been utilized before as noted above and has been endorsed by the staff (5,6,7) and various industry standardsIE' N .

The relationship between the error components and the statistical instrumentation error allowance for a channel is defined as follows:

1. For parameter indication in the racks using a DVM;

- +a.c

~ Eq.1

2. For parameter indication utilizing the plant process computer;

- + ac ,

~

Eq. 2

3. For parameters which have control systems;

+ a.c .

~

  • Eq. 3 where:

CSA = Channel Statistical Allowance PMA = Process Measurement Accuracy PEA = Primary Element Accuracy ,

SCA = Sensor Calibration Accuracy SD = Sensor Drift 3a

- , . - - - - - - -, --- - - , - -,..----,-----.-,y , .,-n---r

. - , ---n.-,.---. ._r., - , , , ., - - - - - - , - - - - - - - - , - - - - - - - - - - - - - - . - . , ,,,,m-

[

WESTINGHOUSE PROPRIETARY CLASS 3 STE = Sensor Temperatum Effects SPE = Sensor Pressure Effects RCA = Rack. Calibration Accuracy AD = Rack Drift RTE = Rack Temperature Effects DVM = Digital Voltmeter Accuracy ID = Computer Isolator Drift A/D = Analog to Digital Conversion Accuracy CA = Controller Accuracy The parameters above are as defined in reference 4 and am based on SAMA standard PMC-20-1973(10) However, for ease in understanding they are paraphrased below:

PMA - non-instrument related measurement errors, e.g., tempera-ture stratification of a fluid in a pipe, PEA - errors due to metering devices, e.g., elbows, venturis, orifices, SCA - reference (calibration) accuracy for a sensor / transmitter, SD -

change in input-output relationship over a period of time at reference conditions for a sensor / transmitter, STE - change in input-output mlationship due to a change in

- ambient temperature for a sensor / transmitter, SPE - change in input-output mlationship due to a change in static pressum for a Ap cell.

RCA - reference (calibration) accuracy for all rack modules in loop or channel assuming the loop or channel is tuned to this accuracy. This assumption eliminates any bias that could be set up through calibration of individual modules in the loop or channel. '

RD - change in input-output relationship over a period of time at mference conditions for the rack modules, RTE - change in input-output relationship due to a change in ambient temperature for the rack modules, DVM - the measurement accuracy of a digital voltmeter or multi-meter on it's most accurate applicable range for the parameter measured, 4a ,

I l

)

WESTINGHOUSE PROPRIETARY CLASS 3 ID - change in input-output mlationship over a period of time at reference conditions for a control / protection signal isolating device, ,

A/D - allowance for conversion accuracy of an analog signal to a digital signal for process computer use, CA - allowance for the accuracy of a controller, not including deadband.

A more detailed explanation of the Westinghouse methodology noting the interaction of several parameters is provided in refemnce 4.

III. Instrumentation Uncertainties The instrumentation uncertainties will be discussed first for the two parameters which are controlled by automatic systems, Pressurizer pres-The uncertainties for both of sure, and T,yg (through Rod Control).

these parameters are listed on Table la, Typical Instrumentation Uncer-tainties.

1.a . Pressurizer Pressure Pressurizer, pmssure is controlled by a system that compans the mea-sured ' pressure against a reference value. The pressure is measumd by a Allow-pressum cell connected to the vapor space of the pressurizer.

ances are made as indicated on Table la for the sensor / transmitter and the process racks / controller. As noted, the CSA for this function is

]+a,c,

[ ]+a,c which corresponds to a control accuracy of [

The accuracy assumed in the ITDP analysis is [ 3+a,c,thus, i margin exists between analysis and the plant. Being a contmiled para-j meter, the nominal value of 2235 psig is reasonable and bounded by ITDP 1 error analysis assumptions, i.e., assuming a nomal, two sided distribu-tion for CSA and a 95+1 probability distribution (which will be docu-mented later in this response), o for the noted CSA equals

[ 3+a,c. Assuming a noma 1, two sided distribution for the ITDP assumption of [ ]+a c and a 95+1 probabilfty distribution results in a o = [ J+a.c. Thus, Sa

nst:Emeust peerestim Ctass 3 EME 1e

~

TVPICAL InstaWEstATies MAletir5 (asteg ser eles) .

and Centrol (feuperature)

Feeenter Feeesoter Feeesotor Pressortaer Fee h ter ste mitar Ist Stage Steemilan ap Pressure Tempereture Pressere F I Pressertaer Tert >tse Pressure Temperature Pressure N C Indicottee Instcotten Inetcottee Indicottee taskettee tedtcettee toescottee Pressure tapelse ludicettee inescottee Caetret (Il Tag (1) Pressure (1) (Casester (1) (Computer) (1) (Campster) (1) (Congster) (1, (WN (l? leUN) (1) (ete) (1) (Well (t) (Wu) (I)

__ +e.c 408T 15ae pst lessap see pst 4e87 1200 pst 188T 188T t see pst leet 188 7 tres pst til s testruent spee (23 Correspeaes to en occuracy of [ ye.c ,

(31 ertemtmed estag Eg. 3 (4) ertemixed estag Eq. I

15) ertemined estag Eq. 2 (6) Correspones to en occuracy of [ y e.c .

(Il Correspones to e ertft of [ y e.c .

6a

(J WESTIMH00$E PROPRIETARY CLASS 3 i

( margia exists betreen the expected and assumed standard deviations for l Pressurizer pressure.

l 2.a T gyg T

avg is controlled by a system that compares the auctioneered high T,,g.f rom the loops with a reference derived f rom the First Stage l Turbine Inpulse Pressure. Tavg is derived from the average of the l narrow range TH and TC f rom the bypass manifolds. The highest loop T

l ayg is then used in the controller. Allowances are made as noted on Table la for the sensor / transmitter and the process racks / controller. As

noted, the CSA for this function is [ ]+a c which corre-l sponds to an instrumentation accuracy of [ ]+a.c . Assuming a normal, two sided distribution for CSA and a 95+% probability distribu-tion results.in a standard deviation, o = [ ]+ac, I

l However, this does not include the controller deadband of _+ 1.5'F. To determine the controller accuracy the instrumentation accuracy must be t

, combined with the deadband. Westinghouse has detemined that the proba-f bility distribution for the deadband is [

].+ac The variance for the deadband uncertainty is then:

I

{ )+a,c and the standard deviation, o ::::[ ]+a,c ,

Combiring statistically the standaro deviations for instrumentation and deadband results in a controller standard deviation of:

o, = [o;2 , op2, [ 3+ac ,

e 7a

(

t

/

f .

WESTINGHOUSE PROPRIETARY CLASS 3 Therefore, the controller uncertainty f or a 95+5 nomal probability distributionisN[ ].+a.c This is the uncertainty assumed f or the ITDP error analysis and reasonably bounds the nominal value corresponding to the f ull power T,yg, 3.a. Reactor Power Generally a plant performs a primary / secondary side heat balance once This heat every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when power is above 155 Rated Thermal Power.

balance is used to verify that the plant is operating within the limits of the Operating License and to adjust the Power Range Neutron Flux channels when the difference between the NIS and the heat balance is greater than that required by the plant Technical Specifications.

Assuming that the primary and secondary sides are in equilibrium; the core power is determined by summing the themal output of the steam generators, correcting the total secondary power f or steam generator blowdown (if not secured), subtracting the RCP heat addition, adding the primary side system losses, and dividing by the core rated Stu/hr at f ull power. The equation f or this calculation is:

N Eq. 4 RP = 1 (E[0 g - 0,) +0g ),100 3

  • ( H )

where; RP = Core power ( % RTP)

  • N = Number of primary side loops 03g . Steam Generator thermal output (Btu /hr)

Op = RCPheatadder(Stu/hr)

Og . Primary system net heat losses (Btu /hr)

H = Core rated Btu /hr at f ull power.

l For the purposes of this uncertainty analysis (and basea on H noted l

I above) it is assumed that the plant is at 100% RTP when the measurement is taken. Measurements perf ormed at lower power levels will result in Da L

I ..

ESTINGHOUSE PROPRIETARY CLASS 3 different uncertainty values. Ibwever, operation at lower power levels results in increased margin to DNB far in excess of any margin losses due to increased measurement uncertainty.

The themal output of the steam generator is detemined by a calorime-tric measurement defined as:

Eq. 5 0g 3

=

(h, - h )p Wg where;

= Steam enthalpy (Btu /lb) h, hg = Feedwater enthalpy (8tu/lb) ,

Wg = Feedwater flow (Ib/hr).

The steam enthalpy is based on the measurement of steam generator outlet

- steam pressure, assuming saturated conditions. The feedwater enthalpy is based on the measurement of feedwater temperature and an assumed feedwater pressure based on steamline pressure, plus 100 psi. The feed-water flow is detemined by multiple measurements and a calculation based on the following:

Eq. 6

,.g W - = (K)(F,) (Ver ap) where:

K = Feedwater venturi flow coefficient F, = Feedwater venturi correction for thennal expansion

= Feedwater density (1b/ft3 )

Pf ap = Feedwater venturi pressure drop (inches H 2O).

The feedwater venturi flow coefficient is the product of a number of constants including as-built dimensions of the venturi and calibration tests perfonned by the vendor. The themal expansion correction is based on the coefficient of expansion of the venturi material and the Da

I WESTINGHOUSE PROPRIETARf CLASS 3 diffemnce between feedwater temperature and calibration temperature.

Feedwater density is based on the measurement of feedwater temperature and feedwater pressure. The venturi pressure drop is obtained from the output of the diffemntial pressure cell connected to the venturi.

The RCP heat adder is detemined by calculation, based on the best esti-mates of coolant flow, pump head, and pump hydraulic efficiency.

The primary system not heat losses are detemined by calculaticn, con-sidering the following system heat inputs and heat losses:

Charging flow Letdown flow Seal injection flow RCP themal barrier cooler heat mmoval Pressurizer spray flow Pressurizer surge line flow Component insulation heat losses Component support heat losses .

CRDM heat losses A single calcuated sum for full power operation is used for these los-ses/ heat inputs.

The core power measurement is based on the following plant measurements:

Steam 11ne pressum (P,)

Feedwater temperature (Tf ) ,

Feedwater pressure (Pf ) '

Feedwater venturi differential pressure ( Ap)

Steam generator blowdown (if not secured) and on the following calculated values:

Feedwater venturi flow coefficient (K)

Feedwater venturi themal expansion correction (F,) .

Feedwater density (of) 10a

T ESTINGN0USE PROPRIETARY class 3 Feedwater enthalpy (hg )

Steam enthalpy (h,)

Moisture carryover (impacts h,)

Primary systen not heat losses (Og)

RCP heat adder (0,)

These measumments and calculations am pmsented schematically on Figure 1.

Starting off with the Equation 6 parameters, the detailedd erivation of the measurement ermrs is noted below.

Feedwater Flow Each of the feedwater venturis is calibrated by the vendor in a hydrau-*

lic laboratory under controlled conditions to an accuracy of

. [ ]+a,b,c 5 of span. The calibration data which substantiates this accuracy is provided for all of the plant venturis by the mspective vendors. Anadditionaluncertaintyfactorof[ 3+a.c 5 is included for installation effects, msulting in an overall flow coef-ficient (K) uncertainty of [ 3+a.c 5. Since steam generator themal output is proportional to feedwater flow, the flow coefficient uncertainty is expressed as [ ] +a c 5.powe r. ,

The uncertainty applied to the feeduater venturf themel expansion corme-tion (F,) is based on the uncertainties of the measured feedwater tem-perature and the coefficient of themal expansion for the venturi material, usually 304 stainless steel. For this material, a change of + 2*F in the feedwater temperature range changes F, by [ 3a,b,c 5 and the steam generator thema1* output by the same amount. For this deriva-tion, an uncertainty of C ]+a.c in feedwater temperatum was assumed (detailed breakdown for this assumption is provided in the feed-water enthalpy section). This msults in a total uncertainty in F, and steam generator output of [ ]+a.c5.

11a

ESTINGHOUSE PROPRIETARY CLASS 3 Based on data introduced into the ASE code, the uncertainty in F, for 304 stainless steel is +5 percent. This results in an additional uncer-tainty of [ ]+8'C 1 in feedwater flow. A conservative value of

[ ]+a.c % is used in this analysis.

Using the ASE Steam Tables (1967) for compressed water, the effect of a

[ 3+a.c error in feedwater temperature on the %is

[ 3+a c 1 in steam generator thermal output. An error of

[ ]+a.c in feedwater pressure is assumed in the analysis (detailed breakdown of this value is provided in the steam enthalphy section). This results in an uncertainty in (ofof[ ]+a,c g in steam generator thermal output. The combined effect of the two results in a total % uncertainty of [ 3+a c 1 in steam generator thermal output.

Table la provides a listing of the instrumentation errors for feedwater op (including an allowance for the venturi as defined above) assuming display on the process computer. With the exception of the computer readout error, the electronics errors are in percent op span and must be translated into percent feedwater flow at full power conditions.

This is accomplished by multiplying the error in percent Ap span by the conversion factor noted below:

span of feedwater flow transmitter in 5 of nominal flow i 2

[Y1\

(j (

100 .

For a feedwater flow transmitter span of ( 3+C 1 nominal flow, the conversion factor is [ ]+a.c (which is the value used for this analysis).

As noted in Table 2a the statistical sum of the errors for feedwater flow is [ 3+a.c 1 of steam generator thernal output.

12a

ESTINGHOUSE PROPRIETARY CLAS$ 3 Feedwater Enthalpy The next major error component is the feedwater enthalpy used in Equa-tion 5. For this parameter the major contributor to the error is the uncertainty in the feedwater tesperature. Table la provides the detailed error breakdown for this temperature measurement assuming indication on the process computer. Statistically summing these errors (utilizing Eq. 2) results in a total temperature error of [ 3+a.c 5 span.

Assuming a span of [ 3+a,c resalts in a temperature error of

( ).+a.c A conservative, bounding value of [ ]**'C was assumed for this analysis. Assuming smaller spans results in smaller temperature errors. .

I Using the ASE steam tables (1967) for compressed water, the effect of a

[ 3+a c error in feedwater temperatum on the feedwater enthalpy (h ) is [ 3+a,c 5 in steam generator themal output.

f Assuming a [ 3+a c error in feedwater pressure (detailed break-down provided in the steam enthalpy section) results in a

[ 3*8'C 1 effect in h and f

steam generator themal output.

The combined affect of the two results in a total hf uncertainty of

[ 3+a c 1. A conservative value (based on round-off effects of individual instrumentation errors) of [ 3+a.c 5 for h uncer ,

f tainty is used in this analysis (as noted on Table 2a).

Steam Enthalpy The steam enthalpy has two contributors to the calorimetric error, steamline pressure and the moisture content. For steamline pressure the errors are as noted on Table la. assumino display on the process compu-ter. This msults in a total instrumentation error (utilizing Eq. 2) of

[ 3+a c 1 span. Based on a 1200 psig span this equals

[ 3 +a c A conservative value of ( 3+bC is assumed in this analysis. The feedwater pressure is assumed to be 100 psi higher than the steamline pressure with a conservatively high measure-ment error of [ 3.+a,c Table la provides a breakdown of expected errors if feedwater pressure is measured directly and d'isplayed 13a

WESTINGHOUSE PROPRIETARY CLASS 3 on the process computer. The results indicate an expected error of

[ 3***C, well within the assumed value. -

1 Using the ASE Steam Tables (1967) for saturated water and steam, the effect of a [ 3+a,c([ 3+a,c) error in steamline pressure on the steam enthalpy (h,) is [ 3**'C 1 in steam generator themal output. Thus a total instrumentation error of [ 3**'c in steamline pressure results in an uncertainty of [ 3**'C 1 in steam generator thermal output.

The major contributor to h, uncertainty is moisture content. The nominal or best estimate perfomance level is asstaned to be [ 3+a.c g, which is the design limit to protect the high pressure turbine. The most conservative assumption that can be made in regards to maximizing steam generator themal output is a steam moisture content of zero. This conser-vatism is introduced by assigning an uncertainty of [ 3+a.c 5 to the moisture content, which is equivalent through enthalpy change to

[ 3+8'C 5 of themal output. The combined effect of the steamline i pmssure and moisture content on the total h, uncertainty is *

[ 3+a.c 1 in steam generator themal output.

Loop Power The loop power uncertainty is obtained by statistically combining all of the error components noted for the steam generator themal output (QSGI I" tems of loop power. Within each loop these components are independent effects (or fomed into independent quantities) since they are independent measurenents. Technically, the feedwater temperature and pressure uncer-tainties are common to several of the error components. However, they are

, treated as independent quantities because of the conservatism assumed and

' the arithmetic sumation of their uncertainties before squaring them has no significant effect on the final result.

1 i

14a

- - . - . . . . . . , _ _ . _ . _ , , , . _ _ _ _ _ _ . ___.y. . . _ _ _ _ . . _ _ _ . _ _ _ . . _ _ __ - - _ _ . , __ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ . _ _ _

i WESTINGHOUSE PROPRIETARY CLASS 3

\

The only effect which tends to be dependent, affecting all loops, is the accumulation of crud on the feedwater venturis, which can effect the ap for a specified flow. Although it is conceivable that the crud accumulation could affect the static pressure distribution at the ven-turi throat pressure tap in a manner that would result in a higher flow for a specified ap, the reduction in throat area resulting in a lower flow at the specified ap is the stronger effect. All reported cases of venturi fculing have been associated with a significant loss in elec-trical output, indicating that the actual thermal power has been below '

the measured power rather than above it. Losses in net power generation which have been correlated with venturi fouling have occurred in about half of the more than 20 Westinghouse pressurized water reactors oper-ating in the United States. These power losses have been generally in the range of two to three percent.. Power losses have' also ' occurred in at least three, and'possibly five plants out of the more than ten West-inghouse plants operating abroad. In no case has venturi foulin'g been reported which resulted in a non-conservative feediater flow measure-ment. Because the venturi crud formations have resulted in a conserva-tive, reduced power condition, no uncertainty has been included in the analysis of power measurement error for this phenomenois.

The' net pump heat uncertainty is derived in the following manner. The primary system net heat losses and pump heat adder for a four loop plant are summarized as follows:

Systems heat losses - 2.0 MWt Component conduction and convection losses - 1.4 l

Pump heat adder +18.0 1

Net Heat input to RCS +14.6 MWt 15a

WESTINGHOUSE PROPRIETARY CLASS '3 7

The uncertainties for these quantitites am as follows: The uncertainty on system heat losses, which are essentially all due to charging and letdown flows, has been estimated to be [ 3+a c 5 of the calculated value. Since direct measurements are not possible, the uncertainty on component conduction and convection losses has been assumed to be

[ 3+a,c 1 of the calculated value. Reactor coolant pump hydraulics are known to a reletively high confidence level, supported by the system hydraulics tests perfomed at Prairie Island II and by input power mea-surements from several plants, so the uncertainty for the pump heat adder is estimated to be [ 3+a,c 5 of the best estimate value.

Considering these parameters as one quantity which is designated the net pump heat uncertainty, the combined uncertainties are less than 3+a c 1 of the total, which is equivalent to [ 3+a,c g of

[

core power.

The Total Loop. Power uncertainty (noted in Table 2a as [ .]ia,c %)

is the statistical sum of the Loop Power uncertainty (Q 3+a,c %,

. 3 g), [

and the Net Pump Heat Addition, [ 3+8'" 5. The Total Secondary Power uncertainty is the statistical combination of the Loop Power f

uncertainty and the number of primary side loops in the plant. As noted

. in Table Za, the Secondary Power uncertainty for N loops is as follows:

N.= 4 uncertainty = 1 1.2 % power 3 + 1.4 % power 2 + 1.7 % power In all cases the total Secondary Power uncertainty is less than or equal to the historically used value of + 2 % power. For ITDP, credit is taken for the increased knowledge of reactor power and the values noted above are used in the ITDP error analysis, i.e., the standard deviation for reactor power, at the 95+1 probability level is:

1Ca

, , , . - - , e .- - - -

WESTINGHOUSE PROPfdETARY CLASS 3 FIGURE 1 POWER CALORIMETRIC SCHEMATIC I P i i P 1 1 T l l AP f s f f

\'

p / 'l h h F, K s f of O - measured _. -

Qss . ,

O - calculated - l if

< Other Loops

+

1f Q

L P -

u ,

1 Core Power s s,

ESTINGHOUSE PROPRIETARY CLASS 3 ,

TABLE 2a SECONDARY POWER CALORIETRIC EASUREENT UNCERTAINTIES 9

Power Component Instrument Error Uncertainty Feedwater Flow +a,e Venturi, K Thermal Expansion Coefficient Temperature Material Density Temperature Pressure Electronics ap Cell Calibration Sensor Pressure Effects Sensor Temperature Effects Sensor Drift

' Rack ' Calibration Rack Temperature Effects l

L Rack Drift '

Computer Isolator Drift Computer Readout f Total Electronics Error fr(e)2 Total Feedwa'ter Flow Error I(e)2 s

13a l

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 2a (Cont)

SECONDARY POWER CALORIMETRIC MEASUREMENT UNCERTAINTIES Power Component Instrument Error Uncertainty Feedwater Enthalpy ~

~ +a,c Temperature (Electronics)

RTD Calibration RTD Drift R/I Converter Rack Accuracy Rack Temperature Effects Rack Drift Computer Isolater Drift Computer Readout -

Total Electronics Error fE(e)2 Feedwater Temperature Error Assumed Pressure Total Feedwater Enthalpy Error fI(e)2 Stean Enthalpy Steamline Pressure (Electronics)

Pressure Cell Calibration Sensor Temperature Effects Sensor Drift Rack Calibration Rack Temperature Effects l

e 19a

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 2 af Cont)

SECONDARY POWER CALORIETRIC EASUREENT UNCERTAINTIES Power Instrument Error Uncertainty Component.

Steam Enthalpy (Conti) g +a,c

_a,c_

+

Rack Drift '

Computer Isolator Drift Computer Readout Total Electronics Error fI(e)2 Steamline Pressure Error Assumed Moisture Carryover Total Steam Enthalpy Error fI(e)2 LoopPowerUncertaintyfz(e)2 Net Pump Heat Addition Uncertainty

~ ~

Total Loop Power Uncertainty (8)

~ ~

Total Secondary Power Uncertainty f[t(e)2]/N where N = 4 loops 11.2%

3 loops 11.4%

2 loops 11.7%

20a

WESTINGHOUSE PROPRIETARY CLASS 3 NOTES FOR TABLE 2 a

1. Temperatum effect on Themal Expansion Coefficient is assumed to be linear with an uncertainty of [ ]+a,b,c per 2*F change.

4

2. Conservative assumption for value, particularly if steamline pressure

+ 100 psi is assumed value. Uncertainty for steamline pressure noted in -

Steam Enthalpy.

3. To transfom error in percent op span to percent of feedwater flow at 100% of nominal feedwater flow; multiply the instrument error by:

Span of feedwater flow transmitter in percent of nominal flow \2

[1/2 100 )

( )(

In this analysis the feedwater flow transmitter span is assmed to be

, [ 3+a,c 1 of nominal flow.

3*"'" and a maximum

4. In this analfsis assumed an error of [ 3.+a,c swing in feedwater pmssure from no load to full power of [
5. [ '

. )+a,c 3+a.c equals [ 3+a,c which equals

6. [ 3+a,c span of [

[ 3+a,c power.

7. Conservative assumption for instrumentation error for this analysis.

'8. Statistical sum of Loop Power Uncertainty and Net Pump Heat Addition Uncertainty.

i l

1 21a

3 WESTINGHOUSE PROPRIETARY CLASS

+a,c power N = 4 e =

power 3

power 2

t 4.a RCS FLOW The Improved Themal . Design Procedure (ITDP) and some plant Tech-nical Specifications require an RCS flow measurement with a high degree of accuracy.

It is assumed for this error analysis, that this flow measurement is performed within seven days of calibrating the measurement instrumentation therefore, drift effects are not It is inc.l uded (except where nece'ssary due to sensor location).

also assumed that the calcHaetric flow measurement is performed at the beginning of a cycle, so no allowances have been made for feed-water venturi crud buildup. .

The flow measurement is perfomed by detemining the steam generator themal output, corrected for the RCP heat input and the loop's share of primary system heat losses, and the enthalpy rise (Ah) of Assuming that the primary and secondary sides

, ,the primary coolant.

are in equilibrium; the RCS total vessel flow is the sum of the individual primary loop flows, i.e.,

l (Eq. 7)

Wgg3 = EWg .

The individual primary loop flows are detemined by correcting the themal output of the steam generator for steam generator blowdown ,

(if not secured), subtracting.the RCP heat addition, adding the loop's share of the primary side system losses, dividing by the primary side enthalpy rise, and multiplying by the specific volume of .the RCS cold leg. The equation for this calculation is:

(

Qsg-O +/ QQ d h /i(V) (Eq. 8) i p e WL " (Y)

  • Lng -ng )

22a

WESTINGHOUSE PROPRIETARY CLASS 3 where; W g = Loop flow (gpm) y = 0.1247 gpm/(ft3 /hr) 03g = Steam Generator themal output (Btu /hr)

Q,

= RCP heat adder (Btu /hr)

Qt = Primary system net heat losses (Btu /hr) 3 V

e

= Specific volume of the cold leg at TC (ft /lb)

N = Number of primary side loops h = Hot leg enthalpy-(Btu /lb)

H h = cold leg enthalpy (Btu /1b).

c The themal output of the steam generator is detemined by the same calorimetric measurement as for reactor power, which is defined as:

Osg = (h (Eq. 5) s -h)Wf f

where; h-s = Steam enthalpy (8tu/lb) h = Feedwater enthalpy (Btu /lb) l

, f W

f

= Feedwater flow (1b/hr). l l

l The steam enthalpy is based on measurement of steam generator outlet steam pressure, assuming saturated conditions. The feedwater enthalpy is based on the measurement of feedwater temperature and an assumed The feed- l feedwa,ter pressure based on steamline pmssum plus '100 psi. '

water flow is detemined by multiple measurements and the same calcula-tion as used for reactor power measumments, which is-based on the fol-lowing:

Wf (Eq. 6) -

= (K) (F,){V pf ap }

i -

where; K = Feedwater venturi flow factor F, = Feedwater venturi correction for themal expansion O = Feedwater density (1b/ft3) f ap '= Feedwater venturi pressum drop (inches H2O).

l

, 23a

WESTINGHOUSE PROPRIETARY CLASS 3 The feedwater venturi flow coefficient is the product of a number of constants including as-built dimensions of the venturi and calibration tests perfomed by the vendor. The themal expansion correction is '

based on the coefficient of expansion of the venturf material and the difference between feedwater temperature and calibration temperature.

Feedwater density is based on the measurement of feedwater temperature and feedwater pressure. The venturi pressure drop is obtained from the output of the' differential pressure cell connected to the venturi.

The RCP heat adder is detemined by calculation, based on the best esti-mates of coolant flow, pump head, and pump hydraulic efficiency.

The primary system net heat losses are detemined by calculation, con-sidering the following system heat inputs and heat losses:

Charging flow Letdown flow Seal injection flow RCP themal barrier cooler heat removal Pressurizer spray flow

- Pressurizer surge Ifne flow Component insulation heat losses Component support heat losses CRDM heat losses.

A single calculated sua for full power operation is used for these los-ses/ heat inputs.

The hot leg and cold leg enthalpies are based on the measurement of the hot leg-temperature, cold leg temperature and the pressurizer pressure.

The cold leg specific volume is based on measurement of the cold leg temperature and pressurizer pressure.

The RCS flow measurement is thus based on the following plant measure-ments:

24a

--e , - - , -

WESTINGHOUSE PROPRIETARY CLASS 3 Steaaline pressum (P,)

Feedwater temperatum (Tf )

Feedwater pressure (Pf )

Feedwater venturi differential pressure (Ap)

Hot leg temperature (THI Cold leg temperature (TC I Pressurizer pressure (Pp)

Steam generator blowdown (if not secured) and on the following calculated values:

Feedwater venturi flow coefficients (K)

Feedwater venturi themal expansion correction (F,)

Feedwater density (of)

Feedweter enthalpy (hf)

Steam enthalpy (h,)

, Moisture carryover (impacts h,)

Primary system net heat losses (Qg)

)

RCP Hot legheat adder (Q,(h I enthalpy M~

Cold leg enthalpy (he ).

These measurements and calculations are presented schematically on Figure 2.

Starting off with the Equation 6 parameters, the detailedd'erivation of the measurement errors is noted below.

Feedwater Flow Each of the feedwater ventuff s is calibrated by the vendor in a hydrau-lies laboratory under controlled conditions.to an accuracy of

[' .]+a,b,c 1 of span. The calibration data which substantiates this accuracy is provided for all of the plant venturis by the mspec-tive vendors. An additional uncertainty factor of [ ]+a,c.5 is f

25a

/

WESTINGHOUSE PROPRIETARY CLASS 3 included for installation effects, resulting in an overall flow coef-ficient (K) uncertainty of [ ]+a,c 5. Since RCS loop flow is proportional to steam generator themal output which is proportional to feedwater flow, the flow coefficient uncertainty is expressed as

[~ ]+a,c g fj ,,,

J The uncertainty applied to the feedwater venturi themal expansion cor-rection (F,) is based on the uncertainties of the measured feedwater temperature and the coefficient of themal expansion for the venturi material, usually 304 stainless steel. For this material, a change of

+ 2*F in the feedwater temperature range changes F, by

[ ]+a,b c 5 and the steam generator themal output by the same amount. .For this derivation, an uncertainty of [ ]+a,c 9, feedwater temperature was assumed (detailed breakdown for this assump-tion is provided in the feedwater enthalpy section). This results in a negligible impact in F, and steam generator output.

i Based on data introduced into the ASlE Code, the uncertainty in F, for This results in an additional uncertainty 304 stainless steel is + 5 %.

of [ ]+a,c 5 in feedwater flow. A conservative value of

[ ]+a,c 5 is used in this analysis.

Using the ASE Steam Tables (1967) for compressed water, the effect of a

[ ]+a,c error in feedwater temperature on the / o f is

[_

]+a.c 5 in steam generator th'emal output. An error of ,.

[ ]+a,c in feedwater pressum is assumed in this analysis l

(detailed breakdown of this value is provided in the steam enthalpy ~

section) . This results in an uncertainty in %of [ J+a,c 5

! in steam generator themal output. The combined effect of the two-results in a total / p f uncertainty of [ ]+a,c 5 in steam generator themal output.

I It is assumed that the op cell (usually a Barton or Rosemount) is read l locally and soon after the Ap cell and local meter are calibrated (within 7 days of calibration). This allows the elimination of process  ;

l 2Ga

WESTINGHOUSE PROPRIETARY CLASS 3 rack and sensor drif t errors f rom consideration. Therefore, the op cell errors noted in this analysis are [ ]+a c % f or calibration and [ ]+a,c % for reading error of the special high accuracy, ~

local gauge. These two errors are in % Ap span. In order to be useable in this analysis they must be translated into % f eedwater flow at f ull power conditions. This is accomplished by multiplying the error in % Ap span by the conversion f actor noted below:

2 I

Il )d span L7 of f eedwater luu flow transmitter in percent of nomin I

/

( /\

For a feedwater flow transmitter span of [ ]+a c % nominal flow, the conversion f actor is [ ]+a,c (which is the value used in this analysis).

As noted in Table 3 a, the statistical sum of the errors for feedwater flowis[ ]+a,c % of steam generator thermal output.

Feedwater Enthalpy The next major error component is the feedwater enthalpy used in Equa-tion 5. For this parameter the major contributor to the error is the uncertainty in the f eedwater temperature. It is assumed that the f eed-water temperature is determined through the use of an RTD or thermo-couple whose output is read by a digital voltmeter (DVM) or digital multimeter (DMM) (at the output of the RTD or by a Wheatstone Bridge f or RTD's, or at the reference junction f or thermocouples). It is also assumed that the process components of the above are calibrated within 7 days prior to the measurement allowing the elimination of drif t effects f or all but the RTDs. Theref ore, the error breakdown f or f eedwater temperature is as noted on Table la. The statistical combination of these errors results in a total feedwater temperature error of

[ ]+a,c .

27a

. WESTINGHOUSE PROPRIETARY CLASS 3 Using the ASME Steam Table (1967) for cogressed water, the effect of a

[ ]+a,c error in feedwater temperature on the feedwater enthalpy (hf ) is [ ]+a c % in steam generator thermal output. Assuming a[ ]+a,c error in feedwater pressure (detailed breakdown provided in the steam enthalpy section) results in a [ 1+a,c%

effect in hf and steam generator thermal output. The combined effect of the two results in a total hf uncertainty of [ ]+a,c % steam generator thermal output, as noted on Table 1.

Steam Enthalpy, The steam enthalpy has two contributors to the calorimetric error, steamline pressure and the moisture content. For steamline pressure the error breakdown is as noted on Table la. This results in a total instru-mentation error of [ ]+a.c %, which equals [ ]+a,c f or a 1200 psi span. For this analysis a conservative value of [ ]Y is assumed for the steamline pressure. The feedwater pressure is

. assumed to be 100 psi higher than the steamline pressure with a conser-vatively high measurement error of [ ]+a,c. If f eedwater pres-sure is measureion the same basis as the steamline pressure (with a DVM) the error is [ ]+a,c % span, which equals [ ]+a,c f or a 1500 psi span. Thus, an assumtion of an error of [ ]+a,c is very conservative.

Using the MME Steam Tables (1967) f or saturated water and steam, the eff ect of a [ ]+a,c ([ ]+a,c) error in steamline pressure on the steam enthalpy is [ ]+a,c % in steam generator the'rmal output. Thus, a total instrumentation error of [ ]+a.c results in an uncertainty of [ ]+a,c % in steam generator thermal output, as noted on Table 3a. ,

The major contributor to hs uncertainty is moisture content. The nominal or best estimate performance level is assumed to be [ .]+a.c %

which is the design limit to protect the high pressure turbine. The most conservative assumption that can be made in regards to maximizing steam 20a

WESTINGNOUSE PROPRIETARY CLASS 3 1

generator themal output is a steam moisture content of zero. This conser-

' vatism is introduced by assigning an uncertainty of [ 3**** 1 to the moisture content, which is equivalent through enthalpy change to

[ 3+a c % of themal output. The combined effect of the steamline pressu e 'and moisture content on the total sh uncertainty is

[ ]+a,c 5 in steam generator themal ouiput.

Secondary Side Loop Power The loop power uncertainty is obtained by statistically' combining all of the error components noted for the steam generator themal output (Q3g)

L in tems of 8tu/hr. Within each loop these components are independent effects since they are independent measurements. Technically, the feed-water temperature and pressure uncertainties are cossnon to several of the error components. However, they are treated as independent quantities ,

i because of the conservatism assumed and the arithmetic, summation of .their uncertainties before squaring them has no significant effect on the final result.

The only effect which tends to be dependent, affecting all loops, would be the accumulation of crud on the feedwater venturis, which can affect the l

ap for a specified flow. Although it is conceivable that the crud accu-mulati.on could affect the static pressure distribution at the venturi thmat pmssure tap in a manner that would result in a higher flow for a l

specified ap, the reduction in throat' area resulting in a lower flow at the specified ap is the stronger effect. No uncertainty has been included in the analysis for this effect. If venturi fouling is detected by the plant, the venturi should be cleaned, prior to perfomance of the measurement. -If the venturi is not cleaned, the effect of the fouling on the detemination of the feedwater flow, and thus, the steam generator power and RCS flow, should be measured and treated as a bias, i.e., the error due to venturi fouling should be added to the statistical sucenation of the rest of the measurement errors.

?

29a 4

I WESTINGHOUSE PROPRIETARY CLASS 3 The net pump heat uncertainty is derived in the following manner. The '

i primary system net heat losses and pump heat adder for a four loop plant are summarized as follows:

System heat losses -2.0 MWt -

Component conduction and convection losses -1.4 Pump heat adder +18.0

)

l Net. Heat input to RCS +14.6 MWt The uncertainties for these quantities are as follows: The uncertainty on systems heat losses, which is essentially all due to charging and

-letdown flows, has been estimated to be [ 3+a,c % of the calculated value. Since direct measurements are not possible, the uncertainty on j component conduction and convection losses has been assumed to be

[ ]+a,c % of the calculated value. Reactor coolant pump hydraulics are kncwn to a relatively high confidence level, supported by the system hydraulics tests perfomed at Prairie Island II and by input power mea-surements from several plants, so the uncertainty for the pump heat adder is estimated to be [ ]+a,c % of the best estimate value.

Considering these parameters as one quantity which is designated the net pump heat uncertainty, the combined uncertainties are less than L [ -]+a,c '% of the total, which is [ ]+a,c % of core power.

i The Total Secondary Side Loop Power Uncertainty (noted in Table 3a as

]+a,c %) is the statistical sum of the secondary side loop

[

power uncertainty (Q 3 g), [

]+a,c %, and the net pump heat addi-l i tion,[ ]+a,c g, Primary Side Enthalpy The primary side enthalpy error contributors are TH and TC measure-ment errors and the uncertainty in pressurizer pressure. The instrumen-tation errors for TH are as noted on Table la. These errors are based i 30a 3

WESTINGHOUSE PROPRIETARY CLASS 3 on the assumption that the DVM has been recently calibrated (within 7 days prior to the measurement) and the DVM is used to read the output of the RTD, or a bridge, thus allowing the elimination of drift effects in the racks. The statistical combination of the above errors results in a total TH uncertainty of [ ]+a,c, Table la also provides the instrumentation error breakdown for TC. The errors are based on the 'same assumptions as forHT , resulting in a total TC uncertainty of [ 3+a,c, Pressurizer pressure instrumentation errors are noted on Table la. A sensor drift allowance of [ ]+a,c % is included due to the dif-ficulty in calibrating while at power. It is assumed calibration is perfonned only as required by plant Technical Soecifications.

Statistically combining these errors results in the total pressurizer

. pressure uncertainty equaling [ ]+a,c % of span, which equals

. [ ]+a,c for an [ 3+a.c span. In this analysis a conservative value of [ 3+a,c is used for the instrumentation error for pressurizer pressure.

The effect of an uncertainty of [ 3+a,c in TH on hH is

[ _ ,3+a,c % of loop flow. Thus, an error of [ 3+a,c in TH introduces an uncertainty of [ ]+a c percent in hH . An error of [ 3+a,c in TC is worth [ ]+8sC % in hc - '

Therefore, an error of [ 3+a,c in TC results in an uncer- l tainty of [ 3+a,c % in hc and loop flow. An uncertainty of l

[ ]+a,c in pressurizer pressure introduces an error of i

[ 3+a,c % in hH and [ 3+a,c % inch . Statistically combining the hot. leg and cqld leg temperature and pressure uncertain-

) ties results in an hH uncertainty of [ 3+a,c %, an he uncer-tainty of [ 1]+a,c%, and a total uncertainty in Ah of

[ ]+a,c % in loop flow.

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

31a l l

i

l WESTINGHOUSE PRC?AIETARY CLASS 3 FIGURE 2 RCS FLOW CALORIMETRIC SCHEMATIC T T C

l I Pg  ! I P f l l (Tf l [ ap l H P I l

% P s e ,,

K h h h, h.f of F, H C

\ 1 r Ah Wf , =

- 1 r

? -Qg s C If Measured o

- +

  • Calculated D
  • O

[Q

  • p

}

W[ ,

7 t

Other Loops <

1F RCS Flow '

i 32a

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 3a CALORIMETRIC RCS FLOW MEASUREMENT UNCERTAINTIES Flow Instrument Error (1) Uncertainty Component Feedwater Flow

- " +a,c Venturi, K Thermal Expansion Coefficient Temperature Material Density Temperature Pressure Instrumentation op Cell Calibration Ap Cell Gauge Readout Total Instrumentation Error

~ Total Feedwater Flow Error I(e)2 Feedwater Enthalpy Temperature (Electronics)

RTD Cal;bration Sensor Drift DVM Accuracy Total Temperature Error I(e)2 Pressure Total Feedwater Enthalpy Error . t(e)2 A

33a

l i

WESTINGHOUSE PROPRIETARY CLASS 3 l

TABLE 3a (Cont) l CALORIMETRIC RCS FLOW MEASUREMENT UNCERTAINTIES Flow Component Instrument Error (1-) Uncertainty

+a,c Steam Enthalpy Steamline Pressure (Electronics)

Pressure Cell Calibration Sensor Temperature Effects Rack Calibration Rack Temperature Effects DVM Accuracy Total Electronics Error fI(e)2 Steamline Pressure Error Assumed

' Moisture Carryover TotalSteamEnthalpyErrorfE(e)2 Secondary Side Loop Power Uncertainty fI(e)2 ,

IJet Fump Heat Addition Uncertainty Total Secondary Side Loop Power

_ Uncertainty [I(e)2 Primary Side Enthalpy TH (Electronics)

RTD Calibration Sensor Drift .

DYM Accuracy T

H Instrumentation Error fI(e)2 THTemperature Streaming Error TTemperatureError[I(e)2 H

O 34a l

l

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 3a (Cont)

CALORIMETRIC RCS FLOW MEASUREMENT UNCERTAINTIES Flow Component Instrument Error (1) Uncertainty

+a,c i

~ -

TC (Electronics) t RTD Calibration Sensor Drift DVM Accuracy T

C Instraentation Error fI(e)2 Pressurizer Pressure (Electronics)

Pressure Cell Calibration Sensor Temperature Effects Sensor Drift

. Rack Calibration Rack Temperature Effects DVM Accuracy

. Total Pressurizer Pre.ssure Error}I(e)2 I

Pressurizer Pressure Error Assumed TH Pressure Effect

'T H TotalError)l(e)2 I

TC Pressure Effect T

C TotalErrorfI(e)2 Total ah Uncertainty fI(e)2 Primary Side Loop Flow Uncertainty fI(e)2, Total RCS Flow Uncertaintybj [I(e)2]/N where N = 4 loops + 1.9%

3 loops + 2.2%

2 loops + 2.7%

i 35a

' i WESTINGHOUSE PROPRIETARY CLASS 3 NOTES FOR TABLE 3a

1. Measurements perforined within 7 dvs after calibration thus Rack Drift, l and dere possible Sensor Drift, effects are not included in this analy- l si s. l

+

.\ ,

2. Conservative ~asstanption for value, particularly if steamline pressure )

+ 100 psi is assumed value. Uncertainty for steamline pressure noted in

steam enthalpy.
3. To transform error in percent op span to percent of feedwater flow at 100% of nominal feedwater flow; multiply the instrument error by:

2 1/2 Span of feedwater flow transmitter in percent of nominal flow

( )( 100 )

In this analysis the feedwater flow transmitter span is assumed to be

[ 3+a,c % of nominal flow.

4. Reading error for multiple readings of a Barton gauge.
5. Conservative assumption for instrumentation error for this analysis. ,

i

6. Ma'ximum allowed moisture carryover to protect HP turbine.
7. Calibration accuracy of [ ]+a,c5 span of [ ]+a,c which eauals

[ 3+a,c,

8. Credit taken for the 3 tap scoop RTD bypass loop in reducing uncertain-ties due to temperature streaming.
9. Convoluted stan of TH Temperature Error and TH Pressure Effect.
10. Convoluted sum of TC Instrumentation Error and TC Pressure Effect.
11. Convoluted sum of TH Total Error and TC Total Error.

35a

l WESTINGHOUSE PROPRIETARY CLASS 3 l

results in a Primary Side Loop Flow Uncertainty of [ ]+a c g loop flow. The RCS flow uncertainty is the statistical combination of the primary side loop flow error and the number of primary side loops in the plant. As noted in Table 3a, the RCS Flow uncertainty for N loops is: ,

N=4 uncertainty = + 1.9% flow 3 = + 2.2% flow 2 = + 2.7% flow.  ;

For ITDP, credit is taken for the increased knowledge of RCS flow and the values noted above are used in the ITDP error analysis, i.e., the standard deviation for RCS flow, at the 95+% probability level is:

+a.c

~

N=4 o =- '% flow 3 =  % flow 2 =  % flow

5. USE OF AN LEFM If a plant uses a Leading Edge Flow Meter (LEFM), from the Oceanics Division of Westinghouse, for the measurement of feedwater flow, several changes are made in the calorimetric power and flow uncertainty analy-ses.' The following are typical LEFM uncertainties in mass flow (1bs/hr):
a. A nominal accuracy of [ 3+a,c flow. This is based on a feedwater temperature uncertainty of [- ]+a,c and a feedwater pressure uncertainty of [ 3+a,c,
b. For each [ 3+a,c increase in Feedwater temperature uncer-tainty, the mass flow uncertainty increases by [ 3+a,c,
c. For a feedwater. pressure uncertainty greater than

[ 3+a,c but less than [ ]+a,c, the mass flow uncertainty increases by [

]+a,c, 37a

/

IESTINGHOUSE PROPRIETARY CLASS 3 Thus, for a typical LEFM installation with a feedwater temperature uncertaint'y of [. 3+a c and a pressure uncertainty less than

[ 3+a,c, the mass flow uncertainty is [ 3**'# flow.

The effect of the use of an LEFM is seen primarily in the measurement of Reactor Power. The following table provides a comparison of the uncer-tainties for a power calorimetric using a feedwater venturi and an LEFM. It is assumed for these calculations that a measurement device (either a venturi or an LEFM) is in the feedwater line to each steam generator.

~

0 33a

WESTINGHOUSE PROPRIETARY CLASS 3 L

TABLE 4a COWARISON OF VENTURI VS. LEFM POER CALORIETRIC UNCERTAINTIES Venturi

+a,c leactor Power Feedwater Temperature-Feedwater Flow .

Feedwater Enthalpy Steam Enthalpy Loop Power Uncertainty Total Locp Power Uncertainty Total Secondary Power Uncertainty 4 loops 1 1.2% RTP 1 0.4% RTP 3 loops 1 1.4% RTP 1 0.4% RTP 2 loops + 1.7% RTP + 0.5% kTP

  • from Table 2a -
    • due to [ ]+a,c assumption The impact of the LEFM on RCS Flow measurement is considerably less (primarily due to the [ ]+a,c feedwater temperatum error already being' assumed and the prime error contributors being TH and T C for primary side ah). However, the following table notes the differences between the two measurements for an RCS Flow calorimetric measumment. For these calculations it is assumed that a measurement device (either a venturi or an LEFM) is in the feedwater line to each steam generator.

3:a

=

l l

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE Sa COMPARISON OF VENTURI VS. LEFM FLOW CALORIMETRIC UNCERTAINTIES Venturi

- - +a,c RCS Flow

.Feedwater Flow 4

Feedwater Enthalpy Steam Enthalpy Secondary Loop Power Uncertainty

-Total Secondary Power Uncertainty l

Primary Enthalpy Primary Loop Flow Uncertainty Total RCS Flow Uncertainty a_.

4 loops f;1.9% flow f;1.9% flow 3 loops f; 2.2% flow f; 2.2% flow 2 loops f; 2.7% flow f; 2.7% flow

  • from Table 3a
    • due to [ ]+a,cassumption Therefore, if a plant has installed an LEFM to measure .feedwater flow credit would be taken in the.ITDP error analysis for the lower uncer-tainty in Reactor Power, but no credit would be taken in RCS flow.

6.a NORMALIZED ELBOW TAPS FOR RCS FLOW MEASUREMENT .-

Based on the results of Table 3a, in order for a plant to assure opera-tion within the ITDP assumptions an RCS flow-calorimetric would have to i be performed once every 31 EFPD. However, this is an involved procedure which requires considerable staff and setup time. Therefore, many plants perform one flow calorimetric of the beginning of the cycle and normalize the loop elbow taps. This allows the operator to quickly

-determine if there has been a significant reduction in loop flow on a shift- basis and to avoid a long monthly procedure. The elbow taps are ,

40a

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

WESTINGHOUSE PROPRIETARY CLASS 3 forced to read 1.0 in the process racks after performance of the full power flow calorimetric, t'hus, the elbow tap and its op cell are seeinp normal operating conditions at the time of calibration / normalization and 1.0 corresponds to the measured loop flow at the time of the measurement.

For monthly surveillance to assure plant operation consistent with the ITDP assumptions two means of determining the RCS flow are available.

One, to read the loop flows from the process. computer, and two, to mea-sure the output of the elbow tap Ap cells in the process racks with a DVM. The uncertainties for both methods and their convolution with the calorimetric uncertainty are presented below.

Assuming that only one elbow tap per loop is available to the process computer results in the following elbow tap measurement uncertainty:

%ap span  % flow %ap span  % flow -

pg +a,c +a,c RCA PEA RTE SCA RD SPE ID STE A/D SD Readout op span is converted to flow on the same basis as provided in Note 3 of Table 3a for an instrument span of [ ]+a,c Using Eq. 2 results inaloopuncertaintyof[ ]+a c flow per loop. The total uncer-tainty for N loops is:

=

+a,c f)g, N 4 3 ,

2 The instrument / measurement uncertainties for normalized elbow taps and the flow calorimetric are statistically independent and are 95+% prob-ability values. Therefore, the statistical combination of the standard deviations results in the following total flow uncertainty at a 95+%

probability:

41a

i WESTINGHOUSE PROPRIETARY CLASS 3 4 loops = + 2.0 flow 3 loops + 2.4 2 loops + 2.9 l Another method of using nomalized elbow taps is to take DVM readings in j the process racks of all three elbow taps for each loop. This rc.ults ein average flows for each loop with a lower instrumentation uncutainty for the total RCS flow. The instrunentation uncertainties for this measurement are:

%Ap span  % flow %ap span  % flow

+a,c +a,c PMA SD PEA RCA SCA RTE SPE RD-STE DVM

- Readout ap span is converted to flow on the same basis as provided in Note 3 of Table 3a for an instrument span of [ ]+a,c Using Eq. 1 results in a channel uncertainty of [ ]+a,c flow. Utilizing three elbow taps (which are independent) results in a loop uncertainty of [ ]+a,c flow per loop. The total uncertainty for N loops is:

+a,c f)gg

'.N =-4 3

2 The calorimetric and the above noted elbow tap uncertainties can be statistically combined as noted earlier. The 95+1 probability total flow uncertainties, using three elbow taps per loop are:

4 loops  : + 1.g% flow 3 loops + 2.3 2 loops + 2.8 The following table summarizes RCS flow measurement uncertainties.

42a

., .e i

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 6a TOTAL FLOW MEASUREMENT UNCERTAINTIES Loops 4 3 2 Calorimetric uncertainty

  • 1 1.9 1 2.2 1 2.7 Total uncertainty 3 elbow taps / loop 1 1.9 + 2.3 1 2.8 Total uncertainty 1 elbow tap / loop + 2.0 1 2.4 1 2.9
  • Calorimetric uncertainty noted assumes feedwater mehsurement with a venturi, however, use of an LEFM for feedwater measurement results in essentially the same value.

IV. PROBABILITY JUSTIFICATION As noted in Section III, it is Westinghouse's belief that the total uncertainty for Pressurizer Pressure, Tayg, Reactor Power, and RCS Flow are noma 1, two sided, 95+% probability distributions. This sec-tion will substantiate that position with a comparison between three approaches, the first being that noted in Section II, the second involves detemination of the variance assuming a unifom probability distributton for each uncertainty and then detemination of the 95%

probability value assuming a one sided nomal distribution, and the third involves detemination of the variance assuming a noma 1, two sided probability distribution for each uncertainty and then determina-tion of the 95% probability value assisning a two sided iomal distribu-ti on.

Table 7a lists the results of the three approaches. Column 1 lists the values noted for CSA on Tab'le la which are determined through the use of equations 1, 2, or 3, whichever is applicable to that particular func-tion. Column 2 lists the variance for each function assuming the uncer-tainty for each of the parameters listed in Section 2 is a unifom prob-ability distribution. For this assumption, 43a

^

/

WESTINGHOUSE PROPRIETARY CLASS 3 2

2 R Eq. 9 l o = y where R equals the range.of the parameter. The variance for the func-

- tion equals the arithmetic sum of the parameter variancos. From a safety point of view deviation in the direction of non-conservatism is important. Therefore, Column 3 lists the one sided 951 pmbability values based on the variances provided in Column 2, i.e., the one sided 955 probability value.fo near nomal distribution can be reasonably approximated by: 1.645 .

Column 4 lists the variance for each function assuming the uncertainty for each of the parameters listed in Section 2 is a near noma 1, two sided probability distribution. Efforts have been made to conserva-tively determine the pmbability value for each of the parameters, see Table 8. For example, [ .

pa c The corre-sporiding Z value listed on Table 8 is from the standard 'nomal curve where:

Eq.10 I = (x - u)/a The variance for a parameter is then the square of the uncertainty' divided by its Z value:

Eq.11

,2 , [ uncertainty}2 Z j

(

44a e ~ . - - - -- . , ,. , ,. ,-

ESTINGHOUSE PROPRIETARY CLASS 3 The variance for the function equals the arithmetic sum of the parameter variances. From the variance the two sided 95% robability value'for a 2

a, nomal distribution can be calculated: 1.96 To sumarize; Column 1 is the results of Equations 1, 2, and 3. Column 2 is the total variance assuming unifom probabilty distributions, i.e.,

2 2 2 2

Rj ,R2 + ... = (2 uncj)2 ,(2 unc2I + ... Eq.12 o= ,, ,,

Column 3 is 1.645 Column 4 is the total variance assuming near nomal probability distri-butions, i .e. ,

funcj )2 +

f.unc23 Eq.13 o 2=1 + ...

' Column 5 is 1.96 .

A comparison of Columns 1, 3, and 5 will show that the approach used in Section 2 results in values more conservative than those of Columns 3 and 5. Thus, it can be concluded that the results presented in Section l 3 are total uncertainties with probabilities in excess of 951.

Confidence limits are applicable only to a particular data set, which in this case not available. Therefore, based on the relatively small num-ber of reports indicating large values of deviation, f.e., the number of instances where a channel fatis a functional test is very small as com-pared to the many thousands of functional tests perfomed, Westinghouse believes that the total uncertainties presented on Table la are 95% prob-

ability values at a high confidence level.

45a i~ .

WESTINGHOUSE PROPRIETARY CLASS 3 3 V. CONCLUSIONS The pmceding sections provide what is believed to be a reasonable means of accounting for instrument and measumment errors for four parameters used in the ITDP analysis. The assumptions used in this response am generic and conservative. It is the intent of this response to generi-cally resolve any concerns with the measumment and control of Reactor Power, RCS Flow, Pressurizer Pressure and T,yg as they are applied to ITDP. As such, plant specific msponses will provide only that infoma-tion which indicates that,1) the instrument and measurement uncertain-ties for that plant are consistent with or conservative with respect to those pmsented here, or 2) specific instrument and/or measurement uncertainties for that plant are not consistent with those presented.

In the second case the impact of the inconsistency on the four param-eters will be provided with cormsponding new total uncertainties if the impact is sufficiently large.

O O

I

'l 46a

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 7a ,

COMPARISON OF STATISTICAL ETHODS 3 4 5 1' 2 Variance 955 Probability Variance 95% Probability Method 2 Method 2 Method 3 Method 3 Method 1 l +8,C Pressurizer Pressure - Control T,,,- Control Steam 11ne Pressure - Computer Feedwater Temperature - Computer Feedwater Pressure - Computer Feedwater ap - Computer Pressurizer Pressure - DVM Steamline Pressure - DVM.

Feedwater Temperature - DVM TH - DVM TC-DM Notes for Table 7

1. dncertainties presented in columns 1, 3, and 5 are in' 5 span.
2. While values noted are listed to the second decimal place, values are accurate only to the first decimal . place. Second place 1s noted for round-off purposes only.

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 8 UNCERTAINTY PROBABILITIES Two Sided Two Sided Normal Probability (%) Nonna1, I Value

+a.c PMA PEA SCA SD-STE SPE RCA ,

- RD RTE DVM ,

ID A/D M ,

l l

40a g .-_ _ _ . - . --

WESTINGHOUSE PROPRIETARY CLASS 3-REFERENCES

1. Westinghouse letter NS-CE-1583, C. Eiche1dinger to J. F. Stolz, NRC, dated 10/25/77. .

I

2. Westinghouse letter NS-PLC-Sill, T. M. Andersor, to E. Case, NRC,- i dated 5/30/78.
3. Westinghouse letter NS-TMA-1837. T.'M. Anderson to S. Varga, NRC, dated 6/23/78.
4. Westinghouse letter NS-TMA-1835, T. M. Anderson to E. Case, NRC, dated 6/22/78.
5. NRC letter, S. A. Varga to J. Dolan, Indiana and Michigan Electric Company, dated 2/12/81.
6. NUREG-0717_ Supplement No.' 4. Safety Evaluation Report related to the operation of Virgil C. Summer Nuclear Station Unit No.1, Docket 50-395, August, 1982.
7. NRC proposed Regulatory Guide 1.105 Rev. 2, " Instrument Setpoints",

dated 12/81 for implementation 6/82.

8. ANSI /ANS Standard 58.4-1979, " Criteria for Technical Specifications for Nuclear Power Stations".
9. ANSI /N719 ISA Standard S67.04, Draft F, 5/22/79, "Setpoints for Nuclear Safety-Related Instrumentation Used in Nuclear Power Plants".
10. Scientific Apparatus Manufacturers Association, Standard PMC-20-1-1973, " Process Measurement and Control Terminology".

4Da

/

WESTINGHOUSE PROPRIETARY CLASS 3 9

APPENDIX B

2 S

I

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 1 PRESSURIZER PRESSURE CONTROL SYSTEM ACCURACY

. .. . +A.C PMA =

SCA = ~

SPE =

STE = .

SD =

EA =

RCA =

RTE =

RD =

CA =, , ,

. +A.C ELECTRONICS CSA =

PLUS CONTROLLER CSA =

-CONTROLLER SIGMA =

PLUS f

lb

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 2 ROD CONTROL SYSTEM ACCURACY TAvo TORB PRES

. a A.C PMA = -

SCA =

SPE =

STE =

SD =

EA =

RCA =

RTE =

RD =

CA = .. -

. . +A.C ELECTRONICS CSA =

ELECTRONICS SIGMA =

CONTROLLER SIGMA =

CONTROLLER CSA =

BIAS VALUE ' =

0

.i

, 2b

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 3 POWER CALORIMETRIC INSTRUMENTATION UNCERTAINTIES

(% SPAN) FW TEMP FW PRES FW DP STM PRESS ,

~ ~

SCA =

SPE =

STE =

SD =

EA =

RCA =

RTE =

RD =

ID =

A/,D =

CSA =

DEG F PSIG  % DP PSIG INST SPAN = 4SO. 2000. 120. 1300.

' +A.C INST UNC ={ 3 NOMINAL = 440. 108S. 98S.

3b

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 4 POWER CALORIMETRIC SENSITIVITIES FEEDWATER FLOW FA . .tA.C TEMPERATURE =

MATERIAL =

DENSITY TEMPERATURE =

PRESSURE =

DELTA P =

FEEDWATER ENTHALPY TEMPERATURE =

PRESSURE ~ =

HS =

HF =

DHSG =

STEAM ENTHALPY PRESSURE =

MOISTURE =

m '*

4b

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE S SECONDARY SIDE POWER CALORIMETRIC MEASUREMENT UNCERTAINTIES COMPONENT INSTRUMENT ERROR POWER UNCERTAINTY FEEDWATER FLOW

. . +A.C VENTURI THERMAL EXPANSION COEFFICIENT TEMPERATURE MATERIAL DENSITY

. TEMPERATURE PRESSURE DELTA P FEEDWATER ENTHALPY

. TEMPERATURE PRESSURE STEAM ENTHALPY PRESSURE MOISTURE WET PUMP HEAT ADDITION ,

+A.C

[ 3 m.mm INDICATE SETS OF DEPENDENT PARAMETERS

_ _ +A.C SINGLE LOOP UNCERTAINTY (WITHOUT BIAS VALUES)

N LOOP UNCERTAINTY (WITHOUT BIAS VALUES)

N LOOP UNCERTAINTY (WITH BIAS VALUES) e 5b

7_

f WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 6 FLOW CALORIMETRIC INSTRUMENTATION UNCERTAINTIES

(% SPAN) FW TEMP FW PRES FW DP STM PRESS TH TC PRZ PRESS

+ A.C g,

. SPE =

STE =

SD =

RDOT=

EA =

CSA =

DEG F PSIG  % DP PSIG DEG F DEG F PSIG INST SPAN = 450. 2000. 120. 2000. 100. 100. 800.

INST UNC =[

NOMINAL = 440. 1085. 985. 620.0 556.8 2235.

O 4

0 1 i 6b

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 7 ,

FLOW CALORIMETRIC SENSITIVITIES FEEDWATER FLOW FA . - +A.C TEMPERATURE =

MATERIAL =

DENSITY TEMPERATURE =

PRESSURE =

DELTA P =

FEEDWATER ENTHALPY TEMPERATURE =

PRESSURE =

HS =

HF =

DHSG =

STEAM ENTHALPY PRESSURE =

MOISTURE =

HOT LEG ENTHALPY TEMPERATURE =

=

PRESSURE....

HH =

HC =

DHV =

COLD LEG ENTHALPY TEMPERATURE =

PRESSURE =. . .

e 7b

WESTINGHOUSE PROPRIETARY CLASS 3 TABLE 8 CALORIMETRIC RCS FLOW MEASUREMENT UNCERTAINTIES COMPONENT INSTRUMENT ERROR FLOW UNCERTAINTY FEEDWATER FLOW

~ _ +A.C VENTURI THERMAL EXPANSION COEFFICIENT TEMPERATURE MATERIAL DENSITY TEMPERATURE PRESSURE DELTA P FEEDWATER ENTHALPY TEMPERATURE PRESSURE STEAM ENTHALPY PRESSURE MOISTURE NET PUMP HEAT AD.DITION HOT LEG ENTHALPY TEMPERATURE STREAMING PRESSURE COLD LEG ENTHALPY ,

TEMPERATURE PRESSURE . -

+A.C L

3 m mm e mum INDICATE SETS OF DEPENDENT PARAMETERS

., +A.C SINGLE LOOP UNCERTAINTY (WITHOUT BIAS VALUES)

N LOOP UNCERTAINTY (WITHOUT BIAS VALUES)

N LOOP UNCERTAINTY '(WITH BI AS VALUES) _ _,

8b

WESTINGHOUSE PRDPRIETARY CLASS 3 .

1

-TABLE 9 l COLD LEG ELBOW TAP. FLOW UNCERTAINTY l INSTRUMENT UNCERTAINTIES 1 DP SPAN  % FLOW

_ _, +A.C PMA =

PEA =

SCA =

SPE =

STE =

SD =

RCA =

RTE =

RD =

ID =

A/D =

RDOT=

BIAS =

FLOW CALORIM'ETRIC = , .

INSTRUMENT SPAN = 120.

+A.C SINGLE LOOP ELBOW TAP FLOW UNC =

N LOOP ELBOW TAP FLOW UNC =  !

N LOOP RCS FLOW UNCERTAINTY.

(WITHOUT BIAS VALUES) =

N LOOP RCS FLOW UNCERTAINTY (WITH BIAS VALUES) = 2.1 9b

r i M

tc AT1ACHENT B Fuel Centerline Temperature Curves (Non-Proprietary) 9 l

1 J

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